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)

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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

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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

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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, , HG1-219 Chapeltown Rd/Savile Road LS7, HG1-222 Din Buildings, Road, HG1-225 South Parkway and Brooklands, , HG1-237 25 Moorland Avenue, Woodhouse, HG1-241 114 Burley Road, HG1-250 Theaker Lane, HG1-251 Mistress Lane, HG1-252 Oak Road, Armley, HG1-257 Avenue, , HG1-259 236 Tong Road, HG1-264 86 , , HG1-271 Malvern Rise, HG1-274 Waverley Garth, HG1- 277 272A Dewsbury Road, , HG1-303 Cartmell Drive, , MX1-6 , 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.

3.3 As noted in paragraph 2.3 above, the identification of employment land allocations and floorspace is District-wide rather than apportioned by HMCA. As part of the Employment Land Assessment Update 2017, EB3/7, the Council wrote to landowners in December 2016 (which includes Identified sites with expired planning permission), to make informed decisions as to how sites contribute to the future supply of employment land through an assessment of availability. The Council updated the ELR EB3/7 according to the landowner’s

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intentions for the site including confirmation that development for employment purposes could be delivered within the plan period to 2028. In response to that process, one main modification (to site EG1-48 Opposite Ravell Works, Gelderd Road in Wortley, in Outer South West HMCA) is proposed to delete part of the site from the boundary following confirmation that this part of EG1-48 will not be available for the delivery of employment land.

4 Is the proposed mix of uses on mixed use allocated sites justified?

4.1 Yes. As explained in paragraph 2.42 of the Submission SAP CD/1/1 capacities for housing sites use a standard methodology used in the SHLAA, which applies a standard density multiplier, which varies according to location and to the net area of a site. Where a mix of residential and other uses is proposed, the approach has been to take half of the calculated housing capacity and half of the general employment (or other use) capacity/area, unless there is a specific reason for varying from this approach. For example, in the city centre, ground floor office and town centre uses may be appropriate with residential on upper floors, so the housing capacity will be more than half the standard methodology, or a development brief may exist that suggests a mix of uses.

4.2 As CD1/1 states ‘capacities can only be an indication of what could be achieved on a site’. The Inner Area contains 7 proposed mixed use allocations which all include a mix of housing and employment except one which is a mix of housing and town centre use. That site (MX2-8 Compton Arms, Compton Road) reflects the aspirations of the CS which expects shopping frontages to be active where possible in Town and Local centres (5.3.31/5.3.32). Five of the other six sites are all sites that are currently in or have been in employment use. The employment mix on these sites recognises the importance employment plays in the area. The remaining allocated site, which was previously in education use, has recent permission for a B8 development supporting the 1 Ha of employment aspect to the mix. The approach to mixed use is considered by the Council to be a justified and sound approach for Leeds, in not only providing the necessary quantum of necessary development overall but also allowing for flexibility in responding positively to market conditions, in facilitating a viable, attractive and versatile Inner area. With this in mind 2 of the remaining 6 sites have a proposed 50/50 split use (MX2-11 Armley Gyratory – former gas Works and MX2-13 – Benyon House). Two of the residual 4 sites are edge of City Centre and reflect the desire to use brownfield land in such locations to develop a City Centre residential community (CS Paragraph 5.1.3) and are therefore proposed for a mix with offices. The MX2-7 Thomas Danby College, Roundhay Road has site specific circumstances and MX2-27 Hudson Road, Hudson Mill – Arcadia has a 75/25 split to reflect representations from the site owners.

4.3 Mixed use sites are detailed in the Plan in the same format as other allocations, with both the housing capacity and site capacity for general employment or

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office use given along with any specific site requirements.

5 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?

5.1 Yes. Please see the Council’s response to Matter 5 Infrastructure. In addition, CD 1/35 identifies infrastructure requirements across the District and potential sources of funding/provision, and includes sections on transport modelling and school provision – from looking at the cumulative effect of the proposed allocations, what the infrastructure needs are in terms of the highway network and school provision. Strategic and site specific infrastructure needs are identified, both through the Infrastructure Delivery Plan and in site specific site requirements where necessary.

5.2 In terms of new water and waste water infrastructure there are no site specific requirements within the Plan. Water has been involved in the Plan throughout its preparation. Provision for new water and waste treatment infrastructure can be delivered subject to further feasibility work to look at capacity of existing systems. Yorkshire Water are currently analysing the requirements for water and waste water infrastructure and will look to work with and developers to ensure its timely provision. Yorkshire Water raised no objections during the formal consultation stages of the Plan and have confirmed their agreement to this statement.

5.3 Where other critical infrastructure including a new road, or other pre- commencement works are required, these are detailed in the site requirements for specific sites. As identified in the CS (Paragraph 1.8, Paragraph 4.6.17) CD2/1, the Inner HMCA is an important focus for growth, being adjacent the city centre which is a major strategic and accessible transport hub and a sustainable location. Within this overall context and the transport initiatives outlined in CD1/35, all proposed allocations (housing and employment and mixed use) can be accommodated without the need for new road provision.

5.4 Transport modelling has considered the cumulative impact of proposed allocations upon the road network, and where necessary site requirements for contributions to mitigate any impacts are attached to 9 specific sites HG2-99 Buslingthorpe Tannery/Hill Top Works , HG2-112 Oak Road, New Wortley - Gassey Fields, HG2-113 Round House (rear of), Graingers Way, Armley, MX2-10 Wellington Road, Leeds, MX2-11 Armley Gyratory – former Gas Works, MX2-37 Hudson Road, Hudson Mill (Arcadia), , EO2-2 Office Scheme Wellington Road & Gotts Road Leeds 12, EG2-36 Land at Armley Road/Wellington Road, Leeds and MX2-9 Road, Leeds.

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5.5 The site requirements are considered justified and no evidence has been received to suggest that they cannot be delivered. The Council is therefore satisfied that the site requirements will ensure timely delivery of infrastructure.

6 Are the identified Protected Areas of Search sites justified?

6.1 There are no UDP PAS sites in Inner and no safeguarded land designations in the SAP.

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Main Issue 2: For each site, are the policies and specific site requirements sound?

1 Are the general policies and site requirements relating to all sites positively prepared, justified and effective (are they clearly expressed so they can be applied in day to day decision-making?) and consistent with national policy?

1.1 Yes. The general policies for each site include policy HG2 and policies HG3, HG4 and HG5 where applicable on sites allocated for housing, policy EO2 on office allocations, and Policy EG2 on general employment allocations. The Council considers that the SAP has been positively prepared on the basis that it is delivering a strategy which seeks to meet objectively assessed development and infrastructure requirements, and is consistent with achieving sustainable development principles (NPPF, CD3/1). As outlined in CD1/28, City Region authorities have been involved through the Duty to Cooperate process and consultation stages of the Plan. In certain cases, where allocation of sites have the potential to impact upon infrastructure in neighbouring authorities, site requirements have been applied to specific sites to mitigate the impact . The SAP is set within the context of the adopted CS and the Council considers that its policies and site requirements are justified. They have been based on up to date evidence, and all reasonable alternatives have been assessed, through the site assessment process and the sustainability assessment of sites. (See the Council’s response to Matter 6).

1.2 The general policies have been positively prepared, in accordance with this approach and are considered justified and effective. The policies are considered to be unambiguous to enable decision makers to apply them in dealing with specific planning applications. Please see also the Council’s response to Question 4 below. The response to this question regarding site requirements is given under Question 2 below. Not all sites have specific site requirements over and above the general policy requirements. Assessment of applications on these sites will therefore rely on policies elsewhere in the Local Plan to guide decision making, all of which have been found to be sound.

2. Are the specific site 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? For example, many suggest that ‘consideration’ should be given to various matters as part of proposals / planning applications but does not explicitly require anything further to be done beyond that.

2.1 Yes. The site requirements are considered to be justified, effective and consistent with national policy CD3/1, and clearly expressed. Where sites listed

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within the general policy (see response to Question 1 above) have specific requirements, these are listed as site requirements under the allocation concerned. The site requirements are considered necessary in order to make the site sound and enable the delivery of sustainable development in accordance with the policies in the NPPF CD3/1. For example, site requirements concerned with conservation areas and listed buildings will help deliver section 12 of the National Planning Policy Framework.

2.2 See the response above to Main Issue 1, Question 5 regarding critical infrastructure site requirements. In addition to requirements for infrastructure provision, sites have requirements where heritage, ecology or other factors need to be taken into account in ensuring development is sustainable. Certain site requirements have been triggered where a site lies within a certain distance of a designation, such as a Conservation Area or Listed Building, or where a culvert or pipeline crosses or incurs into a site boundary. Where any such trigger is present, we have consulted appropriate bodies further on such sites – for example, on sites adjacent to Conservation Areas or Listed Buildings, the Council’s heritage officers have been consulted and involved in the production of site requirements and the Heritage Background Paper, and Historic have been involved in both the production of the Background Paper and consulted on the site requirements. The site requirements stem from NPPF guidance, including on flood risk (paragraphs 100 to 104 NPPF), section 11 on conserving and enhancing the natural environment and section 12 on conserving and enhancing the historic environment.

2.3 With regards to the Inspector’s reference in this question to site requirements which refer to ‘consideration’ being given rather than an explicit requirement, across the Plan as a whole there are 554 specific site requirements (attached to 208 sites). Only 48 site requirements have wording referring to ‘consideration should be given……’ and most of these (39) relate to a site requirement for re- opening or restoration of culverts.

In the Inner Area, 29 allocations have specific site requirements, which amounts to 59 individual site requirements. As with the general policies, the site requirements are considered to be unambiguous, to enable decision makers to apply them in dealing with specific applications. Only 5 individual site requirements in Inner Area have wording referring to ‘consideration should be given to…. or “regard should be had to… ‘ The table below lists these, and provides the justification for this.

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Site ref and Site requirments that include Explanation of this address wording to ‘consideration should be given to…’

HG2-85 Culverts and Canalised Water To use the word ‘consider’ in this Courses context is considered appropriate as Beckhill opening of culverts needs to take full Approach, The site contains a culvert or account of public safety Miles Hill canalised watercourse. considerations, and in some cases Primary Development proposals should development cannot be achieved School, consider re-opening or restoration through opening a culvert. The Meanwood in accordance with saved UDP wording allows for the implementation Policy N39B of the UDP policy.

HG2-92 Culverts and Canalised Water As above Courses Askets and Boggarts (D), As above Seacroft

HG2-96 Culverts and Canalised Water As above Courses South Parkway and As above Brooklands, Seacroft

HG2-99 Culverts and Canalised Water As above Courses Buslingthorpe Tannery/Hill As above Top Works Sheepscar

HG2-214 Culverts and Canalised Water As above Courses York Road/South As above Parkway, Seacroft

3 Does the evidence demonstrate that the deliverability and viability of the allocated sites is not prejudiced by the site requirements, particularly those that have been subject to additional / revised requirements as a result of consultation during the plan process?

3.1 Yes. See the Council’s response to Question 1, paragraph 1.7 above and to Matter 6, Question 7. There is no evidence that any of the site requirements would unduly affect deliverability of the sites or that viability would be prejudiced and no representations have been received on any particular site to suggest that development is not viable. As stated, the online PPG CD3/2 states “Assessing the viability of plans does not require individual testing of every site or assurance that individual sites are viable” (Paragraph 006 Reference ID: 10- 006-201440306 revision date 06 03 2014). If any detailed viability issues do

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arise over the plan period these would be assessed at planning application stage and be subject to full viability appraisals.

3.2 In the Inner Area, 14 allocations have been subject to additional/revised site requirements which were advertised as pre-submission changes to the Plan in February 2017. These sites are:

Site ref and Pre submission changes to site requirement/additional site address requirement added as pre-submission change

HG2-91 Askets and Change of wording to request an Ecological Assessment and Boggarts (B), appropriate mitigation where appropriate. Seacroft HG2-96 South Parkway and Flood Risk Site Requirement added Brooklands, Seacroft HG2-99 Buslingthorpe Local Highway Network Site Requirement added Tannery/Hill Top Works Sheepscar Listed Building Site Requirement deleted.

Specific information regarding the Hill Top works added to the Conservation Area Site requirement

HG2-201 York Road (land Clarification on name of school added. south of), East of Pontefract lane, Richmond Hill LS9

HG2-211 Older persons housing/independent living Site Requirement added

Burley Liberal Club, Listed Building Site Requirement added Burley Road/Willow Road

HG2-212 Older persons housing/independent living Site Requirement added

Seacroft Crescent, Seacroft

HG2-214 Older persons housing/independent living Site Requirement added York road/ South Parkway, Culverts and Canalised Water Courses Site Requirement added Seacroft Conservation Area Site Requirement added

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HG2-215 Older persons housing/independent living Site Requirement added The Halton Moor PH, Halton Moor Highways Access to Site Site Requirement added

HG2-216 Older persons housing/independent living Site Requirement added Ramshead Approach, Additional general wording added stating the site is part of the Seacroft and Seacroft Neighbourhood Framework.

MX2-9 Highways Access to Site changed to delete unnecessary detail.

Kirkstall Road, Local Highway Network Site Requirement changed to add Leeds needed detail.

Changes to Ecology Site Requirement to remove text regarding mitigation measures.

Changes to Education Site Requirement to delete association with nearby sites and the need for a masterplan of the site.

MX2-37 Older persons housing/independent living Site Requirement added. Hudson Road, Hudson Mill Local Highway Network Site requirement added. (Arcadia), Burmantofts Ecology Site requirement added

Registered Parks and Garden Site Requirement added

EO2-2 Detail added to Local Highway Network Site Requirement as agreed with Highways England. Office Scheme Wellington Road & Listed Building Site Requirement added. Gotts Road Leeds 12

Site ref and Pre submission changes to site requirement/additional site address requirement added as pre-submission change

EG2-12 Ecology Site Requirement added

Gelderd Road Leeds 12

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EG2-36 Highway Access to Site Site Requirement added.

Land at Armley Local Highway Network Site Requirement added. Road/Wellington Road, Leeds Listed Building Site Requirement added.

3.3 All the changes to site requirements listed above have given more clarity as to the specific requirements, but are not considered to unduly affect viability or deliverability of the sites concerned and no representations have been received suggesting this.

4. Some sites are identified as being suitable for older persons / independent living. (a) Whilst a preference is highlighted on some sites, it does not appear to be expressed as a requirement. Will Policy HG4 therefore be effective in the delivery of this type of housing? (b) Is the identification of these sites justified?

4.1 a) Policy HG4 is not intended to allocate sites for older persons/independent living. It identifies sites which are particularly suitable for older persons housing/independent living as those within walking distance of a local centre. This is simply an indication of which sites could be suitable for this use. It is considered that Core Strategy policies H4 on Housing Mix and H8 on housing for independent living will ensure delivery of this type of housing, with Policy HG4 in the SAP being effective in assisting in this process by identifying potential sites. In Inner Area 17 sites have been identified under Policy HG4 – sites – HG2-85 Beckhill Approach, Miles Hill Primary School, Meanwood, HG2- 87 Amberton Terrace, HG2-93 Brookland Avenue, HG2-99 Buslingthorpe Tannery/Hill Top Works Sheepscar, HG2-107 Neville Road, Halton Moor, HG2- 108 Burley Willows Care Home, Willow Garth, Burley, HG2-110 Wesley Road (west of), Tong Road (north of), Armley, HG2-113 Round House (rear of), Graingers Way, Armley, HG2-114 Cambrian Street, Beeston, HG2-211 Burley Liberal Club, Burley Road/Willow Road, HG2-212 Seacroft Crescent, Seacroft, HG2-214 York Road/South Parkway, Seacroft, HG2-215 The Halton Moor PH, Halton Moor, HG2-216 Ramshead Approach, Seacroft, MX2-8 Compton Road – Compton Arms, Burmantofts LS9 7B, MX2-13 Benyon House and MX2-37 Hudson Road, Hudson Mill (Arcadia), Burmantofts.

4.2 b) Identification of such sites is considered justified in that it is supported by evidence that such housing should be located within easy distance of centres/local community facilities. Policy H8 states that “LDF Allocation Documents should seek to identify land which would be particularly appropriate for sheltered or other housing aimed at elderly or disabled people”: The SAP is therefore in conformity with this CS policy. In the Council’s view, the alternative approach to not identify such sites would be unhelpful to those providers of

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such housing seeking appropriate sites. However, in order to allow for flexibility, a specific allocation for older persons has been avoided. Due to the range of types of delivery of such housing, including private developments for over 55 year olds, Council provision, sheltered, nursing and residential care homes etc, the requirements for a particular type of provision may vary, and to require such provision at the exclusion of other housing, is considered to be too restrictive. Moreover, older people can acquire housing on the general market providing that it meets their needs and other CS policies on mix and independent living as well as emerging policies on Housing Standards will seek to ensure the housing product in Inner meets their needs.

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Additional Site Specific Questions

1 In respect of EG2-11 and EG2-12 are the sites deliverable in the light of the identified flood risk?

1.1 Yes, the Council considers that both sites are deliverable in the light of the identified flood risk. Firstly, with reference to site EG2-11 (Former Co-op Dairy Depot Gelderd Road LS12), this site has now received a planning consent (15/05199/FU). Conditions are attached to the permission which state that development shall not commence until a feasibility study into the use of infiltration drainage methods and details of surface water drainage works have been submitted to and approved in writing by the Local Planning Authority. The maximum rate of discharge off-site should not exceed 5 L/s, for the critical 1 in 100 year rainfall event, including a 20% uplift for climate change.

1.2 Secondly, policies already exist within the adopted Local Plan for Leeds to protect sites from flood risk. Policy Water 6 of the Natural Resources and Waste Local Plan CD2/2 requires that all sites that have flood risk include a flood risk assessment with their planning application.

1.3 To assist Plan users these wider policies are highlighted in paragraph 2.51 of the SAP, which states: ‘All sites within or partly within higher flood risk areas (Flood Zones 2 and 3) should be planned to ensure the development will be safe, will not increase flood risk elsewhere, and will apply a sequential approach to the layout of the site so that the built development is in the area of least flood risk where possible’.

1.4 In line with the approach taken in the Flood Risk Sequential and Exception Test Background Paper CD1/30, less vulnerable uses, such as employment, are appropriate in flood zones 2 and 3a. The measures that the Council would expect to see in a flood risk assessment for the two sites, as have been successfully delivered on other employment sites along the and city centre, include: flood resilient construction, the raising of floor levels above adjacent ground level and surface water drainage measures as per the Council’s Minimum Development Control Standards for Flood Risk. In light of these requirements, site EG2/12 Gelderd Road is therefore considered deliverable.

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