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Examination of Leeds Site Allocations Plan (SAP)

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Examination of Leeds Site Allocations Plan (SAP) Examination of Leeds Site Allocations Plan (SAP) Matter 7: Selection of sites allocated for development Indigo Planning on behalf of Keyland Developments Limited Page 1 Matter 7: Selection of sites allocated for development Indigo Planning on behalf of Keyland Developments Limited Introduction 1.1. This Matter Statement is submitted by Indigo Planning, on behalf of Keyland Developments Limited (herein ‘Keyland’), in relation to the forthcoming hearing sessions for the Leeds Site Allocations Plan (SAP) Examination. 1.2. Keyland have control of land east of Moor Road, Bramhope, Leeds, which has been promoted as a housing allocation in the SAP. The site is however located within the Green Belt in the SAP Submission Draft. Representations were previously submitted by Indigo Planning to the Publication Draft (November 2015) and the Outer North East Consultation (November 2016). We request that this Matter Statement be considered alongside these previous representations. 1.3. It should also be noted that Keyland have control of land at Shadwell Grange, Leeds (Location Plan at Appendix 1) which has not to date been promoted for housing in the SAP process. As it has never previously been promoted it is located within the Green Belt in the SAP Submission Draft. 1.4. We intend to appear at the hearings in relations to Matter 7 (Selection of sites allocated for development) and this Statement provides further written evidence to support our position. We also intend to appear at the hearings for Matters 3 and 6. 1.5. In summary, we consider the methodology to site selection is not sound, and we draw specific reference to the Outer North East and Outer North West HMCA’s. Issue 1: For each Housing Market Characteristic Area, are the individual sites selected sound? Questions relevant to all HMCAs: Question 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? 1.6. The selected sites are not justified having regard to the site selection methodology and process, which is evident given certain sites proposed to be allocated in the Outer North West HMCA have deliverability issues, whereas Land at Moor Road, Bramhope provides a better alternative. 1.7. For example, there are concerns raised in the Matters and Issues paper as to the deliverability of sites HG1-15, HG1-20, HG1-25, and MX1-26 in the Outer North West area, and given wider concerns regarding proposed allocations (eg MX2-39 Parlington), there is substantial concern that not all of the proposed allocations can be delivered. 1.8. The site selection process is therefore flawed, and a reassessment should be undertaken, giving sufficient regard to sustainability and these objectives of the CS. Question 2 –Are sufficient sites identified in the HMCA consistent with the CS? 1.9. No comment. Leeds Site Allocations Plan Examination Statement rpt.011..23680001 Indigo on behalf of Keyland Development Limited Page 2 Question 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) 1.10. No comment. Question 4 - Is the proposed mix of uses on mixed use allocated sites justified? 1.11. No comment. Question 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? 1.12. No comment. Question 6 - Are the identified Protected Areas of Search sites justified? 1.13. No comment. Main Issue 2: For each site, are the policies and specific site requirements sound? Questions relevant to all HMCAs: 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? 1.14. No comment. 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? 1.15. No comment. 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? 1.16. No comment. 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? 1.17. No comment. (b) Is the identification of these sites justified? 1.18. No comment. Outer North East - Parlington (MX-32) Question 1. Is the approach to site selection in the Outer North East HMCA which favours a new settlement (Parlington) over the expansion of existing settlements or release of Leeds Site Allocations Plan Examination Statement rpt.011..23680001 Indigo on behalf of Keyland Development Limited Page 3 Safeguarded sites previously identified in the Leeds UDP justified and consistent with the CS? 1.19. CS Policy SP10 clearly states a two-step process to Green Belt review should take place. Firstly, completing a strategic review of parcels of land and secondly, an assessment of individual sites. This first stage however has not been carried out and therefore the approach to site selection in the Outer North East HMCA is flawed as it is not justified or consistent with the CS. 1.20. The SAP relies on the allocation of a new settlement within the Outer North East to be delivered within Phase 1 of Policy H1 of the Core Strategy to make up for the shortfall created by the withdrawal of the Headley Hall site. The proposed allocation of 114.5 ha within the Green Belt will significantly undermine the purpose of the Green Belt as defined by paragraph 80 of the NPPF. 1.21. The rural character of this part of North East Leeds is defined by swathes of agricultural land interspersed by small villages such as Scholes, Barwick in Elmet and Aberford. The proposed allocation is located between Barwick in Elmet and Aberford in the heart of the Green Belt. Visually the allocation will merge the historic villages with the new settlement and be contrary to the second purpose of the Green Belt as set out in the NPPF. 1.22. The centres of Aberford and Barwick in Elmet are both designated as conservation areas, the scale of the proposed settlement and its proximity to the two villages will also damage the setting and historic character of the villages and therefore be contrary to the fourth purpose of the Green Belt as set out in the NPPF. 1.23. Over the plan period the site is expected to deliver 1,850 units with the longer term intention of developing 5,000 units in this location. The size of the settlement, the level of proposed employment land (11.5ha), along with the provision of schools, a new town centre and new community greenspace will result in a new Major Settlement that will dwarf the adjacent villages. The creation of a new settlement is contrary to the Council’s own spatial strategy as set out in Core Strategy Policy SP1. 1.24. The site requirements set out in the SAP include significant investment in the highway network and public transport network. The rural location of the allocation and the distance from major centres of employment such as Leeds city centre inevitably means that a significant proportion of residents will rely on private transport to access a full range of services, therefore making this an unsustainable location for a new settlement. 1.25. Furthermore, in our opinion Site MX2-39 is incapable of delivering the projected 1,850 dwellings over the plan period, for the reasons set out below. 1.26. Based on the Council’s optimistic view that the SAP will be adopted in winter 2017, followed by a lead in time of around two years to secure planning permission, discharge conditions and commence work on site; new dwellings might finally start to be delivered at some point during 2020. However given the significant level of investment required to bring the site forward this time period could easily be extended. 1.27. On a site of this size with two or more developers an average build rate would likely be in order of 75 dwellings per annum. Therefore within the plan period the site is only likely to deliver in the region of 600 dwellings which is less than half that anticipated. 1.28. Allocating a single site to deliver 37% of the housing required in the Outer North East has not been sufficiently justified in the context of the persistent under delivery of housing. The Council have consistently overestimated the rate of delivery possible from sites under construction. 1.29. Finally we are aware that this site has been known to the Council as a potential development site for some time. We would suggest that the site has not come forward for development Leeds Site Allocations Plan Examination Statement rpt.011..23680001 Indigo on behalf of Keyland Development Limited Page 4 until now, precisely because of the issues surrounding its deliverability that we have highlighted. 1.30. The allocation of MX2-39 is therefore neither justified nor effective. A more achievable strategy would be to allocate smaller, deliverable sites within the Outer North East or adjoining HMCAs.
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