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Selection of Sites Allocated for Development

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Selection of Sites Allocated for Development Matter 7 Hearing Statement – Selection of sites allocated for development Our ref 50765/JG/JCx Date 25 August 2017 Subject Leeds: Site Allocations Plan (SAP) - Public Examination Matter 7 Selection of Sites Allocated for Development - Hearing Statement on behalf of Persimmon Homes West Yorkshire Issue – For each Housing Market Characteristic area, are the individual sites selected sound? 1.0 Introduction 1.1 This Hearing Statement has been prepared by Lichfields on behalf of Persimmon Homes West Yorkshire (PHWY) and responds to all questions set by the Inspector in relation to Matter 7. In addition, it provides responses to site-specific questions in relation to the Outer South and Outer South East Housing Market Characteristic Areas (“HMCAs”). 2.0 Main Issue 1 – for each Housing Market Characteristic Area, are the individual sites selected sound? Q1 – Are the selected sites justified having regard to the site selection methodology and process, paying particular attention to the deliverability of the allocated sites? 2.1 For the most part, yes. Throughout the preparation of the SAP, the adopted methodology has continued to appraise and sift potential sites to ensure that the most suitable and appropriate allocations are taken forward. This process has been subject to scrutiny via public consultation, thus ensuring that it has been undertaken in a robust and objective manner. 2.2 As part of this process, the accompanying Sustainability Appraisal has considered alternative sites and strategies (also taking into account any potential scope for mitigation measures to be adopted), using a scoring mechanism in order to consider different sites against individual sustainability objectives in a consistent manner. This approach is considered to be entirely appropriate and one which has commonly been used by other Local Planning Authorities in the production of plans that have subsequently been identified as sound at Examination. 2.3 Notwithstanding the above, we consider that the deliverability of certain sites – an example being Site HSG-124 – have been appraised in an overly-optimistic manner. Our response to Matter 2 provides further details on this, with our recommendation being that further sites are allocated in order to ensure that the SAP is flexible and resilient enough should identified and / or allocated sites fail to deliver at the pace envisaged. Q2 – Are sufficient sites identified in the HMCA consistent with the CS? 2.4 No, we do not consider this to be the case. Whilst this is set out in further detail in our response to Matter 2, the HMCAs where there is currently a shortfall could be made consistent with the CS through the allocation of additional suitable and available housing sites. For example, Pg 1/10 Lichfields.uk 14709144v2 PHWY’s site at Barwick Road, Garforth (SHLAA ref. 2516, 1226, 3114 & 1165) has been identified as a site that is suitable and available for allocation within the Outer South East HMCA. Similarly, sites at Cemetery Lane, Lofthouse (SHLAA ref. 3085) and Warm Lane, Yeadon (SHLAA ref. 2162 & 1104) have been demonstrated as suitable and available for development within the Outer South and Aireborough HMCAs, respectively. Q3 – On identified sites where planning permission has expired, is there very convincing written or verbal evidence that the intentions of the owners/developers have changed? (Please see schedule 1) 2.5 Whilst schedule 1 does not provide a list of sites where planning permission has expired (rather, it provides a list of sites where no planning permission exists), we can confirm that all sites which are in control by PHWY are ones where housing is being proactively promoted and there is a clear intent for a future planning application for new housing development to be submitted. With reference to schedule 1, these sites include sites MX1-26 (East of Otley, Off Pool Road) and HG1-288 (East Leeds Extension). Q4 – Is the proposed mix of uses on mixed use allocated sites justified? 2.6 The only site within PHWY’s control that this question is relevant to is Site MX1-26 (East of Otley, Off Pool Road), where the latest masterplan for the site (see Annex 1) proposes the following mix of uses: • 550 dwellings; • Provision of a relief road (East Otley Relief Road); • Relocation and provision of sports pitches; • A new two-form entry primary school; • Elderly persons accommodation; • 5 hectares of employment land; and • Public open space. 2.7 PHWY’s masterplan therefore accords with the mix of uses identified within the SAP which, in turn, will ensure that a sustainable form of development is delivered on this strategic site. Q5 – Where the development of a site relies on the delivery of critical infrastructure (e.g. new roads, new water and waste water infrastructure, significant pre-commencement work), does the evidence support that the infrastructure will be in place to support the timely development of these sites? 2.8 Yes, in most cases. The East Otley Relief Road can be provided in a timely manner to support the planned delivery of the proposed East Otley (MX1-26) allocation and the park and ride infrastructure at Stourton which is required to enable the Haighside, Rothwell (HG2-173) site to come forward, is already in place. 2.9 The Northern Quadrant of the East Leeds Extension (HG1-288) is capable of being brought forward before the delivery of the East Leeds Orbital Route, as access could be achieved from the A58 as demonstrated in the current planning application (ref. 16/05095/FU). Pg 2/10 Lichfields.uk 14709144v2 2.10 However, there is an over-reliance on certain allocations coming forward when the implementation of these developments is subject to the delivery of critical infrastructure. The outcome of the highways modelling work for the Parlington and Stourton Grange allocations will not be available until October 2017 and therefore, the extent of the highways infrastructure required is not yet clear. As a result, additional flexibility needs to be built into the SAP in order to ensure that the type and amount of development anticipated within the CS is delivered, in the event that certain allocations don’t deliver either in full or in part during the plan period. Consequentially, additional sites need to be allocated in the Outer South East HMCA, such as at Barwick Road, Garforth (SHLAA refs. 2156, 1126, 3114 & 1165). Q6 – Are the identified Protected Areas of Search site justified? 2.11 To an extent, yes, as they help give much needed flexibility to the SAP, should the delivery of certain sites not be forthcoming in full or in part during the plan period. 2.12 As stated in our response to Matter 2, however, we have expressed concerns as to the deliverability of Sites HG-124 and MX-32 during the plan period. This is highly significant given that both of these sites make up the majority of the identified housing supply within their respective HMCAs. 2.13 Given the above concerns, it would be prudent for Site HG3-18 (Selby Road, Garforth) to be brought forward as a Phase 1 housing allocation within the outer south east HMCA, rather than held back as safeguarded land. 3.0 Main Issue 2: For each site, are the policies and specific site requirements sound? 3.1 Our response to the following questions reflects views on the sites within our client’s control (in whole or in part). These are listed in Table 1 as follows: Table 1 Proposed allocation sites controlled by PHWY 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 east HG2-226 Land to the east of Wetherby HG1-288 East Leeds Extension Outer south HG2-173 Haighside, Rothwell Outer south east HG3-18 Land south of Selby Road, Garforth Outer south west HG2-150 Churwell (land to the east of) LS27 HG2-149 Lane Side Farm, PAS Morley HG2-153 Albert Drive, Morley HG1-514 Albert Drive – Lower Moor Farm, Morley HG1-351 Owlers Farm PAS, Wide Lane, Morley Pg 3/10 Lichfields.uk 14709144v2 Q1 – Are the general policies and site requirements relating to all sites positively prepared, justified and effective (are they clearly expressed so that they can be applied in day to day decision-making?) and consistent with national policy? 3.11 Yes. These appear to be consistent with policies set out in the adopted Core Strategy. Given that the Core Strategy has been confirmed as sound at a separate Examination in Public, it follows that the general policies and site requirements within the SAP are also positively prepared, justified, effective and consistent with national policy. 3.12 Q2 – Are the site specific requirements relating to individual sites justified and effective (are they clearly expressed so they can be applied in day to day decision- making?) and consistent with national policy? 3.13 MX1-26 – we support the allocation of this site and consider it to be justified and effective on the basis that the site is suitable and available for development. 3.14 HG1-228 – we support the allocation of this site and consider it to be justified and effective on the basis that the site is suitable and available for development. 3.15 HG2-226 – the site requirements clearly express the need for a comprehensive development on this site. PHWY agree with this and the illustrative masterplan included in Annex 2 shows one such way that a comprehensive, sustainable development could be realised on the allocation site. To ensure its effectiveness, however, additional wording should be added to the site requirements of HG2-226, requiring a phasing plan to be agreed by all three landowners which ensures that the entirety of the site is delivered within the plan period in an appropriate and timely manner.
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