Notes on the Leeds City Council Development Plans Panel (DPP) Meeting of 16th October 2018
I have assumed that readers of this will recognise the various acronyms used in the notes.
The meeting had two items of interest: –
- A report of housing need – changes to household projections and Government Methodology / Guidance. (This from the most recent Gov housing need projections).
- Site Allocation Plan Update
The reports start at page 7.
New housing needs projection (2016 sub-national housing projections) from Gov show national reduction by 25% over next 25 years, and in Leeds down 32%. Stats come with a health warning, as the methodology used now has changed again, leading to some confusion.
Figures that Gov will be publish in December 2018 are much more likely to be better indicators and these current figures can only be regarded as a signal to lower housing needs, without any sound quantification of that.
Leeds intends to note the downward trend, but not to change their methodology or their current target. See 3.7 page 10 for Leeds’ justification of this.
Gov figures ignores effects of economic growth. Leeds situation within Leeds City Region (and its plans) is expected to generate the extra need well above the basic housing needs identified by Gov methodology.
Leeds think their methodology is way ahead of that of the Gov. New Gov method has removed household projection data going back to 1971 and limits it from 2001. One might argue that a more modern set of projections for 2001 to 2016 in a time of recession and austerity is more relevant to reality than a wider period of 1971 to 2016, when there have been periods of strong growth.
What is clear is that the “downward housing target trajectory” (as Leeds have put it) is true and significant. What is also clear is that Leeds pays lip-service to it and will determine Leeds figures based on what they think and not using approved methodology. We cannot therefore expect there to be much, if any, change to the situation already proposed within CSSR.
Report starts page 15 in Agenda notes.
SAP hearing report. Leeds is “spinning” the Inspector’s comments on limiting the loss of green belt. “The Inspectors agree with us that………….”
Two issues have emerged from the Inspectors: –
a). Broad locations out. Sites remain GB.
b). Procedural issue, in that Inspectors said they were testing the RSAP against the CS. But throwing out BL means that they now want Leeds to revert to the original SAP, and it is this they will test against the CS in their final report. However, this will be done only in terms of the first part of the plan period 2014 to 2023 (for which there would be a housing target of no more than 42,000 – and therefore no need for GB).
Based on this new approach this would suggest that there remain GB sites to accommodate 6,450 houses in the plan to 2023. A review of the SAP in 2023 would then look at the later period.
However, CSSR gets in the way! The elephant in the room (as kept coming up in the hearing) is that housing need is clearly falling. See later in this report.
This is Leeds’ plan of action: –
Based on Inspector’s most recent correspondence re BL and reverting to original SAP – Provide Modifications list to Inspector by the end of October 2018.
Inspectors then respond with their modifications (when?)
Leeds review these and carries out any new site assessments (sustainability appraisals and GB reviews) needed where sites are modified out, and new ones come in. This is based within HMCAs. A site removed in a HMCA is replaced by one or more sites within the same HMCA.
This information to DPP and Exec Board, to agree action and agree further public consultation for 6-weeks.
Response to consultation submitted directly to Inspectors (as previous).
Inspectors provide their report on the whole SAP hearing, based on the original SAP. Can’t imagine this being before May??? 2019.
Concerns about “weight” of Leeds’ plan, in planning determinations. Weight of dev plan increases at each stage of “progress”. A dev plan before SAP hearing had less weight than one after it. Dev plan will have more weight after Leeds modifications, and then after Inspectors suggested modification etc. etc.
But ………………. In the back ground is the CSSR.
Inspector Sherratt (one of the SAP Inspectors) has been appointed to hear this. Martin Elliot talked about a hearing in February 2018 if they can book her and the Programme Manager (Helen Wilson).
So, the CS and SAP train is moving along a set of rails. The CSSR and any revised SAP would be moving along another set of rails.
I think the two will collide timewise, and the result might be that CSSR and RSSAP emerge (by stealth – what a surprise) as the dev plan direction – and Leeds will pat themselves on the back as a job well done. This is what we have been suggesting Leeds does.
What does this mean for GB sites? Answer: nothing. The ones at risk during the RSAP are still at risk. Martin Elliot suggested that DPP should “expect few surprises” in terms of sites allocated and suggested this was necessary to avoid further lengthy public consultation. He stated at the moment that there were no indications from Inspector’s as to what sites they might want to remove in their proposed modifications.
I believe that we should be praying for the Inspectors to make significant site changes in their modifications, and that these then take Leeds to needing public consultation. Time will then pass significantly, and the CSSR train will be up to speed and overtake the CS / SAP train, so that we get housing target properly reflected in revised site allocations – with as little GB as possible.
Chair, Yorkshire Greenspace Alliance
17th October 2018