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Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds Sap Matters & Issues (M7/141/2) Matter 7A

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Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds Sap Matters & Issues (M7/141/2) Matter 7A STATEMENT IN RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS TO EXAMINATION OF LEEDS SAP MATTERS & ISSUES (M7/141/2) MATTER 7A JUNE 2018 LANDSEC Q50295 Contents 1 Introduction ______________________________________________________________________ 1 2 Matter 7A – Selection of Site Allocated for Development __________________________________ 2 Appendices Appendix 1 Schedule of Cumulative Capacity of Allocated, Identified and Broad Locations in Outer South West HMCA Appendix 2 Draft Authority Monitoring Report (1 April 2016 – 31 March 2017) Appendix 3 LCC’s Five Year Housing Land Supply Statement (2017 Update) Quod | Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds SAP Matters and Issues | Matter 7A | June 2018 Quod | Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds SAP Matters and Issues | Matter 7A | June 2018 1 1 Introduction 1.1 This Statement supports the representations by Landsec to the Revised Submission Draft Site Allocations Plan (“SAP”), prepared by Leeds City Council (“LCC”). 1.2 Representations have been previously made by Landsec to the postponed Examination of the SAP, and in this regard, reference should be drawn to the previous representations to Matter 7 (dated August 2017) – Examination Ref No M7/141. 1.3 These representations relate to Landsec’s interests on Land to the South of White Rose Shopping Centre (“the Site”), which has been promoted through various iterations (Regulation 18 and 19) of the emerging SAP, where objections have been made to the SAP on the grounds that it is unsound, in that it fails to ensure that sufficient, appropriately located land for housing development is available, as well as critical education (primary school) infrastructure and that in order to remedy this: 1.3.1 The Site being suitable for residential purposes, in an area of housing need, should be Allocated for such. 1.3.2 As a consequence, the Green Belt boundary should be redrawn to exclude that part of the Site to be Allocated for residential. 1.3.3 The Site, in part, is suitable for a new primary school to meet the education needs of South West Leeds. 1.4 The previous evidence supporting the various representations to the emerging SAP make the planning case for residential and primary school development on this “omitted” Site. This Statement maintains that the Site remains available, suitable and deliverable for housing (and a school), and as such will assist in making what is current an unsound Development Plan, sound. 1.5 This Statement along with others made on behalf of Landsec (Statement Reference numbers M2/81/2, M3/70/2, M5/22/2, M6/59/2), demonstrates that the Revised Submission SAP does not comply with the Core Strategy (“CS”) and fails to give proper effect to, and is inconsistent with, the adopted CS. Most notably, it fails: 1.5.1 To plan fully for the population growth of the City that is required under Spatial Policy 7 of the CS. 1.5.2 To support the provision of the necessary infrastructure, (notably, in this case, education) to meet the needs of that part of the City in which the Site falls (as required by Policy P9). 1.6 It is of especial note that the Revised Submission SAP supresses the scale of housing provision beyond that required in the CS, and seeks to set a spatial distribution of development that looks forward to an emerging Development Plan Document (the Leeds Core Strategy Selective Review, 2018) that has an untested housing provision strategy. 1.7 In summary, the SAP fundamentally fails to provide the site allocations (housing and schooling) and requirements that are necessary to deliver the adopted CS policies, and as a consequence insufficient land is achievable within the SAP in appropriate locations to meet the targets set out in the CS. In order to remedy this, it is necessary for the SAP to introduce new sites for housing allocation, including the subject Site. Quod | Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds SAP Matters and Issues | Matter 7A | June 2018 2 2 Matter 7A – Selection of Site Allocated for Development 2.1 Landsec’s previous Statement M7/141, as well as other representations by the company, demonstrates that: 2.1.1 The site selection process in the Outer South West HMCA was unsound. 2.1.2 Insufficient sites had been Identified in the HMCA in response to the CS requirement. It was also demonstrated that several other HMCAs could not meet their minimum housing requirements. 2.1.3 Delivery rates during the first four years of the Plan period had been considerably below the CS minimum requirement. 2.1.4 There was considerable doubt that some of the sites Allocated or Identified in the Outer South West HMCA were achievable for housing development. 2.1.5 There was a deficit in critical education infrastructure required to meet the planned housing needs in the Outer South West HMCA. 2.2 As a consequence, it was concluded that the SAP wasn’t sound in that it wasn’t justified and resilient enough to respond to the Plan’s needs to deliver the required scale and distribution of housing. It was demonstrated that the site to the south of White Rose Shopping Centre would, if Allocated for housing and a primary school, assist in remedying the unsoundness of the Plan in this HMCA. 2.3 This Statement does not repeat the previous evidence, other than to confirm that the above matters apply equally at the time of preparing this Statement, if not more, as demonstrated below. 2.4 Quod have undertaken a recently analysis of the cumulative capacity of the sites Allocated, Identified and Broad Locations in the Outer South West HMCA; see the Table at Appendix 1. 2.5 It is demonstrated in Appendix 1 demonstrates that when measured against the CS requirement (Policy SP7) for this HMCA the Plan suggests the cumulative capacity of the Identified and Allocated sites is only 5,667dwellings (column 3), ie, 21% less than the CS requirement (7,200 dwellings). However, when account is taken of the change in capacity arising between that purported in the Revised Submission SAP and the actual planning permissions granted on each site (column 7), the capacity reduces by a further 216 dwellings (ie, total capacity of only 5,451 dwellings). 2.6 Moreso, the delivery of many of the Identified sites (ie, where planning permission has been granted) is doubtful for the following reasons: 2.6.1 Some of these no longer benefit from extant planning consents (column 11), suggesting there are constraints on this development (in market or site conditions). 2.6.2 Many are long standing UDP sites which have not come forward, and there is nothing to suggest that circumstances will change. 2.6.3 Many are small scale, and their delivery uncertain (see Statement M2/81). In addition they represent double counted sites for those included in the windfall allowance (500 dwellings per annum) in the CS. Quod | Statement in Response to Inspectors Matters, Issues and Questions to Examination of Leeds SAP Matters and Issues | Matter 7A | June 2018 3 2.7 Even allowing for the development of the eight Broad Locations (which sum to a capacity of 1,607dwellings) there is an overall total of only 7,058 dwellings capacity in this HMCA at best. Given the serious doubt over many of these sites and their ability to deliver, it is clear that this HMCA will not meet the scale and distribution required by the CS. 2.8 This is also supported by the evidence of recent delivery rates in this HMCA. LCC’s recent Draft Authority Monitoring Report (May 2018) (Appendix 2) demonstrates, that over the first five years of the Plan period, only 1,473 dwellings were constructed in the Outer South West HMCA. This represents only 20% of the total CS requirement for this HMCA. Consequently, circa 80% of the requirement still needs to be delivered over the remaining 11 year period. 2.9 This poor level of delivery in the HMCA is representative of a poor delivery rate throughout the City. Attached at Appendix 3 is a copy of LCC’s Five Year Housing Land Supply Statement (2017 Update) which demonstrates that the net delivery over the first five years of the Plan period is only 13,824 dwellings, ie, less than 20% of the overall housing requirement (70,000 net). 2.10 It is accepted by the Council that they are persistently under-performing in housing delivery, and in this respect it is clearly important that the Plan is resilient enough to respond to the delivery problems that are evident within the City. What is the justification for allocating HG2-167a as Phase 1 site and HG2-167b as a Broad Location (BL1-28)? 2.11 Landsec have no specific comments on this question. Broad Locations BL1-29 (formerly HG2-171), BL-24 (formerly HG2-144), BL1-26 (formerly HG2-147) AND BL-27 (formerly HG2-148) is the identification of these sites as Broad Locations justified and consistent with the approach taken elsewhere? 2.12 Landsec have no specific comments on this question. HG2-145 – what is the justification for deleting part of the site and allocating it as a school site (HG5)? Will this be deliverable? What is the justification for the change from an allocated site to a broad location for BL1-25? 2.13 Landsec have no specific comments on this question. HG2-150 – site has been moved to Phase 1 but was originally held back to Phase 2 due to transport infrastructure – will it be effective to deal with this as part of the planning application? 2.14 Landsec have no specific comments on this questions.
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