Agenda item

The report of the Director of City Development sets out a revised approach to progressing the Leeds Site Allocation Plan through its examination.  This is to ensure that the Council responsibility reflects a recent Government consultation and new evidence therein, which suggests that the housing need in Leeds is to reduce when compared to that in the adopted Core Strategy and therefore despite being sound, the Site Allocations Plan may result in green belt being released for housing which is ultimately not required.

The report sets out the initial scope of a revised approach to the SAP examination for consideration.  It updates the Panel on discussion with the DCLG and correspondence with SAP Inspectors.

The Director of City Development submitted a report setting out the initial scope of a revised approach to progressing the Leeds Site Allocations Plan (SAP) through the Examination process. The report also provided an update on discussions with the Department of Communities and Local Government (DCLG) and correspondence with the SAP Inspectors.

In presenting the report, the Group Manager, Policy & Plans, set out the background to the need to take a revised approach to the SAP to have full regard of the consultation and reiterated that the figure specified in the consultation was intended to be a minimum and did not reflect the need that some authorities, such as Leeds, may have to match housing growth with economic growth ambitions. Additionally, the Government had made it clear that local authorities at advanced stages of Plan making should carry on regardless of the new approach to housing need.

Specifically the revised approach sought to ensure that Leeds reflected the most recent DCLG consultation “Planning for the right homes in the right places” and the evidence which suggested that the housing need in Leeds is likely to reduce. Using the Government’s proposed standardised method to calculate housing need had set a lower baseline for Leeds (the consultation figure is 2,649 homes per annum; equating to 42,000 for a 16 year plan period); compared to the 70,000 (net) requirement contained within the adopted Core Strategy (2012-2028).

At the time the SAP was submitted to the Secretary of State, the Council’s view was that planning for a lower Core Strategy Review housing requirement would ensure that the release of Green Belt remained justified. However, although the current SAP is considered sound, it was recognised that in light of a lower housing figure trajectory, it may result in green belt land being released for housing development which is ultimately not required and may not meet Government guidance. Careful consideration of whether the sites proposed to be released from the green belt to meet the CS targets remain fully in accordance with the exceptional circumstances required to release land from the Green Belt was now required – having regard to the latest consultation and methodology; and a revised housing requirement through the Core Strategy Selective Review which had indicated a downward trajectory of housing need.

Three options available to the Council were outlined: 

(a) Withdraw the Plan - Withdrawal of the plan would mean that Leeds would have no plan in place for the delivery of housing; leading to less certainty for investors in the City and an increase in speculative development proposals

(b) Carry on notwithstanding the recent consultation (as advised by the Government consultation) which could place the Inspector in a very difficult position with regard to the exceptional circumstances required to justify green belt loss and may ultimately result in a Plan which the Council may find very difficult to Adopt without challenge.

Support was sought for the third option - (c) continue to assess the SAP against the Core Strategy but to modify the Plan to ensure that it reflects the latest evidence and has contextual regard to the downward trajectory of housing needs through the introduction of a third category of “Broad Locations” in line with Paragraph 47 of the National Planning Policy Framework (which states that housing requirement can be met in local plans through the identification of specific sites or broad locations). This approach would identify an amount of existing proposed housing allocations and safeguarded land as “Broad Locations”. These would remain in the Green Belt and not be released until a SAP review is undertaken, following adoption of the Selective Core Strategy Review.

During discussions held at the workshop on 4^th November 2017, Members had provided a steer that that there should be a fair share of “Broad Locations” across Leeds and each Housing Market Characteristic Area (HMCA).

(Councillor J Procter withdrew from the meeting for a short while at this point).

The Panel discussed the definition of the term “Broad Location”; noting that ‘broad locations’ had already been discussed in correspondence with the Inspectors as part of the SAP process. Officers reported that the SAP evidence already submitted would help support the revised approach and enable a boundary to be drawn around some of the sites already identified within the in the SAP for possible development in the future and define them as “Broad Locations”. These would remain in the Green Belt and would not be the same as Safeguarded Land sites which are removed from the Green Belt.

As part of the discussion, one Member commented that this approach would simply alter the designation of some of the land to be released for development aimed to deliver the 70,000 target. Additionally a request was made to present Members with information on the use of “Broad Locations” by other authorities. In response, the Legal Adviser explained that Leeds was in a unique position having already assessed sites and gathered detailed information as part of the SAP process; whereas other Local Planning Authorities did not yet have that level of detail and could only indicate broadly where land may be released and developed. Additionally very few other authorities had consistently used one approach to “Broad Locations”.

The Panel also discussed the following matters:

-  Acknowledged that the Authority had limited influence over developers’ build-out rate

-  The view that the 42,384 housing target figure should be seen as a baseline figure, allowing for variables across different HMCAs; demolitions etc.

-  A view that adopting a figure higher than 42,384 as calculated by Central Government would encourage investment and social mobility

-  The information available to the public about the two very separate SAP and Core Strategy Selective Review processes

-  The suggestion that the assessments should reference transport infrastructure; social sustainability; environmental and economic issues

-  A comment that a further informal workshop could facilitate discussions on the Authority’s approach to “Broad Locations” in order to inform the Councils position at future appeals

Finally, the Chair reiterated the findings of the workshop - that the spread of Broad Locations should be equable across the HMCAs and should take account of those areas where a HMCA was already committed to a high number of housing permissions.

RESOLVED -

a)  To note the revised approach to the Examination of the Site Allocations Plan as set out in the report as representing a prudent and responsible way forward when considered against the alternatives of withdrawing the Plan or proceeding irrespective of the consultation from the Government on housing need;

b)  That the comments made during the discussions be noted; and

c)  To note that the outcomes of the further technical work and any other procedural arrangements will be presented at the Panel meeting on 21st November.