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.
Details of the policy and paragraph changes can be seen at: –
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.
Chair, Yorkshire Greenspace Alliance