Response to Leeds City Council's Site Allocation Process

Labour-run Leeds City Council has been consulting residents on its plan to build 12,200 new homes across the Elmet & Rothwell constituency.

For over three years Alec has been working with local community groups to oppose the Council’s housing target of 66,000 new homes across Leeds by 2028. This figure is too high and does not correlate with recent predictions on population growth. By reducing its target to 45,000 the Council would be able to utilise brownfield land first, before it developed greenfield and green belt land in our area. The Labour-run Leeds City Council has so far refused to rectify this problem.

Below is a copy of Alec’s submission to Leeds City Council’s public consultation on its site allocations process.

NB: Please read the response in full as each section refers to an argument made earlier in the response.

Leeds City Council’s Site Allocations Plan
The development of new homes in the Elmet & Rothwell constituency

Alec Shelbrooke MP
November 2015

A formal response to a public consultation on Leeds City Council’s Site Allocations Plan

Contents

1. Introduction
2. Background
3. The Core Strategy
   1. The Housing Target
   2. The Housing Market Characteristic Area (HMCA)
   3. Greenbelt Land

4. Sustainable Communities
   1. Community Infrastructure Levy
5. Outer South East (Garforth & Swillington and Kippax & Methley wards)
   1. Exclusion of Polling District GSN from the Housing Market Characteristic Area
   2. Garforth Town Council
   3. Peppered development across Garforth and surrounding villages
   4. Peckfield Farm (Sturton Grange Farm South)
   5. Alternative single standalone sites
   6. Sturton Grange Farm North

6. Outer North East (Wetherby & Harewood wards)
   1. Peppered development across rural villages
   2. Single standalone development
   3. Headley Hall
   4. Alternative single standalone sites

7. Outer South (Rothwell ward)
   1. High Speed Rail
   2. Rothwell Town Council
   3. Peppered development across Rothwell and surrounding villages
   4. Royds High School & Rothwell Leisure Centre

8. Conclusion

 

1. Introduction

The National Planning Policy Framework (NPPF), published by the Coalition Government on 27th March 2012, sets out a clear objective for local authorities to publish their ‘Local Plans’ for the allocation of new homes[1]. It provides a framework within which local communities (in the form of constitutionalised Neighbourhood Forums and Parish Councils) and elected local Councils can produce plans that reflect the needs of their local communities.

Leeds City Council published its Local Plan for public consultation in September 2015. The drafting of a Local Plan is a responsibility solely devolved to elected Councillors. As a local Member of Parliament I have made a number of representations to Leeds City Council throughout this process. Furthermore, following complaints from a number of constituents regarding Leeds City Council’s actions as a planning authority, I wrote to the Secretary of State for Communities & Local Government requesting Ministerial intervention. On 27 March 2015 the Minister of State for Housing & Planning, Brandon Lewis MP, responded:

“Local planning authorities have the statutory responsibility for planning and development matters in their areas. The Government is clear that localism and decentralisation are at the heart of their planning agenda and the general approach of the Secretary of State for Communities and Local Government is not to interfere with the jurisdiction of authorities on planning matters.”[2]

It is therefore evident that the detailed formation and adoption of the local authority’s plan is a matter to be determined solely by the local Council and Councillors in Leeds and not by the national Government in Westminster. Nevertheless, the consequences of the Council’s decisions will directly affect the communities I represent in Parliament and, following ongoing work with local Neighbourhood Forums and Parish Councils, I submit this document as my formal response to this public consultation.

2. Background

In the decade preceding 2010 housebuilding in the United Kingdom fell to its lowest level since the Second World War, while at the same time the UK population increased by over 3 million. This rise in population was in part due to there being 1.4 million more births than deaths and in part due to the policy decision of the 1997-2010 Governments to weaken immigration controls pertaining to migration from inside and outside of the European Union. The result was 2.1 million more international migrants arriving than emigrants leaving the UK[3].

These factors led to unprecedented pressures on the housing market across the United Kingdom, where demand outstripped supply and triggered a house price increase of 117% between Q1 2000 and Q2 2010[4]. Residents in my constituency have long complained of the difficultly young people and those on low incomes experience in getting onto the housing ladder in their locality and across their local authority area.

Nonetheless, and despite common misconceptions, the overall landmass of the United Kingdom that is currently developed is just 11.6% (this figure includes urban and rural infrastructure such as highways)[5]. Therefore, local authority officials, planners and developers would be forgiven for thinking that there is sufficient land available to develop new homes in the United Kingdom. This view does, however, ignore the fact that the UK is made up of communities and not just sprawling developments within vast swathes of agricultural land. Communities are made up of people, and people should have a right to shape the communities in which they live and work.

The National Planning Policy Framework (NPPF) decentralised and transferred power from central government to local authorities by requiring local councils to produce a deliverable rolling five year land supply for new dwellings. We must all recognise that factors of the previous decade have given rise to the need for more affordable housing in Leeds; housing to help young people into the property market, assist families to upsize and pensioners to downsize.

It would be a fair assessment to say that the policies of the 2010-2015 Government require local authorities to adopt a plan for the building of new homes. It would, however, be improper to suggest that central government is forcing councils to build on specific individual sites within an authority area. As is set out in legislation the responsibility for allocating sites for housebuilding lies solely with the local authority and it is therefore paramount that residents in my constituency are actively encouraged to engage with Leeds City Council’s public consultation on the allocation of land for new homes.

3. The Core Strategy

i) The Housing Target

The NPPF puts a requirement on local councils to have a deliverable rolling five year land supply for new housing, the figure at which Leeds City Council set its housing target was 66,000 new homes between 2012 and 2028. This figure was voted on and adopted by Leeds City Council on 12th November 2014.

In a Core Strategy Inquiry on 23rd October 2013, I made representations alongside local community groups and parish councils from my constituency, putting forward the argument that Leeds City Council had set its housing target too high for the plan period. Together with residents, Conservative Councillors and I questioned the validity of projected population figures used by the Council in setting its housing target and we urged the Council to re-evaluate its methodology. By reducing the figure to a lower target of 45,000 dwellings the Council could ease pressure on greenfield and greenbelt land in the city.

In March 2015, new figures from the Office for National Statistics confirmed that the number of households needed in Leeds is projected to rise by only 44,500 by 2028 – less than expected. Despite this new evidence reaffirming the arguments made by myself and communities in my constituency, the Executive Member for Planning on Leeds City Council, Labour Councillor Peter Gruen, responded:

“Our Core Strategy remains in place and we continue to work on preparing our draft Site Allocations Plan for new housing around the city, and we do have a number of sites around the city which have widespread support which can be brought forward for early approval.”[6]

Although local communities and I lost this argument against Leeds City Council, it remains my opinion that the current target is unachievable. By keeping the target of 66,000 dwellings the Council is putting considerable additional pressure on local communities to allocate land for the building of new homes. In doing so, by opting for the higher figure, the Council then dilutes its ability to allocate housing on brownfield land first. I therefore urge the Council to review its housing target before it adopts the Core Strategy.

ii) The Housing Market Characteristic Area (HMCA)

Leeds City Council has chosen to allocate land for its housing target of 66,000 dwellings by creating eleven Housing Market Characteristic Areas (HMCA) across the City. Three of these HMCAs cover the five electoral wards within my constituency[7]:

HMCAOuter North EastOuter South EastOuter South

Electoral WardWetherby

 

Harewood

Garforth & Swillington

 

Kippax & Methley

Rothwell

Housing Allocation5,000 residential dwellings4,600 residential dwellings2,600 residential dwellings

 

Whilst I understand the objective behind grouping local communities with similar market characteristics into designated areas, it is my view that adopting such an approach within the Core Strategy will lead to the premature development of greenfield and greenbelt land across the local authority area.

By apportioning a set number of new homes to each HMCA within this plan period, the Council is encouraging a situation by which developers will cherry pick the most profitable sites first. For example, a greenbelt site in my constituency with planning permission for large executive homes would acquire a greater profit margin for a developer than a brownfield site with planning permission for smaller affordable homes in the inner city. By offering developers greenbelt, greenfield and brownfield sites at the same time, the Council is discouraging the development of affordable homes; the very type of residential development most required by young families and elderly downsizers in Leeds. Furthermore, in doing so, the decision drastically slows the regeneration of brownfield areas.

Leeds City Council should therefore not only revise down its housing target of 66,000 dwellings to a lower figure of 44,500, but at the same time re-evaluate the format within which it has constrained its ability to allocate brownfield land for development before greenfield or greenbelt sites.

 

iii) Greenbelt Land

The National Planning Policy Framework (NPPF) sets out a national position on the protection of greenbelt land in the United Kingdom:

“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence[8].” NPPF, DCLG.

In Leeds City Council’s Site Allocation Plan 20% of all sites allocated for residential development are apportioned on land currently classified as greenbelt. A further 18% of land is classified as greenfield and 62% brownfield. Across the local authority area brownfield sites allocated for residential dwellings account for 39,600 of the 66,000 homes in the housing target, this means over 26,000 dwellings have been allocated for development on greenfield or greenbelt land[9].

Within my constituency of Elmet & Rothwell, Leeds City Council has allocated 19 greenbelt sites for development, totalling 6,937 dwellings (57% of all new homes). These sites are detailed in the table below:

HMCAPlan ReferenceAddress% of Site Classified as Green BeltCapacity

Outer North EastHG2-24Keswick Lane, Bardsey99.99%10

Outer North EastMX2-33Headley Hall, Nr Bramham98.64%3,000

Outer North EastHG2-25Farfield House, Bramham96.25%14

Outer South EastHG2-126Micklefield Railway Station85.19%18

Outer South EastHG2-124Sturton Grange Farm South (Peckfield Farm), Garforth99.88%2314

Outer South EastHG2-131Whitehouse Lane, Great Preston36.98%40

Outer South EastHG2-127Newton Farm, Micklefield96.65%42

Outer South EastHG2-132Brigshaw Lane, Kippax100%76

Outer South EastHG2-133Ninevah Lane, Allerton Bywater99.98%57

Outer South EastHG2-128Selby Road/Leeds Road, Kippax100%40

Outer SouthHG1-411Royds Green Farm, Oulton100%7

Outer SouthHG2-177Alma Villas, Woodlesford11.75%12

Outer SouthHG2-173Haighside, Rothwell99.98%578

Outer SouthHG2-175Bullough Lane, Rothwell99.98%154

Outer SouthHG2-179Fleet Lane, Oulton100%40

Outer SouthHG2-174Wood Lane, Rothwell99.88%52

Outer SouthHG2-183Swithens Lane, Rothwell100%136

Outer SouthHG2-180Fleet Lane, Oulton99.99%322

Outer SouthHG2-186Main Street, Methley19.37%25

   Total dwellings6,937

 

Leeds City Council should heed arguments made by local communities at the Core Strategy Inquiry and acknowledge that there is now a compelling case to revise down the housing target. In doing so, the Council could protect many of the 19 greenbelt sites in my constituency and a great many more across the local authority area. By adopting a lower recommended housing target of 44,500 dwellings, Leeds City Council could keep its existing allocation of 39,600 homes on brownfield sites across Leeds, leaving only 5,000 dwellings to be allocated across current greenfield sites in the local authority area.

From my conversations with activist groups it is my opinion that communities would be considerably more willing to engage with a process to allocate this smaller number of homes across greenfield land in the City if they knew that the allocation process had utilised all brownfield sites first.

 

 4. Sustainable Communities

NB: The following comments and observations are made on plans currently put forward by Leeds City Council (i.e. with a housing target of 66,000 new dwellings).

When considering the allocation of sites for new homes in my constituency I urge Leeds City Council to acknowledge the boundaries of existing communities. Peppering small developments of a few hundred new homes across existing communities will result in death by a thousand cuts for villages and towns. Existing infrastructure in our rural and semi-rural communities is already reaching saturation with local village schools and health services at capacity. It is therefore paramount that new development is built concurrently with new services to support it, so new primary and secondary schools, shops, health centres and associated services form part of new settlements.

Notwithstanding my opposition to Leeds City Council’s current housing target, and the way in which it has chosen to allocate housing across Housing Market Characteristic Area (HMCA), local communities in Elmet & Rothwell now have to deal with the hand dealt to us by the local authority. This means Leeds City Council will be allocating land for the development of 12,200 homes in my constituency. Under these circumstances it is my strongly held view that the allocation of housing within each HMCA should be apportioned to single standalone sites with new infrastructure built in to service those new homes.

It’s the natural evolution of communities that they will grow and expand over time, but such expansion should occur evenly and alongside supporting infrastructure. It is not fair to those currently living in existing communities or those who purchase a home within a new development if the nearest school to their home has no space left to accommodate their child. It is therefore vital that Leeds City Council acknowledges its responsibility to existing communities when considering the location of new developments across my constituency. Accordingly the right thing for the council to do within the parameters it has set itself would be to allocate housing to single standalone developments.

Crucially, new developments must be formed as sustainable communities, distinctly separate from existing communities and, in most part, self-serving with new highways infrastructure. Within my constituency it would make logistical and financial sense to position any new single standalone communities alongside, or within easy reach of, the A1M or M62 motorways.

i) Community Infrastructure Levy

The Community Infrastructure Levy (CIL) came into force in April 2010. It allows local authorities in England and Wales to raise funds from developers undertaking new building projects in their area. The money can be used to fund a wide range of infrastructure that is needed as a result of development. This includes new or safer road schemes, flood defences, schools, hospitals and other health and social care facilities, park improvements, green spaces and leisure centres[10].

The CIL charging authority covering my constituency is Leeds City Council.

Guidance from the Department for Communities & Local Government states that local authorities are required to spend the levy’s funds on the infrastructure needed to support the development of their area and they will decide what infrastructure is needed. The levy is intended to focus on the provision of new infrastructure and should not be used to remedy pre-existing deficiencies in infrastructure provision unless those deficiencies will be made more severe by new development.

Using new powers introduced in the Localism Act 2011, the Government requires charging authorities such as Leeds City Council to allocate a meaningful proportion of levy revenues raised in each neighbourhood back to that neighbourhood. Local authorities are advised to work closely with neighbourhoods to decide what infrastructure they require.

The CIL further strengthens the argument for Leeds City Council to allocate housing to single standalone sites in locations separate from existing communities. Funds collected by Leeds City Council from the levy should be used to make new settlements sustainable, by upgrading existing highways and developing new infrastructure to service new developments.

It is, far and away, a more sensible option to construct new infrastructure such as schools and health centres within a new development than it is to use funds from the levy to patch up existing services. In many cases, local schools don’t have the physical land space to expand, whereas new amenities in new developments can be included in initial detailed planning applications.

I urge Leeds City Council, as the charging authority for the Community Infrastructure Levy, to commit to delivering a fair settlement for the local communities affected by new development.

 

5. Outer South East (Garforth & Swillington and Kippax & Methley wards)

Leeds City Council has determined that land for 4,600 new homes must be allocated within the Outer South East Housing Market Characteristic Area (HMCA), this area includes both the Garforth & Swillington and Kippax & Methley wards.

i) Exclusion of Polling District GSN

When drafting the boundaries of each HMCA it appears that Leeds City Council decided to exclude land within the Garforth & Swillington ward from the Outer South East HMCA. This land is known electorally as polling district GSN but is referred to within Leeds City Council’s Site Allocation documents as ‘Aire Valley Skelton Gate’. Leeds City Council has chosen to allocate this land to the Leeds East HMCA and has credited the land with the capacity to accommodate 3,328 dwellings.

I have been working alongside the Garforth Neighbourhood Forum throughout this site allocation process and have questioned the Council’s decision to disestablish this land from the Outer South East HMCA. I have yet to receive a response explaining these actions.

Furthermore, in its own documentation relating to the Outer South East HMCA, Leeds City Council uses this land in the GSN polling district to calculate the overall green space within the Outer South East. On this point, Leeds City Council is obviously at odds with itself.

The Garforth Neighbourhood Forum has argued that this land should be excluded from the Leeds East HMCA and re-introduced to the Outer South East HMCA. Collectively we have questioned why representations to this effect were not made by Councillors when the HMCA boundaries were being considered. There is precedent for Councillors successfully changing the boundaries of the HMCAs as this happened in the Outer North East following a successful partnership of work between elected Councillors and representatives from the Scholes community.

The Garforth Neighbourhood Forum is right to accuse the Council of increasing the pressure to build on land in and around Garforth by excluding the GSN site from the Outer South East HMCA and I urge Leeds City Councillors to look again at crediting this site back into the same HMCA as Garforth.

ii) Garforth Town Council

An increasing amount of powers are being decentralised from central government to local authorities, in many instances powers are being further devolved to town and parish councils. My constituency is well served by town and parish councils, from Wetherby Town Council is the north of the constituency to Allerton Bywater Parish Council in the south, there are 22 town and parish councils currently serving their local communities.

Garforth does not, however, have any existing example of a publicly elected town council that is constituted to receive or administer decisions on behalf on the local community.

As detailed in section 4.i. legislation introducing the Community Infrastructure Levy allows for a percentage of the levy to be handed back to the community for the upgrading and delivery of new services affected by development. In most instances the body administering such funds is the town or parish council.

The Garforth Neighbourhood Forum has recognised that this has created a problem for Garforth in terms of dealing with the pressure of Leeds City Council’s Core Strategy and, with certain conditions, I support their call for the establishment of a locally elected body to further decentralise powers of the state.

As a Conservative it is my natural instinct to resist any move to create a further layer of governance, locally or nationally. However, it is also one of my core beliefs that decisions directly affecting only local communities should be made as local as possible. Therefore, I believe the formation of a Garforth Town Council would serve Garforth much better than the existing formation of local government, but it is my view that the following reforms must occur at the same time:

• Garforth residents already pay their fair share of Council Tax and I fundamentally disagree that taxpayers should see their rates increase to pay for another layer of governance.
• Like all electoral wards in Leeds, Garforth is currently served by 3 elected Councillors. As an individual Member of Parliament I serve the same geographical area as is served by 15 Councillors; I think this is excessive and costly. The Government is currently seeking to reduce the number of MPs represented in the House of Commons and I therefore believe Leeds City Council should reduce its number of Councillors at the same time.
• Leeds City Council currently conducts local elections three years out of four, at significant cost to the Council. The UK Parliament is elected for a five-year term of office and I believe Leeds City Council should also move to this format: electing Councillors in an all-out election once every five years at an election held at a mid-term juncture between Parliamentary elections. This would save Leeds City Council the considerable cost of running elections three years out of four.
• In summary, each Leeds City Councillor receives an annual salary for their service. By reducing the number of Councillors in each ward I believe Leeds City Council could better utilise its money to create a more local tier of governance (i.e. Garforth Town Council) without increasing taxes for local rate payers.

iii) Peppered development across Garforth

I have outlined my objection to infill development peppered across Garforth. We experience severe flooding annually on account of an outdated drainage system that has been unable to cope with increased development between 1970s and the present day. I share the view of the Garforth Neighbourhood Forum and the Garforth Flood Group that further development within Garforth town will lead to permanent flood issues for owners of existing properties.

On the basis of flood risk management and the saturation of existing schools, health centres and highways, I would strongly oppose development on the following sites:

1. Land behind homes on A63/Selby Road leading south to the Holiday Inn, Garforth
2. Land opposite homes on the A642/Wakefield Road, Garforth
3. Land at Town End on the A642/Aberford Road, Garforth
4. Land either side of Barwick Road, Garforth
5. Land behind Sandgate Drive, Kippax

 

iv) Peckfield Farm: Site 1232B (HG2-124)

Leeds City Council has earmarked land known locally at Peckfield Farm (known to the Council as Sturton Grange Farm South) for the development of 2,314 dwellings. Notwithstanding my continuing objection to the Council’s inflated housing target, I welcome the approach of designating one single standalone site with the capacity to develop new infrastructure within it.

Peckfield Farm does not, however, satisfy my belief that single standalone developments should be beside a motorway to alleviate further pressure on existing highways. Peckfield Farm is therefore not a satisfactory compromise for the community of Garforth and the surrounding villages of Kippax and Ledston Luck. The site is hindered by its location beside the A63 Selby Road which is already a hotspot for traffic congestion at peak travel times, a situation made worse by recent development of 79 dwellings on Garforth Cliff (Harvest View).

In short, there is no reasonable way in which the Council can engineer a solution to prevent associated traffic from 2,314 new homes travelling west down the A63 Selby Road.

I have been made aware that Councillors are discussing the idea of a bypass, from the Peckfield roundabout to the Holiday Inn roundabout, over greenfield land in the Kippax & Methley ward; I would urge Leeds City Council to reject this idea as nothing less than a Machiavellian approach to deceive local residents that this preferred site would create no impact on Garforth. The financial impact on the Council of constructing such a bypass would result in the Council either imposing a roof tax to pay for its construction or using funds generated from the Community Infrastructure Levy (CIL). If the Council adopted the latter approach then there would be less money available from the CIL to fund new schools, health centres and services which would lead to increased saturation of existing services within Garforth.

Finally, elected representatives were recently made aware that the landowner of the Peckfield Farm site (Sturton Grange Farm South) does not own the Mineral Rights over this land, thereby bringing into question the deliverability of the site for development.

On receipt of this information I contacted the Garforth Neighbourhood Forum and elected representatives in Garforth to raise my concern that if this site is not deliverable then it will not be included in the Council’s Core Strategy, thereby putting at risk all the infill sites in Garforth unless another single standalone site is included in the Council’s plan.

Local Councillors responded: “I’m very mindful that these are community matters and residents should steer this via the current consultation”.

 

v. Alternative single standalone sites

Following a number of meetings with the Garforth Neighbourhood Forum I understand that the forum itself, much like the community, is split on where new development should be located, if at all.

Within this section of my submission I would like to praise the committee members of the Garforth Neighbourhood Forum who, with very little support, have kept momentum and promoted community engagement in relation to Leeds City Council’s site allocations process.

It is my opinion that local Councillors and I are elected to positions of responsibility in order to show leadership and in difficult circumstances such as these, take the bull by the horns and not simply dodge the bullet. On my part I have therefore consistently argued against Leeds City Council’s housing target but equally acknowledged that this is now the target that the ruling administration has democratically chosen for our area. Whilst I am disappointed by this decision, it would be irresponsible of me to simply walk away from the Garforth community and let Leeds City Council ride roughshod over our town.

In May 2015 I stood on an election manifesto that made my position on planning clear: I oppose the housing target imposed on our area by Leeds City Council and urge the Council to adopt a strategy of single standalone communities if it is determined to go ahead without revising down the housing figure. I was re-elected on this platform and I therefore view it as a responsibility to my electorate to campaign against peppered development across Garforth and in favour of one single standalone site.

In discussions on the location of sites, the Forum members and I reflected on a number of options available in the Outer South East HMCA, some of which have been discussed earlier in this document.

In light of the questionable deliverability of the Council’s preferred site, it is therefore important that local residents, the Forum and I take deliverability into consideration when responding to the Council’s consultation. With this in mind, we can only draw attention to sites that have a landowner’s willingness to develop for housing.

I am deeply concerned that unless Leeds City Council revise down its housing target or review the boundaries of its Housing Market Characteristic Area, the housing allocation in the Outer South East may be subject to a legal challenge that could put at risk all the infill sites across the area, something that would result in death by a thousand cuts for our town and surrounding villages.

On 19th October 2015, local Councillors and I received correspondence indicating that the Council’s preferred Peckfield Farm site (1232B) was undeliverable as the landowner does not possess all rights over the land. On receipt of this correspondence I wrote to local Councillors and the Garforth Neighbouhood Forum to outline my concerns that this could have an effect on the Council’s site allocations in Garforth. I reiterated my concern that if the Council’s preferred site for the development of 2,314 homes is undeliverable then this may leave the Outer South East wide open for peppering the allocation on infill sites across the area, for example, down Wakefield Road and Selby Road with no new infrastructure, as opposed to it being within one single stand-alone site with new infrastructure built in.

I am resolute in my objection to infill developments but I fear this is what Leeds City Council’s actions will lead to. If the Council continues to push ahead with a desire to allocate site 1232B for the building of new homes, knowing that the site is undeliverable, then the Council’s Local Plan could also be deemed undeliverable when it is reviewed by an independent planning inspector. If this is the case, I fear that the Council will simply amend its plan and allocate infill sites across the Outer South East for peppered development, instead of choosing one strategic single standalone site elsewhere within the Outer South East HMCA.

 

vi) Sturton Grange Farm North: Site 1232A

As I have repeated many times, I remain resolute in the view that Leeds City Council should reduce its housing target figure from 66,000 dwellings to 44,500, thereby reducing the pressure on areas such as Garforth to allocate greenfield and greenbelt land for the development of new homes. We are, however, where we are, and at this present time Leeds City Council is consulting with local communities as to where such development should be located within the Garforth area.

Acknowledging, albeit reluctantly, that Leeds City Council is asking communities in the Outer South East HMCA to take an additional 4.600 dwellings in its plan period, it is my opinion that the allocation of homes should have the following conditions if the Council is unwilling to review its position:

1. Homes should be developed only on one single standalone site with excessive capacity available to develop supporting infrastructure such as schools, health centres and additional services.
2. Single standalone sites should be located adjacent to the existing motorway network to allow for the free flow of traffic along such corridors, thereby restricting additional pressure on current highways.
3. Standalone sites should be formed with a clear divide between existing communities, so they are not seen as an extension of existing communities. Furthermore, green bunds should be required between communities and classified as greenbelt land.
4. Standalone sites should not be located where access in and out of the existing towns is needed for the site, it should be self-servicing with new highways extended from existing trunk roads and motorways only.

In reviewing the threat that peppered developments across Garforth would cause to existing infrastructure, and in light of the knowledge that the deliverability of the Council’s preferred site is now in question, it is my view that the Council should consult with residents about site 1232A before it considers peppering development across Garforth, for example, on sites down Wakefield Road, Selby Road and Barwick Road, with no additional infrastructure.

I would like to see the Council make an assessment on the comparative impact on Garforth of developing this site with its location next to the M1 motorway and its ability to relieve additional pressure on Garforth town, compared to the Council’s preferred Peckfield Farm site or individual smaller sites within Garforth itself.

Nevertheless, if Leeds City Council were to consider placing its housing allocation to the Sturton Grange Farm North site (assuming it remains reluctant to reduce its housing target), I would, only support such a decision if the Council attached the following conditions to any future outline or detailed planning application:

1. The site must be self-contained within its boundaries, there must be no extension of existing highways within the housing estates off New Sturton Lane, Cedar Ridge or Braemar Drive to access the site.
2. Access to the site must not be granted from the A642 Aberford Road.
3. Leeds City Council must use funds acquired from the CIL payment to upgrade the A656/Ridge Road bordering the site to a dual-carriageway.
4. Access from the site onto a new A656/Ridge Road dual-carriage way must only be north-bound, i.e. cars exiting the site must be forced up to the M1 junction 47 roundabout from where the majority of traffic will enter onto the motorway network to travel north or south rather than further congesting the A642/Wakefield Road or the A63/Selby Road to the south.
5. An agreement must be made between Aberford Parish Council and Leeds City Council for a fair allocation of CIL payments made by the Council back to the community, it would be wrong for Aberford Parish Council to claim an unfair share of this money when the site is nearer to Garforth. Additionally, every effort must be made to redraw the parish boundary should a Garforth Town Council be established.
6. The M1 junction 47 motorway slip roads northbound and southbound will need upgrading to accommodate additional traffic.
7. Leeds City Council and external agencies must ensure that the drainage needs of any new development is not simply connected to the existing drainage system servicing Garforth. A new community must be self-sufficient in its drainage needs with assessments should be made of additional flood defences for Garforth town.
8. The site must include new school provision onsite, a new health centre and retail opportunities to service the new dwellings.
9. Agreements should be made with developers for the provision of new facilities and amenities in Garforth to benefit the existing community, for example, new sports facilities and a new football stadium.
10. Leeds City Council must enforce that any development retains the existing trees and shrubbery that currently separates the farmland from the housing estate. Furthermore, planners must demand the installation of a green bund and shared community parkland here so any new development does not look onto the existing housing estate.
11. Any new community on this site must not be known as Garforth. This must be a separate village in its own right, with its own name and highways.

Notwithstanding all of the above, Leeds City Council could negate the pressure forced upon our communities by re-evaluating its approach to the allocation of its housing target.

 

6. Outer North East (Wetherby and Harewood wards)

Leeds City Council has determined that land for 5,000 new homes must be allocated within the Outer North East Housing Market Characteristic Area (HMCA), this area includes both the Harewood and Wetherby wards of my constituency.

i) Peppered development across rural villages

I have outlined my objection to infill development peppered across the rural villages of the Wetherby and Harewood wards. Highway infrastructure and the saturation of existing services such as schools and health centres are the main concerns regarding overdevelopment in these rural villages.

As previously outlined, it is paramount that any new development is sustainable and this can only be achieved if Leeds City Council choses to apportion its allocation of housing in the Outer North East to single standalone site, next to the motorway junction and with new schools and services built in.

I therefore strongly oppose large developments on the following sites:

1. Land East of Scholes
2. Land at Thorp Arch Trading Estate
3. Land off Leeds Road, Collingham
4. Land off Grove Road, Boston Spa

 

ii) Single standalone development

Within this section of my submission I would like to praise the neighbourhood plan groups and parish councils across the Wetherby & Harewood wards who have engaged fully in this process with the support of their elected Leeds City Councillors. Additionally, Scholes resident George Hall has provided extensive support to communities throughout this process and has kept momentum whilst promoting community engagement.

Alongside these groups I have consistently argued against Leeds City Council’s housing target. Nevertheless, I acknowledge that this is now the target that the ruling administration has democratically chosen for our area and whilst I am disappointed by this decision, it would be irresponsible of me to simply walk away from the rural villages in my constituency and let Leeds City Council ride roughshod over them.

In May 2015 I stood on an election manifesto that made my position on planning clear: I oppose the housing target imposed on our area by Leeds City Council and urge the Council to adopt a strategy of single standalone communities if it is determined to go ahead without revising down the housing figure. I was re-elected on this platform and I therefore view it as a responsibility to my electorate to campaign against peppered development across the Wetherby and Harewood wards and in favour of one single standalone site.

In discussions on the location of sites, the neighbourhood forum members, activist groups and I reflected on a number of options available in the Outer North East HMCA, some of which have been discussed earlier in this document.

In view that the Council’s final site allocation will be subject to an independent legal review by a planning inspector, it is important that local residents, neighbourhood forums and parish councils take deliverability into consideration when responding to the Council’s consultation. Simply saying we don’t want any housing at all is not an option.

 

iii) Headley Hall – Site MX2-33

As I have repeated many times, I remain resolute in the view that Leeds City Council should reduce its housing target figure from 66,000 dwellings to 44,500, thereby reducing the pressure on areas such as Wetherby and Harewood to allocate greenfield and greenbelt land for the development of new homes. We are, however, where we are, and at this present time Leeds City Council is consulting with local communities as to where such development should be located within the Outer North East HMCA.

Acknowledging, albeit reluctantly, that Leeds City Council is asking communities in the Outer North East HMCA to take an additional 5,000 dwellings in its plan period, it is my opinion that the allocation of homes should have the following conditions if the Council is unwilling to review its position:

1. Homes should be developed only on one single standalone site with excessive capacity available to develop supporting infrastructure such as schools, health centres and additional services.
2. Single standalone sites should be located adjacent to the existing motorway network to allow for the free flow of traffic along such corridors, thereby restricting additional pressure on current highways.
3. Standalone sites should be formed with a clear divide between existing communities, so they are not seen as an extension of existing communities. Furthermore, green bunds should be required between communities and classified as greenbelt land.
4. Standalone sites should not be located where access in and out of the existing towns is needed for the site, it should be self-servicing with new highways extended from existing trunk roads and motorways only.

In reviewing the threat that peppered developments across our rural villages would cause to existing infrastructure it is my view that the Council should consider site MX2-33 before it considers peppering development across the Wetherby and Harewood wards, for example, on sites in Scholes, Boston Spa and Thorp Arch, with no additional infrastructure.

I am aware that, at the eleventh hour, the landowner of site MX2-33 (The University of Leeds) withdrew the site from the site allocation process. The landowner did so citing the following reason:

“Our work to explore the feasibility of the development has revealed the significant up-front costs and scale of investment required to provide the infrastructure for a development of this size[11].”

I urge Leeds City Council to reopen negotiations with the University of Leeds and in order to explain how the removal of this site from the allocation process puts greenfield and greenbelt sites right across the Outer North East at risk, and does so with no new infrastructure.

Furthermore, I urge the Council to discuss options for financing with the University of Leeds by opening dialogue with the Homes & Communities Agency (HCA) as regards the Infrastructure Fund. It is my belief that discussion with the HCA might bring about additional finance opportunities for the University of Leeds by way of financial loans for the preparation of the site for development. It would seem illogical to me that a University, with charitable status, would not pursue an opportunity to increase the value of its land by submitting it for development within the site allocation process. Pursuing the opportunity of a HCA loan to finance the site would not necessarily cost the landowner anything upfront, it would just mean they made a little less profit on their investment.

If Leeds City Council were to consider placing its housing allocation to the Headley Hall site (assuming it remains reluctant to reduce its housing target), then I would urge the Council to attach the following conditions to any future outline or detailed planning application:

1. The site must be self-contained within its boundaries, there must be no extension of existing highways from Bramham village via the Aberford Road to access the site.
2. The allocation of housing must be apportioned to the south of the site so there is significant green space and land between a new settlement and the existing settlement of Bramham, i.e. so you would not be able to see this from Bramham village.
3. Leeds City Council planners must demand the installation of a green bund to separate the new development from existing Bramham dwellings.
4. The A1M junction 45 motorway slip roads northbound and southbound will need upgrading to accommodate additional traffic.
5. Leeds City Council and external agencies must ensure that the drainage needs of any new development is not simply connected to the existing drainage system servicing Bramham. A new community must be self-sufficient in its drainage needs.
6. The site must include new school provision onsite, a new health centre and retail opportunities to service the new dwellings.
7. Any new community on this site must not be known as Bramham. This must be a separate village in its own right, with its own name and highways.

Notwithstanding all of the above, Leeds City Council could negate the pressure forced upon our communities by re-evaluating its approach to the allocation of its housing target.

iv) Alternative single standalone sites

Leeds City Council must make every effort to ensure that the allocation of its housing target is delivered without unnecessary blight to villages across the Wetherby and Harewood wards. I believe the Council should make every effort to locate a strategic single standalone site before peppering development across rural villages, as such I urge the Council to go back an review all available sites to locate one single standalone development that should be next to the motorway network where new infrastructure can be built in to support a new settlement.

If the Council is unwilling to pursue options available at Headley Hall, then I urge the Council to review other available single standalone sites around the A1M/A64 junction near Aberford and Bramham before it peppers development in our villages with no new infrastructure.

It is my view that Leeds City Council should consider the following conditions when looking for a strategic standalone development site:

1. Homes should be developed only on one single standalone site with excessive capacity available to develop supporting infrastructure such as schools, health centres and additional services.
2. Single standalone sites should be located adjacent to the existing motorway network to allow for the free flow of traffic along such corridors, thereby restricting additional pressure on current highways.
3. Standalone sites should be formed with a clear divide between existing communities, so they are not seen as an extension of existing communities. Furthermore, green bunds should be required between communities and classified as greenbelt land.
4. Standalone sites should not be located where access in and out of the existing towns is needed for the site, it should be self-servicing with new highways extended from existing trunk roads and motorways only.

Notwithstanding all of the above, Leeds City Council could negate the pressure forced upon our communities by re-evaluating its approach to the allocation of its housing target.

 

7. Outer South (Rothwell ward)

Leeds City Council has determined that land for 2,600 new homes must be allocated within the Outer South Housing Market Characteristic Area (HMCA), this area includes the Rothwell ward of my constituency.

i) High Speed Rail

Over the past three years I have been working alongside local community groups and residents in opposing HS2 Ltd’s initial proposed route through Woodlesford. Since the publication of this first draft route, the community and I have made significant progress in raising the agenda of how inappropriate such a route would be. In early 2015, the Prime Minister and Chancellor of the Exchequer visited Leeds and announced that, following calls for the delivery of HS2 in Leeds to be revised, Sir David Higgins would publish an interim report by the end of 2015 with options to relocate the HS2 station into the city centre, thereby altering the way in which HS2 will enter the city. The Chancellor announced that HS2 Ltd, Network Rail and Leeds City Council would be equal partners in the delivery of options in that interim report.

Three years ago I put forward an alternative route suggestion to HS2 Ltd, this alternative route was supported by the community of Woodlesford. It is my belief that any proposed HS2 route into Leeds should follow existing transport corridors of blight and not cause unnecessary destruction of villages and towns.

Our community awaits the publication of HS2 Ltd’s interim report and the publication of a proposed route for HS2. I therefore support the view of the Woodlesford & Oulton Neighbourhood Forum that Leeds City Council should extend its timescale for site allocations until an announcement on High Speed Rail has been made. It is inconceivable that Leeds City Council, with its own role in supporting the delivery of HS2 to Leeds, could expect communities to plan for the building of new homes when it does not yet know the outcome of the consultation on HS2’s proposed route.

I urge Leeds City Council to suspend its site allocation plan for the Outer South until such an announcement has been made public.

 

ii) Rothwell Town Council

An increasing amount of powers are being decentralised from central government to local authorities, in many instances powers are being further devolved to town and parish councils. My constituency is well served by town and parish councils, from Wetherby Town Council is the north of the constituency to Allerton Bywater Parish Council in the south, there are 22 town and parish councils currently serving their local communities.

Rothwell does not, however, have any existing example of a publicly elected town council that is constituted to receive or administer decisions on behalf on the local community.

As detailed in section 4.i. legislation introducing the Community Infrastructure Levy allows for a percentage of the levy to be handed back to the community for the upgrading and delivery of new services affected by development. In most instances the body administering such funds is the town or parish council.

For the same arguments as have been put forward by other towns in my constituency, I support calls for the establishment of a locally elected body to further decentralise powers of the state.

As a Conservative it is my natural instinct to resist any move to create a further layer of governance, locally or nationally. However, it is also one of my core beliefs that decisions directly affecting only local communities should be made as local as possible. Therefore, I believe the formation of a Rothwell Town Council would serve Rothwell much better than the existing formation of local government, but it is my view that the following reforms must occur at the same time:

• Rothwell residents already pay their fair share of Council Tax and I fundamentally disagree that taxpayers should see their rates increase to pay for another layer of governance.
• Like all electoral wards in Leeds, Rothwell is currently served by 3 elected Councillors. As an individual Member of Parliament I serve the same geographical area as is served by 15 Councillors; I think this is excessive and costly. The Government is currently seeking to reduce the number of MPs represented in the House of Commons and I therefore believe Leeds City Council should reduce its number of Councillors at the same time.
• Leeds City Council currently conducts local elections three years out of four, at significant cost to the Council. The UK Parliament is elected for a five-year term of office and I believe Leeds City Council should also move to this format: electing Councillors in an all-out election once every five years at an election held at a mid-term juncture between Parliamentary elections. This would save Leeds City Council the considerable cost of running elections three years out of four.
• In summary, each Leeds City Councillor receives an annual salary for their service. By reducing the number of Councillors in each ward I believe Leeds City Council could better utilise its money to create a more local tier of governance (i.e. Rothwell Town Council) without increasing taxes for local rate payers.

 

iii) Peppered development across Rothwell and surrounding villages

I have outlined my objection to infill development peppered across our towns and villages. Highway infrastructure and the saturation of existing services such as schools and health centres are the main concerns regarding overdevelopment in existing communities.

As previously outlined, it is paramount that any new development is sustainable and this can only be achieved if Leeds City Council chooses to apportion its allocation of housing in the Outer South to a single standalone site, near to the motorway network and with new schools and services built in.

I therefore strongly oppose peppering developments on numerous sites within and around Rothwell, Woodlesford, Oulton and Carlton without new infrastructure. I am opposed to the sites selected by Leeds City Council and put forward for consultation.

Within this section of my submission I would like to praise the neighbourhood plan groups across the Rothwell ward who have engaged fully in this process and have provided support to communities throughout this process whilst keeping momentum and promoting community engagement.

I have consistently argued against Leeds City Council’s housing target. Nevertheless, I acknowledge that this is now the target that the ruling administration has democratically chosen for our area and whilst I am disappointed by this decision, it would be irresponsible of me to simply walk away from communities in my constituency and let Leeds City Council ride roughshod over them.

In May 2015 I stood on an election manifesto that made my position on planning clear: I oppose the housing target imposed on our area by Leeds City Council and urge the Council to adopt a strategy of single standalone communities if it is determined to go ahead without revising down the housing figure. I was re-elected on this platform and I therefore view it as a responsibility to my electorate to campaign against peppered development across the Rothwell ward and in favour of one single standalone site.

 

iv) Royds High School & Rothwell Leisure Centre

As I have repeated many times, I remain resolute in the view that Leeds City Council should reduce its housing target figure from 66,000 dwellings to 44,500, thereby reducing the pressure on areas such as Rothwell to allocate greenfield and greenbelt land for the development of new homes. We are, however, where we are, and at this present time Leeds City Council is consulting with local communities as to where such development should be located within the Rothwell area.

Acknowledging, albeit reluctantly, that Leeds City Council is asking communities in the Outer South HMCA to take an additional 2.600 dwellings in its plan period, it is my opinion that the allocation of homes should have the following conditions if the Council is unwilling to review its position:

5. Homes should be developed only on one single standalone site with excessive capacity available to develop supporting infrastructure such as schools, health centres and additional services.
6. Single standalone sites should be located near to the existing motorway network to allow for the free flow of traffic along such corridors, thereby restricting additional pressure on current highways.
7. Standalone sites should be formed with a clear divide between existing communities, so they are not seen as an extension of existing communities. Furthermore, green bunds should be required between communities and classified as greenbelt land.
8. Standalone sites should not be located where access in and out of the existing towns is needed for the site, it should be self-servicing with new highways extended from existing trunk roads and motorways only.

In reviewing the threat that peppered developments across the Rothwell area would cause to existing infrastructure, and in light of the knowledge that existing facilities in the location are reaching a state of disrepair, for example, Royds High School, I urge Leeds City Council to go back to the drawing board and reassess how it can better deliver its imposed housing allocation for the Outer South.

I would like to see the Council make an assessment on the comparative impact on Rothwell of developing small peppered developments on sites across the Rothwell district, compared to allocating housing to one strategic site within the Outer South.

Before the communities within the Outer South are asked to give their views on sites put forward by Leeds City Council, I believe Leeds City Council should make an assessment on the feasibility of utilising land within its ownership at Royds High School and Rothwell Leisure Centre to develop a strategic standalone development on one site and the construction of a brand new high school and a new leisure centre on the other using CIL payments and other funds generated from the development of new homes.

It is irresponsible for Leeds City Council to expect my constituents living in the communities within the Rothwell district to accept the development of a further 2,600 new homes without knowing what additional infrastructure will come alongside to support it. Additionally, my constituents will want to know what actions Leeds City Council will take to resolve the fact that Royds High School will soon require extensive building work.

If Leeds City Council were to consider this option (assuming it remains reluctant to reduce its housing target), I would, only support such a decision if the Council attached the following conditions to any future outline or detailed planning application:

1. The site must be self-contained within its boundaries, there must be no extension of existing highways within the existing housing estates around the site.
2. The allocation of housing must be apportioned so there is significant green space and land between any new settlement and the existing settlements of Rothwell and surrounding villages.
3. Leeds City Council must use funds acquired from the CIL payment to upgrade the A642 Wakefield Road to a dual-carriageway to alleviate extra traffic and make it easier to access the M62 motorway network.
4. Leeds City Council and external agencies must ensure that the drainage needs of any new development is not simply connected to the existing drainage system servicing Rothwell. A new community must be self-sufficient in its drainage needs.
5. Any development in this area must be on the basis that a brand new secondary school and primary school be constructed, alongside a new leisure centre for the town.

Notwithstanding all of the above, Leeds City Council could negate the pressure forced upon our communities by re-evaluating its approach to the allocation of its housing target.

 

8. Conclusion

Leeds City Council is currently consulting on its Local Plan to deliver 66,000 new dwellings across the local authority area by 2028. The consequences of this could be deeply concerning for communities within my constituency of Elmet & Rothwell. In my own submission I have put forward a number of suggestions for how the Council could mitigate these consequences, these include:

1. Reducing the Housing Target across Leeds to 44,500 dwellings
2. Reallocating the Housing Market Characteristic Area
3. Utilising brownfield land first for new development
4. Allocating a fair amount of Community Infrastructure Levy back to communities
5. Adopting a strategy to prevent peppered development by supporting single sustainable standalone communities

 

I urge Leeds City Council to take these points into consideration when it decides where new development is to be located in my constituency.

 

[1]
National Planning Policy Framework, Department for Communities & Local Government, http://planningguidance.planningportal.gov.uk/blog/policy/

[2]
Ministerial Correspondence, Minister of State for Housing & Planning, Department for Communities & Local Government to Alec Shelbrooke MP, 27 March 2015.

[3]
Population Estimates for UK, mid-2001 to mid-2010 revised, Office for National Statistics, http://www.ons.gov.uk/ons/rel/pop-estimate/population-estimates-for-uk–england-and-wales–scotland-and-northern-ireland/mid-2001-to-mid-2010-revised/index.html

[4]
House Price Index, Nationwide Building Society, http://www.housepricecrash.co.uk/indices-nationwide-national-inflation…

[5]
UK Environmental Accounts 2015, Office for National Statistics, http://www.ons.gov.uk/ons/dcp171778_408987.pdf

[6]
U-turn on Leeds 70,000 houses target? Yorkshire Evening Post, http://www.yorkshireeveningpost.co.uk/news/yep125/u-turn-on-leeds-70-00…

[7]
Leeds Site Allocation Plan: Issues & Options, Leeds City Council, http://democracy.leeds.gov.uk/documents/s94103/Volume%201%2025th%20Apri…

[8]
Protecting Green Belt Land, National Planning Policy Framework, https://www.gov.uk/government/uploads/system/uploads/attachment_data/fi…

[9]
Under Threat, Save Leeds Greenbelt, http://saveleedsgreenbelt.com/under-threat/

[10]
Community Infrastructure Levy, Department for Communities & Local Government, https://www.gov.uk/government/uploads/system/uploads/attachment_data/fi…

[11] Setback for Leeds long-term housing plan. Yorkshire Evening Post. http://www.yorkshireeveningpost.co.uk/news/latest-news/top-stories/setb…