Leeds Site Allocations Plan Leeds Local Plan Leeds City Council s Response to Revised Submission Plan Inspector s Initial Questions Development Plan Document 8 th May 2018 Page 1 of 8
The Council welcomes the Inspector s initial comments and questions. The answers to the Inspector s questions are provided below. Meeting the CS Requirements for housing Q1. If no Broad Locations were identified in the Revised Submission SAP it appears that it would make provision for 61,363 (67,817 6454) dwellings, assuming delivery of all Phase 1 sites. This is sufficient, the Council suggests, to demonstrate a 5 year housing land supply (from adoption) until the period 2022/23. Having regard to Table 1, this would equate to the following breakdown in each HMCA. HMCA CS Housing Requirement Housing provision excluding Broad Locations 2012-28 +/- target (2012-28) Aireborough 2,300 1,517-783 City Centre 10,200 11,909 +1,709 East Leeds 11,400 9,686-1,714 Inner 10,000 13,042 +3,042 North Leeds 6,000 5,151-849 Outer North East 5,000 3,918-1,082 Outer North West 2,000 1,690-310 Outer South 2,600 1,558-1,042 Outer South East 4,600 2,956-1,644 Outer South West 7,200 5,632-1,568 Outer West 4,700 4,304-396 Total 66,000 61,363-4,637 1A. Do the Council agree with these calculations? 1.1 Yes. However, the Inspector is reminded that the Council, in its revised submission Plan have used figures that align with the initial submission Plan i.e. planning/construction information as at April 2016. This is because the Council considered that the revised submission plan was not the place to make selective updates. To that end, the revised submission Plan will, in the Council s opinion, require modification to reflect the passage of time since initial Submission. An update as at April 2017 has already been provided (EX8). The Council is in the process of providing a further update as at April 2018. This will be proposed as a further Examination Document. For clarity the updates are set out below: as at April 2016 CD1/1 as at April 2016 CDR1/1 as at April 2017 EX8 updates CD1/1 as at April 2018 further examination document will update CDR1/1 Page 2 of 8
1B. Could the Council please provide pro-rata +/- housing provision figures to the year 2022/23 (year 11) for each HMCA, excluding Broad Locations? 1.2 Table 1 below is an assessment based on information in the published 2017 SHLAA update; and amended to reflect the status of sites in the revised Submission SAP. It shows the result of amending the position of sites in the SHLAA to reflect that they are Broad Locations (i.e. held back to beyond 2022/23) and the status of sites that were initially Phase 2 and Phase 3, as being Phase 1 in the revised Submission SAP. This approach to sites that are dependant on the Adoption of the SAP (i.e. Green Belt releases placed to start delivering in year 3 post adoption once they have the opportunity to gain planning permission, subject to other deliverability information) is in line with the SHLAA methodology and is considered to be a conservative approach based on SHLAA lead-in timeframes. There are no site availability or achievability impediments to these sites. Indeed, the owners and agents of these sites have made representations to the SAP calling for them to be advanced in this manner. Note that the table also includes the contribution of sites in the Aire Valley Leeds Area Action Plan as amended in the SHLAA 2017 as a result of that Plans adoption. Table 1: Housing trajectory figures to year 11 of the plan period (2022/23) HMCA Completed pre-2017 2017/18 to 2022/23 Total to Year 11 Aireborough 699 1,092 1,791 City Centre 968 7,392 8,360 East Leeds 859 3,922 4,781 Inner Area 1,902 8,255 10,157 North Leeds 975 3,537 4,512 Outer North East 379 1,426 1,805 Outer North West 302 1,000 1,302 Outer South 213 1,371 1,584 Outer South East 546 999 1,545 Outer South West 1,291 3,193 4,484 Outer West 983 3,203 4,186 Total 9,117 35,390 44,507 1.3 When considered against plan requirements and allocations targets in the SAP (taking into account the Core Strategy smaller windfall allowance (i.e. below SHLAA threshold) and demolitions to properly reflect the net requirement) the deliverable supply in the plan up to Year 11 exceeds the amount needed for the same period by +757 units where the allocations target is 43,750 and the deliverable supply is 44,507. This is shown in Table 2 below. Page 3 of 8
Table 2: Calculation of deliverable supply up to 2022/23 post-adoption Calculation Total Net Requirement (3,660 per annum * 5 years) + (4,700 per 46,500 to Year 11 annum * 6 years) Windfall (500 per annum * 11 years) 5,500 Demolitions (250 per annum * 11 years)* 2,750 SAP Allocations (Requirement - Windfall + Demolitions) 43,750 Target SAP Deliverable Sites in 11 HMCA totals to Year 11 44,507 supply to Year 11 Balance (+/-) SAP Deliverable supply to Year 11 - SAP Target +757 * note that demolition activity has maintained a 5 year average of <50 dpa. since 2012 (due to an absence of bulk clearance programmes; a trend which will continue) so the 2,750 dwellings is a significant over-estimate. 1.4 This, as stated, would also provide a comfortable buffer for the future post adoption five year supply period from 2018/19 to 2022/23. Identified Sites 2.1 For clarity, the Council takes the opportunity to provide a summary of its approach to identified sites. The approach is agreed in para 4.6.12 of the Adopted Core Strategy (CD3/1) and explained in para 2.29 of the revised Submission SAP (CDR1/1) and para 4.2 of the Housing Background Paper (CD1/34). 2.2 The revised Submission Draft Plan contains 527 identified housing/mixed use sites. These are split as follows: 255 sites have planning permission 142 sites are built out 78 sites have expired planning permissions 52 sites are UDP allocations without planning permission 2.3 Since submission of the Plan in May 2017, the Council has provided further updates on identified sites in response to previous Inspectors questions as follows: EX2 - Council s response to the Inspectors Initial Comments / Questions to the Council, 26 June 2017 specifically response to Question 9a and 9b (including a table of 39 sites which expired on or after 1st April 2012 and subsequently gained permission) and Question 10 (with a list of sites including status at Appendix 1) EX2c - Council s response to the Inspectors Further Questions, 7 August 2017 para 1.1 to para 1.4 (including table on the latest position of identified sites with expired permissions) EX8 update of planning permissions for housing, employment and greenspace sites. Page 4 of 8
EX24 Further Response by the Council to Actions from Stage 1 Hearings, 9 February 2018 - Hearing Day 4, Question 3 M2/1 Statement by the Council response to Questions 6 and 8 M7/1 a i Statements by the Council response to question 3 Q2. Like policies EO1 and EG1 that relate to identified sites, Policy HG1 refers to identified housing sites. Some of these no longer benefit from extant planning permissions. At the Stage 1 hearings the Council explained that former UDP sites would need to be considered against relevant UDP policies. Can the Council please clarify what other development management type policies the identified sites requiring planning permission would be considered against should applications be submitted? 2.5 The Plan specifies at paragraph 2.52 (CDR1/1) all development management type policies against which planning applications will be assessed. In addition, EX9 Proposed Further Modifications to the Submission Plan, modification no. 6 proposes a further modification by deletion of the title Site Requirements and inserting a new title Existing Planning Policy in order to clarify to the reader that the policies specified are generic policy considerations, which must be considered over and above specific site requirements specified elsewhere in the SAP, Core Strategy or UDP (and where applicable Aire Valley Leeds Area Action Plan and Natural Resources and Waste Local Plan), when submitting a planning application. 2.6 To add further clarity the Council propose a further modification to the Plan to include an additional paragraph after Policy HG1 to state: Existing Planning Policy 2.29a The identification of a site for housing establishes that it is suitable for that use. However, each planning application will be considered on its individual merits and will need to take account of all policies in the Development Plan, which include saved UDP policies, the Core Strategy the Natural Resources and Waste Local Plan as well as this Plan. Specific technical and infrastructure requirements should also be considered. This Plan signposts further generic planning policy considerations as outlined at paragraph 2.52, which apply equally to identified and allocated sites. Q3. Is it sufficient to identify site requirements in an Appendix of the Revised Submission SAP as proposed by the Council (See Actions from Stage 1 Hearings 9 th February 2018) 3.1 To clarify, the Council confirms, as in its response to Actions from Stage 1 (EX24), that that it does not propose to identify site requirements (for UDP Identified Sites) in the Appendix to the SAP. 3.2 Rather, the Appendix will, pursuant to Schedule 8 of the Planning and Compulsory Purchase Act 2004, specify all UDP policies which are to be deleted on adoption of the SAP. For completeness this Appendix will also Page 5 of 8
specify all UDP policies which remain saved (the policy number in the UDP, as opposed to the detailed policy wording, including any site requirements). This is consistent with the approach taken in the adopted Core Strategy, Aire Valley Leeds Area Action Plan and the Natural Resources and Waste Local Plan. 3.3 Where an identified site is an existing UDP housing allocation, the SAP specifies in Policy HG1 for each HMCA, the UDP site reference number, so that a reader of the Plan may be appropriately signposted to the specific site requirements related to that site. This in addition to the proposed Main Modification described above, relating to a new paragraph 2.29a is considered to provide a clear indication as to the matters applicants need to consider in respect of identified sites. 3.4 The Council have already proposed a modification to the Plan in respect of Policy HG1 (modification no.1 EX9), to insert; Saved UDP allocations that are identified sites also have a list of site requirements that are saved and apply to the site. 3.5 Consequentially, for clarity, the Council now propose to withdraw this modification and replace it with the following, to be in line with the modifications proposed for EO1 and EG1 as set out in EX24. The Modification proposed is: To insert a sentence at paragraph 2.29, after For purpose of ease and reference this is repeated for each HMCA in Section 3, with the relevant list of sites which form part of the policy further wording to state: UDP allocations which have not yet been fully developed remain as identified allocations within the saved UDP. Policy HG1 lists all identified sites comprising: saved UDP allocations and sites with planning permission/recently expired planning permission. Column 2 in the table of sites within the policy identifies the UDP reference retained, where applicable. Any site requirements identified in the UDP under this reference are also retained and planning applications should have regard to these. Q4. What is the rationale for not including identified sites that no longer benefit from planning permission as allocations in the SAP? 4.1 Sites that no longer benefit from planning permission are identified in the SAP as identified sites. As detailed in the pretext to the Inspectors questions, there are 78 identified sites which have an expired planning permission, of which 39 have now received further up to date permissions. The rationale for including them as identified sites rather than allocations is that they are still considered suitable, available and deliverable and are therefore sound in terms of contributing to the delivery of the housing target as evidenced by the SHLAA and the fact that the principle of residential development has been accepted by virtue of the site having obtained panning permission. The Council s detailed response in relation to this matter is provided in EX2c. Page 6 of 8
Site Requirements Q5. Have any site requirements in the Revised Submission SAP changed? If so could the Council please confirm which sites, and how the requirements have changed? 5.1 With the exception of three sites, there are no changes to the site requirements in the Revised Submission Draft SAP. The sites where it has been necessary to amend site requirements are set out below. The need for the revisions directly relates to the introduction of the Broad Locations Policy. 5.2 The amendments are set out in CDR1/2 Revised Submission Draft Schedule of Amendments January 2018 and relate to the three sites: MX2-39 Parlington, Outer NE HMCA amendment no. 66 HG2-124 Stourton Grange Farm South, Selby Road, Ridge Road, Garforth, Outer SE HMCA amendment no. 104 HG2-167 Land at Old Thorpe Lane, Tingley amendment no. 118 5.3 In all three cases, the requirements have been amended to reflect the change in the boundary to the allocated site for example in relation to site HG2-124, gas pipelines and listed buildings site requirements no longer affect that part of the site which is proposed for allocation. 5.4 For clarity, all sites proposed as Broad Locations do not have any site requirements. The above answer does not take into account any modifications proposed prior to submission of the Revised Submission Draft Plan (as set out in EX9). Neighbourhood Plans Q6. What stage in the process has the Adel Neighbourhood Plan reached? 6.1 The Adel Neighbourhood Forum conducted Pre-Submission Consultation on the draft Adel Neighbourhood Plan from 24th September to 4th November 2016. The Forum is currently undertaking some additional work to assist in the preparation of the Submission draft Plan and is proposing to submit the draft Plan for examination in summer/autumn 2018. The Plan is therefore still subject to examination and referendum. No specific housing allocations are proposed in the Adel Neighbourhood Plan. Q7. Are any other Neighbourhood Plans in the process of preparation, and if so what stage have they reached? 7.1 There are 35 designated Neighbourhood Areas in the Leeds District. Table 3 shows the stage of preparation that each Neighbourhood Plan has reached and is accompanied by a map showing each of the Neighbourhood Areas within individual HMCAs below. Page 7 of 8
Table 3: Stage of Neighbourhood Plan preparation (Housing Market Characteristic Area) Neighbourhood Area Designated and Early Engagement Aireborough (Aireborough) Beeston (Outer South West/Inner) Carlton (Outer South) Harewood Kirkstall (North) Rothwell (Outer South) Draft Plan in preparation* East Keswick Garforth (Outer South East / East) Headingley (North / Inner) Horsforth (North) Hyde Park (Inner) Little Woodhouse (Inner / City Centre) Pre-Submission Consultation complete Aberford and District Adel (North / Outer North West) Bramham-cum- Oglethorpe Kippax (Outer South East) Otley (Outer North West) Oulton and Woodlesford (Outer South) Wetherby Seacroft Pool-in-Wharfedale (Inner) (Outer North West) Rawdon (Aireborough) Shadwell Thorner * Draft Plan in preparation means that the LPA has seen and provided comments on an early draft Plan. Submission and Examination Scarcroft Walton Post-examination** Alwoodley (North / Outer North West) (referendum scheduled for 28 th June 2018) Made Bardsey-cum-Rigton Barwick-in-Elmet and Scholes Boston Spa Clifford Collingham Holbeck (Inner) Linton Thorp Arch ** Post Examination is defined by the Neighbourhood Planning Act 2017 as those NPs that have had a successful examination and the LPA has decided under Regulation 18 of the Neighbourhood Planning Regulations that the Plan should proceed to referendum. Page 8 of 8
WETHERBY WALTON LINTON THORP ARCH OTLEY POOL in WHARFEDALE CP EAST KESWICK COLLINGHAM BOSTON SPA CLIFFORD Outer North West HAREWOOD BARDSEY cum RIGTON AIREBOROUGH Aireborough ALWOODLEY Outer North East SCARCROFT BRAMHAM cum OGLETHORPE ADEL SHADWELL THORNER RAWDON HORSFORTH North Leeds BARWICK IN ELMET and SCHOLES KIRKSTALL HEADINGLEY SEACROFT ABERFORD & DISTRICT HYDE PARK Inner Area Outer West LITTLE WOODHOUSE City Centre HOLBECK East Leeds GARFORTH BEESTON Outer South East KIPPAX Key Housing Market Characteristic Area Neighbourhood planning progress Neighbourhood Area Designated and Early Engagement Draft Plan in preparation Pre-Submission Consultation complete Submission and Examination Post-examination Made Outer South West Crown Copyright and database rights 2018 Ordnance Survey 10019567 PRODUCED BY CITY DEVELOPMENT, GIS MAPPING & DATA TEAM, LEEDS CITY COUNCIL Path: L:\CGM\Nazia Fazal\Projects\Abbie Miladinovic\Neighbourhood Planning\NP progress and HMCAs.mxd Produced by: NF Date: 08/05/2018 ROTHWELL OULTON AND WOODLESFORD Outer South CARLTON