Leeds City Council Site Allocations Plan Examination Matter 7: Selection of sites allocated for development – East: Main Issue 1 Main Issue 2 Additional Site Specific Questions Doc No. M7/1c Leeds Local Plan Page 1 of 14 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 the East HMCA. It highlights the specific characteristics of and evidence relating to East and notes whether there are any specific issues arising. 1.2 Further to paragraph 3.3 of the Submission SAP CD1/1, East has the largest housing target set out within the Core Strategy, a target of 11,400 new dwellings equating to 17% of the overall housing requirement. East is an area of contrasting character areas reflective of its location sandwiched between the Inner area of Leeds and the outer rural areas of the Outer North East, Outer South East and Outer South, most of which is Green Belt. A significant amount of housing within East Leeds is post-war Council-built housing, focused around areas such as Whinmoor, Stanks and Swarcliffe. This is contrasted with areas such as Colton and Wellington Hill which are characterised by a mix of pre-war and modern, private housing. Cross Gates and Halton are the identified town centres within East and Temple Newsam house and grounds provides the largest greenspace within the area. In East major strategic highway infrastructure, the East Leeds Orbital Road (ELOR), will be delivered during the plan period (expected completion date 2021) to enable the delivery of significant housing growth. Combined with the Manston Lane Link Road this strategic infrastructure will enable the development of sites HG1-288 East Leeds Extension, HG2-119 Red Hall Offices & Playing Field, HG2-120 Manston Lane – former Vickers Tank Factory Site, Cross Gates, MX1-25 Land bounded by Park Approach and Barrowby Lane off Manston Lane, Manston, Leeds, MX2-38 Barrowby Lane, Manston and EG2-27 Manston Road, Leeds. 1.3 The methodology as outlined in Matter 6 is considered robust. In East in terms of new housing allocations 29 sites were put forward for consideration, 15 of which are in or partly in Green Belt. In East there are: a) 8 housing allocations (2 of which are Green Belt/part Green Belt) b) 1 mixed use allocation (MX2-38 Green Belt) c) 20 sites are rejected (12 of these are Green Belt). Page 2 of 14 The reasons for allocation and rejection of sites are detailed at Appendix 2, pages 98 to 110 in the Housing Background Paper CD1/34 1.4 In terms of office and general employment allocations, 9 sites were put forward for consideration in East. In East there are: a) 1 general employment allocation (EG2-27) b) 1 Mixed use allocation (MX2-38 – Green Belt) c) 7 rejected sites Reasons for allocation and rejection of sites are detailed at Appendix 1, page 30 to 32 of the Employment Background Paper CD1/29. 1.5 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. 1.6 Deliverability 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 East (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. 1.7 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. As the 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. The Council is actively preparing Planning Briefs for a number of allocated sites (HG2-119 Red Hall Offices & Playing Field LS17, HG2-122 Cartmell Drive, Halton Moor and HG2-210 St Gregory’s Primary School, Stanks Garden, Swarcliffe) with a view to inform future land disposals. A number of the sites are already being actively promoted by the agents/developers as evidenced in representations received. In addition there Page 3 of 14 are planning applications pending determination on sites HG2-120 Manston Lane – former Vickers Tank Factory Site, Cross Gates (14/02514/OT) and HG2-121 Killingbeck Bridge – Wykebridge Depot (14/03958/OT). An update on planning permissions on sites, since 1/4/16 will be sent to the Inspector before the commencement of the hearing sessions. 1.8 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. There is no evidence and no landowner 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 East is 1,714 under the indicative target of 11,400 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 +/- Market Strategy supply allocations housing Target Characteristic Housing (‘Identified supply Area Target sites’) East 11,400 17% 6,133 3,553 9,686 -1,714 2.3 Due to a number of factors, including the significant Green Belt restrictions in the area and the need to balance the purposes of the Green Belt against the CS target, East is significantly under the CS target (this is evidenced through the Council’s reasoning for not allocating sites set out within the Housing Background Paper CD1/34 pages 106-110). In addition, as outlined within the Council’s response to Question 11 of the Inspector’s Initial Questions EX2 the total proposed supply of housing in East has been reduced due to comments from statutory bodies such as Historic England which have reduced site capacities, reductions in site capacities within the Aire Valley Leeds Area Action Plan (which contributes to the East target) and other factors as set out in the response. The Council have outlined how it will address this shortfall in our response to Matter 2 and in EX2, response to Question 11. 2.4 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. Page 4 of 14 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 East, 3 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 EX2c and Appendix 1 of the Council’s response to the Inspector’s Initial Questions June 2017 EX2.