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YGA have always stated that the housing target was too high, and challenged the way in which it was calculated, using out of date population statistics from the 2008 Census.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YGA amongst others, challenged Leeds, and the SAP hearing Inspectors, about testing the SAP against an out of date CS (66,000 houses), when both Leeds and the government were suggesting a lower housing requirement.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.
Chairman, Yorkshire Greenspace Alliance