BARWICK in ELMET & SCHOLES PARISH COUNCIL Response to Leeds City Council’s position statement of 8th September 2017 Clerk to the Parish Council : Mr. K Langley 33 Flats Lane, Barwick in Elmet, Leeds LS15 4LJ phone 0113 393 5861 : email – [email protected] Below are the comments of Barwick In Elmet and Scholes Parish Council (“BIESPC”) on the answers provided by Leeds City Council (“LCC”) – LCC’s position statement on the SAP Examination and Selective Core Strategy Review, dated 8th September 2017 This document follows the structure of LCC’s position statement, and comments under the headings in the statement. LCC’s replies are in black ink. BIESPC’s comments are in blue ink Question a What is the effect of the selective review of the CS on the soundness of the SAP? a.1 The effect of the Core Strategy Review (CSR) on the soundness of the SAP is considered to be minor and broadly contextual, not least because the scope of both Development Plan Documents (DPD) is substantially different; 1. LCC’s reply to this question seems merely rhetorical and lacking in detail and substantiating evidence. This answer is inconsistent with LCC’s adopted Core Strategy. Core Strategy 1.4 states “The CS is the main document setting out the overall vision and strategic level policies… All other LDF documents will be guided by its policies including the Site Allocations Plan …”. Therefore the scope of the documents cannot be ‘substantially different’ and LCC is ignoring its own policies to suit its own ends; 2. To help overcome this weakness in LCC’s response, we would request that the Inspector also asks the following question: “What is the effect of the selective review of the CS, in comparison with the effect of a comprehensive review, on the soundness of the SAP?”; 3. Notwithstanding any review (selective or otherwise), BIESPC’s main concerns remain: a. Housing numbers, and; b. Protection of the Green Belt. These concerns are, of course, intrinsically linked. Fewer houses needed in Leeds would mean fewer sites in the Green Belt need to be allocated. BIESPC therefore refutes that the effect of the CSR on the soundness of the SAP would be minor. a.2 The Leeds Site Allocations Plan (SAP) is a DPD which has been foreshadowed in the Leeds Adopted Core Strategy (CS). The scope of the SAP is clearly set out in paragraph 1.6 of CD1/1 to: “provide site allocations and requirements that help deliver the Core Strategy policies, ensuring that sufficient land is available in appropriate locations to meet the targets set out in the Core Strategy and achieve the Council’s ambitions”. 4. BIESPC recognises the above statement to be true. However this statement again demonstrates that the CS and the SAP are interconnected and interdependent documents and therefore any review or amendment of one must impact upon the other. BIESPC also recognises that if the adopted Core Strategy housing numbers (target) changes, the scope of the SAP is bound to change. The fewer houses in the target, less land (particularly Green Belt) is required in the SAP to achieve LCC’s ambitions; 5. LCC’s original housing numbers are no longer valid. On 13th July 2017 the press release, ‘Update on the initial conclusions of the Leeds Strategic Housing Market Assessment (SHMA)’, was published on LCC’s website. LCC stated that, as part of the SHMA, it had undertaken new technical work and consulted residents through a survey of their housing aspirations. In developing this approach, a SHMA Reference Group had been established and consulted, consisting of representatives from community groups, older people and student groups, affordable housing providers and house builders from across Leeds; 6. Following the latest meeting of this group, LCC executive member for regeneration, transport and planning Councillor Richard Lewis said in the press release, “The housing figure set out in the Core Strategy was based on evidence at the time and it is important to remember it was endorsed by an independent government inspector following a thorough examination. We committed to a review within three years and the latest information and population evidence points to lower and slower growth than was originally forecast.” This statement from Richard Lewis categorically supports a reduction in numbers of houses; 7. Richard Lewis continued "So it is likely this review will recommend the overall figure for housing need should be reduced to reflect what we know now; Once the findings of the SHMA are finalised, the council will need to consider a revised housing requirement as part of the Core Strategy review, the implications for site delivery and phasing for development.” 8. In addition to Councillor Richard Lewis's statements in the press release, the Chair of the Strategic Housing Market Assessment (SHMA) Reference Group, Councillor Peter Gruen, said “I welcome the opportunity to take soundings from the SHMA Reference Group on the initial conclusions of the technical work, which indicates that a revised housing need for Leeds may be in the region of 55,000 homes up to 2033 (the revised plan period of the Core Strategy review). There is more work to do in finalising the SHMA and the council will need to fully consider its findings. Any revised housing figure would then be subject to wider public consultation by the end of the year.” 9. With this knowledge LCC has ignored new information and continues along the SAP process, even though the entire landscape has changed. It is not feasible, given there is a high likelihood that the housing numbers for Leeds will be reduced, that the SAP as it stands could provide site allocations and requirements that help deliver the Core Strategy policies. The SAP cannot ensure that sufficient land is available when LCC doesn’t know how much land that should be nor can it know what the appropriate locations would be to meet the targets set out in the Core Strategy. In fact it seems all together likely that the effect of the CSR would be that Green Belt will be released prematurely and unnecessarily and therefore make the SAP unsound. a.3 The City Council’s approach to the preparation of a sound SAP involves following the spatial strategy and housing requirement of the adopted, statutory plan (i.e. the Adopted CS). The SAP has been in preparation since 2013, with extensive rounds of consultation being undertaken at each regulatory stage. The Council’s Executive Board has endorsed progression of the SAP to submission stage in February 2017, with a view to maintaining procedural momentum and its progress, and ultimately to have put in place, a development plan for the City Council that substantially delivers upon Government ambitions for plans to be in place by 2017. 10. BIESPC maintains that LCC’s response is based on rhetorical text – not answering the question but merely providing a description of the process adopted in developing the SAP. BIESPC believes that the Inspector is already aware of the process; 11. LCC’s Policy, for example, has been to only carry out a Selective Review of its Green Belt based on sites proposed for the SAP. This is even though LCC has been specifically instructed to revise this Policy and carry out a Non-selective (or Comprehensive) Review by the Planning Inspector of the 2014 Core Strategy*. *”The Council acknowledge that the growth planned in the Core Strategy cannot be accommodated without a review of Green Belt boundaries but, as submitted, the Core Strategy only commits the Council to a selective review. This may lead to pressure to release land in the review area when, having regard to the advice in paragraph 85 of the NPPF, there is more suitable land elsewhere. A comprehensive review is also more likely to ensure consistency with the spatial strategy and increase the likelihood that boundaries will not need to be reviewed again at the end of the plan period. Consequently, MM1, MM13 and MM14 remove references to a selective review. The Council intend that Green Belt boundaries will be reviewed through the Site Allocations Plan which is due to be submitted for examination in 2015.” 12. LCC is proposing to fulfil a significant proportion of its out-of-date and over-stated housing requirement with Green Belt and Green-field sites without properly assessing all its Green Belt. The Selective Green Belt Review of SP10 lacks objectivity and does not give local communities any confidence that the site-selective Green Belt Assessment has any meaningful influence over whether or not a site is nominated for house building. 13. LCC should undertake a comprehensive and objective review of the Green Belt such as was conducted by Kirklees Council. This assessed all Green Belt boundaries with regard to local contexts and characteristics and assessed the effects of development in terms of the NPPF five purposes of Green Belt land. (Kirklees Local Plan Submission Documents SD19 Green Belt Review, SD21 Green Belt Boundary Changes – April 2017). It is also interesting to note with regard to housing numbers that using the new government methodology Kirklees housing target varies by only 1%. a.6 The scope of the CSR was agreed by Executive Board in February 2017 to include inter alia: • updating the housing requirement in Policy SP6, considering and making any necessary consequent revisions to other parts of the Plan considering any implications for the spatial strategy; • extending the plan period from 2012 - 2028 to 2017 – 2033; 1 ID:12-008-20140306; • updates to greenspace provision policies; • incorporation of national housing standards. 14. The submission draft of the SAP is based on the adopted CS housing requirement figure of 70,000 homes for the SAP period and proposes allocating 12,481 dwellings across 73 current Green Belt sites (thus moving these sites out of the Green Belt) to help meet that requirement.