Leeds Publishes Core Strategy Review Consultation Papers – February 2018

 

The details of the Leeds Core Strategy Selective Review (CSSR) Consultation have been published, which started on 9/2/2018 and completes at 5 pm on 23/3/2018.

https://www.leeds.gov.uk/your-council/planning/core-strategy-introduction/leeds-core-strategy-selective-review

Details of the policy and paragraph changes can be seen at: –

https://www.leeds.gov.uk/Local%20Plans/Publication%20Draft%20Plan%20Supporting%20Documents/3.Core%20Strategy%20Selective%20Review%2c%20Publication%20Draft%2c%20Proposed%20policy%20and%20paragraph%20changes.pdf

The CSSR is fully separate from the Site Allocation Plan Review Consultation, which started on 15/1/2018 and completes at 5 pm on 26/2/2018.

For those of you with arithmophobia (fear of numbers) – you might want to stop reading now……!

Here is some background to the Core Strategy Selective Review.

Leeds admitted (July 2017) that the housing target (66,000) was too high and had promised a review and consultation. This consultation is it. Whilst covering a number of issues, the key ones are Leeds’ housing target and the plan period. These are proposed as a net requirement of 51,952 houses, in a revised plan period of 2017 to 2033.

It is notable that in the existing plan period of 2012 to 2028, 13,272 houses have been built in the 5-year period. If you add these to the 51,952 above, you get a total of c. 65,500 – not so different from the original 66,000: just 5 years longer to deliver them.

Leeds has delivered 13,272 houses (2012 to 2017), has in the original plans 43,769 houses allocated or identified on non-greenbelt sites, and planned for 12,385 on green belt land. This is a total of 69,424 – greater than the 66,000 in the current Core Strategy.

In September 2017, Government suggested the Leeds land allocation target should be 42,000 houses, with the figure excluding housing needed to accommodate “ambition growth”.

The numbers remain confusing, as the important measure is the housing number that requires the allocation of land that has not already been allocated. So, some corrections to the housing target figure, for land allocation, needs to be carried out, and this is explained in pages 4 to 7 of the Core Strategy Selective Review Publication Draft, copied above.

Whilst 51,952 is the target, Leeds expects to lose 150 houses per year in demolitions (c. 2,400 over the life of the plan). This figure is added back into the housing target to give 53, 856 for the period 2017 to 2033.

On the other side of the equation, Leeds has demonstrated in the past that some 500 houses per year (8,000 over the life of the plan) arise from employment land that becomes available for housing (4,000) and another 4,000 unoccupied houses coming back into use. Both of these do not require the allocation of new land. So these houses are taken off the housing target to give a revised total of 45,856 (c. 46,000) that need land to be allocated for them.

With the existing housing target set at 66,000 houses on land to be allocated, a reduction to 46,000 is eye-popping and must beg the question as to whether any Green Belt land release is required at all. You’ll recall that the Site Application Plan Review allocates c. 6,000 houses on Green Belt Land for development in phase 1 (the first 5 years of the plan from 2017 to 2022/2023) and places the remaining c. 6,500 in a new category, “broad locations”. This puts Green Belt land “on the shelf” for possible housing use later on after 2022/2023.

A powerful argument arises in that broad locations are being used to prop up the testing of the Site Allocations Plan (in July 2018) against a Core Strategy that will still be out of date in July 2018 (as the review will not have been completed).

It would be more logical for reset the Core Strategy to the new housing target and new plan period, and then test the revised Site Allocations Plan against that. Broad locations would not be needed, and proper Green Belt assessment should limit or exclude the use of any Green Belt site for new housing, as clearly there is enough land elsewhere already available, as Leeds has demonstrated.

What you should do now…………..

My recommendation is that you put in a response to the consultation. I fear we won’t be listened to – but that is another matter. No change there.

Your key points might be:  –

  • Acceptance of the new nett housing land requirement for c. 46,000 houses in the new plan period 2017 – 2033
  • Rejection of the Core Strategy Selective Review (CSSR) timing, in relation to the Site Allocations Plan (SAP) Review, on the basis that Leeds plans to test the revised Site Allocations Plan on an out of date Core Strategy, as the CSSR review will not have been completed by July 2018.
  • Call for the SAP hearing in July 2018 to be delayed until the CSSR has been completed, so that the revised SAP can be properly assessed by Inspectors against an in-date Core Strategy. 

 

This is a bit convoluted, but I believe Leeds have not made this easy for us, and I can’t help wondering if there is some method behind this.

 

Martin Hughes

Chair, Yorkshire Greenspace Alliance

Leeds Continues to Confuse on Forward Planning

At this stage of Leeds’ Forward Planning process, you might expect some clarity to have come out of the mess that Leeds have got themselves into. Not so.

Leeds Core Strategy (CS) sets out housing target, plan period and a host of policies relating to land use, housing, employment, retail and traveller requirement. Targets are set widely by identifying areas called housing market character areas (HMCA). The Site Allocations Plan (SAP) allocates land in these HMCAs for these purposes in detail.

The formation of the CS and SAP are two separate processes, with the CS fore-running the SAP, as you might expect – identify how many houses are needed (CS) and then determining where to locate them (SAP). The principle that the CS is followed by the SAP is well established in planning procedure.

Leeds adopted its CS in 2014 based on 66,000 houses, in a plan period 2012 – 2028. The SAP was to allocate land for those houses in a hearing due to start in October 2017.

Community groups and YGA have always stated that the housing target was too high, and challenged the way in which it was calculated, using out of date population statistics from the 2008 Census.

In July 2017, Leeds agreed that population data from the 2011 Census was indicating lower population growth, and that a revised housing target of 55,000 might be more accurate, and allow for a target that included growth and ambition. They also suggested extending the plan period to 2033. These changes require that a CS Selective Review be carried out, and this includes public consultation.

Government put in its penny-worth on housing targets during September 2017, proposing a methodology for calculation of them and an estimate of housing, which for Leeds was set at 42,000 houses, not taking account of growth or ambition. Projections for other northern cities were also significantly lower too.

YGA amongst others, challenged Leeds, and the SAP hearing Inspectors, about testing the SAP against an out of date CS (66,000 houses), when both Leeds and the government were suggesting a lower housing requirement. This would have led to the SAP allocating too much Green Belt land to housing that was not accurately assessed.

Leeds’ reaction to this was to allow the SAP to continue in October 2017 to allocate land for employment, retail, travellers and greenspaces (and other things), but to delay any further consideration of housing land allocation (including that on Green Belt) until July 2018 – a delay of 8 months.

Applying horse and cart theory to this might suggest that Leeds would carry out the CS Selective Review, as above, BEFORE allocating sites within the re-started SAP.

Leeds have not done this.

In January 2018 Leeds has published revisions to the SAP, for consultation now. In February 2018 they will be publishing details of CS Selective Review, the primary parts of which are a revision of housing target to 52,000, in a new plan period 2017 to 2033.

Leeds say that the SAP revisions will be in place sooner than the CS Selective Review revisions, and that it is important to allow the SAP to go ahead, based on a housing target of 66,000.

This leaves the same question as above – testing the SAP against an out of date CS. However, this problem is overcome by Leeds, by introducing “broad locations” – a device that earmarks Green Belt land for housing, without allocating it or taking it out of the Green Belt – effectively putting such land on the shelf for later use. There are now only two classifications for SAP housing sites – allocated, and broad locations. Allocated land is deemed suitable for housing now. Broad locations are sites that may or may not be required in the planning period after 2022 / 2023.

In the original CS, Leeds said it needed approximately 12,500 houses, out of the 66,000, to be placed on Green Belt land. In the original SAP, land would have been identified for this. The SAP revision will allocate some Green Belt for about half these houses, and designate the rest as broad locations, for later, if needed.

A few more questions arise: Some 13,500 houses have been built during the initial plan period of 2012 to 2017. If you add these to the 52,000 houses in the plan period 2017 to 2033, you get 65,500 houses. This is very close to the original CS target of 66,000. So, what we are seeing is much the same number of houses, but planned for a longer period.

This therefore raises Leeds’ intentions for the Green Belt sites designated as broad locations, in the plan period after 2022 / 2023. This means that YGA’s work is not over!

Donations made to YGA have meant we have been able to take expert advice from a planning barrister. We think the use of this advice was instrumental in delaying the SAP and causing Leeds to pause the allocation of many green belt sites.

Leeds’ introduction of “broad locations” allows them to carry on with an out of date CS, against which a revised SAP can be tested, where the SAP allocates limited Green Belt for housing, and lines up the rest for later, without its removal from the Green Belt. We think that this is ploy so that Leeds effectively makes no changes to overall housing numbers and where they are to be placed.

Where next for YGA?

We will be consulting with our planning barrister to obtain the best advice and have two chances to challenge what Leeds are doing. The first is in the two consultations on the SAP revisions and CS Selective Review consultations. The second is during the SAP re-started hearing in July 2018. We know that Leeds has not taken any notice of responses from public forward planning consultations, so we do not expect that to change. In the SAP revisions consultation of this moment, we are asked for comments about the allocation of some sites (or partial sites) to broad locations. The response document is prescriptive, warning that off-topic comments will be binned, on the basis that previous comments still stand and “have been considered”.

YGA feel that it must maintain three key challenges: –

  • The legality of the use of “broad locations” within a revised SAP, as a device to prop up testing of the SAP against an out of date CS
  • The illogical procedure of reviewing SAP before CS, where the principle of CS followed by SAP is well established in forward planning procedure
  • The continuing use of 1) quantum (housing number) and 2) “fairness” (that reduction in housing number should be reflected proportionately over the area of Leeds City) as exceptional circumstances for the removal of land for housing from the Green Belt.

Your help and support of YGA has got the organisation this far, but there is further to go. Thank you for the help you have given us, and please continue to provide it in any way you can. You can donate via the website www.yga.org.uk. Thank you.

Martin Hughes

Chairman, Yorkshire Greenspace Alliance

Revised housing target and implications on green belt requirement for Leeds?

Yesterday (21/11/2017) Leeds Development Plans Panel set the wheels in motion for a reduced housing target from 70,000 down to 52,000. This needs to be agreed by the Leeds Executive Board and form part of the Core Strategy Selective Review, which will go through its own consultation process in early 2018.

The other key decision yesterday concerned the introduction of “broad locations” in to a review of the Site Allocations Plan, the second part (allocation of housing and green belt) of which with be tested against the existing Core Strategy in about July 2018..

The notes I took at the meeting are below.

Development Plans Panel (DPP) 21/11/2017

1). Core Strategy Selective Review – Housing Target.

Paper from Robin Coghlan. Link: –http://democracy.leeds.gov.uk/documents/g8061/Public%20reports%20pack%2021st-Nov-2017%2013.30%20Development%20Plan%20Panel.pdf?T=10

Starts at page 7.

Summary recommendations

OAN Requirement /

Methodology

Annual housing Plan period housing Land to allocate (houses) Indicative 5-year land supply (years)
DCLG Consultation (OAN) 2,649 42,384

 

36,784 11
SHMA ADJUSTMENT 3,247 51,952

 

46,352 9
SHMA REM 2017 3,478 55,648

 

50,048 8
SHMA HIGH GROWTH 3,783 60,528

 

54,928 7
Core Strategy 2014

 

4,700 70,000

 

66,000

 

4.3

 

 

REM = Regional Economic Model

SHMA = Strategic Housing Market Assessment

Land to Allocate = Housing target less windfalls etc.

DPP asked to recommend one of these 4 methodologies to Executive Board. Note that it’s the methodology being recommended, not the number – the number might change if the figures used in the methodology change. I don’t think councillors necessarily grasped this.

One hour of discussion and questioning by councillors resulted in a vote which went 7:2, and 2 abstentions, in favour of the SHMA Adjustment model. If you like, this is a recommendation to Exec. Board for 52,000 houses.

If Exec Board approves, this will move forward in the CS Selective Review and go to city-wide consultation during January / February 2018.

It was stressed that the housing target NOW, remains at 70,000 and that the SAP will continue to be tested against this – subject to 2) below. Lower target signals availability of good 5-years land supply.

2). Amendments to the Leeds Site Allocations Plan – further technical work on

housing allocations and safeguarded land and revised timetable

 Paper from Martin Elliot. Link: –

http://democracy.leeds.gov.uk/documents/g8061/Public%20reports%20pack%2021st-Nov-2017%2013.30%20Development%20Plan%20Panel.pdf?T=10

Starts at page 19.

Summary recommendations, which were approved by a majority for recommendation to Executive Board.

Development Plan Panel was invited to: –

  1. Note the update on further technical work on housing and Green Belt and revised

timetable for the hearing sessions of the SAP Examination

  1. Consider the revised approach to Green Belt sites in the Submitted SAP and the

consequent continued allocation of a selection of those sites, alongside the

designation of Broad Locations for the remainder

iii. Recommend to Executive Board that the Submission Draft SAP be amended to

reflect this revised approach and be subject to public consultation prior to

submission to the Secretary of State.

Key points: –

Of the 12,385 houses that were to be allocated on Green Belt GB) land, 5,594 will remain in SAP for allocation from GB. 6,787 houses proposed on GB will be defined as “broad locations” (BL). See table below.

BLs remain in the green belt, but are identified in the SAP as reserved land should it be needed after the first 5 years of the revised plan 2017 -2033.

BLs are loosely defined and can be general areas or site specific says Leeds. Leeds have gone with site specific. This is to best inform the public, they say.

All PAS sites (UDP safeguarded site) become BLs, unless already released for development.

To maximise GB in the “bank” and limit GB for use, some GB sites needs to be advanced in terms of phase. This is from later phases to phase 1. Those sites becoming BLs in phase 1 move to later phases.

Summary of sites can be seen at : – http://democracy.leeds.gov.uk/documents/b19028/Supplementary%20Pack%20-%20Items%206%20and%208%2021st-Nov-2017%2013.30%20Development%20Plan%20Panel.pdf?T=9

Starts at page 8.

SAP hearing on housing allocation now programmed for July 2018. This is expected to test the soundness of the revised SAP against 70,000 CS, and it is expected that the BLs will overcome the GB problems re allocating too many GB sites in the light of expected housing target reduction.

Fairness (re individual HMCA house targets and sites) still foremost in considerations. That is, any reductions in housing should be reflected across the whole city and be based on what has already been delivered. When submitted to Exec Board, this table will be extended to prove fairness, but e.g. adding a column that shows planning application approvals in each HMCA.

Table 1: Site Allocations Plan target per HMCA and number of homes needed to remain in each HMCA 

HMCA Target Submission SAP

Housing

Allocations on

current UDP Green

Belt

45.2% target of

Green Belt land to

remain as housing

allocation

 

54.8% target of GB

to be redesignated

as

Broad Locations

 

Aireborough 2,300 972 439 533

 

City Centre 10,200 0 0 0
East 11,400 245 111 134
Inner 10,000 0 0 0
North 6,000 1365 617 748
Outer North East 5,000 1974 892 1082
Outer North West 2,000 152 69 83
Outer South 2,600 1634 738 895
Outer South East 4,600 2595 1172 1422
Outer South West 7,200 2456 1109 1346
Outer West 4,700 992 448 544
Total 66,000 12,385 5,594 6,787

 

3). Strategic Housing Land Availability Assessment Update 2017

 Paper from Matthew Brook / Kathryn Holloway. Link: –

http://democracy.leeds.gov.uk/documents/g8061/Public%20reports%20pack%2021st-Nov-2017%2013.30%20Development%20Plan%20Panel.pdf?T=10

Starts at page 33.

Summary recommendations, the least contentious item on the agenda, which was approved by majority. The committee agreed to publish the full report, which starts on page 43 from the link above.

DPP was requested to note: –

  1. This 2017 update of the Strategic Housing Land Availability Assessment (SHLAA) has used the Council’s established methodology in accordance with national planning policy and up-to-date interpretation of planning guidance.
  2. The assessment concludes that an improving stock of deliverable land supply exists in Leeds within the context of the strengthening market, recent planning permission activity and ongoing housing growth initiatives.
  3. The Council anticipates that it will be able to demonstrate a five-year housing land supply upon the adoption of the Site Allocations Plan, if not sooner pending changes to the National Planning Policy Framework and consequent implications for the housing land supply requirement for Leeds.

 

Martin Hughes

Chair, Yorkshire Greenspace Alliance

November 2017 – An Update on the YGA Campaign

Following the successful initial YGA campaign to raise funds to employ a barrister, YGA is launching a second campaign to boost funds to support the delayed Site Allocation Plan hearings that will reconvene in March 2018 or later. WE thought you’d like an update on where we stand………

A quick recap of what has happened so far?

  • Leeds adopted the Core Strategy for 70,000 dwellings in 2014, carried out the consultations in 2015-2016 and ignored literally thousands of formally raised objections from members of the public and the region’s community groups who were all opposed to the proposals to use the region’s Green Belt to achieve their overly ambitious house building targets.
  • Yorkshire Greenspace Alliance was formed in 2016 with the sole intention of forming an effective legal challenge to protect the entire region’s Green Belt; and set out fund raising to deliver this goal with the use of specialist legal representation at the forthcoming Government Inspector’s review of the Leeds Site Allocations Plan.
  • In early 2017 Leeds announced a selective review of the Core Strategy (CS) to include a new housing target and plan period, as Leeds’ own data was showing need-evidence for 55,000 dwellings; while simultaneously still pressing on with the original 70,000 target.
  • Using funds from donations raised, YGA sent a formal legal letter querying how the hearing could go ahead, to be tested against a target that was out-of-date; sent to the Government Inspectors and Government Housing Minister.
  • In summer 2017, as expected, the Government published a new standardised methodology for housing target figures, which suggested a Leeds housing target of just 42,000.
  • In autumn 2017, Leeds then postponed the main aspects of the Government Inspector’s review which deal with allocating housing and removing land from Green Belt. Only the aspects dealing with methodology, infrastructure, employment and retail sites and anything other than housing and Green Belt was held during the week starting 23/10/2017.
  • All community group leaders and members of the public who had pre-registered to make their points to the Inspectors were quickly shut down before they could finish their pre-planned points for review. Only the barristers representing the big-name house builders were allowed to speak freely; and did so at length, with the Inspectors.

So, what is going to happen next?

  • Leeds City Council will carry out the selective review of housing target, plan period and other issues. There will then need to be a review of the new plan to take account any changes. This will involve (yet another) community consultation where submissions from the public will most probably be ignored again.
  • The six-week pre-hearing period will give the public, the community groups and YGA a further chance to respond to changes, potentially communicating directly with the hearing Inspectors (expected Jan/Feb 2018).
  • Leeds will submit a final revised plan for the government appointed Inspectors, whose consideration and public hearing is now expected in March 2018 or possible later in May 2018.

What are the new major risks for the region’s Green Belt?

  • The largest Green Belt sites (such as Garforth, Horsforth and Parlington) are now most at risk; as the Council and major house building companies want to prioritise the sites which can deliver in excess of 1,000 houses, for maximised profit.
  • The new lower housing target from 70,000 is still to be confirmed. If Leeds do lower it to below 55,000 it could negate the use of any Green Belt, but given their track record of being lead by the big developing companies, this is highly unlikely without intervention forcing them to deliver brownfield sites first.
  • Lead Planning Councillor Richard Lewis has announced a new intention of creating “broad locations for development”. If these are areas of Leeds Green Belt which are not officially allocated in the revised plan, they may still be subject to call-up later, if house build rate is not achieved.
  • House builders continue to influence the housing market, the lead Councillors and Leeds City Council by choosing not to develop large areas of brownfield land which are laying dormant with approved planning permission, to control house supply, selecting the most profitable build locations and the most profitable housing types.

Why is funding YGA’s specialist barrister more vital then ever before?

  • The only way to make any legal arguments against the house builder’s profit focussed plans, and the misguided targets of Leeds City Council heard during the next Inspector’s review (March 2018 or after) is to continue to use the specialist barrister.
  • When Leeds City Council publish their revised plans, they need to be meticulously reviewed to ensure that any attempts to utilise the Green Belt to deliver house building targets are vehemently contested and the council’s house building targets are really reduced in line with the Government guidelines, negating the need to include any Green Belt.

HOW CAN YOU HELP?

  • Please make a contribution to the increased legal costs which have resulted from Leeds City Council’s decision to delay the hearings and revise their plans at the last minute. PLEASE DONATE HERE TODAY: www.yag.org.uk
  • Please volunteer your time for social media, leafleting, fund raising or other types of assistance: chair@yga.org.uk

 

Martin Hughes, Chairman, YGA

Tong and Fulneck Valley, Bradford – “The Countryside Next Door”

As YGA moves forward, attention is turning to the next local plan for consideration, which is that of Bradford, as their site allocations proceed.

Bradford appears to be travelling in the same direction with its forward planning as Leeds was, and to be making the same fundamental mistakes that YGA hopes the Leeds SAP Inspectors will take into account during the October 2017 hearing.

A special part of Bradford is that area formed by the Tong and Fulneck Valley.

  • LOCATION: The Tong/Fulneck valley is a fine example of greenbelt protected land that provides ‘countryside next door’ to 2.2 million people of urbanised communities in West Yorkshire, and lies at the centre of this urban conurbation. In addition to statutory ‘Duty to Co-operate’ tasks, Bradford’s responsibility is increased due to it being an area that cuts deep into Leeds territory. We believe this has been done minimally and tokenistically.
  • SCALE:   The area is scheduled to be the largest site for green belt release in Bradford MDC – 2,700 new houses of the 11,000 projected would be built on a large swathe of land deep in the Tong Valley and across Westgate Hill.   25% of Tong green belt would be lost – and more could follow.
  • SIGNIFICANCE: In addition to the green space significance and potential of the land, the unique ancient heritage settlements of Tong and Fulneck are a vital extra feature.
  • FLAWED POLITICAL PROCESS: In the so-called Tong & Holme Wood Neighbourhood Development Plan, local people was over-ridden by professionals and politicians. All the local representatives signed a ‘Minority Report’ that opposed the large scale green belt release proposed in the NDP.
  • FALSE PROMISES – Bradford Council’s assurance that they would use ‘New Homes Bonus’ money from the ‘Holme Wood Urban Extension’ is tokenistic and probably unrealistic. The housing growth would further damage the quality of life of Holme Wood residents.
  • POLITICAL SUPPORT – our three Ward Councillors and our MP are all Labour – and have supported their Party’s Local Plan housing proposals, including the Urban Extension. They however oppose the building of a new highway through the Valley – see below.
  • PROPORTIONATE HOUSING: TFVA is urging that any greenbelt release in the Tong Valley must be proportionate, and on land that is less sensitive and environmentally significant. We are not opposed to the building of up to 900 homes as infill or on degraded land.

 Key Points – BRADFORD – Britain’s ‘youngest city’ 

  • RE-IMAGINED CITY CENTRE: Bradford has opportunity for housing on post-industrial city centre brownfield sites and vacated commercial premises.       It could pioneer a re-imagining of Bradford & provide models for others to emulate, rather than invade precious countryside.
  • AIR QUALITY: Bradford’s traffic congestion problems are immense, and widely recognised, resulting in growing levels of air pollution, with related health problems. The need to ensure that new housing does not lead to increased C02 emission should be a top priority.
  • GREEN BELT REVIEW: It is disappointing that Bradford’s Green Belt Review is being included in the Local Plan Allocations Proposals       The ‘Exceptional Circumstances’ case for Green Belt release has inappropriately focused almost entirely upon housing need.
  • NEW LINK ROAD: A proposed new highway would cross the Tong Valley to link the A650 at Westgate Hill with A647 Leeds Road at Thornbury. Further greenbelt release would result, with industrial development adjacent to it. The road would suck higher levels of traffic into the area, and further damage air quality. We are struggling to get adequate information.
  • REVISED TARGETS: There is justification for Bradford to revise its new homes requirement from 42,000 to 35,000 – in line with Leeds, – reducing green belt release required to only 4,000 homes, and perhaps eliminate this if a ‘re-imagining’ of the City Centre is adopted.
  • PUBLIC TRANSPORT: the new housing would result in much greater car dependency. The area is not served by the rail network, and bus travel is expensive and inefficient.

QUESTIONS:

What more can be done to strengthen and secure Government greenbelt protection policy?

Are there any hopeful national initiatives being taken that it might be helpful for us to know about?

How might we improve our campaign to prevent large scale loss of green belt protected land for housing and industrial development in the Tong Valley?

What key factors might force Bradford Council to have to revise its plans to invade the green belt?

How might we gain more accurate and up to date information about the new Highway that has been projected?

 

Author: Canon Gordon Dey, Save Tong Valley

www.savetongvalley.org.uk