This is the YGA response to the Site Allocations Plan Review Consultation, which closes today in about 25 minutes.
I am responding to the Site Allocation Plan review on behalf of Yorkshire Greenspace Alliance (YGA).
YGA is concerned about the unnecessary inclusion of green spaces, and especially Green Belt (GB), into Leeds’ currently confused forward plans for housing provision. This SAP review does not go to allay the confusion on this; it compounds it.
YGA supports comments made by CPRE on the SAP Review, whose arguments are strong indicators to the unsoundness of the SAP Review on which this response is based.
YGA notes numerous plans with varying titles – only one of which is adopted: –
SAP – original SAP, the part 1 hearing of which commenced on 23/10/2017
SAPR – the revised SAP proposal – the subject of this consultation
CS – the original Core Strategy – approved April 2014
CSSR – the CS Selective Review – now in consultation from 9th February 2018.
To avoid any doubt, the non-use of the standard Word or Online response forms should not invalidate this response, neither should comments that relate to CSSR, which we believe is strongly connected to SAPR. One cannot be considered without the other. We do not accept statements from Leeds City Council indicating invalidation of comments about CSSR within this SAPR.
YGA wishes to make a few wide overarching points, which are not attributed to any SAPR amendment number, but look at the lack of soundness of the whole SAPR: –
- SAPR and CSSR cannot be separated. They are indelibly linked, however far Leeds would like to go in attempting to uncouple them. The principle exists that the CS sets a housing target and roughly where to place them (HMCAs). The SAP sets out the exact sites for that. The SAP supports the CS, with the CS coming first and being followed by any SAP. It is not reasonable for Leeds to suggest that the two plans (though we agree they are, in Leeds’ case, developed separately) should not be linked in this consultation response.
- The testing of the SAPR against an out of date CS is unsound. It is illogical to validate a key site allocating plan for Leeds, where the land needed to be allocated for housing is so way out of kilter with the actual CS test figure. It is also clear that carrying out such a test raises inconsistencies between the CS and SAPR especially in relation to the Spatial Policies within the CS, namely SP1 and SP6.
- Broad locations (BL) is a fudge, being used as a device to prop up the testing of the SAPR against a CS that is out of date. The evidence for this is the CSSR itself, in consultation now. All BL does is to place a stay of use on GB land for a 5-year period, which provides no long-term protection – failing in keeping GB land permanently open – as called for within NPPF 79.
- Our assessment indicates that land for c. 46,000 dwellings would need to be allocated for the proposed CSSR revised housing target. This is c. 20,000 houses for land allocation less that the current out of date CS. With GB allocations originally set in SAP at c. 12,500, the reduction is more than enough to exclude any GB at all.
- At the very minimum, to allow the illogical test of the SAPR against the out of date CS, all GB sites should be allocated to BL (retaining our BL objections), until CSSR has been completed. Leaving c. 6,000 dwellings allocated in phase one from GB, and re-designating the remaining c. 6,500 land as BL remains a fudge, leaves allocations from GB failing tests of exceptional circumstances (based on achieving a housing target), and provides limited c. 5-year protection in the future to some GB BL-designated sites.
- Claims that GB sites moved to phase one allocations for housing are those with the least impact on GB is mostly nonsense. The allocation of a fraction of Parlington is an illustration of that. It cannot be said that the allocation of any land at Parlington has least impact on the GB, so it cannot be said that one third of the site will either. Parlington can be shown to be unsustainable, so one third of Parlington is even more unsustainable.
- YGA notes that Safeguarded or PAS sites have been re-designated as BL, having previously been identified within UDP 2006. With our reservations repeated about BL, we accept the designation of these sites, so that they are given up to 5-years of protection. However, ultimately, we expect to see these sites remain in the GB because they will be unlikely to be required for housing, given a CSSR reduced allocated land housing target.
- The SAPR will allocate land from the GB to fulfil an out of date housing target, which is not justified and where exceptional circumstances have not been demonstrated, and will not be able to be demonstrated. The CSSR provides the evidence that GB allocations are not required, and the evidence that there are no exceptional circumstances to warrant loss of most GB.
- The SAPR cannot be set aside separately from the CSSR – now in consultation, overlapping with this SAPR consultation. It makes no sense to place the planning procedure that sets housing target and plan period (amongst other things) after a site allocation plan procedure that allocates land based on the housing target. It’s back to front; cart before horse. YGA does not accept Leeds’ reasons for continuing with the SAPR and the subsequent hearing (planned for July 2018).
- The government has stated that it will give planning authorities time to address government proposals concerning reduced housing targets (published in September 2017) and Leeds should come in line with that, carry out the CSSR and then address the SAPR. It is illogical to do anything else, especially where the procedure in developing a local development framework is well-established as CS first followed by SAP. Leeds will not be left undefended against house builders appealing speculative planning applications, because the Government has said that there will be weight assigned by Planning Inspectors to substantially developed local plans, which are having to be realigned – along with their SAPs – to reflect government baseline housing assessments.
- The solution to the forward planning confusion is to halt the SAPR, bring forward the CSSR, and as soon as possible reset the SAPR to deliver the sites called for in the CSSR. This is the only logical approach.
- If Leeds persists with the SAPR on technical grounds, and if it can BL- designate roughly half of the GB housing, then it can BL-designate it all, until such a time as CSSR is properly and fully in position and the real need for GB has been assessed through a comprehensive and region-wide GB assessment and review.
- SAPR is a “sticking plaster” plan that needs to be suspended, the CSSR adopted, and then reintroduced, so that it can be based on proper housing need assessment.
Chair, Yorkshire Greenspace Alliance.