Representations to Leeds Site Allocations Plan Document Examination Turley (Representor Id: Pdp09291) on Behalf of Gallagher Estates (Representor Id: Pdp09290)
Total Page：16
File Type：pdf, Size：1020Kb
REPRESENTATIONS TO LEEDS SITE ALLOCATIONS PLAN DOCUMENT EXAMINATION TURLEY (REPRESENTOR ID: PDP09291) ON BEHALF OF GALLAGHER ESTATES (REPRESENTOR ID: PDP09290) Matter 3 – Green Belt This Statement sets out Gallagher Estates’ response to the questions and issues raised and, where appropriate, explains why the plan is not considered to be sound as presented. A series of amendments to address deficiencies with respect to soundness are suggested within Gallagher Estates’ representations to the Leeds Site Allocations Plan document. The representation document (Vision Framework) is provided at Appendix A of the Matter 7 Statement prepared on behalf of Gallagher Estates (Ref: PDE02754). By way of pre-amble, it is clear that the Core Strategy has demonstrated that there are exceptional circumstances that warrant the release of Green Belt in Leeds to meet future development requirements. Notwithstanding Green Belt policy, development on the edge of major settlements often represents the most sustainable option; and is a factor that needs to be weighed in the balance of assessing potential sites (see also representations under Matter 6) 1. Core Strategy consistency: Are proposed revised boundaries of the Green Belt consistent with the intentions of the CS? 1.1 The Leeds Green Belt was first designated by a variety of development plans produced from 1960 onwards; the Green Belt was finally consolidated and precise boundaries identified in the Leeds UDP (2001). Parts of the Green Belt have remained unchanged since the mid-1960s when boundaries were tightly drawn around existing settlements. 1.2 The Core Strategy [CD2.1] recognises the constraints posed by the tightly drawn Green Belt boundary and the impact this has on achieving the quantum of development required in Spatial Policy 6 (SP6) and the distribution of development identified in Spatial Policy 7 (SP7) of the plan. Paragraph 4.6.15 of the Core Strategy states: “…. to meet the longer term housing requirement urban extensions are needed including greenfield and Green Belt land. Spatial Policy 1 and 10 sets out the overall approach to the future release of such land and the need for this to be achieved through a Green Belt review (to be progressed via the Site Allocations Plan). The emphasis of this approach is to achieve opportunities for housing growth in sustainable locations, linked to the Settlement Hierarchy, whilst respecting local character and distinctiveness”. 1.3 Spatial Policy 10 (SP10) confirms that a review of the Green Belt is required to accommodate the scale of housing and employment growth identified in the plan and that it will be focussed on land around: • The main urban area • Major Settlements (Garforth, Guiseley/Yeadon/Rawdon, Morley, Otley, Rothwell and Wetherby); and • Smaller Settlements as specifically identified in Appendix 1 of the plan 1 1.4 SP10 goes on to state that while, exceptionally, sites unrelated to those locations could be considered where they are in sustainable locations and appropriate to meeting the spatial objectives of the plan; there is no intention to undertake a [general] review of the Green Belt in order to ensure that its general extent is maintained. Finally, individual sites considered for allocation will be assessed against the purposes of including land in Green Belt as set out in NPPF. 1.5 The subsequent Green Belt Review Background Paper [CD1-31] confirms that the Council’s approach to identifying and assessing sites for allocation in the SAP accords with the specific criteria set out in Core Strategy Policy SP10 with the aim of meeting both the quantum and spatial distribution of development identified in policies SP1 (spatial distribution), SP6, SP7 and SP9 (employment land). To that extent, it is agreed that the general approach adopted by the Council to identifying the revised boundaries of the Green Belt are consistent with the intentions of the Core Strategy. Parlington New Settlement 1.6 The only exception to the above approach arises in respect of the proposed allocation of a new settlement at Parlington (MX2-39). 1.7 Gallagher Estates (Gallagher) notes that the Core Strategy makes no reference to the potential for the SAP to identify a new settlement in the Green Belt. While not raising a specific objection to the new settlement allocation, Gallagher is concerned that such allocation is not consistent with the Core Strategy policies SP1 and SP10. The Parlington new settlement should not be preferred to the provision of housing sites within each HMCA in accordance with the spatial distribution contained in the Core Strategy (see also comments on Matter 2). 2. Release of Green Belt land as opposed to UDP Protected Areas of Search: Is the release of Green Belt land in preference to some Protected Areas of Search identified in the UDP justified? 2.1 The Leeds UDP [CD2/4] identifies a number of Protected Areas of Search (UDP policy N34). Paragraph 4.8.6 of the Core Strategy confirms that those sites are designated to meet unidentified needs in the future (i.e. at the end of the plan period of the Leeds UDP in 2016) and “will provide one of the prime sources for housing allocations in the LDF.” 2.2 It is clear that the Protected Areas of Search (PAS) sites are not the only source of potential suitable and sustainable future allocations in the LDF and the ability of those sites to meet the strategy for spatial distribution of development is also a relevant factor determining their release. Paragraph 4.8.6 of the Core Strategy goes on to state: “Which land is identified by LDF Allocation Documents (and in particular the Site Allocations Plan) will depend on how well it meets the strategy for housing distribution, embodied by the criteria in Spatial Policy 6. Land not appropriate for housing might be needed for employment allocations or retained as future PAS in the LDF” (my emphasis) 2.3 It is clear from this that the Core Strategy envisages a situation where some PAS sites may be retained in the SAP and other sites, including those in the Green Belt, might be released for development if required to meet the proposed spatial distribution in the plan. That is particularly the case for the Outer HMCAs, which contain limited PAS sites 2 in the UDP and have tightly drawn Green Belt boundaries around settlements, yet the spatial strategy requires an appropriate proportion of housing (and employment) development to be delivered. In those HMCAs it is clear that a Green Belt review is the only viable option to meeting the spatial strategy, regardless of whether PAS sites are potentially available in other parts of the borough. 2.4 This scenario is particularly prevalent in Aireborough HMCA where the PAS sites allocated in the UDP comprise just c.2.3ha of land and would only be capable of accommodating a fraction of the development requirement. This is acknowledged at paragraph 5.4 of the Green Belt Review Background Paper [CD1-31]. “As a result, in the Submission Draft Site Allocations Plan, the 9 HMCAs that contain Green Belt land all propose to allocate Green Belt land for housing, in order to meet District-wide and HMCA targets as set out in SP6 and SP7. In each case there is an insufficient pool of alternative non-Green Belt sites to meet housing needs.” 3. Core Strategy criteria for selected sites: Do the sites selected meet with the criteria set out in the CS? 3.1 Having identified a need to identify Green Belt sites to meet the overall and district-wide HMCA targets in accordance with the spatial strategy, the criteria for selecting those sites is clear in SP10 of the Core Strategy, in that the sites should be tested against the 5 objectives of including land in the Green Belt. The Green Belt Review Background Paper [CD1-31] confirms that this is the approach adopted by Leeds City Council, subject to the fact that there has been no assessment against the fifth objective of Green Belt1 because “the Core Strategy policies encourage regeneration within the urban area”. 3.2 The Council produced a pro-forma for assessing each of the proposed housing allocations against the other 4 purposes of including land in Green Belt. The pro-forma also set out a range of criteria and definitions and assessment responses for each of those criteria against which to test each purpose. The exercise enabled a consistent and comprehensive approach to the review of each potential Green Belt allocation, thereby ensuring that the Core Strategy (and NPPF criteria) could be thoroughly tested and met. Land at New Birks Farm, Ings Lane, Guiseley 3.3 Gallagher Estates does not wish to comment specifically upon individual sites allocated for development by adopting the Green Belt review process, other than in respect of the site at New Birks Farm, Ings Lane, Guiseley (site ref: HG2-1). 3.4 Gallagher has an option on that site and representations were submitted on their behalf to the SAP in support of the allocation (see also Matter 7 Statement). Gallagher is satisfied that in allocating the site for housing development, the Council has conducted a thorough assessment of it against the criteria set out in the Core Strategy. Notably, that assessment confirms that the site: 1 assisting in urban regeneration by encouraging the recycling of derelict and other urban land 3 • Has low potential to lead to unrestricted urban sprawl since it would not constitute ribbon development nor result in an isolated development and is not separated from the existing urban area by any physical barrier. The site is also connected to the urban area and would represent a rounding off of the settlement. • Would not result in the merging of settlements as it contains features to provide appropriate boundaries to the development and would not lead to the physical connection between settlements.