LDF Core Strategy Briefing Note 2

Response to LDF Core Strategy – Reasons why Wilsden should not lose greenfields to 300 houses

Briefing note prepared by Cllr Jane Callaghan for  the Wilsden Parish Council discussion on a response the LDF Core Strategy Document.

 ‘Housing, Evidence and Policies’ lays out the aims of the Core Strategy, viz;

  • sheer scale of need from projected population growth
  • developing a location strategy which reflects where need is greatest; where jobs, services and infrastructure are concentrated, which avoids highly sensitive environments but also reflects where land is available and developable
  • promoting maximum use of brownfield sites
  • ensuring mix reflects type of need
  • providing enough affordable housing in areas where needed
  • improving design and quality of housing development
  • assessing and providing for the needs of travellers, gypsies
  • reducing overcrowding and decreasing the number of long-term vacant homes
  • delivery at a time of weak economy, limited access to lending, low and decreasing public housing investment
  • jobs, services and infrastructure

Leaving aside doubts over the figures derived for population growth from the ONS (which we are told are achieved by formula), the expected growth in Bradford is due mainly (84%)  to children being born. The annual increase will not therefore need to be settled into new housing, but will be absorbed into larger households. The assertion that Bradford will need another 45,000 houses is flawed, though there will be a need for some larger houses to be provided in the areas with higher birth-rates.

None of the aims given at the start are addressed by the Core Strategy.

There is no hope of achieving anything like the number of houses that have been suggested – in boom years with a building industry at its peak, there were 1560 completions per annum. How then can a figure of 2700 per annum be achieved in a recession (even factoring in the notional 10% fewer  over the next eight years due to the weak economy – a figure seemingly plucked from thin air and bearing no resemblance to the moribund building situation at present)?
Indeed ‘HO2 Land Supply’ states that many permissions such as city centre apartments are currently undeliverable. If the Planners’ answer to this is to release greenfield sites in the lowest hierarchy settlements because those are the only places developers are willing to build in the current economic climate, then we will have an increased housing stock which does not fulfil any housing need, and we will have ruined the openness of our countryside forever.

The SHLAA conclusions (developed via a working group with significant Developer input) state;

  • current housing land supply is limited and inadequate
  • approximately 44,000 dwellings but this includes areas currently protected from development such as Green Belt
  • finding future land supply which is both viable and economically acceptable is very challenging
  • there are market viability  and deliverability issues particularly in Bradford
  • weak market and therefore low annual completion rates until 2016
  • 5 year land supply of only 5,747 = 1.98 years
  • greatest physical and viability constraints in urban areas where developments will be dependent on infrastructure improvements
  • greatest environmental constraints in and around Ilkley and the Pennine Villages

These conclusions are broadly what would be expected from a Developer-led forum. The danger of taking them at face value is that any shortfall in number of houses built can be blamed upon constraints due to viability issues, putting pressure upon the release of greenfield sites for a quick-fix solution.

The Local Authority is expected to have in hand a 5-7 year supply of deliverable land. If the RSS (set at 2700 per annum 2008-28) was set at a realistic figure, there is enough brownfield land in the urban regions for at least 5 years.

A report commissioned by the CPRE in Nov 2011 (‘Building in a small island – why we still need the brownfield first approach’) demonstrated that brownfield land is not a finite commodity which is being exhausted, but rather is a recyclable and, over the long term, reliable supply of building land which can be used when there is the desire to do so. This contradicts the statement in the ‘Land Supply Data - implications’ that ‘falling PDL [brownfield land] percentages compared to recent delivery are inevitable’.
The danger of identifying any greenfield sites, even if phasing them in at a later date, is that developers will ignore the brownfield land in favour of waiting for the easier greenfield sites to become available. One only has to look as far as Leeds for confirmation of this happening. The problems of this are two-fold, the separate character of the villages becomes indistinct as their settlement edges encroach on each other, and the neglected brownfield sites of the urban area become derelict, reducing the social and economic attractiveness of the city still further.

HO4 (Phasing and Release of sites) states; Sustainable growth means that sites will need to be released in phases based on the following goals:

  • maintaining a 5 year land supply
  • prioritise deliverable brownfield sites
  • prioritise urban regeneration areas
  • time release in relation to planned infrastructure improvements
  • ensure an even delivery pattern within smaller/rural developments

The best way of achieving this, in fact the only way, is to put targets on the minimum use of brownfield land, as has previously been the case. Developers may say that it is undeliverable in their opinion, but their lack of will to build on already developed land does not equate to undeliverable. Targets on brownfield use have been met previously and there is no reason to suppose that they could not be met now. Brownfield sites already have the associated infrastructure in place. They are sound choices on environmental grounds, especially carbon reduction, and so are better in terms of sustainability. Prioritising them benefits urban renewal, countryside protection and social welfare.

Finally, the Green Belt in Wilsden and other villages should remain Green Belt because, in the words of the ‘Draft National Planning Policy Framework Impact Assessment’,

‘Core Green Belt protection will remain in place..... In all cases the test to preserve the openness and purposes of including land in the Green Belt will be maintained.’

Green Belt land must not lose its designation in order to appease developers who wish to build on ‘easy’ sites. Our green fields are the lungs of Bradford and even from the city centre the open land can be seen on the surrounding hills. They can be accessed in minutes rather than hours and should be cherished and protected for the sake of future generations, who will be living in an England of declining population after the next 40 years. The decisions we make now will have consequences forever and we cannot afford to get it wrong.