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

Object

Representation ID: 18396

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat supports and endorses the position of the HBF as set out in its representations regarding draft Policy HO5.

In particular, part E of the draft Policy incorrectly reflects national planning policy and needs to be corrected.

Paragraph 64 of the NPPF clearly states that ‘where major development involving the provision of housing is proposed, planning policies and decisions should expect at least 10% of the homes to be available for affordable home ownership’, which is then qualified by footnote 29 to confirm that this 10% of the total number of homes forms part of the overall affordable housing contribution from the site.

Bullet point 3 under part E of the draft Policy suggests that this 10% is the proportion of the overall affordable housing contribution that should be available for affordable home ownership, which is incorrect.

For example, a 50 unit scheme in a location where the affordable housing target is 20% (10 units) would provide 5 units for affordable home ownership (i.e. 10% of 50) and the remainder (5 units) of other tenures.

Object

Representation ID: 18397

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 HO6.

In particular, the Council should present appropriate evidence to support the requirement for 5% of the total plots on developments of over 100 dwellings to provide service plots for custom or self-build housing.

Object

Representation ID: 18398

Received: 24/03/2021

Respondent: Johnson Mowat

Supports the position of the HBF regarding draft Policy HO9.

Part C / accessibility standards - it is incumbent on the Council to provide a local assessment evidencing the specific case for Bradford which justifies the inclusion of optional higher standards for accessible and adaptable homes in its Local Plan policy. If the Council can provide the evidence then the HBF recommends that an appropriate transition period is included within the policy.

The requirement for a greater proportion of dwellings to meet particular accessibility standards is likely to affect the overall level of development that may be achieved on a site, which then needs to be reflected in policies relating to the expected density of development (draft Policy HO2) and assessments of development viability.

The requirement at part E/1 of the Policy for all new market and affordable homes to meet the Nationally Described Space Standard (NDSS) for internal space in new dwellings should only be included if the Council can provide appropriate evidence to support this in terms of need, viability and timing as stated in PPG.

Object

Representation ID: 18399

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 EN2.

Part H of the draft Policy indicates that all development should deliver a measurable net gain in biodiversity value. Whilst paragraph 4.26.11 states that ‘to demonstrate biodiversity net gain, the development must raise the score by at least 10%’ this measure should be stated in the policy wording for clarity and consistency with Government policy.

As the HBF representations state, 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. As the specific requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays, the Council should not deviate from the Government’s proposals.

As there are significant additional costs associated with biodiversity gain, this should be fully accounted for in the Council’s updated viability assessment.

Comment

Representation ID: 18400

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat has no comment on draft Policy EN6, but notes that the extent of Countryside as defined on the Policies Map is expected to change to accommodate additional allocations for development as required to meet the housing requirement and ensure that land is allocated for employment development in the most appropriate locations.

Object

Representation ID: 18401

Received: 24/03/2021

Respondent: Johnson Mowat

Paragraph 4.48.8 states that ‘Policy CO3 sets out the criteria for screening and when a HIA will need to be submitted with a planning application’.

Johnson Mowat considers that draft Policy CO3 does not set out adequate screening criteria and only provides a specific indication of a requirement for Health Impact Assessment (HIA) in relation to hot food outlets.

The draft Policy indicates a threshold above which a screening assessment will be required, but provides no indication of the nature or context of development proposals above the threshold that would be expected (or not expected) to be accompanied by a HIA. Greater clarity on this should be provided to make sure the plan is effective in this regard.

Object

Representation ID: 18402

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat objects to part I of draft Policy ID1 which suggests ‘all residential and new employment development should consider the mobile telecommunications requirements of the development proposals and ensure and demonstrate that there would sufficient coverage’. This requirement is considered to be disproportionate to the scale of smaller developments and likely to be beyond the reasonable ability of a developer to ensure there is sufficient coverage.

This part of the draft Policy should therefore be amended to apply to major development proposals only.

Object

Representation ID: 18403

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat objects to the draft Appendix 13 ‘Planning Obligation Formulas’ as this appears to be potentially incomplete and lacking of satisfactory justification or evidence. Indeed, the third paragraph indicates that this appendix ‘will be further developed and form part of the Local Plan’.

We are therefore concerned that it is not only premature to consult on its content, but also that items to be added or amended in future may have a material effect on the deliverability and viability of development.