Leeds City Council and B¡Ll Mckinnon

Statement of Gommon and Uncommon Ground between Leeds City Council and B¡ll McKinnon

Reference -Green Space Background Paper (CDL/321

HMCA: lnner (and reference to l site in North)

Ward: Hyde Park and Woodhouse (and L site in Chapel Allerton)

Name of Representor: Bill McKinnon

Representation number(s): PDEO2546 (Publication Draft stage) & PSE00599 (Pre Submission Change stage)

Site Allocat¡ons Plan Examination

Leeds Local Plan

Leeds ffi CITY COUNCIL

I 1 Introduction

1.1 This statement of common and uncommon ground has been prepared jointly between Leeds City Council and Bill McKinnon (the parties).

1.2 It sets out matters which Mr McKinnon and Leeds City Council agree on and also identifies specific issues raised by My McKinnon in his oral representation presented atthe Matter4: green space hearing session on24th October 2017 which the Council disagrees with.

2 Background

2.1 Mr McKinnon has expressed a number of concerns about the contents of the various versions of the Green Space Background Paper ln relation to green spacê identification in Hyde Park and Woodhouse Ward and the subsequent calculation of surpluses and deficiencies against the standards set out in Core Strategy Policy G3. He submitted representations at Publication Draft stage (PDE02546) and to the proposed pre-submission changes (PSE00599). The details contained in his representation to the Publication Draft SAP were considered carefully by the City Council and some changes were made (as identified at paragraph 3.1 below). Nevertheless, there remain facts and issues over which the parties disagree which are set out below in paragraph 4.1

3 Areas of Gommon Ground

3.1 The parties are in agreement in respect of the following:

Statement Statement from Mr McKinnon Statement from Leeds City of Common Council Ground Number 1) Mr McKinnon promotes the designation The Council agrees with Mr and protection of the open space McKinnon and has proposed adjacent to the former sorting office off pre-submission change number Cliff Road as green space. 341 in Pre-Submission Changes Document (CD1/6). Further comments from Mr McKinnon are This extends green space G917 contained in Appendix 1 which repeat (Cliff Road Green Space) to comments made in his oral statement include the open land adjacent (pages 2, 3, 6, 13) and reflect the issue to the former sorting office. raised on pages 4, 10 and 11 of Rep No. PDE02546. 2) Mr McKinnon points out that Cliff Mount The site was re-classified as Fields (G941) was gifted to City of Leeds outdoor sport prior to the Academy and fenced off thereby calculation of surpluses and preventing public access. The site was deficiencies in the Submission reclassified as outdoor sport and has not Green Space Background been included in the calculation of Paper (GSBP) (CD1/32). This

2 surpluses and deficiencies in the GSBP change has not been included (CD1l32) as it lies within an educational as a pre-submission change establishment and access is limited. therefore a minor modification to the GSBP (CD1/32) is Further comments from Mr McKinnon are proposed to reflect this change contained in Appendix 1 which repeat to the typology of G941. comments made in his oral statement (page 8) and reflects the issue raised on page 2 of Rep No. PDE02546. 3) Woodhouse Moor Park is 19.07ha (as The area of Woodhouse Moor stated in the Council's Woodhouse Moor Park (G159) as identified in the Management Plan 2004) rather than SAP is 19.8 ha. This was 19.8ha as this area includes watenruorks measured using the Council's owned by Yorkshire Water. GIS system and is set out in the table in Appendix 1 of the Further comments from Mr McKinnon are GSBP (CDlt32). In light of contained in Appendix 1 which repeat further information recently comments made in his oral statement supplied by Mr McKinnon in his (pages 4 - 5) and reflect the issue raised oral statement, the Council on pages 2-3of Rep No. PDE02546. proposes a minor modification to redraw the site boundary on the proposals map to exclude the watenruorks and to revise the site area in Appendix 1 of the GSBP (CD1t32) accordinqly.

4 Areas of Uncommon Ground

4.1 The following are issues in respect of which the Parties disagree. ln respect of all of the matters, the Council maintains its position as set out in the submitted GSBP (CD1l32) and the Submission Draft SAP for the specífic reasons set out below:

Statement Statement from Mr McKinnon Statement from Leeds City of Gouncil Uncommon Ground Number 1) The conclusions relating to provision of The Council disagrees with this green space in Hyde Park and representation as the conclusions Woodhouse Ward as set out in the of the GSBP (CD1l32) are the GSBP (CD1l32) are the result of an result of robust and sound attempt by the Councilto make the analysis of data collected through information fit pre-determined site visits using a standard conclusions. methodology that was fit for purpose. Further comments from Mr McKinnon are contained in Appendix 1 which repeat comments made in his oral

3 statement (pages 1 - 2) though the comments relating to the NGT inquiry were not made in Rep. No. PDE02546. 2) Areas of grass verge and other left over The Council reiterates that only green spaces were added to the total of land which functions as green "Amenity Green Space" in Hyde Park space is included in the SAP and and Woodhouse to show that the ward proposed for designation and had a surplus in "Amenity Green Space" protection as such - see para and therefore could spare land on 1.13 of GSBP (cD1t32). Woodhouse Moor for the trolleybus. The trolleybus/NGT scheme is no Further comments from Mr McKinnon longer being proposed. are contained in Appendix 1 which repeat comments made in his oral statement (page 14). Rep No. PDE02546 expresses concerns about the lack of protection of green space in Hvde Park and Woodhouse. 3) Woodhouse Moor should be designated This is a new issue which has not as a single site and be classified as a been raised previously and it has neighbourhood park i.e. Park and been submitted after the Gardens typology. consultation period. Notwithstanding this, the Council Further comments from Mr McKinnon disagrees as the current proposal are contained in Appendix 1 which of dividing the area into a number repeat comments made in his oral of separate green spaces in the statement (pages 2,3). PDE02546 SAP reflects the different does not include comments on the functions of the sections through "subdivision" of Woodhouse Moor more accurate typology however it does refer to the site classification and is a sound adjacent to the old sorting office (see approach. above in Statement of Common Ground,l).) 4) The ONS mid-year 2014 population This is a new issue which has not estimate is 27 ,174 been raised previously and it has been submitted after the Further comments from Mr McKinnon consultation period. are contained in Appendix 1 which Notwithstanding this, the Council repeat comments made in his oral has used the figure of 28,292 as statement (page 4). Rep No. provided by the Council's PDE02546 does not include comments lntelligence Team, lntelligence on this issue, however previous and Policy Services using the population figures were used in previous Mid-Year 2014 ONS Population drafts of the GSBP. Estimates. 5) Lovell Park lies outside the city centre This is a new issue which has not boundary therefore may be it has been been raised previously and it has included in city centre in error. been submitted after the consultation period. Further comments from Mr McKinnon Notwithstanding this, Lovell Park are contained in Appendix 1 which is green space site G141 which

4 repeat comments made in his oral lies within the City Centre HMCA statement (page 4). Rep No. boundary. lt is shown on the City PDE02546 does not include comments Centre HMCA Plan in Appendix 1 on this issue. of the GSBP (CD1l32) and on the plan at the end of the City Centre Chapter of the Submission Draft SAP (CD1/1c) 6) Hanover Square (G128), Woodhouse This is a new issue which has not Square (G161) and St George's Field been raised previously and it has (G181) lie in both the City Centre and been submitted after the lnner Areas. consultation period. Notwithstanding this, as Further comments from Mr McKinnon evidenced by the City Centre are contained in Appendix 1 which HCMA Plan in Appendix I of the repeat comments made in his oral GSBP (CD1l32) and the plan at statement (page 4). Rep No. the end of the City Centre PDE02546 does not include comments Chapter of the Submission Draft on this issue though it suggests there SAP (CD1/1c), sites G128, G161 are errors in total areas. and G181 lie completely within the City Centre HMCA. 7) Mr McKinnon questions the total of The Council considers the totals Green Space and Civic Space in the of green space and civic space City Centre and cross-ward use of green as detailed in the GSBP space in Hyde Park and Woodhouse (CD1l32) are correct. All sites Ward. are digitally recorded and measured on a GIS system. Further comments from Mr McKinnon are contained in Appendix 1 which repeat comments made in his oral statement (page 4). Rep No. PDE02546 does not include comments on the cross-ward use of green space however it does question green space totals. 8) There are anomalies in "amenity green The Council disagrees. The total space" in the Hyde Park and has been calculated taking into Woodhouse Ward in the GSBP account only those green spaces (CD1l32), including the totalwhich is or parts of green spaces that fall wrong. The entire area of Kirkstall Road in Hyde Park and Woodhouse Green Corridor (Willows)(G 1 075) Ward. Only the 2.72ha (61%) of (4.46ha) has been included in the total Kirkstall Road Green Corridor in Appendix 2 even though some lies (Willows) (G1075) that lies within outside the Ward. the Ward has been included in calculating the totals relating to Further comments from Mr McKinnon the surpluses and deficiencies in are contained in Appendix 1 which the Ward. repeat comments made in his oral statement (pages 5-6) and reflect the issues raised on pages 3, 4 and 12 of Rep No. PDE02546.

5 e) "ln order to achieve a surplus in The Council has included new "Amenity Green Space," the council has sites where it considers they added several "f'ìew" sites...." many of have a green space function and which were not designated as green merit designation. This is space in the UDP but were identified as considered a sound approach. green corridor in the LOSSRA. (EB6/4)

Further comments from Mr McKinnon are contained in Appendix 1 which repeat comments made in his oral statement (pages 6-7) and reflect the issues raised on pages 1,3, 4,7 and 12 of Re No. PDE02546. 10) Mr McKinnon questions the calculation The total outdoor sport is 3.33ha of surpluses and deficiencies of outdoor and with a ward population of sport in Hyde Park and Woodhouse 28,292 there is a provision of Ward and apparent discrepancy 0.12ha (rounded to 2dp). The between the actual area of outdoor sport standard in Policy G3 is 12ha and the calculation of the area going therefore there is a deficiency of back from the deficiency stated in the 1.08ha (as stated in the GSBP (CD1t32). Submission GSBP (CD1/32)). The discrepancy between 3.33ha Further comments from Mr McKinnon and 3.40ha is due to the are contained in Appendix 1 which necessary need to round totals to repeat comments made in his oral 2 decimal places during the statement (page 7) and reflect the calculation. issues raised on page 4 of Rep No. PDE02546. 11) Much is written by Mr McKinnon on the A response to this was given at proposed allocation of Burley Liberal the hearing session. The Club and land to the south for housing Council's Development Plan (HG2-211) and the incorrect Panelwas verbally updated at its classification of the disused playing meeting on 14th June 2016 on Mr pitch as amenity which justified the McKinnon's representation and proposed housing allocation. Mr as a result a decision was McKinnon states that councillors were deferred until 19th July meeting to persuaded in July 2016 by an officer allow officers to collate further report to re-designate half the site as information as to the status of the housing land. pitch. Officers confirmed that the pitch had not been designated as Further comments from Mr McKinnon green space in the UDP and was are contained in Appendix 1 which identified as amenity green space repeat comments made in his oral in the Publication Draft SAP. The statement (pages 7-8) and reflect the field has never been included in issues raised on pages 4, 5 and l3 of the Council's calculations of Rep No. PDE02546 and in Rep No. playing pitch provision within its PSE00599. emerging playing pitch strategy. Although the field has been used historically by the Rugby Club for traininq purposes, no formal

6 arrangement or lease was ever in place and the field has not been in use since before the Liberal Club went into receivership around December 2005. The Council is satisfied that the classification is correct. 12) Mr McKinnon questions the number of 'Equipped play areas'consist of play areas in Hyde Park and playgrounds, MUGA's, teen Woodhouse Ward as only 4 are listed in shelters, skate parks and goal Appendix 1 of the GSBP (CD1/32) and ends. these must be excluded from the There are 4 sites in Hyde Park calculations of surpluses and and Woodhouse Ward which are deficiencies as they lie within listed as "children's play" in ed ucational establishments. Appendix 1: . Little London Play Area Further comments from Mr McKinnon (G172) are contained in Appendix 1 which o Quarry Mount Primary School repeat comments made in his oral (G16e4) statement (page 8) and reflect the . Grafton School (G1696) issues raised on pages 5-6 of Rep No . Rosebank Primary School PDE02546. (G1700) All but Little London Play Area lie with in ed ucational establishments and therefore have not been included in the calculations of surpluses and deficiencies. Equipped play areas also lie within the following green spaces which are classified as alternative typologies ín recognition of their dominant use: . Hanover Square (Amenity) (G128) o Woodhouse Moor Park (Neighbourhood Park, Park and Garden)(G159) o Blackman Lane Rec (Local Recreation Area, Park and Garden)(G167) o North West Road (Local Recreation Area, Park and Garden)(G170) . Hyde Park Rec Ground Next to Mosque (Local Recreation Area, Park and Garden) (G3e1) . Queens Road Recreation Ground (Local Recreation

7 Area, Park and Garden) (G3e2) a Burley Lodge (Local Recreation Area, Park and Garden)(G393) a Woodhouse Street Recreation Ground (Local Recreation Area, Park and Garden)(G918) a Hartley Avenue Park (Local Recreation Area, Park and GardenXG1169) 13) Mr McKinnon questions the amount of There are two areas of natural natural green space that lies within green space in the Ward: Hyde Park and Woodhouse Ward o 5.02ha of G160 (Woodhouse Ridge, rest of the site is in Further comments from Mr McKinnon other wards) are contained in Appendix 1 which . 1.68ha of G1820 (Rosebank repeat comments made rn his oral Millennium Green). statement (page 9) and reflect the These have both been included issues raised on pages 5,13-14 of Rep in the calculation of surpluses No. PDE02546. and deficiencies in natural green space within the ward. 14) Mr McKinnon states that the allotments This is a new issue which has not on Woodhouse Moor are temporary, been raised previously and it has with no statutory protection under the been submitted after the Allotments Act 1925. He points out consultation period. many are derelict and not all are held by Notwithstanding this, the local residents. proposed green space designation (allotmentsXG 1 837) Further comments from Mr McKinnon is based on the current usage of are contained in Appendix 1 which sites and not on the statutory repeat comments made in his oral status of an allotment. statement (pages 9, 10, 14). Rep No. PDE02546 does not include comments on this issue. 1 5) Mr McKinnon believes Woodhouse The Council confirms that Moor Allotments are classified as both Woodhouse Moor Allotments "allotments" and "neighbourhood park" (G1837) and Woodhouse Moor and therefore there is double counting. Park (G159) are two distinctly separate sites and no double Further comments from Mr McKinnon counting has occurred. are contained in Appendix 1 which repeat comments made in his oral statement (page 10) and reflect the double counting issues raised on page 7 of Rep No. PDE02546 16) Mr McKinnon states the Council has The Council reaffirms that green failed to remedy deficiencies by re- space sites are classified cateqorisinq sites as promoted in the accordinq to their current use and

8 GSBP (CD1l32) and already undertaken not any previous or historic use by the Council in relation to reclassifying therefore an amenity green corridor to amenity. Cinder Moor classification is appropriate in (part of Cliff Road Green Space G 917) respect of the sites mentioned. and part of Monument Moor (part of Woodhouse Lane Green Space, G390) should be classified as outdoor sport to reflect uses in the latter C1gth and early c2oth.

Further comments from Mr McKinnon are contained in Appendix 1 which repeat comments made in his oral statement (pages 11-14) and reflect the issues raised on pages 8-10, 13 of Rep No. PDE02546. 17) Mr McKinnon supports the designation The site (G1926) was considered of fields at Headingley Hill as natural by the City Council however it green space. remains unallocated in the SAP as it is a field used for grazing Further comments from Mr McKinnon and therefore is in an agricultural are contained in Appendix 1 which use rather than a green space repeat comments made in his oral use. As such it does not justify statement (pages 13-14) and reflectthe designation as green space. issues raised on page 15 of Rep No. PDE02546. 1 I ) Mr McKinnon is of the opinion that Core This comments relates to the Strategy Policy H2 allows the Core Strategy rather than the development of green space if its SAP so it is not within the scope typology is in surplus. of or relevant to the SAP. Policy H2 b) refers to greenfield land Further comments from Mr McKinnon "may be developed if it concerns are contained in Appendix 1 which a piece of designated green repeat comments made in his oral space found to be surplus to statement (page 14) and reflect the requirements by the Open issues raised on page 1 of Rep No. Space, Sport and Recreation PDE02546. Assessment" however a surplus will only exist if all typologies are in surplus. Furthermore Policy G6 (i) clearly states that sites should be considered for use as an alternative deficient open space type before being released for development. 1e) Mr McKinnon questions the quality This is a new issue which has not scoring system and calls for it to be been raised previously and it has done again. been submitted afier the consultation period. Further comments from Mr McKinnon Notwithstanding this, the Council are contained in Appendix 1 which is satisfied that the scoring

9 repeat comments made in his oral methodology as outlined in statement (page 14). Rep No. paragraph 3.8 of the GSBP (CD PDE02546 does not include comments 1132) is robust and sound. on this issue. 20) Mr McKinnon claims housing allocations This is a new issue which has not HG1-111 (in an area of deficiency in been raised previously and it has outdoor sport) and HG1-239 (identified been submitted after the as amenity green space at lssues and consultation period. Options) are further examples of Notwithstanding this each irrationality and d iscrimination. allocation is considered on its own merits against the NPPF, the Further comments from Mr McKinnon policies of the development plan are contained in Appendix I which and other material repeat comments made in his oral considerations. HG1-239 statement (page 14). Rep No. (Carlton Gate, LS7 (lnner PDE02546 does not include comments M+HMCA)¡ is located within a on this issue. regeneration area which has been subject to wider master plannino. 21) Mr McKinnon considers the Site This is a new issue which has not Allocations Plan doesn't take the green been raised previously and it has space needs of different people into been submitted after the account. consultation period. Notwithstanding this, the GSBP Further comments from Mr McKinnon (CD1l32) considers a wider are contained in Appendix 1 which range of green space typologies repeat comments made in his oral to meet differing needs and the statement (pages 14-15). Rep No. methodology set out in PDE02546 does not include comments paragraphs 3.5 - 3.7 takes into on this issue. account the specific population of each Ward (0-16 year old's only for children and young peoples' play). More locally specific needs could guide and be reflected in the Hyde Park Neiqhbourhood Plan. 22) Mr McKinnon states that the Retail This is a new issue which has not Background Paper Submission Draft been raised previously and it has (E811/3) has failed to designate the been submitted after the area of open space diagonally opposite consultation. Notwithstanding the parade of shops called "The this, the SAP does not allocate Crescent" at Hyde Park Corner. sites for retail. The site identified by X on the plan submitted by Mr Further comments from Mr McKinnon McKinnon in Appendix 1 lies are contained in Appendix 1 which within the Hyde Park Local repeat comments made in his oral Centre therefore town centre statement (pages 15-16.) Rep No. uses will be looked on favourably PDE02546 does not include comments subject to other policy and on this issue. material considerations.

10 23) Mr McKinnon claims that allstages of Paragraph 6.2 of the GSBP the Site Allocations process, at least so (CD 1 132) clearly acknowled ges far as green space is concerned, have that green space is continually been categorised by numerous serious changing and that information errors. contained in the GSBP is inevitably a snap shot in time. Further comments from Mr McKinnon Changes have been made to are contained in Appendix 1 which update and improve the accuracy repeat comments made in his oral of data. The Council is satisfied statement (pages 16.) Rep No. that the methodology for the PDE02546 identifies a number of identification and assessment of suggested errors. green space has been applied consistently throughout the SAP process.

5 Agreement of Statement of Common Ground

Signed on behalf of Leeds City Council:

Name: Tim Hill

Role: Chief Planning Officer

Ë<(tf ûÊ^-tÀ Signature:

Date: 21st December 2017

Signed by Bill McKinnon:

Name: {,lV I L Lt f4//1/l m C /1t''-'t /rè Ñ

Role: Signature h,a /flc,(,*^ Date: at' /a- / 1

Aooendix 1- Further lnformation from Mr McKinnon

Statement Mr McKinnon's additional comments of Common Ground Number 1) The following paragraphs and photographs replicate those on pages 2,3,6 and 13 of Mr McKinnon's oral statement and reflect the ¡ssue raised on pages 4, 10 and 11 of Rep No. PDE02546.

The council appears not to want to designate the area between Woodhouse Cliff and the former sorting office at Hyde Park Corner. The former sorting office is owned by Samara Properties, a company based offshore. About ten years ago, Samara Properties fenced off the area of the park adjacent to the former sorting office for three or four years. The fencing was removed only after persistent lobbying of the council by a local resident.

An interactive map 1 published by the council in 2015 at the same time that it published the Green Space Background Paper Publicatíon Draft (E86/1-) showed that the area previously fenced off by Samara Properties had been excluded by the council from the larger area of Cliff Road Green Space (G917) and given no protective designation. The interactive map gave the total area of Cliff Road Green Space as 2.29 hectares. This is the same area in terms of hectares, as shown in the table on page 46 of Appendix 1 of the Green Space Background Paper Submission Draft ((EB6/3). This means that the council still wants to exclude this area from the rest of the park. But by detaching the 0.07 hectare area adjacent to the former sorting office from the green space to the south, it reduces this adjacent green space to the south to 0.14 hectares, which is less than the 0.2 hectare cut-off figure given at paragraph2.22 of the Leeds Open Space, Sport and Recreation Assessment 2011 (OSSRA) (E86/4). And yet the Green Space Background Paper Submission Draft (E86/3) still designates this 0.14 hectare area to the south as "Amenity Green Space," even though the council has claimed that the reason the adjacent area to the north hasn't been designated is that it's less than 0.2 hecta res.

The attempt by the Green Space Background Paper Publication Draft (EB6/1) and the Green Space Background Paper Submission Draft (E86/3) to detach the area adjacent to the former sorting office from the rest of the park raises questions as to the reason. lt should also be noted that the Site Allocations Publication Draft proposed excluding the former sort¡ng office from the Hyde Park Corner Local Shopping Centre. So, the Publication Draft proposed excluding both sites from the Hyde Park Corner Local Shopping Centre, and now the Submission Draft proposes including both sites in the Hyde Park Local Shopping Centre. Why is the council so intent on keeping these two sites linked when one of the two sites is part of Woodhouse Moor? lt suggests that the council wants there to be no impediment to development of the two sites. This would seem to also have been the aim of

l lnteractive Map Published with the Site Allocations Publication Draft https://leedscc.maps.arceis.com/a pps/weba ppviewer/index. html?id=409a 1efd0ecb427d8ae3878f98468985 Samara Properties when it fenced off the section of Woodhouse Moor adjacent to the former sorting office.

For the green space adjacent to the former sorting office to be developed, it would first have to be sold to Samara Properties. lt wouldn't be the first time the council sold off part of the park. About twenty years ago, flower beds next to the Library Pub were sold to Stonegate Pubs, the company based offshore which owns the pub. To protect the area of green space adjacent to the former sorting office, please can it be excluded from the proposed Hyde Park Corner Local Shopping Centre.

soßftitc oftcE

PARÍ OF WOODIIOT'SE ¡IOOR ilElrloSORnnGoFF|CE The total area of the part of Cliff Road Green Space on the other side of Cliff Road from Cinder Moor is 0.21 hectares. This is more than 0.2 hectares (the cut-off figure of 0.2 hectares is from OSSRA. Although this figure is not mentioned in the Site Allocations Plan, it seems that the council is still using it.) By removing the 0.07 hectares of the area adjacent to the former sorting office from the total 0.2L hectares, the remaining area is just 0.14 hectares, also less than the cut-off figure of 0.2 hectares. So to avoíd creating another anomaly, please do not allow the council to arbitrarily draw a line dividing in two the section of Cliff Road Green Space on the other side of Cliff Road from Cinder Moor. 2't The following paragraph replicates that on page 8 of Mr McKinnon's oral statement and reflects the issue raised on page 2 of Rep No. PDE02546.

Another sports field had N1 designation in the UDP. lt was called Bedford's Fíeld. OSSRA called the site Cliff Mount Fields and gave it the designation "Parks and Gardens." The version of the Green Space Background Paper Draft which preceded the Green Space Background Paper Publication Draft (E86/1) published ín 20L5, also gave it the name Cliff Mount Fields (G941), and also classified the site as "Parks and Gardens." lt was laid out as a football pitch. On the 1st August 20L4, Leeds City Council gave the playing field free of charge to City of Leeds Academy. Early in 2015, the playing field was fenced off denying access to the public. 3) The following paragraphs replicate those on pages 4- 5 of Mr McKinnon's oral statement and reflect the issue raised on pages 2 - 3 of Rep No. PDE02546.

Below is a list of "Parks and Gardens" sites in Hyde Park and Woodhouse. The list has been extracted from a longer list of sites at Appendix L of the Green Space Background Paper Submission Draft (E86/3). The areas in hectares are the areas given at Appendix 1. The total is the actual total of all the figures in the column below.

SITE ID SITE NAME AREA G147 Lovell Park 1.55 G159 Woodhouse Moor Park 19.80 GL67 Blackman Lane Rec L.30 G770 North West Road 0.78 G391 Hyde Park Rec next to 0.31 mosque G392 Queens Road Rec Ground o.64 G393 Burley Lodge L.00 G918 Woodhouse Street Rec 0.94 Ground G1169 Hartley Avenue Park 7.t4 Total 27.46

Whilst Appendix 1 states that the area of "Woodhouse Moor Park" is 19.8 hectares, the council's Woodhouse Moor Management Plan 20042 reveals that the area is actually L9.07 hectares, 0.73 hectares less than claimed at Appendix 1

2 Extracts from Woodhouse Moor Management Plan 2004 http://a660.orelwp-content/uploads/2014109/Ma nagement-Pla n-a. pdf When the council published its Green Space Background Paper Publication Draft (EB6/I| in 201-5, it also published an interactive map. This map shows that the 19.80 hectare figure that the council has given for Woodhouse Moor wrongly includes an area of waterworks owned by Yorkshire Water. This is not part of the park and never has been. The area of 19.80 hectares given by the council for Woodhouse Moor Park is therefore wrong. lt overstates the actual area by 0.73 hectares.

Correcting the error relating to the area of Woodhouse Moor Park gives a total area for "Parks and Gardens" o126.73 hectares. Assuming the population of Hyde Park and Woodhouse is28,292 (the population estimate given at Appendix 2), the provision for "Parks and Gardens" in Hyde Park and Woodhouse is 0.94 hectares per 1,000 population. This is less than the minimum requirement of 1.00 hectare per L,000 population, and less than the figure given in the table on page 1-9 of Appendix l- of 0.97 hectares per L,000 population. Statement Mr McKinnon's additional comments of Uncommon Ground Number 1) The following paragraphs replicate those on pages t-2 of Mr McKinnon's oral statement. Reference to the NGT inquiry was not made in Rep No. PDE02546.

ln 2014, at a public inquiry ¡nto a proposed trolleybus scheme called NGT, the council claimed that Hyde Park and Woodhouse has surplus open space, and could therefore spare land on Woodhouse Moor for the trolleybus to run across. During cross-examination, when it was pointed out to Stephen Speak, the Deputy Chief Planning Officer that the previous week, one of his planning officer's reports on the St Michael's College re-development had stated, "The wørd of Hyde Pork ond Woodhouse records one of the highest levels of green spoce deficiency across the city," 3 Mr Speak claimed that this was an error, and that the true position was one of surplus, as shown in the Draft Site Allocation Plan, a copy of which he waved in the air.a At the time, the document Mr Speak referred to had not been published and was only available to him. Mr Speak's statement explains why the authors of the Green Space Background Paper Publication Draft (EB6/1) and its successor, the current Green Space Background Paper Submission Draft (E86/3) added areas ofgrass verge and other left over greên spaces to the total of "Amenity Green Space" in Hyde Park and Woodhouse. lt was an attempt to show that the ward has a surplus in the category "Amenity Green Space" and that the ward could therefore spare land on Woodhouse Moor for the trolleybus to run across.

At paragraph 4f on page 4 of the NGT Project Board Minutes of the 16th September 2OL3,5 it states that Deputy Chief Planning Officer Stephen Speak

3 Report of the Chief Planning Officer dated L7 July 2Ot4 on Planning Application 13/04862/FU (see paragraph 6.2.15 of the sub report dated 8 May 2014) http://a660.orelwp-content/uploads/201"7/1"0/Application-L304862FU.pdf a Recording of Day 37 of Leeds Trolleybus lnquiry 21, July 2OI4 https://www.mixcloud.com/CosmicClaire/dav-37-leeds-trollevbus-pu blic-enquirv-21--iulv-2014-onlv-session/ s NGT Project Board Minutes http://a660.orelwp-content/u ploads/2014l09/NGT-Pro iect-Boa rd-minutes.pdf "reised concerns thot it will be difficult to designote the land on Woodhouse Moor os surplus."

At paragraph 4f on page 4 of the ruGt Project Board Minutes of the 21st October 2Ot3,it says that John Henkel of Metro stated that 'ft is difficult to argue the cose for the land being classed os surplus."

At paragraph 5d on page 9 of the Project Board Minutes of the 1.8th June 20L3, it says that Tom Gifford of Metro advised the group that the open space position in relation to Woodhouse Moor contravened both local and national guidance.

The proposal to take the trolleybus route across Woodhouse Moor contravened UDP 6 Policy N1 which states that NL protected green space has to be replaced if it's going to be developed, unless the need in the locality can be shown to be met. The proposal also contravened Paragraph 74 of the National Planning Policy Framework.T This states that open space should not be developed unless it's surplus to requirements, or replaced.

Because of Mr Speak's action, waving the unpublished Draft Site Allocations Plan in front of the trolleybus inspector, and claiming that the green space position in Hyde Park and Woodhouse was one of surplus, the inspector, whose report 8 was published on the 12th May 2016, could only say at paragraph 9.97 of his report, " ln terms of the use of the open space ot Woodhouse Moor, there is conflicting evidence regording whether there is a deficit of 'omenity green space' in that ared." However, the inspector added at paragraph 9.94 on page 660 of his report, "The ossessment in the Environmentol Statement oÍ the effect of the NGT on the choracter and appeorance of Woodhouse Moor does not oppeor to me to toke occount of its location within o Conservotion Area and foils to place those wolking on the Meonwood Valley Troil ond Døles Woy Link, which start at Monument Moor, into the most sensitive cotegory of receptor." 2l The following paragraph replicates that on page 14 of Mr McKinnon's oral statement. Rep No. PDEO2546 expresses concerns about the lack of protection of green space in Hyde Park and Woodhouse.

The Green Space Background Paper Submission Draft (E86/3) tries to convey the idea that the council wants to protect areas of green space in areas of deficiency. But by allowing sports pitches to be built on, by trying to run a trolleybus across Woodhouse Moor, and by classifying areas of grass verge and SLOAP as "Amenity Green Space," the council has provided evidence that so far as Hyde Park and Woodhouse is concerned, its real intention is to develop areas of green space in the ward whenever this helps the council to meet its housing targets. The council's true intentions towards Hyde Park and Woodhouse and other inner city wards are demonstrated by its Community lnfrastructure Levy Charging Schedule which charges developers f5 per square metre to build in Hyde Park and

6 Leeds Unitary Development Plan (Review 2006) http://a660.orglwp-content/uploads/2015/05/UDP. pdf 7 National Planning Policy Framework http://a660.orelwp-content/u ploads/2015/05/Nationa l-Pla n nine-Policv-Fra mework.pdf 8 Trolleybus lnspector's Report dated 12May 2OL6 http://a660.orslwp-content/u ploads/2016/05/Trollevbus-l nspectors-Report-12.5.16.pdf Woodhouse compared to f90 per square metre in wealthier and leafier areas such as Adel, Cookridge and Alwoodley. 3) The following paragraphs mainly replicate those on pages 2-3 of Mr McKinnon's oral statement. Rep No. PDE02545 does not include comments on the "subdivision" of Woodhouse Moor however ¡t does refer to the site adjacent to the old sorting office (see above in Statement of Common Ground,l).)

Monument Moor is the nickname for the part of Woodhouse Moor that the trolleybus would have run across. The Green Space Background Paper Submission Draft ((EB6/3) calls Monument Moor "Woodhouse Lane Green Space." lt is one of seven sections that the Draft has divided Woodhouse Moor into. The seven sections are Woodhouse Moor Park (G159), Woodhouse Street Recreation Ground (G918), Woodhouse Cl¡ff (G342), Woodhouse Lane Green Space (G390), Cliff Road Green Space (G917), Woodhouse Moor Allotments (G1837), and an undesignated area adjacent to both Clitt Road Green Space and the former sorting office at Hyde Park Corner.

Woodhouse Moor is the oldest and most intensively used park in Leeds.e The council classifies it as a "community park." Despite this, the Green Space Background Paper Submission Draft ((EB6/3) has not designated the seven sections as "Neighbourhood Park." lnstead, only the largest section called "Woodhouse Moor Park" has been given this designation. "Woodhouse Street Recreation Ground" is classed as a "Local Recreation Area." "Woodhouse Cliff," "Woodhouse Lane Green Space" and "Cliff Road Green Space" have all been classed as "Amenity Green Space," and "Woodhouse Moor Allotments" have been classed as "Allotments." (see page 2 of oral statement.)

Currently, all of Woodhouse Moor is designated as category N1 green space in the UDP. The proposal by the Green Space Background Paper Submission Draft ((E86/3) to divide the park into seven sections with different individual designations is arbitrary and can only be damaging to the park. The hiving off of Monument Moor and calling it "Woodhouse Lane Green Space" with a designation of "Amenity Green Space," enabled the council and Metro to claim it was surplus to requirements and so could be spared to allow a trolleybus to run across it. Hiving off the section next to the old sorting office and giving it no protection at all, would allow the council to sell the land to Samara Properties. Woodhouse Moor is a unit. lt should not be split up. lf it is split up, it will become that much easier for the council to dispose of individual sections or use them for purposes for which they were not intended, which would not be in the interests of local people. (see page 3 of oral statement.)

And if you decide that the site should be given several designations, please can the individual sites be given names such as Woodhouse Moor Site L, Woodhouse Moor Site 2 etc, instead of names which have no relation to Woodhouse Moor as currently proposed by the council. The council has done this with sites G481 and G482 in Morley, giving the sites the names, Glen Road - Morley Site L and Glen Road - Morley Site 2. Giving only one site on Woodhouse Moor, the name Woodhouse Moor Park, and to the other sites names which have no connection to Woodhouse Moor, suggests that these sites are unconnected to Woodhouse s Page 59 of LCC's Park & Greenspace Strategy http://woodhousemooronli ne.com/wp-content/u ploads/2014l01/Pg59.pdf Moor. When the council was proposing to run a trolleybus across the part of Woodhouse Moor which the council propose calling Woodhouse Lane Greenspace, certain councillors and people connected to the project tried to suggest that this area is not part of Woodhouse Moor. 4l The following paragraph replicates that on page 4 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on the population estimates.

Paragraph 3.6 on page 10 of the Green Space Background Paper Submission Draft (E86/3) states, "The ONS Mid-Yeor 2014 Population Estimates have been used to calculate the surpluses and deficiencies for each Word os, olthough these are estimotes, they are more recent thon the 2077 Census doto." The ONS mid-year 2014 population estimate for Hyde Park and Woodhouse is27,L74. The ONS mid- year 2015 population estimate for Hyde Park and Woodhouse is 28,075. The ONS mid-year 2016 population estimate for Hyde Park and Woodhouse is 29,077.1o And yet the table on page 83 of the Green Space Background Paper Submission Draft (EB6/3) shows a population for Hyde Park and Woodhouse o128,292. Whilst, it is unclear where this figure comes from, it is clearly not the ONS mid-year 2Ot4 population estimate as claimed. s) The following paragraph replicates that on page 4 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on the location of LovellPark.

The table on page 40 ofAppendix 1 ofthe Green Space Background Paper Submission Draft (EB6/3) shows Lovell Park (G141) as being in the city centre. ln fact, Lovell Park is outside the city centre boundary. Presumably, its 1.55 hectares have wrongly been included in the total of 22.64 hectares of green space and civic space shown at paragra ph 4.2.3 on page 1.5 of the Draft. 6) The following paragraph replicates that on page 4 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on the location of Hanover Square, Woodhouse Square and St George's Fields though it does suggest there are errors in the total area for "Parks and Garden."

The table on page 40 of Appendix L shows North Street Verge (G171) as being in both the city centre and the inner area. But whilst Hanover Square (G128), Woodhouse Square (G161) and St George's Fields (G181) are also in both the city centre and the inner area, they're only shown at Appendix 1 as being in the city centre. And yet, despite this, their combined 4.82 hectares cannot have been included in the total of 22.64 hectares of city centre green space and civic space shown at paragraph 4.2.3 on page 15 of the Green Space Background Paper Submission Draft (E86/3), as after deducting the total civic space of 18.92 hectares from the total of 22.63 hectares of combined civic space and green space, we're left with just 3.71 hectares of green space, which is more than the 4.82 hectares of combíned green space of Hanover Square (GL28), Woodhouse Square (G161) and St George's Fields (G181).

10 Office for National Statistics Ward-Level Mid Year Population Estimates https://www.ons.gov.u k/peoplepopu lationa ndcommunitv/populationandmigration/popu lationestimates/datasets/wardle velmidvea rpopu lationestimatesexoerimenta I 7't The following paragraph replicates that on page 4 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on the cross-ward use of green space.

Paragraph 4.2.7 on page 16 of the Green Space Background Paper Submission Draft (EB6/3) states, "Provision of green space within the City Centre is poor however the oreo has better access than this would suggest as it benefits from provision just beyond the boundory. For example the proximity of Woodhouse Moor ensures the northern port of the City Centre has good occess to porks and gordens, outdoor sport, children's equipped ploy ond ollotments." But this paragraph fails to mention that Woodhouse Moor is located in Hyde Park and Woodhouse ward which the Green Spaee Background Paper Submission Draft (EB6/3) admits is deficient in the categories "Parks and Gardens," "Outdoor Sports" and "Allotments." So the claim that the city centre has good access to parks and gardens, outdoor sports and allotments because of its proximity to Woodhouse Moor, is worthless. Not only do the residents of Hyde Park and Woodhouse already have insufficient green space, it seems the council now expect them to share what little they have with residents of the city centre. Woodhouse Moor is classed by the council as a "community park." This means that it is intended for use by the local community. lt ¡s not a "city park," like much larger parks such as Temple Newsam and Roundhay Park, which have greater resources allocated to them because of their status as city parks. lnterestingly, the eouncil also uses the proximity of Woodhouse Moor as an excuse to allow developers not to provide the required on-site green space when it awards them

lann rmission for I develo 8) The following paragraphs replicate those on pages 5-6 of Mr McKinnon's oral statement and reflect the issues raised on pages 3, 4 and 12 of Rep No. PDE02546.

Below is a list of "Amenity Green Space" sites in Hyde Park and Woodhouse. The list has been extracted from a much longer list of sites at Appendix 1 of the Green Space Background Paper Submission Draft (EB6/3). The areas in hectares are the areas given at Appendix 1. The total is the actual total of all the figures in the column below.

SITE ID SITE NAME AREA G1_28 Hanover uare 0.90 GL6L Woodhouse uare 0.26 GLTL North Street o.32 G1_68 Meanwood Road 1,.O4 G1_69 Clay Pit Lane (L) 0.99 Gt73 Oatland Towers 0.54 GL74 Ba Fields 0.70 Gt76 Servia Gardens 0.35 G189 Blenheim uare 0.60 G342 Woodhouse Cliff o.26 G390 Woodhouse Lane Green 1.53 G9t7 Cliff Road Green s ace 2.29 G1075 Kirkstall Road Green Corridor 4.46 (wiil G1168 Cross Chancellor 0.74 G1889 St Marks Road o.77 Total 15.75

The above total of 15.75 hectares differs from the total of 14.43 hectares given on page 83 of Appendix 2 of the Green Space Background Paper Submission Draft. Although Appendix 2 doesn't actually state a total amount, we know that the total amount claimed is 14.43 hectares because Appendix 2 states that the total area of "Amenity Green Space" is 1.7 hectares more than the standard required, which is L2.73 hectares (0.45 x28.292). An explanation for the difference may be that Appendix 2 has incorrectly excluded Hanover Square, Woodhouse Square and North Street Verge because these areas have been classed at Appendix 1 as being in the city centre. There are additional errors:

The table on page 47 of Appendix 1 states that the total area of Kirkstall Road Green Corridor (Willows) (G1075) is 4.46 hectares. lt also states that only 6L% of the total is in Hyde Park and Woodhouse. And yet the entire 4.46 hectares has been included in the total in Appendix 2. The actual area of Kirkstall Road Green Corridor (Willows) inside Hyde Park and Woodhouse is 2.72 hectares. The council needs to correct this error in the Green Space Background Paper Submission Draft EB6/3 e) The following paragraphs replicate those on pages 6-7 of Mr McKinnon's oral statement and reflect the issues raised on pages L, ?,4,7 and L2 of Rep No. PDE02546.

ln order to achieve a surplus in "Amenity Green Space," the council has added several "new" sites to its list of "Amenity Green Space" sites in Hyde Park and Woodhouse during the Draft Site Allocations Plan process. The additional sites are, St Mark's Road (G1889), North Street Verge (GL7L\, Clay Pit Lane (1) (Gl-69), Kirkstall Road Green Corridor (Willows) (G1075) and Cross Chancellor (G1168).

St Mark's Road, North Street Verge, Clay Pit Lane (1) and Cross Chancellor were not counted as green space on the UDP Policies Map.tt Presumably St Mark's Road was not included because it was regarded as "Space Left OverAfter Planning." "Space Left Over After Planning" is a term referred to at paragraph2.22 of the Open Space, Sport and Recreation Assessment 2011 (OSSRA) (EB6/a). And North Street Verge, Clay Pit Lane (1) and Cross Chancellor would not have been included because they are grass verges beside busy roads. Paragraph 2.22 of OSSRA states, "The study excluded grass rood verges, unless they ore large enough to be purposive and capable of performing on open space function." Kirkstall Road Green Corridor (Willows), North Street Verge (0.32ha), Clay Pit Lane (1) (0.99ha) and Cross Chancellor (0.74ha) were included at Appendix A of OSSRA12 as "Green Corridors." St Mark's Road was not included in OSSRA, presumably because it should be categorised as "Space Left Over After Planning." (see page 6 of oral statement.)

Space Left Over After Planning

11 UDP Policies Map 22 http://a660.orelwp-content/u ploads/2015/11lUDP-Ma p-PoliciesMa p22.pdf 12 Appendix A of OSSRA http://a660,orelwp-content/uploads/2015/11lU DP-Map-PoliciesMap22.pdf Paragraph 2.6 of The Spelthorne Local Development Framework "Assessment of Open Space, Sport and Recreation Provision in Spelthorne" 13 states:

"ln conjunction with PPG77, there ore o number of types of land use that hove not been included in our ossessment qs open space and recreotion, nomely:

a gross verges on the side of roods

a SLOAP (space left over after planning i.e. in ond around a block of flats)"

"Space Left Over After Planning" (SLOAP) such as St Mark's Road (G1889) should not be included as "Arnenity Green Space" because SLO.AP has little arnenity rvalue and because the council can give planning permission to build on such areas at any time. An example of this is Belgrave Street Public Open Space (G184). The site was shown on the interactive map published with the Green Space Background Paper Publication Draft (EB6/1). lt was 0.25 hectares of green space in the city centre. Even though the Green Space Background Paper Submlsslon Draft (EB6/3) states that the city centre is short of green space, and even though Belgrave Street Prlblic Open Space was designated as "Amenity Green Space" in the Green Space Backgrorrnd Paper Publication Draft (FB6/1) published in2Q15, the council gave planning permission in 2016 for an 18 storey student block to be built on the site. Construction work began several months ago. The planning application reference is 1.6/077 aUFU.

It was wrong for the council to scout around Hyde Park and Woodhouse looking for scraps of "Space Left Over After Planning" in order to create an artif¡cial surplus of "Amenity Green Space."

Grass Verges

Grass verges such as North Street Verge, Clay Pit Lane (1) and Cross Chancellor were excluded from OSSRA as "Amenity Green Space" for the reason given at paragraph 2.22 oI OSSRA, "The study excluded grøss rood verges, unless they are lorge enough to be purposive ond copoble of performing an open spoce function." They should not have been included as "Amenity Green Space" in the Green Space Background Paper Submission Draft (E86/3) as they are beside busy roads and therefore have llttle amenity value. For example, the grass verge on the other slde of the road from the Carlton Gate Housing Site (HG1-239) has not been íncluded as "Amenity Green Space" in the city centre, even though the city centre is short of green space. These grass verges are really just another type of "Space Left Over After Planning."

lf we correct the total of "Amenity Green Space" of 15.75 hectares shown in the table above to reflect the fact that the actual area of Kirkstall Road Green Corridor (Willows) inside Hyde Park and Woodhouse is2.72 hectares, we get a corrected total of 14.0L hectares.

lf St Mark's Road (0.77ha), North Street Verge (0.32ha), Clay Pit Lane (1) (0.99ha) and Cross Chancellor (0.7aha) are excluded from the total of L4.0L hectares, the

13 Assessment of Open Space, Sport and Recreation Provision in Spelthorne (paragraph 2.6 on page 8) http://a660.orglwp-content/uploads/20L7l10/Assessment of Open Space Sept 05.pdf total "Amenity Green Space" in Hyde Park and Woodhouse is shown to be 11.1-9 hectares. Given a population estimate of 28,292, this would give an "Amenity Green Space" provision for Hyde Park and Woodhouse of 0.40 hectares per 1,000 population. This is significantly less that the minimum requirement of 0.45 hectares per L,000 population. 10) The following paragraphs replicate those on page 7 of Mr McKinnon's oral statement and reflect the issues raised on page 4 of Rep No. PDE02546.

The table displayed on page 1.9 of Appendix 1 of the Green Space Background Paper Submission Draft (E86/3) states that the "Outdoor Sports" provision in Hyde Park and Woodhouse is -L.08 hectares per L,000 population. Given that the required provision is 1..2 hectares per 1,000 population, and given the population estimate of 28,292, this means that the total "Outdoor Sports" area is 3.40 hectares. The total requirement should be 33.95 hectares. So the shortfall is 30.55 hecta res.

SITE ID SITE NAME AREA Gt75 Cambridge 3.33 Road Total 3.33

The only site designated as "Outdoor Sports" at Appendix f. is Cambridge Road with its 3.33 hectares. Presumably, this site is the only site included in the total of 3.40 hectares. lt's impossible to know how the council reached a total figure of 3.40 hectares. 11) The following paragraphs replicate those on pages 7-8 of Mr McKinnon's oral statement and reflect the issues raised on pages 4, 5 and 13 of Rep No. P0E02546 and Rep No. PSE00599.

The version of the Green Space Background Paper Draft1a which preceded the Green Space Background Paper Publication Draft (E86/1) published in 2015, designated the 0.854 hectares of the "Willow Road - Rising Sun Public Open Space" síte (G1822)within Hyde Park and Woodhouse as "Amenity Green Space" even though it was a fenced off, locked up sports pitch. Furthermore, it double counted the site by also including it as "Outdoor Sports." The southern half of the site was designated as category N1 green space in the UDP. The Draft Site Allocations Plan now designates the site for housing, even though there is an acknowledged shortage of provision of "Outdoor Sports" in Hyde Park and Woodhouse. For many years, the green space just south of Burley Liberal Club was used by Queens Rugby Club as a junior rugby pitch and for pre-season training. The Club rented the land from Leeds City Council which provided f 16,000 for a high wire mesh fence to surround the pitch. The area was designated as "Amenity Green Space" in the council's Site Allocations Plan Publication Draft published in September 2015. But then in July 2O16, a planning department report persuaded councillors to re-designate half the site as housing land. The report stated, "Ihe site hos not been in ploying field use for around 9 or 70 years. The Site Allocotions Plan Publication Draft had proposed the site as o green space designation, but clossed it os amenity green spoce, not ployinq fields. There is therefore o cleor

1a Previous version of Draft Site Allocations Plan relating to green space in inner wards http://a660.orelwp-content/u ploads/2014110/Site-Allocations-lnner. pdf justificotion for the site being allocoted for housing." ln fact, the site was used by Queens Rugby Club until March 2016. Up until then, the club paid the council rent of f400 annually for the use of the land. The club only stopped using the site because the council had stopped cutting the grass and because players were no longer able to access the adjacent car park. lf the council incorrectly designated the site as "Amenity Green Space" when it should have designated the site as "Outdoor Sports," this is not "clear justification" for the site being allocated for housing. The only action justified by the error is correction of the error, i.e. for the site to be re-classified as "Outdoor Sports." Hyde Park and Woodhouse ward, where the pitch is located, has only a tenth of the "Outdoor Sports" provision required by the Green Space Background Paper Submission Draft (E86/3). Planning officers should be trying to increase outdoor sports provision in the ward, instead of reducing it. When can we expect their "error" to be corrected? The Green Space Background Paper Submission Draft designates large amounts of open space across the city as "Amenity Green Space." So it's worrying when planning officers state that because the junior rugby pitch had been designated as "Amenlty Grcen Spacc," lt could be re-deslgnated for houslng. For lt lmplles êlther that planning officers treat "Amenity Green Space" as undesignated left over space which can be re-designated hy them for any purpose they choose, or, more likely, that because the council is claiming that Hyde Park and Woodhouse has a surplus of "Amenity Green Space," the s¡te can be re-designated for housing. The rugby practice site and the area around it urgently need to be re-designated as "Outdoor Sports." The way that the council has dealt with this site shows why it is so important to the council to establish that Hyde Park and Woodhouse has a surplus in "Amenity Green Space." The claimed surplus has allowed the council to re-designate this site for housing and it also allowed them to claim that Monument Moor could be for the trol s to run across it.

Satellite imagery showing the rugby practice area at the Willow Road POS site at 5 June 2016. There was another sports field in Hyde Park and Woodhouse ward which had N6 designation in the UDP. lt was located at Chestnut Avenue in Hyde Park. But in April2OL4, the council gave planning permission for it to be built on.

There was also the Cliff Mount Fields site which had N1 designation in the UDP which the council transferred free of charge to City of Leeds Academy on the 1't August 2014 and which is now fenced off. The public knew this site as "Bedford's Field." The version of the Green Space Background Paper Draft which preceded the Green Space Background Paper Publication Draft (E86/1) published in 2015, designated the site as "Parks and Gardens" (G941). r2l The following paragraph replicates that on page 8 of Mr McKinnon's oral statement and reflect the issues raised on pages 5-6 of Rep No. PDE02546.

Page 83 of Appendix 2 of the Green Space Background Paper Submission Draft (EB6/3) states that Hyde Park and Woodhouse has 19.51 children's play areas. But it does not state where these play areas are located. Appendix 1 lists just four play areas, and these must be excluded since educational provision has to be excluded. Page 83 of Appendix 2 states that the population of 0-1-6 year olds in Hyde Park and Woodhouse is 2,748. The minimum requirement is 2 facilities per 1,000 children. lf the ward really does have 19 children's play areas, this means that the current provision is 7 per 1,000, which is more than the minimum required. But how can members of the public make meaningful representations about the number of children's play areas, when the Green Space Background Paper Submission Draft (E86/3) fails to identifir the locations of the playgrounds? 13) The following paragraphs replicate those on page 9 of Mr McKinnon's oral statement and reflect the issues raised on pages 5, t3- t4 of Rep No. PDE02546.

SITE NAME AREA G1820 Rosebank Millennium 1.68 Green Total 1.68

The only area of "Natural Green Space" listed at Appendix 1 of the Green Space Background Paper Submission Draft (EB6/3) is Rosebank Millennium Green (G1820) at 1.68 hectares. However, the table on page 19 of the Draft states that Hyde Park and Woodhouse has a deficiency in "Natural Green Space" of -0.43 hectares per 1,000 population. The required standard is 0.7 hectares per 1,000 population. Given a population estimate of 28,292, this means that Appendix 2 is saying that there is a total area of "Natural Green Space" of 7 .64 hectares. To meet the requirement, there should be a total of 19.8 hectares. There is therefore a shortfall o172.L6 hectares.

The fact that Appendix 2 is effectively saying that there is a total "Natural Green Space" oî7.64 hectares, and the fact that Appendix L lists only one site of "NaturalGreen Space," namely "Rosebank Millennium Green" with 1.68 hectares, means that there is a site, or sites missing from the list at Appendix 1.

Appendix t has failed to include the part of Woodhouse Ridge inside Hyde Park and Woodhouse ward. The version of the Draft Green Space Background Paper which preceded the Green Space Background Paper Publication Draft (E86/1) published in 20L5 stated that the area of Woodhouse Ridge within Hyde Park and Woodhouse is 5.02 hectares. lf 5.02 hectares was the correct figure, it would mean that the total area of "Natural Green Space" in Hyde Park and Woodhouse is 6.70 hectares. This is still less than the requirement of 19.8 hectares.

Appendix 1 states that 65% of the 1"6.83 hectares of Woodhouse Ridge is inside Headingley ward. But whilst Woodhouse Ridge is divided between Headingley, Hyde Park and Chapel Allerton wards, Appendix 1 appears to show all of it as being in Headingley ward. Appendix 1 allocates no part of Woodhouse Ridge to either Hyde Park and Woodhouse ward, or Chapel Allerton ward.

A glance at a map shows the figure of 5.02 hectares of Woodhouse Ridge inside Hyde Park and Woodhouse, referred to in the version of the Draft Site Allocations Plan current in 2074 to be incorrect. lf it were correct, the area of Woodhouse Ridge inside Hyde Park and Woodhouse would be bigger than Cinder Moor (Cliff Road Green Space) and Monument Moor (Woodhouse Lane Green Space) combined, which clearly it's not. 14) the followlng paragraphs melnly repllcate thosê on pâges 9, 10, 14 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on allotments.

A view of the allotments on Woodhouse Moor.

The allotments on Woodhouse Moor were established as a temporary measure in L940 in response to the outbreak of war. They were all to have been cleared by the end of 1952. ln December 1950, the Parks Committee chairwoman sâid,Ls ""¡ have been very disoppointed with the allotment holders on Woodhouse Moor. The site we have agreed to take has been a disgrace, with its huts ond shacks. They do nof deserve ony cansideration. They have done their best ta make it into a rubbish heop. But there are also good allotment holders." A change of administration in May L951 gave the allotments a reprieve which was only intended to be temporary - presumably until the end of rationing. But then the issue was

ls Yorkshire Post 7 December 1950 http://woodhousemooronline.com/wp-content/u ploads/2016/05/YP-7.12. i.950-a.ipe forgotten, and the allotments are still there, even though Woodhouse Moor is the most intensively used park in Leeds. They look the same today as they did in L950.

Section 23 of the Small Holdinss and Allotments Act 1908 states that if a council believes that there is a demand for allotments; they have a statutory duty to provide a sufficient number of plots. But there is no legal national minimum provision standard. And there is nothing to say that every ward in a city must provide allotments. Presumably, prior to the establishment of allotments on Woodhouse Moor during the Second World War, the requirement for allotments was met elsewhere in the city on other land owned by the council.

There are temporary allotments, and there are statutory (permanent) allotments The difference between them is explained at page 9 of Northampton Borough Council's Allotment Strategy Draft Consultation16 published in April 2004:

"The legal designation of allotment sites rs either "temporory" or "statutory." Statutory sites ore those sites that when the local authority acquired the land it specifically bought the land for the intention of allotment use. Such sites receive protection under Section I of the Allotment Act ond ony disposal or change of use would need to fulfilthe requirements from the Minister of the Environment, Transport and the Regions.

"Temporory sites ore those s¡tes obtained by the authority for other purposes but are used os ollotments until such time os thot purpose is required. This usage moy go on for many yedrs before the requirement is needed for alternotive use. These sites do not afford the same protection as stotutory sites but are subject to Planning Policy in PPG 77 ond moy be required for review under thot policy from the Office of the Deputy Prime Minister."

So the allotments on Woodhouse Moor are temporary allotments. They're temporary not just because the Parks Committee said in 1951 that they would be temporary, but because they're not covered by the Allotments Act 1925. Temporary allotments have no statutory protection. Temporary allotment holders can be given notice to quit at any time.

According to the Site Allocations Plan Submission Draft (EB6/3), Woodhouse Moor Park (the main Moor) covers L9.8 hectares and the allotments occupy 2.32 hectares of this. lf the figure of 19.8 hectares was correct, it would mean that the allotments cover I!.7% of the main Moor. As we have already seen though, the main Moor actually occupies 19.07 hectares. This means that the allotments occupy L2.2% of the main Moor.

The Site Allocations Plan Submission Draft gives a population estimate for Hyde Park and Woodhouse of 28,292. There are 99 allotments on Woodhouse Moor. lf each allotment has one user, it would mean that the allotments cater for the equivalent of O.35% of the local population. And so, for the payment of a relatively small sum in rent, the equivalent of 0.35% of the local population (or less), has exclusive use of L2.2% of the most intensively used park in Leeds, or those parts of the t2.2% which aren't derelict. Those using the allotments don't have to be local

16 Northampton Borough Council's Allotment Strategy Draft Consultation April 2004 http://woodhousemooronline.com/wp-conte nt/uploads/2016/05/Northam pton-Allotment-Stratesv.pdf res¡cients. To my knowiecige, one of those who rents an aiiotment, iives in ieaty Otley.

Site HG1-1-1i lies in Chapel Allerton ward. Although the site is a 1.57 hectare recreation ground, the council has designated it as a housing site. And yet, according to page 83 ofAppendix L ofthe Green Space Background Paper Submission Draft (EB6/3), ChapelAllerton has a deficit of 6.L2 hectares in the category "Outdoor Sports." Allocating a green space site for housing is giving it a designation that's different from the site's current use. lf this can be done with site HG1-111, it can be done with the allotments on Woodhouse Moor. 1s) The following paragraph replicates that on page 10 of Mr McKinnon's oral statement and reflect the issues raised on page 7 of Rep No. PDEO2546.

The Leeds Open Space, Sport and Recreation Assessment 20LL OSSRA (EB6/4)was a PPG17 study, and so dldn't double count open space. But the Green Space Background Paper Submission Draft (EB6/3) does. Paragraph 5.7 states, "Corc has been taken to ensure any duol functioning of spaces istaken into account butthat double counting is avoided. For exomple, the ploying pitches locoted in Roundhoy Pork are counted within the wider park ond clossified os "pork and gorden" but ore also included in the area of "outdoor sport" within the Roundhay Word." This is double-speak. lt is effectively saying that there is double counting. And so the 2.32 hectares of the allotments on Woodhouse Moor are classified as both "Allotments" and "Neighbourhood Park." 16) The following paragraphs mainly replicate those on pages 11-14 of Mr McKinnon's oral statement and reflect the issues raised on pages 8-10, 13 of Rep No. PDEO2546.

Paragraph 2.1.0 of the Green Space Background Paper Submission Draft (E86/3) states, "There is scope to chonge typologies where there ore excessive amounts of Iond in one typology to address deficiencies in other typologies however its suitability as a revised typology would need to be corefully ossessed." Although paragraph 2.1-0 states that there is scope to change a site's typology where there's an excess in one typology and deficits in another, this hasn't been done to remedy the more serious deficits in Hyde Park and Woodhouse. So the supposed surplus in "Amenity Green Space" has not been used to remedy the deficit in "Outdoor Sports."

This failure to remedy deficiencies by re-categorisation is difficult to understand given that the Green Space Background Paper Publication Draft (E86/3) and the Green Space Background Paper Submission Draft (E86/1-) categorise sites that were not previously categorised and re-categorise previously categorised sites. iitiíñttci {/ ,, - , þ" .. IF.-

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I ask that you do not divide historic Woodhouse Moor into separate sections. But if you do, please can Cinder Moor (part of Cliff Road Green Space) and the upper half of Monument Moor (part of Woodhouse Lane Green Space) be re-designated from "Amenity Green Space" to "Outdoor Sports." Cinder Moor was levelled to form a cricket pitch in 188417 and was used as such until L953 when the council re- designated the land as a heliport (it was re-designated as Public Open Space in 1973 but not restored as a sports pitch).

ln 1888, the upper part of Monument Moor was laid out as an outdoor gymnasium.ls So it would be appropriate given the dire shortage of "Outdoor Sports" provision in the ward, for it too to be re-designated as "Outdoor Sports."

17 Article from the Leeds Times dated 9th August 1884 http://a660.orslwp-content/uploads/2014l10/LEEDS-Tl M Es.pdf 18 Article from the Leeds Mercury dated 1.t June 1888. http://a660.orslwp-content/u ploads/2014110/Gvm n-facilities.pdf The map above was published about 1892 and shows the layout of the gymnasium. lt had separate sections divided by bushes for girls, boys and men, and younger children. You can see more detail on the Ordnance Survey map from 1889 shown below.

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Site HG1-111 lies in ChapelAllerton ward. Although the site is a 1.57 hectare recreation ground, the council has designated it as a housing site. And yet, according to page 83 of Appendix 1 of the Green Space Background Paper Submission Draft (EB6/3), Chapel Allerton has a deficit of 6.t2 hectares in the category "Outdoor Sports." Allocating a green space site for housing is giving it a designation that's different from the site's current use. lf this can be done with site HG1"-1-1-1-, then the sites on Woodhouse Moor can be re-designated.

The site called "Woodhouse Street Recreation Ground" by the council, contains a children's playground which has been disused since 2009. lf the council designates sites according to their current use, as claimed by the council, then why has Woodhouse Street Recreation Ground been given the designation "Parks and Gardens" given that that children's playground is disused, having had its play equipment removed in 2009.

The Queen's Road Recreation Ground (G392) is designated as "Parks and Gardens." I recommend that it be re-designated as "Outdoor Sports" to help reduce the deficit in "Outdoor Sports." The adjacent area that was occupied by the now demolished Royal Park School is currently uncategor¡zed. This site should also be categorized as "Outdoor Sports." 17l The following paragraphs mainly replicate those on pages 13-14 of Mr McKinnon's oral statement and reflect the issues raised on page 15 of Rep No. PDE02546.

There is an undesignated site comprising fields on Headingley H¡ll. lt lies between and joins the sites G1718 and G1533. Site G17L8 has been designated as "Natural Green Space" in the Green Space Background Paper Submission Draft (EB6/3). Site G1533 has been designated as "Amenity Green Space." The undesignated site which lies between sites G1718 and G1-533 covers 1.94 hectares. I recommend that it be designated as "Natural Green Space" in order to reduce the deficit in this category of green space in Headingley ward. I also recommend that site G1533 be re-categorised as "Natural Green Space" to reflect its function. The three sites comprise the majority of the estate of Thomas England, a corn factor who during the early 19th century built Headingley Castle and lived there for almost thírty years. Headingley Castle is located just to the north west of site G1"71"8.

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UNOESIGNAÎED \a sm J e {1 s I -.o .tl' *,,,,,"o'úa. _a The fields on Headingley Hill are open grassland and trees that used to belong to the monks of Kirkstall Abbey. They lie partly within Headingley Conservation Area and partly within the Headingley Hill, Hyde Park and Woodhouse Moor Conservation Area. The fields are separated from Headingley Lane by a listed stone retaining wall. The trees include lime, horse chestnut, sycamore, holly, ash, cherry, elder and willow. Sparrow hawk, blackbirds, bats, collared doves and hedgehogs have been observed. Two of the fields are used for grazing horses. The fields are remnants of Headingley's original countryside and give a feeling of openness within a densely built residential area. The single track road that crosses the fields adds to their rural character. Although fragments have been found on the site that could be of interest to archaeologists, no field assessment of the site's archaeological potential has ever been carried out. The Headingley Hill, Hyde Park and Woodhouse Moor Conservation Area Appraisal identifíes the fields as "sigrrificarrt Breeil späce." The Green Space Background Paper Submisslon Draft (E86/3) shows that Headingley is deficient in all categories of green space. This means that Headingley cloes not have enourgh green space to meet the green space needs of local people. Failure to designate all of the fields on Headingley Hill as green space would put at risk an almost unspoilt area, full of trees and wildlife, a last reminder of how all of Headingley used to be.

Site HG1-111 lies in Chapel Allerton ward. Although the site is a 1.57 hectare recreation ground, the council has designated it as a housing site. And yet, according to page 83 ofAppendix 1 ofthe Green Space Background Paper Submission Draft (EB6/3), Chapel Allerton has a deficit of 6.L2 hectares in the category "Outdoor Sports." Allocating a green space site for housing is giving it a designation that's different from the site's current use. lf this can be done with site HG1-111, it can be done with the site on Headingley Hill. 18) The following paragraphs replicate those on page 14 of Mr McKinnon's oral statement and reflect the issues raised on page 1 of Rep No. PDE02546.

Paragraph 2.I of the Green Space Background Paper Submission Draft (E86/3) states that the document "Protects over 7600 green spoces thqt ore currently in on open space, recreotional use." But where the Draft is able to establish that there's a surplus in any particular category of green space, the protection claimed at paragraph 2.L becomes worthless as Policy H2 of the adopted Core Strategy (CD2/Ll states, "greenfield land may be developed if it concerns a piece of designated green space found to be surplus to requirements by the Open Spoce, Sport ond Reteation Assessment." (NB. The Open Space, Sport and Recreation Assessment (OSSRA July 20L1) (EB6/4) will effectively be replaced by the Green Space Background Paper Submission Draft (E86/3) once it's been approved).

So, whenever the approved Site Allocations Plan shows a surplus in a particular category of green space, it will be possible to develop a piece of land, even if the piece of land has been designated as green space in the Site Allocations Plan. 1s) the following paragraph repllcates that on page 14 of Mr McKlnnon's oral statement. Rep No. PDE02546 does not include comments on quality assessments.

"Old Farm Close Green Space" (G678) in Kirkstall ward is an open field without any facilities. Appendix L gives it an average quality score of 4.89. Appendix 1- also gives "Woodhouse Street Recreation Ground" (G9L8) an average quality score of 4.23. This is the highest average quality score awarded to any part of Woodhouse Moor. And yet the only facility on Woodhouse Street Recreation Ground is a children's playground which had all its equipment removed in either 2009 or 20L0. How is it that such high scores were given to sites without facilities, when the main area of Woodhouse Moor, called "Woodhouse Moor Park" (G159) by Appendix 1, with its trees, paths, toilets, bowling greens, tennis courts, statues and signage, was given a score of just 3.53? These examples show the extreme inconsistency of the scoring system and that the scoring exercise needs to be repeated, with the work carried out to a higher standard and consistency than previously. 20) The following paragraphs replicate those on page 14 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on this issue.

Part of the Carlton Gate Housing Site (HG1--239) in Hyde Park and Woodhouse was included as "Amenity Green Space" in OSSRA. lt amounted to 0.96 hectares. lt was also included as "Amenity Green Space" in the version of the Draft Site Allocations Plan which preceded the Green Space Background Paper Publication Draft (E86/1) published in 2015, and given the labelG165. With Hyde Park and Woodhouse being so short of green space, it's difficult to see the rationale behind selecting this site for conversion from green space to housing. 2tl The following paragraphs replicate those on pages 14-15 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on this issue.

The Green Space Background Paper Submission Draft (EB6/3) fails to take account of people's differing needs for green space. So Hyde Park and Woodhouse, which has a large number of young residents, is assumed to have the same green space needs as wards containing large numbers of older people. Younger people tend to be more active and to play more sport than older people. Younger people would therefore be expected to prefer a higher green space provision, and especially a higher "Outdoor Sports" provision than older people. To remedy this omission, the Green Space Background Paper Submission Draft (E86/3) should have used green space standards based on people's age, and should have calculated each ward's green space requirements based on the age profile of the ward's inha bitants.

ln addition to this, a more useful Green Space Background Paper Submission Draft could be obtained by actually asking people what type of green space, and how much of it, they require. This has not been done. 221, The following paragraphs replicate those on pages 15-16 of Mr McKinnon's oral statement. Rep No. PDE02546 does not include comments on this issue.

The site is shown on the map below by means of a red letter X. tt

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Until the late 1960s, this area was occupied by two very high quality blocks of shops. The block on the corner facing The Crescent was fronted in "Marmo," a type of white terracotta developed by the Leeds Burmantofts Pottery. The Marmo building is shown in the centre of this postcard.

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The two blocks were demolished to make way for the proposed Headingley Expressway, a project whiclt subsequenl.ly f¿iled Lu leceive guverlunenl. approval. So the shops were demolished for no good reason. Today, planning permission to demolish buildings fronted in Marmo would not be given as the remainíng examples of it in Leeds are so few. The site has remained empty ever since the Marmo building was demolished, meaning that one of the four corners of the e Park Corner Local Sho Centre is miss ln orderto restore H Park Corner's original dense grain, and its shopping provision, please can this undesignated open space site be designated as "Retail." 23]' The following paragraphs replicate those on page 16 of Mr McKinnon's oral statement. Rep No. PDE02546 identifies a number of suggested errors.

On the 8th July 2OL5, a deputation from the 4660 Joint Council gave a speechls to a meeting of all the councillors of Leeds City Council, which listed all the errors relating to Hyde Park and Woodhouse in the version of the Draft Green Space Background Paper2o which preceded the Green Space Background Paper Publication Draft (E86/1).

Some of the errors in the earlier version of the Green Space Background Paper were not reproduced in the Green Space Background Paper Publication Draft lE96/fl,just as some of the errors in the Green Space Background Paper Publication Draft (EB6/1) were not reproduced in the Green Space Background Paper Submission Draft (EB6/3). Other errors in the earlier version of the Green Space Background Paper re-appeared in the two subsequent versions. And each version of the document contained errors unique to it alone.

1e 4660 Deputation Speech to a full meeting of Leeds City Council, dated 8 July 2015 http://a660.o relleeds-citv-cou ncil-u reed-to-reconsider-tro llevbus-scheme/ 20 Previous version of Draft Site Allocations Plan relating to green space in inner wards http://a660.ore/wp-content/uqloads/2014/10/Site-Allocations-lnner. pdf