February 2018.
- Introduction
It remains our belief, as detailed in our response to the Leeds City Council’s pre-submission Site Allocations Plan consultation in February 2017, that Leeds City Council’s overinflated housing target is the root cause of pressure on greenfield and greenbelt sites in the communities we serve.
We previously set out our view that the Site Allocation Plan in its current form is causing unnecessary pressure on greenfield and greenbelt sites, such as MX2-39, within the Harewood Ward. We do not consider that the changes made in this revised submission make any real difference to this situation and we therefore remain opposed to the plan, and object to its adoption by Leeds City Council.
This submission does not seek to repeat objections made in our previous submission, although the strength of our objection remains the same. This submission will address the so-called changes proposed by Leeds City Council.
- Broad Locations
Leeds City Council describes the purpose of introducing broad locations as ‘seeking to reduce the impact of the SAP of greenbelt release’.
This is nothing more than a red herring. In the Harewood Ward Leeds City Council’s plan still includes the allocation of the Grade II-listed Parlington Estate, in the greenbelt. Instead of reducing the housing target, as we previously called for, and thereby removing the need to allocate sites in the greenbelt altogether, Leeds City Council has instead opted to fudge the way in which it intends to allocate land by introducing broad locations. Broad locations merely provide a sticking plaster on the Council’s site allocation plan, intended to cover over the fact that the Council still plans to build 70,000 homes, including on greenbelt land in Leeds.
We have been appalled to see publicity items promoting the Council’s revised proposals as being a mechanism to protect the greenbelt. Even if we were to believe that broad locations will not actually be needed in the long-term, it remains the Council’s plan to build c.800 homes on greenbelt in the Harewood Ward.
Furthermore, it is unclear how the implementation of broad location impacts upon the sustainability of site MX2-39. Our constituents were previously told that a larger allocation of dwellings was needed on the site in order to make it sustainable for the provision of education, services and highways improvement. In our mind, this therefore presents one of two situations: a) that the Council is now supporting an allocation that is unsustainable and will lead to the construction of new homes in the greenbelt without any supporting infrastructure; or b) that the Council is relying on the construction of homes in the new broad location in order to make the earlier phase sustainable. In either case, we are not convinced that the Council is being transparent about the consequences of the revisions it has made to its site allocation plan.
- Confusion over the purpose of the Council’s Local Plan in the Outer North East
From the outset Leeds City Council has informed residents that one of the purposes of adopting a Local Plan is to provide the local authority with greater control over where new dwellings are located during the plan period. Communities have been informed that an adopted Local Plan, with a deliverable land supply, would strengthen the Council’s hand when refusing planning applications on sites that do not feature in the Local Plan (the Site Allocation Plan).
We were therefore confused to discover that Leeds City Council officials have presented the Regional Schools Commissioner with a plan to reorganise the provision of secondary education in the Outer North East and that this plan included proposals to sell school sites for development in order to fund the construction of new education facilities elsewhere in the Outer North East.
If this is an active proposal of Leeds City Council then it runs contrary to proposals outlined in the draft site allocations plan. Under this proposal, the Council would find itself in the situation of having approved its site allocations plan with an adopted Local Plan outlining sites on which new developments should be built during the plan period. Then, during that plan period, the Council would seek to sell land within its ownership for development. To realise funds from these assets, the local authority would therefore need to support a planning application to construct dwellings on a site that falls outside of its site allocations plan. If the Council agreed to such an application, then we believe private landowners and developers would seek to use this as precedent and bring forward other sites outside of the site allocation plan, thereby making the local plan irrelevant.
If, however, it is in fact the Council’s intention to allocate additional sites for development as an amendment to its site allocation plan, then we assume the Council will remove sites that are no longer required to meet its self-imposed housing target.
Alec Shelbrooke MP
Cllr Ryan Stephenson
Cllr Matthew Robinson