Response to Leeds City Council’s Position Statement on the examination of the Site Allocations Plan and the initial stages of the Selective Core Strategy Review.
On 20th July 2017 I submitted the following Written Question to the Secretary of State for Communities & Local Government:
“To ask the Secretary of State for Communities and Local Government, what mechanisms are available to his Department to require Leeds City Council to review its Local Plan to take into account the Council’s own downward revision of its housing target before it reaches public inquiry.”
The Minister of State Alok Sharma MP replied on 13th September 2017:
“Under the National Planning Policy Framework (NPPF), local planning authorities should ensure that any Plan they produce is based on adequate, up-to-date and relevant evidence. This is tested by the independent Planning Inspector, during the statutory examination of a Plan.
The 2017 White Paper: Fixing our broken housing market, also set out the scope of Government powers and criteria for making decision on whether to intervene in local plan-making in exceptional circumstances.”
It is my firm belief that Leeds City Council’s Local Plan, in its current form, is reliant on inadequate, out-of-date and irrelevant evidence. As this evidence is tested in the upcoming statutory examination I believe it will be difficult for the Council to carry on arguing that the plan is sound.
What is the effect of the selective review on the soundness of the SAP?
The Council’s response to this question attempts to dismiss the relevance of the selective review as “minor and broadly contextual” (a.1). However, initial findings of the review suggest that the figure required is between 45,000 and 55,000 (a 20 to 35 per cent reduction on this initial target).
Indeed, Councillor Peter Gruen, Chair of the Strategic Housing Market Assessment (SHMA) Reference Group, confirmed in the Yorkshire Evening Post said initial conclusions of the technical work, which indicates that a revised housing need for Leeds was “in the region of 55,000 homes”.
I do not consider a reduction of the housing target by 20 to 35 per cent to be “minor” or “broadly contextual”. In fact the consequence of not reducing the housing target would be devastating to the greenbelt in my constituency.
The Council also indicates that its approach to the preparations of the selective review is to “commit to a review of the Core Strategy within three years of Adoption so as to reflect up-to-date housing and population projections” (a.4). It seems to me that undertaking a review is largely irrelevant if the authority is determined to ignore the outcome of the review or merely consider the results “contextual”.
What are the implications, if any, of proceeding with the SAP examination now that a selective review of the Core Strategy is underway?
If the selective review were to conclude that the annual housing requirement is lower going forward than set out in the adopted Core Strategy, is there potential that land may be released from the green belt through the SAP to meet the requirements of the adopted Core Strategy, that may not have been necessary had the selective review concluded first?
The implications of proceeding with the SAP examination now that a selective review is underway are stark: the unnecessary release of greenbelt land in the Outer North East Housing Market Characteristic Area (HMCA).
To achieve its current target the Council is proposing to remove the Grade II listed Parlington Estate (MX2-39) from greenbelt, whilst at the same time attempting to put rural land into the greenbelt. This is deeply questionable. What is the point of having greenbelt land if the Council then decides to shift it around to suit its self-imposed housing target?
If the selective review concludes that a much lower housing target is required but the current SAP has already been adopted, then the implication is that a Grade II listed site will have been removed from the greenbelt and built on unnecessarily.
The Council has suggested that the selective review could be delayed for a “number of reasons” (b.4), but does not explain what these reasons are. It strikes me that if the Council was determined to act upon the outcome of the selective review then it would make every effort to bring forward the conclusion of the review and set a rigorous work schedule. At present the Council has a mere “ambition” for examination during winter 2018 – to date I have seen no formal work schedule.
The Council makes reference to Government guidance on new methodology being a reason for delay (b.5). In the House of Commons on Thursday 14th September the Secretary of State made the following statement introducing a third stage OAN assessment:
“That is why we have added a third stage of the assessment, which is to set a cap on the level of increase local authorities should plan for. If a local authority has an adopted plan that is less than five years old, the increase will be capped at 40% above the figure in the local plan. If the plan is not up to date then a cap above either the level in the plan or the ONS projected household growth for the area, whichever is the higher.
I believe this significantly impacts upon the Council’s housing target. Initial targets established by the Council aim to deliver circa 3,600 dwellings per year, whereas up-to-date ONS figures could suggest a revised figure circa 2,600 dwelling per year.
To quote the Minister of State: “Under the National Planning Policy Framework (NPPF), local planning authorities should ensure that any Plan they produce is based on adequate, up-to-date and relevant evidence. I no longer believe the Council’s current housing target, on which the Site Allocations Plan is centred, is based on adequate, up-to-date and relevant evidence, and the implications for greenbelt in the Outer North EAST HMCA if not corrected will be irreversible.
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