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Representations to Leeds SAP Remittal – Proposed Modifications to the Remitted Part of the Plan Site HG2-150 – Churwell, Leeds

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Representations to Leeds SAP Remittal – Proposed Modifications to the Remitted Part of the Plan Site HG2-150 – Churwell, Leeds Representations to Leeds SAP Remittal – Proposed Modifications to the Remitted Part of the Plan Site HG2-150 – Churwell, Leeds FEBRUARY 2021 Q100198 Contents 1 Introduction ______________________________________________________________________ 1 2 Background to the Site Allocation, and the Context of Green Belt Release _____________________ 5 3 The Consequence of the Spatial Distribution on Housing Types_____________________________ 10 4 The Consequence of the Spatial Distribution on Affordable Housing _________________________ 13 5 The Consequence of the Spatial Distribution on Infrastructure Delivery _______________________ 15 6 The Specific Consequences for the Outer South West and the Appropriateness of Site HG2-150 ___ 16 Appendices Appendix 1 SHLAA Representations Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 1 Introduction 1.1 Quod act on behalf of Munroe K Development Limited’s, as well as other third parties (Crowther and Brookes). These 3 parties own the land outlined in the Plan 1 below. Plan 1: Site Ownerships 1.2 The site is the subject of a landowner’s agreement which has been drawn up to facilitate the delivery of the White Rose Rail Station (“WRRS”) (see below). HG2-150 1.3 These three parties own a large part of land that was allocated for residential development (Site HG2-150) but has subsequently been reinstated in the Leeds Green Belt. The Site is shown on Plan 2 below. Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 1 Plan 2: Site HG2-150 1.4 The remainder of the former allocation HG2-150 is owned by other parties including Barratts and Persimmon Homes. All parties with land ownership within this former allocation support its development for housing, and in that respect, it is available and deliverable. 1.5 Leeds City Council (LCC) have previously found the site to be suitable for development, and there are no insurmountable barriers in terms of environmental, technical or construction considerations that would prevent its early development. The New White Rose Rail Station 1.6 The Site is in part the subject of a recent planning permission (LCC Ref No 19/07911/FU) for the WRRS, which construction is due to begin shortly, and the railway station will become operational in 2022. The site is already well served by public transport and will be more so once the new station is operational. 1.7 Consequently, the Site is considered to be highly sustainable, suitable and deliverable. 1.8 The area covered by planning consent for the new WRRS is shown on Plan 3 below. Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 2 Plan 3: Area for New WRRS Suitability, Availability and Deliverability of HG2-150 1.9 A more detailed consideration of the Site’s characteristics including its suitability, availability and deliverability, as well as it’s changing characteristics as a consequence of the WRRS are outlined in the attached document submitted to LCC as part of the 2020 SHLAA (Appendix 1). The Need for HG2-150 and Other Sites excluded from the Green Belt 1.10 These Representations go on to demonstrate that the exclusion of HG2-150 and other sites which are proposed to be reinstated in the Green Belt will lead to unsustainable patterns of development within the City, with adverse consequential effects in terms of delivering housing in the locations where it is needed, as well as the type that of new homes required to meet the City’s housing needs, in terms of both housing sector and housing size. Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 3 Sound of the SAP, as Proposed to be Changed. 1.11 These Representations seek the reinstatement of the Site as a housing allocation, and its removal from the Green Belt. Whilst these Representations are concerned solely with the land ownership of the aforementioned three parties, the entire site is appropriate for release from the Green Belt to satisfy LCC’s housing needs. If, however it is considered that only part of the site is appropriate for allocation, that part promoted within the three ownerships outlined is considered appropriate for release. 1.12 These Representations demonstrate that the proposed modifications to the SAP would be unsound on the following grounds: . The proposed changes to the SAP will render the Plan incapable of meeting the housing requirements for designated neighbourhood areas, the Plan will contain a significant imbalance of housing within the inner areas of the City, which will render it incapable of meeting housing needs in terms of different tenures and housing types. There is no evidence that the infrastructure required to satisfy the City’s communities can be delivered in the manner proposed in the SAP, with a significant change to the spatial distribution of housing. The proposed exclusion of site HG2-150 is unsound, given the recent changes to the site’s characteristics and the forthcoming delivery of the new WRRS. 1.13 For the reasons explained further in this report, the SAP would fail the tests of soundness and most notably it would not be positively prepared nor would it be justified as an appropriate strategy, nor consistent with National Policy1. 1.14 This report is structured as follows: 1.14.1 Section 2 considers the exceptional circumstances for Green Belt release, including the need for an appropriate distribution of housing delivery across the City. 1.14.2 Section 3 considers the resultant spatial distribution of housing in the City, compared to that set out in the Core Strategy. 1.14.3 Because of the spatial distribution, that would result from the proposed changes to the SAP, Section 4 considers the implications for housing types. 1.14.4 Section 5 considers the consequences of this spatial distribution on affordable housing. 1.14.5 The report goes on to consider the consequence of spatial distribution on infrastructure in Section 6. 1.14.6 Finally, Section 7 considers the implications of the proposed changes notably in respect of the Outer South West (OSW) housing market character area (HMCA) and the appropriateness of site allocation HG2-150 for allocation. 1 The tests of soundness are set out in paragraph 35 of the NPPF. Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 4 2 Background to the Site Allocation, and the Context of Green Belt Release Leeds Green Belt – Exceptional Circumstances 2.1 The strategic spatial policies of the adopted development plan (the Core Strategy including Selective Review, 2019 – “CSSR”) recognise that in order to meet Leeds’ housing (as well as employment) requirements, some land will need to be taken out of the Green Belt and allocated for these development needs2. 2.2 It is, therefore, the case that “exceptional circumstances” have been proven to exist to justify changes to Green Belt boundaries3. 2.3 Spatial policy SP10: Green Belt of the CSSR clearly states that a review of the Green Belt will need to be carried out to accommodate the scale of housing growth. 2.4 Policy SP10 specifically notes that a review of the Green Belt is necessary in order to satisfy the scale of housing growth required by Policy SP6. SP6 sets the City-wide housing requirement. Policy SP6 recognises that housing requirement will need to be spatially distributed, having regard to a range of principles (Criterion i-vii of SP6) to support the distribution that is set out in Policy SP7. 2.5 SP7 is underpinned by LCC’s Strategy Housing Market Assessment (SHMA)4. 2.6 The SHMA recognises that there are a number of different housing market characteristic areas (HMCA) which have different housing characteristics and needs and demonstrate different functional sub-markets. 2.7 In order to sustainably meet the housing needs of the City, it is necessary to deliver both the overall scale of housing required to meet the City’s needs and in a spatial distribution that reflects the SHMA. The SHMA also demonstrates that there are differing needs for affordable housing, as well as for a range of types and sizes of market dwellings in different parts of Leeds. 2.8 It is therefore necessary to meet both the numerical need for new housing as well as the type of housing, but in the overall context of an appropriate spatial distribution. 2.9 The purpose of Policy SP7 is to interpret those different spatial needs and set an appropriate distribution of housing land and allocations throughout the City. 2 Paragraph 4.8.5 of the CRRS. 3 Paragraph 137 of the NPPF. 4 Strategic Housing Market Assessment, 2017 (arc4). Quod | Site HG2-150 – Churwell, Leeds | Representations to Leeds SAP | February 2021 5 2.10 Policy SP7 guides the distribution of new housing and does not set rigid targets, it is nevertheless important that the spatial distribution largely accords with that contained in SP7, otherwise there is a risk that the spatial delivery of new housing will be unsustainable in a number of respects, including: 2.10.1 Housing will not be delivered in areas where it is needed. 2.10.2 New homes may be delivered that do not satisfy affordable housing targets. 2.10.3 The type and sizes of new homes may not meet the City’s housing needs. 2.10.4 The spatial approach to other development needs may be out of kilter with other housing delivery. 2.11 It is recognised in the NPPF that when reviewing Green Belt boundaries “…the need to promote sustainable patterns of development should be taken into account…”5. 2.12 It is, therefore not a sustainable planning strategy to simply meet housing needs without regard to a spatial distribution that reflects those needs.
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