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Leeds Revised Submission Site Allocations Plan (SAP) Matters, Issues and Questions

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Leeds Revised Submission Site Allocations Plan (SAP) Matters, Issues and Questions Barratt Homes and David Wilson Homes and Taylor Wimpey Representor ID: PDP22906 Matter 7 Ref: M7/59/2 Leeds Revised Submission Site Allocations Plan (SAP) Matters, Issues and Questions 1.0 Introduction 1.1 This statement has been prepared by WYG on behalf of our clients Barratt Homes, David Wilson Homes and Taylor Wimpey (herein referred to as our clients). 1.2 As you will be aware our clients are two of the UK’s leading house builders, who have a number of site interests across Leeds and are therefore very keen to engage and assist in the preparation of sound Local Plan which is positively prepared, justified, effective and consistent. 1.3 This hearing statement is solely based on matters and issues relating to HG2-124 and BL1-40 (Stourton Grange Farm South, Selby Road - Ridge Road, Garforth). 1.4 This hearing statement should be read in conjunction with our comments upon the Revised Submission Site Allocation Plan (SAP) and our previous examination hearing statements, principally matters 2 (ref:M2/33) and 7 (ref: M7/59) of the SAP as originally submitted. In addition, we also previously commented upon the Pre-Submission Changes in March 2017. 1.5 This response seeks to address the key issues to be discussed at the forthcoming Revised Submission SAP concerning Matter 7A – Selection of Sites Allocated for Development. 1.6 Our clients general position on HG2-124 and BL1-40 is that whilst we support the retention of part of the Site as a phase 1 housing allocation, we remain concerned regarding the amendment of part of the Site to a Broad Location (amendment reference 106). We consider that the whole Site is deliverable as a housing allocation in the SAP. Nevertheless, we consider that the phase 1 housing allocation is a deliverable housing Site in a sustainable location which will make a significant contribution towards the housing requirements for the Outer South East HMCA in the early Plan years. 1.7 The response is structured such that it follows the questions posed in the Matters and Issues agenda. 1 Barratt Homes and David Wilson Homes and Taylor Wimpey Representor ID: PDP22906 Matter 7 Ref: M7/59/2 Matter 7a - Selection of sites allocated for development 2.0 Main Issue 1: For each Housing Market Characteristic Area, are the individual sites selected sound? Questions relevant to Outer South East HMCA: 1. Is the approach of undertaking a revised sustainability appraisal justified for this site? What is the justification for splitting site HG2-124 into two sites including a Broad Location (BL1-40)? Sustainability appraisal 2.1 Our clients consider that a revised sustainability appraisal is justified on this site. This is based upon the fact that HG2-124 has effectively been halved in size from that originally proposed, with the remainder of the previous allocation now identified as Broad Location (BL1-40). This is a notable change to the SAP and the Outer South East HMCA and as such it is considered appropriate that it be re-appraised. 2.2 Appendix 1 of the Council’s Sustainability Appraisal Addendum 1 (ref: CDR1/5a) and Addendum 2 (ref: CDR1/5b) clearly demonstrate that the site (HG2-124), as reduced, remains sustainable. Our clients support this statement and highlight that the site is well located within a sustainable location. 2.3 Garforth is the only major settlement within the Outer South East HMCA providing a transport hub for the area and benefitting from a wide range of services and facilities including two train stations, shops, supermarkets, library, medical centre, pharmacy, leisure centre, sports club and banks. HG2-124 has good accessibility to these services and facilities and is therefore referred to as a ‘natural extension’ to Garforth Appendix 2 (ref: CDR1/5a and CDR1/5b). Appendix 1 to this statement provides further details on the proximity of existing local services and facilities to the site. 2.4 The site will also provide significant community benefits and enhance its own sustainability through the provision of services and facilities. These will include the delivery of affordable housing, a 2-form entry primary school, a local centre and community park. 2 Barratt Homes and David Wilson Homes and Taylor Wimpey Representor ID: PDP22906 Matter 7 Ref: M7/59/2 2.5 The site is deliverable and will begin delivering within the first five years, following the adoption of the SAP. It will also provide a continuous, reliable and significant contribution towards the Council’s housing requirement over the plan period from the two largest volume housebuilders in the UK. The NPPF, paragraph 47, places significant emphasis upon the need to provide a continuous supply of deliverable housing sites. 2.6 Our comments upon the submitted Revised Submission SAP (section 5), and response to the Inspector’s original matter 7 Matters, Issues and Questions clearly articulate that the allocation of HG2-124 is justified and that the site is deliverable. To provide greater clarity upon the delivery of this site a Delivery Statement is appended to this response (appendix 2). 2.7 Given the change in circumstance in relation to this site and the wider HMCA between the SAP as originally submitted and the Revised Submission the Council is justified in undertaking further sustainability work upon this site. Our clients firmly agree with the Council’s conclusions that this site remains a sustainable site which should be allocated within the SAP. 2.8 The sustainability credentials of the site are set out within the Council’s evidence base, the discussion above and our previously submitted comments. Splitting site into two, including Broad Location (BL1-40) 2.9 The Council’s justification for splitting the site into two, including Broad Location BL1-40 is based upon the Council’s approach to the Broad Locations. The rationale for this is set out within CDR1/4b which states; “the Council is seeking to reduce the impact of the SAP on Green Belt release by proposing revisions to the Plan as submitted. These revisions propose to designate some land (for a total of 7,834 homes across 43 sites) as ‘Broad Locations’ instead of housing allocations and safeguarded land designations meaning they will remain in the Green Belt until a further review of the Plan. Once a future housing requirement and government guidance have been clarified, the Site Allocations Plan can be reviewed and sites that are Broad Locations can be released if needed for housing, or retained as Green Belt with the Broad Location designation removed”. 2.10 The impact of this proposed change upon the Outer South East HMCA is to reduce the allocations by 1,422 dwellings. Therefore only 53% of the original SAP housing allocations remain in the Revised Submitted SAP. The Council’s updated SAP Background Paper (Ref: 3 Barratt Homes and David Wilson Homes and Taylor Wimpey Representor ID: PDP22906 Matter 7 Ref: M7/59/2 CDR1/4b) identifies that in relation to this site; “Given that there are insufficient brownfield or alternative Green Belt allocations which can deliver at scale within this HMCA to deliver housing numbers required to meet the SAP trajectory to 2022/23, an amount of housing is required to remain allocated as a release from the Green Belt. The site adjoins a major settlement and is in line with the Core Strategy. This will require site to be split into HG2-124 and BL1-40 with amended site requirements for HG2-124. The remainder of the site (BL1-40) will only be required post 2022/23, pending review of CSSR and SAP and is changed to a broad location.” (Appendix 2). 2.11 The rationale for the Council’s decision is understood and our clients support the Council in allocating the site. HG2-124, as defined in the Revised Submission SAP, is a sustainable allocation which will deliver a significant quantum of development in the next five years and over the plan period. The revised site can be successfully developed as a stand-alone allocation. The concept masterplan supporting the allocation clearly identifies how this could be achieved including the creation of a defined and defensible edge to the proposed Green Belt boundary. 2.12 The Inspectors will be aware that our clients have previously objected to the identification of part of the former allocation as ‘Broad Location’ BL1-40, see section 2 of our comments upon the Revised Submission SAP. To aid brevity our comments upon this issue are not repeated here. It does, however, remain our clients’ preference that the whole of the site (HG2-124 and BL1-40) be allocated as a single housing site. This would not only conform with the requirements of the Core Strategy but would also provide much needed flexibility in the Outer South East HMCA, and plan as a whole, should any of the other sources of supply fail to deliver as anticipated, see sections 3 and 4 of our comments upon the submitted Revised Submission SAP. The wider allocation would also have the benefit of an existing hard boundary. 5. Whether the site requirements for transport at HG2-124 are justified, and will this result in the policy being effective? 2.13 Our clients do not fundamentally object to the highway requirements for the site but to ensure that the plan is sound it is recommended that greater flexibility is included within the site requirements. The Revised Submission SAP currently states that; “This site will have a significant impact on the A63 through Garforth and M1 junctions 46 and 47. Possible mitigation is likely to include a southern bypass of Garforth and capacity enhancements at M1 Junctions 46 and 47 as agreed with Highways England.
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