There have been several last ditch recent appeals submitted to the Department of Communities and Local Government for Eric Pickles, Secretary of State, to use his powers under Section 21 of the Planning & Compulsory Purchase Act to call for a serious review of the aspirational housing target of 70,000 set by Leeds in its LDF. The Planning Inspector, Mr A Thickett, despite strong evidence to the contrary, has now submitted his report and has approved plans for this ridiculous and unachievable target in his final report. The report appears to display no real objectivity with regard to real housing need nor to the under-funding of the necessary infrastructure which will be necessary to accommodate demand generated by a further 70,000 dwellings.
Local MPs, Stuart Andrew (Pudsey), and Alec Shelbrooke (Elmet & Rothwell) have, at the request of local communities, already submitted letters to the DCLG asking for an urgent review of the Leeds target. The community groups of Aireborough Neighbourhood Forum, Boston Spa and Scholes have also submitted letters to Eric Pickles requesting a review of the Leeds LDF before its final adoption. This really is an ultimate and final attempt to rescue local communities from severe predation of greenbelt/greenfield sites which, because of the 5 year land supply rule, will allow unscrupulous developers to ‘cherry-pick’ the best sites for building and to ignore brownfield sites in urgent need of regeneration. Consequently, the quality of life of this and future generations will be adversely affected by over-development and inadequate infrastructure.
Below is the WARD letter requesting a review which has now been sent to the Minister:
The Right Hon Eric Pickles MP 14 September 2014
Secretary of State
Department of Communities and Local Government
2 Marsham Street
Dear Mr Pickles
We are writing to you as a Community Networking Organisation to ask you to review the Leeds City Council, Local Development Framework Housing Target of 70,000 net, under Section 21 of the Planning & Compulsory Purchase Act. This, we understand, gives DCLG the power to ask a local authority to modify its local plan before it is adopted.
Our great concern is that the Leeds’ housing target, is the highest in the UK and, as Leeds have admitted, aspirational and not based on household projections using the most recent ONS population data (2012); as deemed necessary by the National Planning Policy Guidance. This means the LDF for Leeds could be deemed unsound as it is based on a set of inaccurate (and therefore flawed) statistics. This target, if accepted as recommended by the Inspector in his final report, will result in the severe predation of greenbelt/greenfield land by developers in order that Leeds may meet the five land supply target. Inspector Thickett at point 28 in his report on Leeds Core Strategy admits that developers will seek the more profitable greenfields before regenerating brownfield land and that this is an important issue. Again, the Inspector refers to the Leeds City Council’s infrastructure delivery plan, at point 23 of his report, as being incomplete and underfunded. This will result in a lower quality of life for communities across Leeds many of which actually need regeneration.
Over the past three years the WARD organisation has constantly requested that Leeds City Council revise this unreasonable and purely aspirational housing target in the light of objective evidence supplied by the 2011 Census. Through our Member of Parliament, Stuart Andrew, and Leeds City Council elected members we have asked Leeds City Council to re-analyse the 2012 population forecasts for households and local SHMA adjustments, rather than continue using the 70,000 target originally justified on 2008 base data. We disagree strongly with the Inspector’s conclusion at point 18 of his report, that the 70,000 is still a reasonable objective analysis. We feel the issues of infrastructure, regeneration, greenbelt and quality of life, are serious enough that we need to be fully confident in the validity and reliability of the data upon which the target is based.
Our appeal is therefore, to the Secretary of State for Communities, to delay the adoption of the Leeds’ Local Development Framework, until the new data for housing need has been properly considered. In this we are supporting the appeal already made to you by Stuart Andrew MP and Alec Shelbrooke MP. We would further add, that in a Leeds paper submitted to the Inspector’s Housing Delivery and Supply Hearing in May 2014, Leeds say at point 24/24 that:
‘the volume house builders ……………………….are not planning and cannot plan to deliver the Core Strategy’.
This is due to the number of houses they can build in a year, market forces, and viability. We cannot find that the Inspector has referred to this in his report. So, if the developers cannot achieve the target, why is it still in the Core Strategy?
Obviously it is important that Leeds City Council adopt a Local Development Plan as quickly as possible. But, it is also obvious that the plan as proposed in its current state does not have the best interests of Leeds communities as its main objective. As currently presented it is not based upon truly objective and accurate evidence with regard to housing numbers required. With regard to infrastructure, nor does the Inspector refer to an objective traffic report (commissioned by WARD in 2011 carried out by MET Engineering, Pontefract Road, Leeds) which clearly demonstrates that the A65 suffers severe congestion at peak periods and is operating at full capacity. This report appears to have been ignored by Inspector Thickett, indeed surprisingly, he claims that a witness stated congestion on the A65 was exaggerated.
I would suggest that the Inspector’s final report is less than objective and that there are numerous valid reasons why, as Secretary of State for Communities and Local Government, you should use your powers to call for a full review before the Leeds LDF is finally adopted.
David C Ingham
Dr David Ingham
Wharfedale & Airedale Review Development