Hallam Land Management Examination of Leeds Site Allocations Plan Matters and Issues Statements Matter 6: Site Selection Method and Process August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management CONTENTS 1.0 INTRODUCTION ........................................................................................................................ 1 2.0 MATTER 6: SITE SELECTION METHOD AND PROCESS ...................................................... 2 Q2. Is the methodology appropriate? ......................................................................................... 2 Q4. Are the reasons for selecting the preferred sites and rejecting the others clear? ............... 3 APPENDICES APPENDIX A SUMMARY TECHNICAL ASSESSMENT APPENDIX B LAND AT BECCA HOME FARM: AN INITIAL MASTER PLAN FOR A NEW YORKSHIRE TOWN APPENDIX C LETTER TO MEMBERS OF THE DEVELOPMENT PLANS PANEL David Lock Associates August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management 1.0 INTRODUCTION 1.1 This statement is submitted by David Lock Associates on behalf of Hallam Land Management (HLM) who are promoting a new settlement on land at Becca Home Farm (BHF). 1.2 HLM submitted representations at the Publication Draft and Revised Publication Draft Stages, promoting BHF as a new settlement location, supported by: • Summary Technical Assessment (November 2016); • Land at Becca Home Farm: An Initial Master Plan for A New Yorkshire Town (November 2016); and, • a letter to Members of the Development Plans Panel (13th July 2016) and enclosures. 1.3 This statement amplifies HLM’s duly made representation to assist the Inspectors in their consideration of the matters and issues. David Lock Associates 1 August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management 2.0 MATTER 6: SITE SELECTION METHOD AND PROCESS Main issue: Has the overall site selection process been based on a sound process and robust methodology within the context of the CS? Q2. Is the methodology appropriate? 2.1 HLM provided comprehensive information in submissions to Leeds City Council (LCC) and members in promoting BHF as a new settlement (see appendices). However, the method adopted by LCC was inconsistent and selective in the information used to adequately make a decision on site allocations. The Council has not provided robust justification or proportionate evidence to discount the BHF site and allocate the Parlington Estate site as a new settlement within the Outer North East Housing Market Character Area. 2.2 The alteration of Green Belt boundaries and the creation of a new settlement is a significant strategic decision for this plan period and beyond. Such a decision needs to be underpinned by a consistent and robust evidence base. It is also important that LCC carries forward its strategy to meet housing needs over the plan period by focusing on the delivery of new settlements in combination with growth at main settlements, as opposed to using the PAS sites that are not sufficient in scale to accommodate long-term needs. 2.3 HLM consider that the approach set out in Paragraph 2.30 of CD 1/1 lacks rigour or transparency. The assessment process has considered the Core Strategy approach; the relationship of the site to the settlement hierarchy, whether brownfield or greenfield, the more preferable sites to release in Green Belt review terms – (those having least effect on the five Green Belt purposes), site attributes – whether it can be developed physically, considering comments from infrastructure providers, local views from the representations received through public consultation and ward members, as well as the findings of the sustainability assessment of sites. It is a combination of all these factors that have led to the suite of allocations in each area. 2.4 Detailed comments on the methodology are set out below. Site Assessment 2.5 The site assessments were based on: • planning metrics such as proximity to train stations, agricultural land classification, etc. • a Green Belt assessment; and, • comments from LCC Highways, Highways England, and Environment Agency. 2.6 However, there were no comments from the following consultees despite comment boxes being provided in the site assessment form: David Lock Associates 2 August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management • Network Rail • Yorkshire Water • Leeds City Council for ecology, education, and flood risk • Utilities – gas, electricity, telecoms • Heritage England • Natural England • Yorkshire Water. 2.7 HLM question why these organisations did not provide comments at the time on the proposed site allocations to ensure a robust assessment. It is not satisfactory to consider highways, Green Belt, and flood risk but not, for example, ecology, foul drainage and utilities. HLM recommended at an early stage that LCC commission a formal study to review the feasibility and sustainability of all new settlement growth options in the Outer North East on a rigorous and transparent basis. Sustainability Appraisal 2.8 The SA makes judgements of potential new settlement sites on 27 criteria and scores the proposed site allocations. HLM is concerned that for new settlements, facilities that would be provided as an integral part of the proposal were not taken into account in the scoring, whereas those sites close to existing facilities benefitted from this in the scoring. 2.9 The SA assessment also included inconsistencies, lacked clarity and varied between stages of the plan preparation. Our representations highlighted these. Further, it has been unclear what sources of information the Council has been using to make their judgements on site. We submitted a Summary Technical Assessment (Appendix A) to help to Council in their decision making, but this appears not to have been taken account of. Q4. Are the reasons for selecting the preferred sites and rejecting the others clear? 2.10 The reasons for selecting the preferred sites and rejecting the others are not clear. HLM’s comments focus on the specific approach to considering BHF against Parlington. These were raised in our letter to members of LCC Development Plans Panel on the 13th July 2016 attached at Appendix C. 2.11 BHF was discounted in the site assessment and sustainability appraisal in favour of Parlington, but there are marginal differences between the sites and significant issues with Parlingon that do no clearly demonstrate the allocation to be justified when considered against BHF. 2.12 HLM rebutted the reasons given in our representation on the Revised Publication Draft Consultation in November 2016. This representation was supported by evidence form the David Lock Associates 3 August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management Summary Technical Assessment (Appendix A) and initial master plan (Appendix B) we submitted to the Council. A summary of our comments is provided below. Site Assessment Heritage 2.13 The Council concluded that there would be an unacceptable impact on several significant heritage assets and the character of Potterton hamlet, but no evidence was provided to support this claim, or comments from Heritage England. Our Summary Technical Assessment and initial master plan showed how these would be protected. 2.14 In contrast, Parlington has numerous heritage assets but there is no discussion of the effect on these assets, or comment from Historic England – this is despite reference in the Report of Consultation (CD1/40) that Historic England ‘expressed concerns over the potential harm to a number of designated and non-designated heritage assets’. Landscape 2.15 The Council concluded that BHF would have a significant impact on the landscape setting in the Special Landscape Area (SLA), but no detailed comments were provided to support these conclusions. Policy N37 does not preclude development on landscape but expects siting, design and materials to be sympathetic, and landscape mitigation to be undertaken where necessary. 2.16 The assessment at the time did not take into account mitigation, which is clearly proposed in our Summary Technical Assessment. Parlington is also located in the SLA, but there is no mention of this policy in the Parlington assessment. Green Belt 2.17 The Council concluded on BHF that: • Tthe site does not have strong, logical boundaries to help contain development. • There would be significant effects on setting and special character of historic features due to the scale and location of the site. • The Becca Banks scheduled monument would be difficult to mitigate, and Potterton would be surrounded and subsumed by the new settlement. • The site would significantly reduce the Green Belt gap with the neighbouring settlement of Barwick in Elmet. The gap would be insufficient and harm would occur. However, no merging of settlements would occur. 2.18 Our Summary Technical Assessment explains how Green Belt issues could be dealt with; for example: David Lock Associates 4 August 2017 Examination of Leeds Site Allocations Plan Matter 6: Site Selection Method and Process Hallam Land Management • The site is well contained by landform and woodland features, and by the A64 to the north. • New defensible boundaries would be identified using existing roads, field boundaries and other notable features. • The south-western corner