LEEDS SITE ALLOCATIONS PLAN MATTER 2 – COMPLIANCE WITH CORE STRATEGY KCS DEVELOPMENT Peacock & Smith Limited Suite 9C Joseph’s Well Hanover Walk Leeds LS3 1AB T: 0113 2431919 F: 0113 2422198 E: [email protected] AUGUST 2017 www.peacockandsmith.co.uk Leeds SAP Examination (Matter 2) Peacock & Smith Ltd 1. INTRODUCTION AND BACKGROUND 1.01 These comments are submitted on behalf of KCS Development, a residential site promotion company seeking the allocation land of south of Harewood Road, Collingham (Site 1293) in the Leeds Site Allocations DPD (SAP) for 85 no. homes with extensive open space and buffer landscaping. 1.02 KCS Development is a Member of a consortium of housebuilders (the Collingham Consortium) and site promoters that is proposing a comprehensive masterplan for future housing development in Collingham. The KCS site comprises one of 4 allocations that are proposed in the settlement that together will deliver: 450 new homes, thus reflecting Collingham’s role as one of the larger settlements in the Outer North East Housing Market Characteristic Area (HMCA), with a good range of shops and services and public transport services; A site for a new primary school, thus providing the opportunity for education facilities within Collingham to be substantially improved, to the benefit of existing and future residents; and A new access route between Harewood Road and the A58 Leeds Road, which would help to reduce traffic through Collingham Local Centre. 1.03 KCS Development is also a member of a consortium of housebuilders and site promoters (the ONE Consortium) that is proposing an alternative strategy to meeting housing needs in the ONE HMCA than that proposed by the Council. This alternative approach seeks to meet housing needs according to the settlement hierarchy set out in the Core Strategy rather than directing substantial development to a new settlement at Parlington and Wealstun Prison, which is considered unsound. 4585 KCS Development Page 1 August 2017 Leeds SAP Examination (Matter 2) Peacock & Smith Ltd 2. MATTER 2 – COMPLIANCE WITH CORE STRATEGY Question 1 - Will the plan deliver the type and amount of development (housing and employment) anticipated in the CS? 2.01 KCS Development is concerned that as drafted there is a significant risk that the SAP will not deliver the overall housing requirement, or the type of housing development anticipated by the CS. 2.02 In respect of the amount of development, our client’s chief concerns are as follows: The inclusion of significant numbers of unimplemented UDP allocations (some 10,901 dwellings across the City) that have been carried over into the SAP without thorough assessment. Given that the UDP was allocated in 2006 such sites are more likely to face delivery and developability issues. The inclusion of significant numbers of sites with expired planning permissions without thorough assessment. Land with planning permission is valuable, and if a landowner/promoter allows a permission to lapse this is an indication that they may be constraints on the availability or viability of the land for housing. Reliance on significant numbers of small sites across the City without permissions that should be treated as windfalls. Reliance on the delivery of 1,850 dwellings from the Parlington site (MX2-39) in the ONE area. The promoter of this site assumes occupation of the first dwelling in 2022 (which is considered to be over optimistic – please see further comments on Parlington in our client’s Matter 7 statement), which requires 308 dwellings/annum to be delivered by the end of the plan period, an unprecedented rate of delivery in an untested housing market location. Over allocation of housing in HMCAs (i.e. Inner and City and Centre HMCAs) where the housing market is more fragile, and a significant proportion of the allocations are brownfield sites that may have viability issues. The Core Strategy identifies four housing zones in Leeds under Policy H5: Affordable Housing, which 4585 KCS Development Page 2 August 2017 Leeds SAP Examination (Matter 2) Peacock & Smith Ltd reflects the various housing characteristics of Leeds. In the City Centre and Inner Leeds HMCAs the affordable housing target is only 5%. Allocating significant numbers of sites in these two HMCAs will not deliver the identified need of affordable housing that the City requires (1,158 dwellings per annum), even where it is viable to do so. The reality is that on many sites it will not be viable to provide even this small percentage of affordable housing required by Policy H5. Lack of flexibility in the overall number of dwellings proposed for allocation. Total housing provision in all HMCAs is 67,817 homes, which is only 2.8% above the Core Strategy requirement. In our view there is a need for a greater margin of flexibility in the event that our concerns about the above housing sources transpire to be correct. 2.03 Regarding the type of housing development proposed, we are concerned that in the ONE HMCA some 53% of new housing proposed is to be provided in the Parlington new settlement (MX2-39), and an additional 4% at land to the North of Wealstun Prison (HG2-227). Neither of these locations accord with the objective of Policy SP1 of the Core Strategy to locate the largest amount of development in the Main Urban Area, Major Settlements and then Smaller Settlements. We comment on these 2 sites further in our client’s associated statement in respect of Matter 7. Question 3 - Are the assumed build out rates contained in the SHLAA realistic and robust? 2.04 The build out rates do not appear to be based on any form of evidence, and we consider that the 50 units/annum assumed for sites of less than 200 dwellings is too high. We note that the Home Builders Federation wrote to the Council on 1 March 2016 (referenced in current HBF submissions attached at Appendix 1) setting out concerns about this rate and advising that a rate of 35 units/annum was more equivalent to what housebuilders are actually achieving. We are concerned that this advice does not appear to have been heeded, despite Planning Practice Guidance stating that the advice of developers and local agents will be important in assessing lead-in times and build-out rates by year (Paragraph: 023 Reference ID: 3-023-20140306). 4585 KCS Development Page 3 August 2017 Leeds SAP Examination (Matter 2) Peacock & Smith Ltd Question 4 – The capacity of a number of housing sites has been reduced between publication draft stage and pre-submission stage. What, if any, are the implications of this? 2.05 Whilst the plan period capacity of the proposed new settlement at Parkington (MX2-39) has not changed, the submitted version of the plan makes it clear that any second phase of development can only take place after a development plan review. This casts uncertainty on the likelihood of that second phase and undermines the ability of the promoters of the site to attract essential supporting retail and commercial uses – since there is doubt whether the critical mass of development will ultimately be achieved to make such uses viable in the long term. 2.06 Without essential supporting retail and commercial uses there is no prospect that the Parlington settlement will ever be a sustainable community. Question 6 - Identified sites include sites where planning permission has expired. Is the inclusion of these sites in the overall supply of housing and employment land justified? 2.07 Where planning permission has lapsed we consider that this should be a warning sign that there may be issues with the site in terms of availability or viability or some other constraint. As stated in our client’s response in respect of Question 1, land with planning permission is a valuable commodity. 2.08 The Council’s responses to the 7 August 2017 Further Questions to the Council indicate that almost 2,900 houses are assumed to be delivered from sites with expired planning permissions, which represents a significant proportion of the overall number of houses proposed for allocation. Whilst the Council attempts to give reasons why such sites are developable there is no robust evidence provided in many instances. There are a large number of sites where the Council has written to the landowner seeking information about developability, but no response has been provided. A standard response is then given by the Council: “No response has been received but on the strength of an improving market there then there are no identified land ownership (i.e. ransom strips or multiple landowners) or achievability impediments to the site being delivered subject to a suitable scheme being brought forward.” 4585 KCS Development Page 4 August 2017 Leeds SAP Examination (Matter 2) Peacock & Smith Ltd 2.09 In our view the above statement does not provide sufficient convincing evidence that these particular sites are available or viable for housing, and therefore there is significant doubt as to whether they remain deliverable or developable housing locations. Furthermore, all HG1 sites should be subject to sustainability appraisal and thorough site assessment like all of the other SHLAA sources considered under HG2. Question 7A - Is it reasonable to include small scale housing sites (less than 10 dwellings) such as HG1-278 (capacity two dwellings), and HG1-286 (4 dwellings), where planning permission has expired as identified sites? 2.10 No, there are a large number of such sites across the City and fresh planning applications will need to be submitted for them. Such sites would ordinarily be treated as windfalls, for which an allowance is already made in the Core Strategy over the plan period (some 500 dwellings/annum).