Housing need, and land allocations can feel very much like calculating Soviet tractor statistics, here we try to pull out the current key figures and points in the Leeds Local Plan, and at the end give details of how to respond to two current consultations on these issues.

OBJECTIVELY ASSESSED HOUSING NEED (OAN)

The Leeds Housing Target of 70,000 net between 2012 – 2028, is out of date, and too high.   Population did not grow as much as anticipated , and is not forecast to grow as much as when the plan was done in 2008.

In September 2017, the Government announced a potential new way of calculating housing need for Local Authorities (LA) – making the calculation nationally more consistent, instead of leaving it to LAs individually.   They calculated that the Leeds’ housing need between 2012 – 2028 should be 42,384 net; 39% lower than original target Leeds City Council (LCC) .  This figure includes an amount for reasonable economic growth.

Following another look at their housing OAN at the end of 2017,  LCC have decided to adopt a new housing target of 51,952, BUT NOTE this is from 2017 – 2033, so 5 years beyond the current Local Plan. (This target is currently the subject of a consultation see below).

To make a comparison between the two figures we need to make some adjustments to cover the period 2012 – 2033 for both

Target need Figures
Government figure 2012 – 2033 = 55,629  (adding on 5 years at 2,649pa)
LCC figure 2012 – 2033 = 65,776  (adding on the actual delivery between 2012-2017 of 13,824)

So, we can see that the LCC figure is roughly 10,000 greater than the Government figure.
We can also see that the LCC figure is only 4,224 less than the previous over ambitious target.
In other words LCC are taking longer to deliver a similar amount of houses as the original 2014 target.

LCC have decided to go for a figure higher than the Government’s calculations because of proposed greater economic growth in the City.  Details of need can be found in their Strategic Housing Market Assessment 2017 (SHMA).   The SHMA estimated a housing need based on different scenarios of between 44,240 and 60,528 between the new plan period of 2017 and 2033.

Hollins Hill – Working Farm on Green Belt for 80 Houses

LAND NEEDED FOR HOUSING ALLOCATIONS

To get to a figure for the amount of land LCC needs to allocated in the Site Allocation Plan (SAP) (under current consultation until 26th February 2018), LCC deem that 6,096 housing units will be built on windfall sites that they did not know would become available in the plan period.   So if we reduce both target need figures by that amount, we get

Target land allocation figures
Government figure = 49,533 (let’s call it 50,000)
LCC Figure = 59,680 (let’s call it 60,000)
Original LCC 2014 target = 66,000

Green Belt Issue

Ings Lane – 160 Proposed Houses on a Flood Plain

In the original 2014 target of 66,000, the Green Belt was earmarked to provide 12,385 housing units.  So a reduction of land needed for allocations to 53,615, would mean no Green Belt was needed, if all other land supply stays the same, ie no more new land is forthcoming.  In essence, LCC’s new target of 60,000, means that 6,000 houses are needed on Green Belt, unless other options come forward before the year 2033.  That could be

• brownfield land in need of regeneration, especially in the Aire Valley; deemed a regeneration priority area. LAs are now required to keep brownfield registers.
• using the greenfield land from the last Urban District Plan that was put aside for future development, and is not currently allocated in the SAP.  Currently around 5,100 units of land.
• other sustainable greenfield land – LCC do a call for new land each year for their Strategic Housing Land Availability Assessment
• the decision to provide for growth by build a new village, or growing a current one via a well planned urban extension near good transport links
• or acknowledging that more people who work in Leeds now live outside the Leeds housing market eg in regenerating Wakefield or Kirklees, and that LCC does not need to allocate land for all need.  In 2016, the percentage of people who lived outside Leeds but worked there was 31%.

The law on green belt is that it should not be deleted unless there are exceptional circumstances and all other options have been looked at.

Leeds Site Allocation Plan 2012 – 2028

Wills Gill – Historic Green Belt Site for 133 Houses

The current SAP is still planning for the housing need target of 70,000.  However, the SAP Planning Inspector indicated in October 2017 that the review of housing figures was pertinent (material in legal terms), and that Green Belt could not be deleted unnecessarily.  The LCC response, has been to divide the 12,385 units of Green Belt as follows

• 5,931 units have been put in the plan to be built in phase 1, before 2023
• 6,454 units have been put in a category of allocation called Broad Locations to be taken if needed before 2033 following public consultation.  Untill deleted they stay in Green Belt.

The issues with this is that

1. the figures on need and supply mean that no Green Belt is needed before 2023
2. LCC have kept the same amount of Green Belt in phase 1 of the revised SAP, as was in the old SAP ie around 6,000
3. all current Green Belt could easily be put into Broad Locations for future consideration whilst a proper review of spatial strategy for regeneration and housing provision was done.
4. Alongside a new spatial strategy LCC could do a comprehensive Green Belt Review* that looked positively on the future role of Green Belt in Leeds.   This was a requirement of the Core Strategy Inspector in 2014 but LCC have not done it.   Such a comprehensive review would include a proper valuation of natural capital and ecosystem services, and a plan put in place to enhance GB that was still needed to fulfil its purpose.  We have started to look at this in the Aireborough Landscape Character report. (*Bradford MDC is currently doing a Comprehensive Review and the Government recommend that LAs co-operate on such strategic projects.)

LEEDS SAP AND CORE STRATEGY CONSULTATIONS

If you would like to comment on LCC’s plans there are two consultations running at the moment

1. Comments on land for site allocations in the SAP should be in by 5pm on 26th February 2018.   All papers and details are here.
2. Comments on the housing targets are in the Core Strategy Review Consultation which is running until the 23rd March.  All papers and address for response are here.

People tell us that the Leeds response forms are difficult to understand if you are not a planner.  LCC have said they accept all responses to the relevant postal address and email,  it is helpful to them if you can make sure responses reference the section of the plans you are commenting on, and the relevant sites.  That can be put in a reference at the top of the correspondence.

We also encourage people to write to their local MPs so that they are aware of people’s views on this complex subject.  Planning law is currently being revised.   Local MPs are

Pudsey, Stuart Andrew –  stuart.andrew.mp@parliament.uk
Leeds North West, Alex Sobel – alex.sobel.mp@parliament.uk
Shipley, Philip Davies – philip.davies.mp@parliament.uk