Revised Submission Leeds Site Allocations Plan
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Revised Submission Leeds 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 Yorkshire – Selection of sites allocated for development 1.0 Introduction 1.1 This Hearing Statement has been prepared by Lichfields on behalf of Persimmon Homes West Yorkshire (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 Pg 1/7 Lichfields.uk 16062351v1 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 Pg 2/7 Lichfields.uk 16062351v1 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 Leeds City Council 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. Pg 3/7 Lichfields.uk 16062351v1 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.