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

 

FREEDOM OF INFORMATION REQUEST to Bradford Council

freedom-of-information-request-oct-2016On 18 October, on behalf of WARD, a Freedom of Information request was submitted to Bradford Council relating to the Council’s own comment in the SHLAA that “a significant number of sites with planning permission within Bradford City Centre … on the advice of volume house builder representatives on the SHLAA Working Group, have been completely left out of the 5 year (housing) supply due to the collapse in the market for city centre flats and apartments.” That comment was made in 2010 in preparation for the issue of the first version of the SHLAA in 2011.

However, there have been two revisions of the SHLAA since then, in 2013 and 2015 and it is not clear whether this “significant number of sites” have been included. The housing market, we are told, is in crisis and people need houses close to where they work. That’s a key part of Bradford Council’s Policy statements, but not one they seem to be adhering to. The housing market has strengthened substantially since 2010 (in the aftermath of the economic crash), and what possible legitimate reason could there be for NOT developing sites in Bradford City Centre, where people wouldn’t need to commute to work, where there are shops which need more custom, and where they would assist Bradford’s regeneration?

Given that these sites weren’t included in the first version of the SHLAA, so not even identified, how are we to know whether they’ve been included subsequently? The Freedom of Information request requires Bradford Council to identify the sites, reveal whether they have now been included and, if not, why they are still ‘sitting there’ with planning permission. If Bradford Council is allowing developers to keep sites in their ‘land bank’, how can they at the same time demand that small communities remote from the city give up Green Belt land for housing when it’s not needed there, and there are no local jobs?

The FOI request was due to be answered within 20 days of receipt, ie. by 17 November but has been delayed because (to quote) a member of staff is on leave, so we are told to expect a reply within a further 20 working days, so by 15 December 2016, or hopefully “before then”.

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:

http://democracy.leeds.gov.uk/documents/s151511/WEB%20WP1%20Planning%20FINAL%20nov16%202.pdf

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.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/527730/16-06-08_DL_IR_Grove_Road_Leeds_2208551.pdf

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

“AT LAST! DCLG reply to WARD letter of complaint re Bradford LDF

The following letter was received from the DCLG as a result of WARD’s complaint about Inspector Stephen Pratt’s re-write of modifications to the Bradford LDF.  Unfortunately, this says very little and WARD can only hope that our follow-up letter (also see below) will serve to fully support Philip Davis’s success in obtaining a ‘hold’ on the Bradford LDF so that planning ministers can consider carefully whether or not the Bradford LDF should be considered unsound and called in by the DCLG Minister Sajid Javid.
Dr David Ingham
Chairman
WARD”
min-reply
ward-letter-2

WARD donates to Yorkshire Greenspace Alliance

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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

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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.

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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.