Revised Submission Site Allocations Plan

Our ref 50765/JG/AJk Exam ref M7/69/02 Date June 2018

Subject Matter 7A Hearing Statement on behalf of Persimmon Homes West – Selection of sites allocated for development

1.0 Introduction 1.1 This Hearing Statement has been prepared by Lichfields on behalf of Persimmon Homes (PHWY) and responds to the questions set by the Inspector in relation to Matter 7A.

1.2 Our responses to the questions are set out in the context of the promotion of the following sites within PHWY’s control (either in whole or in part). These sites are listed in Table 1 below.

Table 1 PHWY Sites

Proposed Allocations HMCA Area Site Ref. Site Description

Outer North West MX1-26 East of Otley, Off Pool Road

East Leeds HG1-288 East Leeds Extension

Outer North East1.3 HG2-226 Land to the east of Wetherby

1.4 HG1-288 East Leeds Extension

Outer South East HG3-18 Land south of Selby Road, Garforth

Outer South West HG2-150 1.5 Churwell (land to the east of) LS27

1.6 HG2-149 Lane Side Farm, PAS Morley

1.7 HG2-153 1.8 Albert Drive, Morley

1.9 HG1-514 1.10 Albert Drive – Low Moor Farm, Morley

HG1-351 1.11 Owlers Farm PAS, Wide Lane, Morley

Broad Locations

Outer South BL1-31 Haighside, Rothwell

Unallocated Sites

Outer North East 5277 1.12 Kings Meadow View, Wetherby 2156, 1226, 3114, 1165 Barwick Road, Garforth Outer South East

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3085 Cemetery Lane, Lofthouse Outer South 2162, 1104 Warm Lane/Greenside Farm, Yeadon Outer West

2.0 Issue - For each Housing Market Characteristic Area, are the individual sites selected sound?

Outer North East

Questions in reference to Parlington (MX2-39 and BL1-42)

Q3 - Would the site allocation constitute a strategic site as envisaged in CS Policy SP10?

2.1 There is no reference to ‘strategic sites’ within the wording of Core Strategy Policy SP10. However, it is noted that Policy SP10 identifies that, exceptionally, sites unrelated to the Main Urban Area, Major Settlements and Smaller Settlements could be considered within the Green Belt, but only:

‘…where they will be in sustainable locations and are able to provide a full range of local facilities and services and within the context of their Housing Market Characteristic Area, are more appropriate in meeting the spatial objectives of the plan than the alternatives within the Settlement Hierarchy’

2.2 Parlington is not a sustainable location and, as referred to in our response to Question 4 below, we do not consider that the revised allocation is capable of providing the full range of services and facilities listed in the allocation’s site requirements. The site is in an isolated location within the Green Belt which will be car dependant in terms of its connectivity and it is considered that the allocation misapplies Policy SP10 and conflicts with paragraph 152 of the NPPF.

2.3 Further detail in respect of site MX2-39 can be found in the accompanying Matter 7A Statement submitted by Carter Jonas on behalf of PHWY.

Q4 - Will a development of the scale envisaged (MX2-39), including services and facilities and necessary infrastructure remain deliverable and viable in the absence of the Broad Location coming forward?

New community infrastructure necessary to service new isolated settlements requires a sufficient critical mass in terms of number of dwellings and population in order for it to be sustained in the long term. We would question whether the revised capacity of the Parlington site at 792 units can viably support the services and facilities listed in the site requirements, namely:

• a school;

• a new centre offering a range of supporting retail and commercial uses/ services;

• new community greenspaces; and,

• enhanced public transport and footpath and cycle links 2.4 PHWY is not aware of any additional evidence being submitted or prepared to demonstrate that the revised MX2-39 allocation will remain deliverable and viable should the Broad Location (BL1-42) not come forward. It is therefore considered that the deliverability and viability of

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MX2-39 has not been assessed in any detail. As a result, it is considered that the site cannot be reasonably considered deliverable in accordance with paragraph 47 of the NPPF.

2.5 Further detail in respect of site MX2-39 can be found in the accompanying Matter 7A Statement submitted by Carter Jonas on behalf of PHWY.

Q5 - Is the continued allocation of MX2-39 (Parlington) justified given the recent Historic Park and Garden (Grade II) registration of the wider Parlington Estate? What further assessments have been carried out to assess the likelihood that an appropriate development of the capacity expected and including local services and facilities could be achieved that would not harm the setting of the heritage asset?

2.6 PHWY is not aware of any detailed heritage assessment having been carried out in relation to the recent Historic Park and Garden registration of the wider Parlington Estate. We therefore consider that no justification has been provided to show that an appropriate development can be achieved of the scale proposed without harm to the heritage asset.

2.7 Further detail in respect of site MX2-39 can be found in the accompanying Matter 7A Statement submitted by Carter Jonas on behalf of PHWY.

Outer North West

2.8 PHWY is bringing forward allocation Mx1-26 on land at East Otley for 550 dwellings, 5Ha of employment land and a new East Otley Relief Road. This allocation is being brought forward in partnership with who is a landowner within the allocation.

2.9 The objection of PHWY to the extent of the allocation is fully set out in the Statement submitted to the SAP Examination in respect of Matters 3 and 5 in August 2017. This sets out the requirement for the boundary of the allocation to be revised to align a permanent and defensible Green Belt Boundary with the updated and engineered route of the East Otley Relief Road, and to include the land comprising the former Ings Landfill Site within the allocation in the interests of good planning.

2.10 Since the submission of the Hearing Statement to the SAP Examination in August 2017, there has been further progress towards the delivery of the MX1-26 East Otley allocation. Regular Steering Group meetings are now taking place with landowners, their representatives and the City Council to co-ordinate necessary technical and planning-related work to support an application for planning permission. Significantly, a bid for Housing Infrastructure Funding for the East Otley Relief Road was submitted by Leeds City Council with the assistance of PHWY and £6.3m was successfully secured in the first round of these funding streams to progress housing delivery nationwide.

Outer South

Q1 - BL1-32 (formerly HG2-181) and BL1-33 (formerly HG2-184). Is the identification of these sites as Broad Locations justified and consistent with the approach taken elsewhere?

2.11 Notwithstanding our concerns regarding the principle of the Broad Locations approach as set out in our Matter 2A Hearing Statement, we would question whether sites of less than 2 hectares can reasonably be defined as ‘broad locations’ for growth.

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2.12 On a wider point, we would like to highlight the over-reliance on Broad Locations within the Outer South HMCA as shown in Table 2 below.

Table 2 Proportion of supply identified as Broad Locations

HMCA Proportion of housing supply identified as Broad Locations Aireborough 25% City Centre 0% East Leeds 0% Inner Area 0% North Leeds 14% Outer North East 22% Outer North West 4% Outer South 36% Outer South East 32% Outer South West 19% Outer West 8%

Source: Lichfields analysis

2.13 As shown in the above table, the Outer South has the largest reliance on Broad Locations in the whole of the Plan area, with 36% of the total ‘supply’ identified in the SAP remaining within the Green Belt as unallocated land. Furthermore, the total housing supply identified in the Outer South, including the Broad Locations, is 166 units below the Core Strategy target of 2,600. This means that the SAP is only allocating land to meet 60% of the Core Strategy housing target for the Outer South.

2.14 PHWY considers that this approach is unsound and could lead to a housing land distribution which is significantly different to that set out in the Core Strategy. It is therefore recommended that BL1-31, which has a capacity of 578 units, be reverted to a housing allocation to address this imbalance. As stated elsewhere within our accompanying Hearing Statements, the site at Haighside, Rothwell is a sustainably located site which has been found in the Council’s own assessment to be preferable to other Green Belt releases in the Outer South. It is relatively free of technical constraints, and development at the site could commence within the early part of the plan period now that the Park and Ride site at Temple Green is operational.

Q2 - Whether the removal of site HG5-7 is justified in respect of the provision of school places in the HMCA

2.15 It is PHWY’s position that additional sites should be allocated in the Outer South through the reintroduction of Broad Locations as housing allocations in the SAP. If this change were to be made, it may be necessary to review the demand for school places and re-allocate site HG5-7.

Outer South East

Q1 - 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)?

2.16 It is considered that the splitting of site HG2-124 into a smaller allocation and adjacent Broad Location designation is unjustified.

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2.17 Notwithstanding our previous comments on the likely lead-in times and delivery rates at this site and the uncertainty regarding the delivery of a southern bypass road for Garforth, the proposed Broad Location designation raises serious Green Belt boundary issues. The previous sites boundaries for HG2/124 were defined by the built edge of Garforth to the west, Selby Road to the south, the A656 to the east and the railway line to the north. Now, it is proposed that the eastern boundary of the site will lie within the middle of an agricultural field, following no existing feature on the ground. The eastern boundary of the site will therefore be very weak and susceptible to development pressure. Indeed, the pressure to develop the adjacent land is established by the proposed Broad Location designation, but if a Plan review subsequently finds that the Broad Location is not needed, the Green Belt boundary which is left will be weak and not compliant with NPPF paragraph 85.

2.18 Core Document CR1/4b claims that there are no other brownfield or non-Green Belt options within the Outer South East HMCA which can deliver at a scale to provide the housing numbers required to meet the SAP trajectory to 2022/23. However, this view completely overlooks site HG3-18 at Selby Road, Garforth which was removed from the Green Belt upon adoption of the UDP and has been designated as a Protected Area of Search (i.e. Safeguarded Land) since that time.

2.19 Site HG3-18 has a capacity of around 300 units, and it is considered that there are other more sustainably located sites which could help accommodate the shortfall arising from HG2-124 along with HG3-18 should HG2-124 not be allocated. This includes PHWY’s site at Barwick Road in Garforth which has an estimated capacity of 900 units, and is located just 5 minutes walk from Garforth Town Centre. Defensible Green Belt boundaries for this site would be provided by the M1 and, following its implementation, HS2.

2.20 We would also question whether the reduced capacity of site HG2-124 could viably support a new school, local centre, new community park and southern bypass of Garforth, all of which are stated as being necessary, amongst other requirements.

2.21 With regards to the undertaking of a revised sustainability appraisal for the site, this approach is correct and supported. However, any findings from the sustainability appraisal need to be weighed in the balance of the release of the site from the Green Belt in the context of there being non-Green Belt options available in the HMCA. It is also noted from the updated sustainability appraisal that the site score negatively on accessibility, air quality, land instability, and agricultural land quality (site has high ALC grade).

Q5 - Whether the site requirements for transport at HG2-124 are justified, and will this result in the policy being effective?

2.22 Whilst the site requirements for transport are considered to be justified in the sense that they will be necessary to mitigate the impact of the development of the site, we have reservations regarding their delivery and the impact this will have on the number of homes which can be provided within the plan period.

2.23 Our accompanying Matter 7 statement on behalf of PHWY sets out how no evidence has been provided to demonstrate that the Garforth bypass or M1 junction improvements, which are deemed by the Council as necessary to deal with the likely significant network capacity issues, are viable or deliverable.

2.24 It is known that a potential route for the bypass contains multiple land ownerships, and no evidence has been provided to demonstrate that any form of land assembly has been

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undertaken. Furthermore, this bypass would likely need to cross over a watercourse and a former railway cutting which, coupled with the cost of the necessary roundabouts and general engineering works over this undulating terrain, will lead to a very high capital cost.

2.25 The time implications of designing and implementing the bypass raises doubt as to the ability of the site to deliver 1,090 homes within the plan period and additional sites such as HG3-18 and PHWY’s Barwick Road site should be allocated in the SAP to ensure housing needs in the Outer South East are met.

Outer South West

Q4 - 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?

2.26 Site HG2-150 (land to the east of Churwell) requires improvements to the A643 Elland Road to provide a frontage footway and pedestrian crossing, along with a suitable vehicular access. The site requirements within the SAP also state that a contribution may be required towards an improvement scheme at the A643 / A6110 junction, as well as potentially the A6110/M621 Junction 1 (to be agreed with Highways ).

2.27 The highways improvements listed for Elland Road and the potential off-site contributions, are not considered to be out of the ordinary and are typical of off-site highway improvements secured at the planning application stage for major, and in some cases relatively minor, residential schemes. Indeed, as this infrastructure can only be secured through developer funded interventions, it would not have been appropriate to hold the site back in Phase 2 due to transport infrastructure concerns, and the inclusion of the site in Phase 1 is therefore justified.

Outer West

Q2 - HG2-80 - the description in the Revised Submission Draft Background Papers (CDR1/4a and 4b) indicates that the site refers to lack of defensible boundary. Will the site be effective in maintaining the permanence of the GB boundary?

2.28 PHWY concurs with the findings of the Council’s Green Belt Assessment for site HG2-80. It is also noted that the site occupies an elevated position which is readily visible from receptors from the east along Troydale Lane. Development of the site will therefore not only create a weak Green Belt boundary to the east leading to potential sprawl, but could also have a significant visual impact on the appearance and sense of openness of the adjacent Green Belt land.

2.29 It is considered that the site at Warm Lane, Yeadon (SHLAA refs: 2162 and 1104) represents a more appropriate location for residential development in preference to HG2-80. PHWY, which has an option agreement on the site, has previously submitted a suite of technical work to the Council in relation to this site as part of previous rounds of consultation on the SAP. This technical work includes a transport assessment, ecology report, masterplan, landscape appraisal, green belt review and flood risk assessment.

2.30 It is estimated that the site at Warm Lane, which is within the Green Belt but around one third of which comprises brownfield land, can accommodate around 130 units. The site is located within close proximity to key services such as shopping facilities, education, healthcare, recreation facilities and public transport. In terms of Green Belt release, the site is bound to the

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north, west and east by existing residential development and built form, with Warm Lane providing a defensible Green Belt boundary to the south.

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