Leeds Consults on changes to the Site Allocation Plan

Leeds City Council (LCC) are consulting on the recent changes to the Leeds Site Allocation Plan (SAP). The changes can be seen here.

It is recommended by WARD that any comments you have about the changes should be sent in by email to sap@leeds.gov.uk rather than use the online response form which can be found on the LCC Changes to Site Allocations website pages. The online response tends to guide the responder into answering questions LCC wants to pose rather than dealing with the ones you might have.

It is recommended that you read the LCC  “How To” Guidance Notes.

Even if you have responded before to the previous SAP consultation, it is very important that you respond again, including your name, address, site reference name and number and the change number (there are 802 of them) referring to the change.

In the WARD area there are changes (as examples only) as below and there are large sites introduced elsewhere.

Specific site information – Aireborough (examples)

 HG1-12 Naylor Jennings – site slightly larger. Change 98, plan 1. See the online link above.

HG2-5 Coach Road, Guiseley – site smaller. Changes 60, 69 and 70. Plan 2. See the online link above.

HG2-12 Woodlands Drive, Rawdon – site smaller.  Changes 61, 62, 75 to 79. Plan 3. See the online link above.

HG2-229 Old Mill, Miry Lane, Yeadon – NEW site. Changes 58, 80 to 87. Plan 4. See the online link above.

EG1-5 (Employment site) – Park Mills, Leeds Road, Rawdon – Airedale site larger, reflecting built area. Change 89. Plan 5. See online link above.

Specific Site information – Horsforth

HG2-41 Strawberry Field – site larger. Changes 373, 387 to 392. Plan 36. See the online link above. If you respond, please comment on this.

HG2-43 Horsforth Campus – site removed. HG1 515 (the buildings) added as suitable for 72 dwellings.  Changes 366, 381, 393 to 396. Plan 37. See the online link above.  You might question that the changes to justify the removal of the area of this site are equally applicable to HG2-41 Strawberry Field.

Specific Site Information – other areas (examples)

HG2-234 Kirkstall Forge. Site larger, with West and East extension of boundary. West boundary opposite Newlay Conservation Area. Changes 378, 408. Plan 39. See online link above.

MX2-39 Parlington – NEW site, and phased site boundary changes. Changes 436, 440, 455. Plan 41A. See the online link above.


Martin Hughes, Treasurer, WARD


Leeds planning – everyone else is to blame, not us!

Leeds City Council yesterday considered a white paper motion  (see previous blogs) on reviewing the overly-ambitious Leeds housing target. Cllr Carter (Con) introduced the motion indicating that he would accept the reasonable amendments put down by Cllr Campbell (Lib Dem), and Cllr Anderson (Con). Two other amendments from Cllr Leathley (Morley Ind) and Cllr Lewis (Lab), he rejected.

There was a passionate debate with finger pointing and shouting and essentially Labour councillors blaming everyone but themselves. I felt it was another case of the Leeds administration just not listening.

No one appears to have understood that without a 5 -year land supply the Leeds Core Strategy is now out of date. Cllr Lewis (shouting) told Council that work on reviewing the housing target was already underway! News to us that follow this closely.

Votes were taken separately for each amendment: –
Cllr. Leathley’s amendment was rejected 34 for / 60 against
Cllr. Campbell’s by the same
Cllr. Anderson’s by the same.

The result of this is that the Labour amendment as reproduced below became “the substantive motion” and was voted on: result 60 for and 29 against with 4 abstentions.

The motion below was therefore passed.

It was shocking to see Labour unprepared to accept that they were wrong. I suppose we should be relieved that at least the housing number is under review.

This is the Labour motion (below) that was passed. It is worth reading in full and carefully e.g. “supposed lack of a 5 year housing land supply”. No. Fact: Leeds does not have a 5 year land supply at the moment, as the housing target is too high! The rest seems to be saying “not our fault”. Having been asked to put party politics aside, the opposite happened. Leeds City Council has to recognise that it was THEY that adopted a Core Strategy containing an overly-ambitious housing target – and no one else! I agree heartily that the NPPF has not helped the mistake that was made with the housing target.

Martin Hughes, Chairman, Yorkshire Greenspace Alliance


“This Council notes that the Secretary of State, a Conservative MP, has overturned local decisions on planning applications in Leeds based on a supposed lack of a 5 year housing land supply. Council believes that decisions like this primarily benefit developers at the cost of local communities.

Council further notes that the Labour administration has a longstanding commitment to selectively review the Core Strategy, including the housing target. Council welcomes the work that is underway to review the government inspector approved target of 70,000 homes in the light of recent evidence and wishes to see this concluded swiftly, whilst continuing to move ahead with the Site Allocations Plan. The results of this review should be reported to Executive Board at the earliest opportunity.

Council notes the Planning Green Paper published in 2010 states that “these radical reforms aim to:
• Restore democratic and local control over the planning system;
• Rebalance the system in favour of sustainable development;
• Produce a simpler, quicker, cheaper and less bureaucratic planning system.

Council laments that in 6 years of Conservative government that this has clearly not been achieved.

Council believes the National Planning Policy Framework needs fundamental change to ensure communities voices can be heard clearly. In particular, Council believes that the practical operation of the 5 year housing land supply undercuts local, democratic decision making and makes a mockery of a plan-led process. In addition, Council notes that inconsistent decisions have been made on the 5 year land supply from government appointed inspectors, with Leeds communities finding themselves at the mercy of housing developers.

Council calls for an overhaul of the planning framework that puts powers truly in the hands of local authorities to reflect local needs and vision, encourages sustainable development and seeks to remove the perverse incentives of holding deliverable land and limiting development on sites in order to increase profits.

In light of the current uncertainty, Council therefore requests that group leaders collectively write to the Housing and Planning Minister to highlight these concerns and, at the very least, call for a suspension of the 5 year land supply requirement on Councils that are progressing quickly towards a Site Allocations Plan hearing. Council also calls on the government to consider introducing penalties against developers who are found to be land banking, and for a report to be brought to Executive board outlining what more can be done in Leeds to address this problem.”


Councillors asked to allow review of Leeds housing target

Leeds City Council’s housing target of 70,000 is now causing serious problems for the sensible, and sustainable, development of the City. To address this serious situation, a White Paper is to be put to the Council on the 9th November 2016, by Cllr Andrew Carter.

The White Paper calls for a review of the housing target to start as soon as possible, and for the Council to ask the Communities Minister to suspend the need for Leeds to have a 5-year land supply, until it has sorted out a site allocation plan. Communities around Leeds are being urged by community groups to support this paper by writing a letter to LCC Councillors urging them to vote for it next week.

This can be done simply by an email to ALL 99 LCC Councillors in one go, asking them to support Cllr Andrew Carter’s White Paper.

Email: Councillors.All@leeds.gov.uk

The online link to the White Paper motion is below:


Your email can be copied and pasted from the one below: –

Dear Councillors

Subject: WP1 on 09/11/2016 Agenda Item 13 – Full Council Meeting

OPEN LETTER TO LEEDS CITY COUNCILLORS REQUESTING YOU TO SUPPORT WP1 on 09/11/2016 Agenda Item 13 – Full City Council Meeting

Dear Councillors

I write to formally request you as an elected representative of the City of Leeds, support WP1 presented by Councillor Andrew Carter.

The Green Belt and Green space across the City of Leeds is under attack by speculative developers seeking to exploit the 5-year land supply anomaly for their own financial gain with little or no regard for the true housing needs of the city and the wellbeing of its electorate.

In summary, the white paper proposes:

• The immediate review of Leeds Housing Numbers
• The council write to Housing and Planning Minister calling for a suspension of 5-year land supply requirement on councils that are progressing towards a site allocations plan hearing.

The green belt and its green infrastructure is the city’s most valued asset, not only for preserving the unique rural character of the city, but also for the health and wellbeing of ALL citizens of Leeds.

We respectfully demand that for the good of Leeds and its citizens you put party politics aside and support this white paper.

Yours Faithfully

Add your name here

Leeds Planning Core Strategy now “out of date”

The Grove Road, Boston Spa Recovered Appeal is worth a glance (first few pages of Secretary of State’s response), especially as it confirms (by Department of Communities and Local Government (DCLG)) that Leeds does not have a 5-year land supply, and confirms that a 20% buffer penalty should apply to Leeds housing land supply because of this failure and the widening gap between target and actual delivery of housing.. The Secretary of State also “agrees with the (Appeal) Inspector that the Council’s land supply figures would seem to be overly optimistic”. This starts from the over ambitious total housing target of 66,000 dwellings.


NPPF 49 states that “policies for the supply of housing should not be considered to be up to date if the local planning authority cannot demonstrate a 5 -year land supply of deliverable sites”.

Richborough Estates had a planning application on a “green gap” site in Cheshire. The application was refused by Cheshire on the basis that there was a “green gap” policy in place as part of the Cheshire CS. Richborough appealed the decision challenging the green gap policy as out of date (NPPF 49) as Cheshire could not demonstrate a deliverable 5-year land supply.

The appeal Inspector agreed the appeal, finding that the green gap policy could not be considered to be up to date and the weight of it should be reduced.

Cheshire appealed to the High Court and Lord Justice Sullivan ruled that the Inspector was wrong to regard the green gap policy as out of date. Sullivan said that this issue ”is of critical importance to the application of national policy throughout the country”.

Richborough appealed the case to the Court of Appeal, with Cheshire claiming that NPPF 49 refers only to policies relating to the amount and distribution of housing. The Court of Appeal found that the words in NPPF 49 –  “relevant policies for the supply of housing”  – should apply to ALL policies which have the effect of restricting residential development and this specifically includes: –

Policies for the greenbelt
The general protection of the countryside
The conservation of the landscape of ANOBs and National Parks.

The Court of Appeal also stated that the appeal decision is not an open door for greenbelt development, as applicants still need to demonstrate very special circumstances (the exceptional circumstance paragraph 83 of NPPF).

Cheshire have appealed further to the Supreme Court and the case will be heard in early 2017.

Martin Hughes

Chairman, Yorkshire Greenspace Alliance

WARD donates to Yorkshire Greenspace Alliance


Yorkshire Greenspace Alliance

WARD has very kindly donated £300 to Yorkshire Greenspace Alliance (YGA), to support its fundraising.

YGA has been set up specifically to raise funds to challenge the “exceptional circumstances” claimed by local authorities like Leeds and Bradford  to use greenbelt to fulfill housing targets. This is contrary to National Planning Policy Framework (NPPF) 2012 paragraph 83.

YGA came into being directly from WARD’s work in defending greenspace and greenbelt, and the new group is very grateful for WARD’s support.

Martin Hughes, Chair, Yorkshire Greenspace Allliance

WARD attends Leeds CoVoP conference


WARD members attending the CoVoP conference

Community Voice on Planning (CoVoP)  held its first conference in Leeds on Saturday 15th October – with the conference title being “NIMBY – reality or slur”.  I attended –  not to find out if I am one, but to explore the background as to why e.g. media, so immediately, and regularly,  calls on those concerned with current planning matters to defend themselves against being NIMBYs.

The conference had a diverse content, which explored fully the mess that is the current planning system, and the very poor outcomes generated by planning law that is simply not fit for purpose. An opening letter was read from Clive Betts MP, chair of the Communities and Local Government Committee. This committee has nothing to do with government, but acts as scrutineer of the Department of Communities and Local Government (DCLG)  re policies, administration and spending. One of their recent calls has been for Gavin Barwell MP (new Housing and Planning Minister) to respond the the DCLG-commissioned Local Planning Expert Group’s  recommendations on planning. This includes a statement that Leeds’ and Bradford’s Core Strategy housing targets are more than 500 houses per year over-provisioned.

Andrew Wood from CPRE presented some complex ideas about greenbelt use for housing and seemed to be suggesting a deal-based planning arrangement where housing needs were met by very selective use of greenbelt sites where fully assessed and sustainable use and requirement had been carried out. He developed the idea that greenbelt is one of the last planning policy tools that local authorities have to control patterns of development, but stated the obvious threats to existing greenbelt boundaries.

Jenny Unsworth  from Congleton  asked the question “Does the National Planning Policy Framework 2012 (NPPF) work?” Through a well presented summary of planning milestones, leading towards the position in her own area, Jenny demonstrated that planning reality in Congleton is the same in Leeds and Bradford –  and very much anywhere else in England. Her key point was that the workings of the NPPF and Localism were at opposite ends of the planning spectrum. She also reminded us that excessive and undelivered housing numbers were resulting in 5-year land supply failure, leading to local authority plans being automatically out of date. It therefore followed that planning had become an ad hoc system defined by appeals, rather than a plan-led one, as sought by the NPPF.  No surprises to find her answer to the question to be “No”.

Julie Mabberly, Chair of CoVoP, and planning activist in Oxforshire, ridiculed the extraordinary basis for setting housing numbers  that is the Objectively Assessed Housing Needs system. She described the system as from the pages of “Alice in Wonderland”  and demonstrated through various slides that a finger-in-the-air figure for housing need became inflated (and totally un-achievable) through a series of speculative additions to housing need, that also included double-counting. Her summary was that OBJECTIVE housing needs assessment was anything but that.

Dr Quentin Bradley, from Leeds Beckett University set out the controlling influence of developers, and in particular the significance of land price and hoarding of land, in respect of affordable housing provision. Dr Bradley suggested that the current structure of both the land and housing markets contribute to a shortage of housing being built,  and the affordable housing build ratio that comes out of that. He argued that with the present structure in place, building more homes alone will not solve the crisis.

Dr Hugh Ellis from the Town and Country Planning Association set out the significant role planning has played in the formation of the nation’s built housing since the Association’s formation some 120 years ago. In particular Dr Ellis considered the outcomes of the planning of garden cities in comparison to the broken system that is currently in place.


Dr David Ingham, Chair of WARD, opened the plenary session of the conference

A pleniary session concluded the conference, introduced by WARD chair, Dr. David Ingham. He referred to the stimulation given to the WARD group in respect of the hold order, from DCLG, placed on the adoption by Bradford of its flawed Core Strategy, some of the policies of which have been written by the very Inspector who declared it sound. Dr Ingham also called for more MP input at Westminster to change planning law, and thanked in particular, Greg Mulholland MP, for his long support to WARD over the last 7 years of campaigning and for his work in Parliament to change planning law.

The panel of 3 MPs, which also included Paul Sherriff MP and Jason McCartney MP, showed their understanding of a broken planning system and their attendance at this conference, with Greg Mulholland, is proof of that.

My view from this remains unchanged, and that is before I went into the conference I was sure the current planning system is not fit for purpose. I came out with more evidence that that is exactly the case. With an appeal-led planning system for the largest housing sites now in place, the NPPF has totally failed to deliver the housing that is needed, or of the right type and in the right places. The result of this is the great threat to the precious greenbelt. If protecting that makes me a NIMBY then I am proud to stand up and be labelled as that.

Martin Hughes, Treasurer of WARD, Chair of Yorkshire Greenspace Alliance

These are my own views and my own summary of the conference.

Case law not supporting Inspector writing Bradford plan policy to achieve “soundness”

Bradford’s Core Strategy (CS), often referred to as “the local plan”, was determined to be “sound”  on 22/08/2016 by the Inspector, on the basis of adding policy text written by that Inspector. The legality of that is questioned. In the meantime the Planning Minister has placed a hold notice on Bradford council to stop them from adopting the plan after interjection from Philip Davies MP. One of the MP’s points concerns the use of greenbelt to fulfill Bradford’s housing target. WARD has also written to Secretary of State Javid at the Department of Communities and Local Government to draw the Inspector’s action to the Secretary of State’s notice.

I am sure  WARD supports the hold notice and WARD should reinforce with the Secretary of State its point about the legality of Inspector Pratt making the Bradford CS sound on the basis of writing parts of it himself.

The Hunston appeal case summary (source below) below indicates that an inspector “should not seek to carry out some of the local plan process as part of determining the appeal”.

Should WARD contest that in respect of determining the soundness of a CS (a much more significant planning issue than an appeal) the inspector should not seek to carry out some of the local plan process as part of determining the soundness of the local plan?

Martin Hughes


Hunston Properties Limited • KEY POINT OF DECISION: INSPECTOR NOT ENTITLED TO USE HOUSING SUPPLY FIGURE FROM A REVOKED PLAN • Inspector dismissed appeal against refusal of development in the Green Belt • Inspector took into account housing figures in the East of England Plan; Court of Appeal held that she was not entitled to do so • The needs assessment should be gleaned from the Local Plan • An inspector on a s.78 appeal should not seek to carry out some sort of local plan process as part of determining the appeal • It is legitimate for a Local Plan to have less than the assessed housing need, if it would not be possible to supply that need because of conflict with other policies, such as those for Green Belt or AONB

http://www.landmarkchambers.co.uk/userfiles/documents/resources/Sasha%20White%20QC%20NPPF%20and%20Localism%20081014.pdf – Page 12


Bradford’s Core Strategy not as “sound” as has been declared by the Inspector

There is new vigour amongst community groups concerning planning matters.
The news that Horsforth’s Strawberry Fields (HG2-41 in Site Allocations Plan (SAP) proposals) was to be increased in size came as a shock, especially as 1952 respondents in the SAP consultation objected to the inclusion of the site for housing in Horsforth.
This, and the use of other significant greenbelt sites across Leeds, prompted the formation of the new Yorkshire Greenspace Alliance (YGA), as it is crystal clear that Leeds is not listening, and that legal challenge has to be made at the Leeds SAP hearing during 2017. This will be held in front of a government inspector. There will be more on this as the YGA group develops its campaign.
Meanwhile (on August 22nd 2016) Inspector Pratt of the Bristol Planning Inspectorate published his findings concerning the soundness of the Bradford (BMDC) Core Strategy. Simply put, he found the plan to be sound, BUT with changes to policy wording that he wrote himself.
Does this not therefore imply that the plan as it stands (as Bradford MDC have not yet agreed the alterations) is unsound?
What is questionable about Pratt’s report is that in many critical sections, like Policy SC7 Greenbelt, Pratt has added policy text to justify the use of greenbelt “in order to meet its (Bradford’s) development needs for housing in full and in order to support long term economic success of the district.” These are, in the same policy text, “the exceptional circumstances (that) exist which justify and require a change to the greenbelt”. Repeatedly the government’s Department of Communities and Local Government (DCLG) has stated that fulfilling a local authority housing target is not to be used as an exceptional circumstance – so Pratt’s revised policy is contrary to that.

So, is Bradford’s Core Strategy unsound without these changes and additions to policy?
How can an Inspector declare his own work sound, and thereby determine Bradford’s CS on the basis of his work rather than that of BMDC?
Has Pratt not exceeded his authority in doing this?
Has Pratt created evidence without which the plan would have been unsound?
WARD will be writing to the minister to draw his attention to the issue of legality of an Inspector writing policy for BMDC, to make a Bradford’s Core Strategy sound.

Martin Hughes


For about 6 years Wharfedale and Airedale Review Development (WARD) has been working to control the influx of housing that Leeds needs to satisfy demand. There has never been a moment when WARD has not agreed new housing is needed, but it has always contested just how many houses, and the impact of the number planned on greenbelt and greenspaces.

In May 2016 WARD and a number of other community groups, with Greg Mulholland MP and Stuart Andrew MP, went to see the top 4 executives responsible for forward planning in Leeds. We hoped to meet Judith Blake (Leader of Council) but she declined to attend. We saw Tim Riordan (Chief Executive), Tim Hill (Director of Planning) and Cllr. Richard Lewis (Executive Member for Communities – which includes planning).

WARD and the others begged (really!) LCC to reconsider the overall housing number for Leeds, but this request was flatly refused and our pleas were directed to the inspector who will determine if the Site Allocations Plan (SAP) supporting the Leeds Core Strategy is sound. The hearing for this is likely to be during late 2017.

More recently, as an example, Horsforth’s large SAP site, Strawberry Fields (HG2 – 41), was increased in size to accommodate the building of 777 houses and a major school, based on a single SAP consultation response from English Heritage. Two other responses were rejected and over 1980 other responses against the site, which is in the greenbelt, were rejected. Proof, if needed, that LCC is not interested in listening to the community. At the meeting detailed above, Tim Riordan used phrases (written down verbatim) in connection with the overall housing target – “playing the cards we have been dealt”, “sharing your (the community group’s) frustrations”, “aspirations on housing are those of the government”, and “we think we are going in the right direction”.

WARD considers that there is no further benefit in talking to LCC as they continue to direct us to the SAP inspector. So that is what it has been decided to do – but outside of WARD, by setting up a single-purpose group – Yorkshire Greenspace Alliance (YGA).

YGA is a growing alliance of community groups concerned with Leeds-wide future housing planning, especially the use of greenbelt to fulfil housing targets. Having been directed to the inspector hearing on the soundness of the Leeds SAP, that is where we are going to have to go. To do so, we need the advice and attendance at the SAP hearing of a planning barrister.

To control the large cost of doing this, YGA will target one main issue of the soundness of the Leeds SAP (and later the Bradford SAP) and that is the legality of the use of greenbelt to fulfil housing target. National Planning Policy Framework 2012 (NPPF) is the summary of planning law and section 9, paragraphs 79 onwards indicate that “greenbelt boundaries should only be altered in exceptional circumstances” (NPPF, paragraph 83). The Department of Communities and Local Government has repeatedly confirmed that local authorities use of greenbelt to fulfil housing targets is not an exceptional circumstance.

YGA’s target is therefore to raise funds to challenge legally Leeds’s SAP with the inspector at the forthcoming hearing. We need the funds to: –

• Help us, through publicity, to raise the funds to mount the legal challenge
• To take advice from a planning barrister
• To have the barrister attend the hearing and make the legal challenge.

YGA believes that at least £10,000 will be required to do this and later more to do the same for Bradford. Bradford’s Core Strategy has just been through inspection, and essentially has been found sound, with some changes, but relies on the same use of greenbelt to fulfil their housing target. As Bradford and Leeds are so closely linked, what happens in Bradford will affect Leeds and vice versa.

YGA feels that the loss of greenbelt is something that all can understand and are generally against. Once a greenspace has been built on it is lost as a greenspace forever. The Alliance will major on this aspect in its publicity so that a simple message emerges that will encourage as many as possible to contribute to funds.

Martin Hughes

Chairman, Yorkshire Greenspace Alliance and Treasurer of WARD


Yorkshire Greenspace Alliance Reinvigorated by Site Allocation Hearing Legal Representaion Target

Yorkshire Greenspace Alliance (YGA) was set up some years ago to support the protection of green spaces. It has been dormant for sometime, but has just been reinvigorated in a revised form to specifically raise funds for legal representation, initially at the forthcoming 2017 Leeds Site Allocation Plan hearings. The Alliance will also later consider the same for Bradford.

I am very honoured to have been elected as its chairman for the forthcoming year. Supporting me is a great team with much local planning experience. I am looking forward to the forthcoming challenges.

The Alliance will have a new constitution and an active committee drawn from planning concerned community groups that are geographically represented around Leeds and Bradford.

The main aim of the Alliance will be to focus on the LCC use of green belt to fulfill the excessive housing target it has imposed on us. It is felt that everyone understands and supports the need for green belt protection, especially where a less aggressive housing number can be fulfilled from existing brownfield sites.

We will be coming to the community with our hands out for cash, but will provide lots of information and engagement as to why you should donate!

Martin Hughes, Chairman. Yorkshire Greenspace Alliance