Giving away the greenbelt – A critique of Bradford’s Local Plan

Author JA Thompson

‘We have got some money from the Government over the next three years to build affordable housing in the area [Bradford]. The issue in Bradford is that some of the private developers do not want to build houses where the Council wants them to. They would like to build on greenfield areas in Airedale and Wharfedale instead.’

Councillor Val Slater (Deputy Leader of Bradford Council) Telegraph and Argus 22/09/2015

The trouble with this is that Mrs Slater isn’t exactly telling the whole truth. Far from discouraging developers from targeting sites here, and elsewhere in the greenbelt, the Council has actively assisted them. Under the NPPF deleting bits of the greenbelt to open it up to development should only be considered in ‘exceptional circumstances’ which generally means having too many households and not enough other land to put them on. Bradford doesn’t have the exceptional circumstances the NPPF calls for so the Council has resorted to telling fibs. Not just one fib or a couple but a whole string of them and across a number of years. There isn’t space here to include all of them so let’s just look at three of the whoppers.

First off how about having too many households? The Council claims that by 2030 over 42,000 new homes will be needed to house its growing population. This isn’t true. Department of Communities and Local Government (DCLG) and ONS projections show that the number of households is likely to grow by just 28,000 between 2015 to 2030 (the lifetime of the Local Plan). So the Council is planning a socking 14,000 more homes than are required. Even if they argue that they need to clear a backlog because too few houses have been built since the economic crash of 2007/8 they only need to build 2,000 more to catch up so a target of 30,000 would be more realistic.

So how did they reach the figure of 42,000? Initially by telling a fib about job creation. They said that over 4,200 new jobs would be created per annum which would in turn create a need for 45,000 new homes. They argued that building houses would create many of these jobs and construction workers would flood into the District boosting the population. The number of construction jobs they posited was so large that, if one assumes an average annual salary of £26,000, the average new house would have to have yielded over £162,000 on top of materials, land and other costs (never mind any profit) just to pay the builders’ wages. When challenged the Council quietly dropped this nonsense and after a brief detour where they picked another number (2,897), seemingly out of a hat, they finally settled on 1,600 based on some actual evidence (the Regional Econometric Model – REM – data). That’s not even enough to mop up all the Bradfordians who will be of working age, the Council predicts there will be 27,000 more in 2030 than there are now but it is assuming that 15.7% will be claiming out of work benefits and many more will be economically inactive. Despite this they only dropped their housing target by 3,000.

So what about the land supply? Are there enough hectares of brownfield and urban land to take all the new homes in the Plan? This is where a disturbing symmetry creeps into the figures. The Council says that around 11,000 or more will have to be on greenbelt because there isn’t. That’s remarkably close to the 12,000 extra homes they’ve put into their plan so without those extra houses even they are saying no greenbelt deletions would be required. But the full picture is even worse. The Council hasn’t compiled a register of brownfield sites as it has been advised to by the DCLG, it is continuing to rely on sites being proposed by developers, sites that already have planning permission and sites it owns in putting together its Strategic Housing Land Availability Assessment (SHLAA). Yet the urban cores of Bradford and Keighley are riddled with vacant and derelict sites. This isn’t an opinion based on casual observation (though the extent of dereliction is striking to anyone driving through) there is clear evidence that jobs have migrated to what were, until recently, greenfield sites and that brownfield sites have been left vacant.

From 1998 to 2008 the DCLG maintained detailed records on business premises. These give year-on-year changes in the net internal area broken down by class for each Local Authority. What they show is that across the decade there was a net reduction of 559,000 square metres in Bradford. This does not reveal the full scale of abandonment though because premises were built on greenfield sites during the period (there was a boom in urban edge development, particularly retail and business parks) so an awful lot more premises were falling idle than at first appears as businesses and jobs migrated out of the urban core. And the net internal area of a typical business is only a fraction of the land it takes up. If we take the formula Bradford uses to calculate land required for employment and reverse it we can estimate that 559,000 square metres of internal space may well translate into 174.69 hectares of land. What about the rest, the gross figure?

Some of this may have been recycled for housing, some excellent developments have been completed (at Manningham Mills, Little Germany and Trident for example). But regeneration was limited. DCLG land use figures show that in recent times only around 40% of new builds here were on previously developed land and much of that was formerly occupied by houses or their gardens, not industrial premises.

And there is clear evidence that the migration of business to greenfield sites has continued apace since 2008. The 2005 Replacement Unitary Development Plan (RUDP) identified 193 hectares of employment land; land to be set aside for new build ‘B’ class premises such as warehouses and factories. Of these 100 hectares are described in the narrative as greenfield with greenfield prospects forming the bulk of the larger sites. By 2013 when a further review was conducted only 107 hectares remained, most of which were smaller (brownfield) sites. Few people would quibble about this if opening up new greenfield land had led to an increase in jobs, but it didn’t. The REM data shows that the number of jobs fell by 2,049 (FTE) from 2007 to 2013. What happened to the land those jobs had been on and what happened to the land left idle as jobs migrated to greenfield sites? The answer is, by and large, nothing. The urban core of the District (Bradford and Keighley) is being hollowed out and this isn’t sustainable either economically or environmentally. We cannot have a Mad Hatter’s tea party approach to planning where homes and jobs are pushed onto greenfield sites and into the greenbelt because developers want a clean bit. We can’t afford it.

Greenfield development requires investment in new infrastructure. Developers are supposed to contribute but they negotiate hard and the bulk of the tab falls on the public purse. They certainly don’t pay for ongoing maintenance. Meanwhile the integrity of the infrastructure that remains in areas with derelict sites needs to be maintained, generally at public expense. These are sites that contribute nothing to that maintenance: no gross domestic product, no rates and no workers’ wages circulating through the local economy to support other businesses. One way or another we pay those bills, not the developers.

One question all this raises is does the Council have some higher, public interest motive for giving the greenbelt to developers and for manipulating the evidence to enable them to do so? It doesn’t look as though they have. They certainly haven’t articulated a plan for housing, employing or training Bradford’s people that relies upon artificially inflating housing requirements, in fact some of the data published alongside the Plan shows that it is likely to be counter-productive. Let’s take meeting housing needs as an example.

To meet housing needs in full you have to make sure that new homes come at the right price for your population. The spread of prices has to link in with the spread of local wages and with underlying property prices or they won’t sell, not even to buy to let investors. And if they can’t be sold they won’t get built.

Looking at Bradford’s proposals it’s clear that they don’t reflect the economic realities of the local housing market. Bradford is a low wage economy, there are some very affluent people here but their numbers are limited. ASHE/HMRC PAYE data for 2013 shows that median incomes (full-time adult wages) ranged from £354.3 per week in Bradford West Constituency to £498.3 in Keighley (which includes Ilkley and other parts of Wharfedale). At a multiple of 3.5 people earning these salaries could raise mortgages of £64,483 and £90,691. It also has a depressed housing market. The Land Registry put mean property prices here at £95,704 in November 2015 which represents a fall of 22% from the pre-crash peak of £123,670 (February 2008). Compare these figures with the prices developers charge, below are averages for three to five bedroom properties taken from the Bradford CIL Viability Evidence Addendum (2015) which gave prices as reported by developers:

£316,000 to £539,000 in CIL Zone 1 (Wharfedale, the most expensive area)

£270,000 to £456,872 in CIL Zone 2

£229,729 to £374,996 in CIL Zone 3

£151,468 to £389,995 in CIL Zone 4

It’s impossible to give a proper estimate of what they might charge for one and two bedroom homes because the report shows figures for only one area, Zone 4, where prices for two bedroomed properties ranged from £99,995 to £117,950 (no prices were given for one bedroom properties). What seems clear from this is that developers are targeting their products at a very small section of the market consisting of the more affluent buyers. This goes a long way to explaining why they are focusing on Airedale and Wharfedale and the greenbelt but it doesn’t explain why the Council is going out of its way to enable them to do so. By facilitating building on the greenbelt when it isn’t needed it will be helping developers to pursue a high margin, low output strategy instead of encouraging them to work harder for their profits by building more houses for the less affluent people who make up the bulk of the population. It will also encourage developers to target buyers who do not rely on the economies of Bradford and its neighbouring Local Authorities for their incomes. In the case of Wharfedale, particularly Ilkley, this includes retired people from far afield who would like to live near the National Park. Ilkley has seen a massive growth in age restricted developments in the past two decades including a large retirement village with eye watering monthly fees. Drawing elderly people into an area, no matter how affluent they are, is imprudent. As they become increasingly frail they put additional and unnecessary pressure on local services and budgets, particularly those of the NHS. This is recognized as a serious problem in coastal towns which draw in retired people.

Releasing greenbelt won’t help the Council to meet local needs for market housing but its proposals for affordable housing are even worse. Its plan puts a substantial proportion into the more expensive parts of the District but given that ‘affordable’ means sold at a discount of usually just 20% below market value or under a part ownership scheme many will still cost more than the average house in the Local Authority area. Those in Wharfedale are likely to cost in the region of 75% more than their equivalents on the open market elsewhere. So they will not be addressing the needs of people who can’t access housing on the open market (which is what affordable housing is supposed to do) but of people who are almost, but not quite, well off enough to buy a house at the full market rate in a particularly desirable area. This is inappropriate to the point of being improper.

Bradford’s Local Plan is a disgrace. It will not meet local housing needs and it will be environmentally and financially costly. On these grounds alone it should be challenged. However, it should also be challenged by anyone who has an interest in maintaining probity in public life. Council Officers have misled ordinary Councillors and the public by feeding them misleading data, in doing so they have destroyed the transparency in the planning system that protects it from corruption.

For more information on the topics covered in this article, including more detailed reports showing key data, please contact Addingham Planning Scrutiny Group by e-mail at:            apsg.addingham@mail.com