Leeds City Council Site Allocations Plan Examination Matter 7
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Leeds City Council Site Allocations Plan Examination Matter 7: Selection of sites allocated for development – Inner: Main Issue 1 Main Issue 2 Additional Site Specific Questions Doc No. M7/1d Leeds Local Plan Page 1 of 16 Main Issue 1: For each Housing Market Characteristic Area, are the individual sites selected sound? 1 Are the selected sites justified having regard to the site selection methodology and process, paying particular attention to the deliverability of the allocated sites? 1.1 Yes. The Council’s response to Matter 6 details the overall site assessment and selection process used for allocation of sites in the Plan. The Council considers that this approach is the most appropriate in terms of meeting CS aims and objectives for the MD as a whole and that the selection of sites is justified. This response to Matter 7 sets out how the overall methodology and process has applied in this HMCA. It highlights the specific characteristics of and evidence relating to Inner and notes whether there are any specific issues arising. 1.2 Further to paragraph 3.4 of the submission SAP CD1/1 the Inner Area comprises a series of distinct areas and neighbourhoods that form a ring around the City Centre, characterised by urban deprivation based on the decline of the manufacturing sector in the UK. However, they all have individual characteristics that make them distinct from each other. The general decline of heavy and light in industry in the UK hit areas such as Leeds Inner HMCA much harder than others. Over time the decline left behind a legacy of large areas of brownfield land much of which is proposed for regeneration. 1.3 The methodology as outlined in Matter 6 is considered robust. In Inner in terms of new housing allocations 102 sites were put forward for consideration. In the HMCA there are: a) 33 housing allocations b) 7 mixed use allocations c) 3 required for school use and designated under HG5 d) 58 sites are rejected (plus 1 site mostly in Outer South West HMCA) The reasons for allocation and rejection of sites are detailed at Appendix 2, pages 120 to 132 in the Housing Background Paper CD1/34. 1.4 In terms of office and general employment allocations, 41 sites were put forward for consideration in Inner. In the HMCA there are: a) 5 general employment allocations b) 1 office allocation (EO2-2 Wellington Road, Gotts Road) Page 2 of 16 c) 6 mixed use allocations d) 29 sites are rejected. Reasons for allocation and rejection of sites are detailed at Appendix 1, pages 33 to 39 of the Employment Background Paper CD1/29. Within the context of the NPPF CD3/1, the deliverability of sites concerns whether they are suitable, available and achievable. Paragraphs 5.5 to 5.17 of the Housing Background Paper CD1/34 considers this at a strategic level, paragraphs 5.6 to 5.8 looking at suitability, paragraphs 5.9 to 5.10 availability and 5.11 to 5.17 achievability. The appropriateness of employment sites is explained in the Employment Background Paper CD1/29 and also in response to Matter 2, Question 9. 1.5 In terms of suitability, the site assessment process has considered an individual site’s suitability for development including physical constraints such as access, infrastructure, flood risk, ecology and heritage considerations alongside compliance with the CS. The Site Assessments document CD1/38 provides the full site assessments for all allocations in Inner (both housing and employment). Where necessary specific site requirements have been applied to sites where mitigation measures are necessary to ensure a site remains suitable for development. 1.6 In terms of the availability of sites, as paragraph 5.10 of CD1/34 and paragraph 3.13 of CD1/29 details, the sites have generally been submitted to the Council for consideration for the allocated use therefore there is landowner intention to release the sites for that purpose. Where this is not the case the Council has contacted the landowners of allocated sites. No evidence has been received that any of the proposed allocations will not be made available apart from HG2- 201 Land South of York Road. On this site, since submission, the landowner has confirmed the site will not be made available for housing. The Council therefore proposes a Main Modification to the plan in this respect. (Proposed modifications to the Plan will be sent to the Inspector no later than 4 weeks prior to the start of the hearing sessions). As the remaining sites are considered to be policy compliant and suitable, any lack of response from a landowner has been deemed to mean that the land remains available and the allocation is justified. 1.7 In terms of achievability, the Council’s response to Matter 6 Question 7 explains how viability has been tested and how the Council will respond to any future changes. In addition, in the Inner HMCA the Core Strategy Inspectors Report (Paragraph 28) CD2/17 recognised that the City Centre and Inner HMCAs had moved from a position of general ‘non-viability’ during the recession to one of general viability which would only improve as the market Page 3 of 16 strengthened. The online PPG1 notes that “Evidence should be proportionate to ensure plans are underpinned by a broad understanding of viability. Greater detail may be necessary in areas of known marginal viability or where the evidence suggests that viability might be an issue.” To that end the Council commissioned three reports from the District Valuer Service (EB8/5 to EB8/7) which focused on the viability of a selected number of sites in the City Centre and the Inner Area on which viability was considered to be a potential issue e.g. by virtue of the character of the site or where issues were raised by members of the SHLAA partnership. All sites assessed in the Inner HMCA were considered to be viable. Furthermore no representations have been received on any particular site to suggest that development is not viable. 2 Are sufficient sites identified in the HMCA consistent with the CS? 2.1 Please see the Council’s response to Matter 2 Question 9. 2.2 Inner is 3,042 above the indicative target of 10,000 as illustrated in the table below. Extract from Table 1 Housing Distribution by Housing Market Characteristic Area (HMCA), paragraph 2.27 of the Submission Draft Plan CD1/1 Housing Core Percentage Existing Proposed Total +/- Target Market Strategy supply allocations housing Characteristic Housing (‘Identified supply Area Target sites’) Inner 10,000 15% 8,970 4,072 13,042 +3,042 The Council has outlined why being over the target in Inner is considered a sound and justified approach, fully in compliance with the CS, the evidence base and national guidance in our response to Matter 2 and in EX2, response to Question 11. 2.3 As regards employment sites there is no specific HMCA target. Provision and distribution of employment sites is addressed in the Council’s response to Matter 2, Question 9. The Inner HMCA, given its location adjacent the city centre provides for 140,555sqm of office development (13.3% of the total allocations). 1 Paragraph: 005 Reference ID: 10-005-20140306 Page 4 of 16 3 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) 3.1 The Council’s response to ‘Further Questions to the Council’ (7th August 2017) EX2c, response to Question 1 provides a narrative in relation to Schedule 1 and gives a detailed response for each expired permission. Since 2012, the base date of the plan, some sites have inevitably expired. This, which is common to all authorities, is a general reflection of the recent state of the market and ‘turn over’ of planning permissions. The Council considers that relying on such sites forming part of supply is justified because: a) of the evidence that sites with expired permissions are developed (see paragraphs 1.1 to 1.4 of the Council’s response to ‘Further Questions to the Council’ (7th August 2017) EX2c, and b) these sites remain suitable, available and achievable. Whilst expiration of planning permissions may have implications for a 5 year land supply assessment and the demonstration that sites are available now, it does not follow that such sites, given Core Strategy aims and objectives and the scope of the SAP, will not come forward over the plan period. 3.2 In Inner, 23 identified sites are listed on Schedule 1 of the Inspectors Matters and Issues. The status of each of these sites is set out in the Council’s response to further questions 7th August 2017 EX2c and Appendix 1 of the Councils response to the Inspectors initial questions June 2017 EX2. In Inner 20 identified sites have expired planning permissions: HG1-207 Beckhill Garth/Approach, HG1-208 Grove Park Care Home Grove Lane, Meanwood, HG1-219 Chapeltown Rd/Savile Road LS7, HG1-222 Din Buildings, Roundhay Road, HG1-225 South Parkway and Brooklands, Seacroft, HG1-237 25 Moorland Avenue, Woodhouse, HG1-241 114 Burley Road, HG1-250 Theaker Lane, HG1-251 Mistress Lane, Armley HG1-252 Oak Road, Armley, HG1-257 Wykebeck Avenue, Osmondthorpe, HG1-259 236 Tong Road, HG1-264 86 Elland Road, Holbeck, HG1-271 Malvern Rise, HG1-274 Waverley Garth, HG1- 277 272A Dewsbury Road, Hunslet, HG1-303 Cartmell Drive, Halton Moor, MX1-6 Mabgate, MX1-11 Whitehall Road – Doncasters, MX1-12 Globe Road – Doncasters. The evidence as to the intentions of owners/developers is already provided in the Council’s response to Question 1 Further Questions to the Council (7th August 2017) EX2c.