3.8.11 Overall based on current evidence, it is considered that there are no fundamental strategic constraints or significant adverse impact to delivering a housing requirement figure of 1,704 new homes/year over the 18-year plan period that cannot be mitigated. However, based on current evidence it is considered that the additional 35% uplift of the standard method cannot be realistically met in terms of deliverable land supply, strategic constraints (Green Belt) and potential significant adverse impacts within the Regional City of Bradford.
3.8.12 The Council is ambitious and supports sustainable housing growth in the District. However, without the identification of significant additional funding to unlock substantial amounts of new land and opportunities and supporting infrastructure within the Bradford urban area, it is considered setting a Housing Requirement based on the minimum LHNA figure of 2,300 new homes/year is neither currently justified or deliverable.
3.8.13 The Council will therefore seek to meet a minimum housing requirement of 1,704 new homes/year over the plan period. This will ensure that the housing requirement will meet (and exceed) demographic housing need in terms of projected household growth and provide significant additional market and affordable homes. This housing requirement would also represent a significant boost in housing delivery over recent years.
It seems they drafted the local plan; the new OAN method came along and they made no changes. The uplift is in line with the pre 2018 based HH projections. But with a weak market with flats in central Bradford on sale for as low as 12,000 they consider this undeliverable.
As I have said the urban uplift will have little impact as either you are overshooting anyway (Liverpool) or it is ridiculous and impractical without major Green Belt loss (Bristol).
A key question is whether the urban uplift is additional reason for ‘exceptional circumstances’ for Green Belt loss? There is no douby that housing need can be (caselaw). The section on ‘Rationale for cities and urban centres uplift’ at no point mentions need to minimise Greenfield loss. Its arguments about existing infrastructure and carbon reductions could apply to well connected edge of city sites.
‘In considering how need is met in the first instance, brownfield and other under-utilised urban sites should be prioritised to promote the most efficient use of land.’
This is the same as the normal Green Belt test. So it would seem the new change could be further exceptional circumstances for Green Belt loss. So LPAs like Bradford that fail to consider this will be in trouble. It would have been a lot better of Bradford had proposed allocating 500 x 18= 9,000 extra Green Belt homes and saying ‘look guv the Government made us do it as the new national policy doesn’t allow exclusion of Green Belt sites from the Urban uplift.’
Note: The plan includes an assumption of 2,500 extra homes from development at the south of the City Centre around an NPR station. I personally think the government will ever find the 6 billion extra to tunnel under Bradford (and Halifax), even if announced it will fall at the first review as costs escalate, so speculators will be going all in for Green Belt sites south of Low Moor which is a more practical location for a station.