Leeds Site Allocations Plan Leeds Local Plan Leeds City Council’s Response to Inspector’s Initial Questions Dated 9th June 2017 Development Plan Document 26th June 2017 Page 1 of 41 The Council welcomes the Inspector’s initial comments and questions. We also welcome the clarification on procedural matters and add the following points to help clarify the running of the Examination. Hearing Sessions Based on the proposed dates submitted, officers are preparing for hearing sessions to begin in October and have built in flexibility in the event that there is a need to continue into November. Further highways modelling is being undertaken (it is currently anticipated that this will be completed in September as in response to Question 3i below). In light of that work, the Inspectors are respectfully asked to consider timetabling of hearing sessions for Outer North East and Outer South East later in the programme. Furthermore, and given the potential cumulative highways impacts from the Outer North East and Outer South East, the Council suggests that, it may be prudent for one Inspector to deal with both HMCAs, it is however appreciated that is wholly a matter for the Inspectors to decide. Soundness The Council welcomes the clarity provided on consideration of the soundness of the Site Allocations Plan (the Plan) and in respect of dealing with omission sites. Questions The answers to the Inspector’s questions are provided below. 1) I understand that the Publication Draft Plan (September 2015), Revised Publication Draft Plan (September 2016) and Pre-Submission Changes (February 2017) have all been subject to a period of consultation. a) Can the Council confirm that the Submission Draft (CD1/1) includes the Pre-Submission changes? i) Yes. As detailed on the cover sheet, immediately prior to page 1 of CD1/1, the updated Submission Draft Plan comprises the Publication Draft Plan (September 2015), the Revised Publication Draft Plan for Outer North East (September 2016) and the Pre-submission changes to the Plan (February 2017). b) Are any further changes included that have not been subject to consultation? i) Yes. In addition to the above, further non material pre-submission changes (May 2017) have been incorporated in CD1/1. These are Page 2 of 41 considered to be minor modifications and have not been subject to consultation. They include (a) typing errors, (b) factual updates (for example an update on HS2 at paragraph 3.2) which do not alter the policies in the Plan, and (c) deletion of some text considered not relevant at submission stage of the Plan – for example paragraphs explaining the work done so far; what the Publication Draft Plan is and the timetable for the Plan. ii) The Inspector is referred to CD1/2. The minor modifications (May 2017) are shown in blue text in CD1/2 for clarity. iii) CD1/1 and CD1/2 are the same Submission Draft Plan. CD1/1 incorporates changes at all stages of the plan, CD1/2 incorporates and highlights these changes in different colour text – red text for pre- submission changes, blue text for further additional minor modifications. 2) Is it the Council’s intention to have any further discussions with representors? If so, could the Council please provide details and confirm when any Statements of Common / uncommon Ground are likely to be completed? i) The Council has already made changes to the Publication Draft Plan and Revised Publication Draft Plan for Outer North East, which comprise the Pre-Submission Changes; in order to address objections that have been raised through representations at the Publication stages. In most cases the representors have clarified their current position via further representations to the advertisement of the Pre-Submission Changes. As a result the Council can, in many cases, confirm whether objections have, either wholly or partially, been addressed by the Pre-Submission Changes and whether there are considered to be any outstanding issues. ii) This clarification can be supported via further discussions with representors, resulting in Statements of Common / Uncommon Ground. However, due to the volume of representations received, these discussions will be focussed on: prescribed statutory bodies – including Historic England, The Environment Agency, Highways England and neighbouring authorities particular sites where circumstances are considered to have changed since Publication Draft, such as site HG2-150 Land to the east of Churwell (where an extension to the site is sought to Page 3 of 41 link in with proposals for a new railway station to serve White Rose shopping centre) developers of sites (especially large sites) who are actively working with the Council to promote development, including sites MX2-39 Parlington and EG3 Leeds Bradford Airport employment hub other bodies and groups, such as neighbourhood planning groups with clearly identified spokespersons; where it would be helpful to the smooth running of the hearings to identify areas of agreement. The Council’s view is that these discussions are best advanced once representatives of specific groups have been identified by the Programme Officer and the Matters and Issues for the examination are known. iii) Discussions between the City Council and those listed above have already begun. Once the Council receive the Matters and Issues for the examination from the Inspectors, a composite list of statements of common ground will be provided. The Inspectors will be further updated as and when new information is received, but the Council’s intention is to complete any statements of common/uncommon ground no later than 4 weeks before the examination. 3) Is any other substantial work / reports likely to be undertaken for the examination, and if so, what is the timetable for such work? i) The Council is undertaking further work for the examination alongside ongoing work which may provide helpful context. For the examination one piece of work is relevant, as follows: Highways modelling. Highways modelling has formed an integral part of the preparation of the Plan in assessing the impact of sites and the cumulative impact of sites upon the highway network. (See CD1/35 Infrastructure Background Paper for more information). Following discussions with Highways England, further modelling is being undertaken to assess the cumulative impacts of site MX2-39 Parlington in Outer North East and site HG2-124 Garforth in Outer South East. Work is ongoing as a joint exercise between the Council, Highways England and the promoters of the respective sites and follows the timetable set out below: Page 4 of 41 o Highways Agency comments received in February o Model specification began in March o Initial surveys in March o Procurement of model between March and April o Award of tender to Pell Frischmann Consultants Ltd in May (delayed due to delays in obtaining written confirmation from site promoters) o Initial outputs expected mid-August o Tests will need to be carried out of potential interventions to be agreed with Highways England in late-August o The work is due to be completed during September and the Inspectors will be updated as soon as information is available. The Inspectors are respectfully asked to consider timetabling of hearing sessions for Outer North East and Outer South East later in the programme for this reason. ii) The Council inevitably carries out ongoing monitoring and evidence base work. Two pieces of ongoing work will provide context at Examination as they update previously submitted pieces of evidence and include: Strategic Housing Land Availability Assessment (SHLAA) Update – this is carried out on a regular basis and the SHLAA Update 2017 is underway. Comments from the Home Builders Federation will be sought during July and a final SHLAA 2017 will be available from August, should it be required for the Examination. The updated SHLAA will inform activity on proposed allocations and capture updated evidence from site promoters and developers on delivery timescales, as well as understanding the latest five year housing land supply position. Strategic Housing Market Assessment (SHMA) - An update of the Council’s SHMA, including a review of the authorities Objectively Assessed Need requirement, is currently underway and will form the evidence base for the Leeds Core Strategy Selective Review. This is at an early stage and currently subject to Regulation 18 (Local Planning) Regulations consultation. It is anticipated that a final SHMA document will be available in Page 5 of 41 September. 4) Please give an indication of the Council’s position on main modifications? This would be advantageous to the efficiency of the examination process and the expectation of participants. Deferring a decision to request modifications until a late stage of the examination may risk both time delay and incur additional examination costs. Minor changes that do not go to the question of soundness or legal compliance are made solely by the Council on adoption and not by the Inspector. i) The Chief Planning Officer has delegated authority pursuant to Part 3 Section 3E(h) of the Officer Delegation Scheme (Executive Functions) to request main modifications to the Plan and therefore it is envisaged that requests in this regard will be addressed throughout the examination. ii) This authority is subject to, where the Leader or relevant portfolio holder has directed or the Director considers that the matter should be referred to Executive Board for consideration. Those matters which are considered necessary for Executive Board consideration are still being agreed and the Inspector will be updated on these in due course. 5) The policy numbering for the overview chapter and each HCMA is the same. This is potentially confusing for future decision making. Is there an alternative way of numbering which the Council might consider? i) Policy referencing in a Plan as large as Leeds Site Allocations Plan is complex.