(This article has been update at 3pm 19 July with extra information since first publication)
We have now completed 5 of the Leeds Site Allocation (SAP) Hearings infront of two Planning Inspectors; this includes a discussion on supporting infrastructure, whether there are the exceptional circumstances for Leeds to delete Green Belt sites, and whether they should have done a comprehensive Green Belt review on the purposes of Green Belt before they started allocating sites.
(Just as a reminder the purposes of designated Green Belt sites are
- to check the unrestricted sprawl of large built-up areas
- to prevent neighbouring towns merging into one another
- to assist in safeguarding the countryside from encroachment
- to preserve the setting and special character of historic towns
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land)
There is huge disquiet around the City, especially in the outer areas, where the story is often the same – poor infrastructure, full schools, and lack of community facilities – with no detailed plans put down for improvements. The Leeds plan is heavy on regeneration, but the issue for this is that developers claim that the areas most in need of regeneration are not ‘viable’ for them. Viable is a specific term that means that developers are guaranteed over 20% profit, anything under is not viable. The reason for this is that they are supposed to pay for the infrastructure that their development needs. But the issue with this is that so much of the needed infrastruture is strategic – travel passes, and on site green space contributions just do not address the problems.
So, LCC assigns Green Belt sites around urban areas such as Aireborough in the hope that it will produce the incentives for developers to build on the regeneration sites in the Inner areas. It will at least produce the funds to pay for education across the City – which we are told is where much of the Community Infrastructure Levy (CIL) is destined. The real investment needed, of course, is in a transport system but here we get into discussions with the West Yorkshire Combined Authority, and from there into devolution investment deals.
Green Belt sites are also more likely to be built on quickly so this helps maintain LCC’s delivery record, which has fallen behind over the plan period.
Another big ‘elephant in this crowded room’ is the fact that this Site Allocation Plan is still allocating sites for the 70,000 housing target 2012 – 2028 which everyone knows is out of date. Last week, Leeds City Council voted for a housing target of 51,952 houses from 2017 – 2033, so why are we working on out of date figures when that is specifically seen as unsound in the National Planning Policy Framework (NPPF)? Because, Leeds want to save greenfield sites allocated in the 2006 Urban District Plan from development, and developers are seeking planning permission through appeals, many of which they have been granted – but recently they have lost some, such as Kirklees Knoll in Farsley. To stop this Leeds needs to have a sound SAP which allocates sites to development.
So, why do LCC want to save greenfield sites that have been previously allocated as potential building sites (Moons field in Guiseley was such a site), and assign Green Belt sites instead; especially when Green Belt sites fulfil a purpose such as stopping Menston and Guiseley from sprawling together, or protecting open landscape character or historic conservation areas such as Gill Lane and Wills Gill, or encouraging regeneration of urban inner city areas !! LCC say the greenfield sites are less sustainable, and some, such as Tingley, have been turned down on access to motorways and shops – but there is no clear evidence that the Green Belt sites are any more sustainable – the Aireborough ones certainly are not. In fact a huge argument at the hearings has been about the fact Green Belt is not more sustainable – AND, besides, it fulfils a strategic spatial planning purpose.
To ‘tip their hat’ at the problem of a SAP for more houses than are needed, the Council have taken out half the Green Belt sites on what they call a fair shares basis. That is to say, each area where there was green belt sites have had around half of them designated as Broad Locations. This does not mean they are taken out of the SAP, it means that they are earmarked for future development ie they could to be taken out of Green Belt and built on before 2028. The arguments over this have also been fierce, including the apportionment between Green Belt to be built on before 2023 (phase 1) ( Ings Lane, Hollins Hill, Wills Gill and Victoria Avenue) , and those that are designated Broad Locations (Coach Road, Gill Lane, Banksfield/Coppice Wood, and a number of Rawdon sites around Layton Lane). Again, the phase 1 sites are deemed more sustainable, and again the evidence shows that many are not.
The Green Belt has been tightly drawn around communities in Leeds since 1966 for the reasons given under purpose above. But in every plan since it has had to be ‘nibbled’ at to build houses – whilst, you could argue, the Inner City has not received the attention it perhaps needs – certainly estate agents say this. When the mills came down this was a great opportunity for brownfield delivery, but that supply is finite. So, now we are back to ‘nibbling’ at the Green Belt. The Core Strategy Inspector in 2014 told the City to do a comprehensive review of the Green Belt – that means to look at the purposes of Green Belt and strategically redraw the boundary. But, LCC have not done this, they’ve continued with nibbling at the sites around the outer area, or trying to find a location for a new settlement on historic sites such as Parlington (and that is another story). LCC need to do a proper GB review on purpose and set the spatial strategy for the City with a degree of certainty. This has to go hand in hand with strategic infrastructure plans, not ‘robbing Peter to pay Paul’ budgeting – which does not address the problem.
Is this all LCC’s fault, no, of course not, as hinted above the North in general is lacking in infrastructure investment. But, LCC have not helped themselves with an hubristic housing target from whence so many of their ills come. Nor, is this a matter of party politics, it will never be solved taking that line, the problem is too huge and needs people working together – but there is little hope of that with current fighting and lack of knowledge of many of the new Councillors. Just look at the video of the recent full Council meeting on the subject. Should the Government step in and appoint a team to come up with a sustainable plan? It could be an option under the Neighbourhood Planning Act 2017 in the right circumstances.
However, we have to get through the hearings first, and the two Inspectors will have to have the ‘wisdom of Solomon’ to report on this. Yesterday, we yet again spent over an hour with two Barristers arguing paragraph this and line that of legal case the other, 2003; and the same the day before. Who knows how this will turn out. The Leeds SAP is obviously poor, is it unsound? The Inspectors have been asked to make suggestions for how it can be made sound, that makes it much harder for them and more responsible !! If the Council cannot do it, how can they? We will have to carry on through the process and see what kind of sausage pops out the other end !!
If you would like to discuss any of this then the Place Space is open from 10am – 12noon today 19th July, or 10am – 1pm tomorrow Friday 20th. We will also be open at similar times on Thursday and Friday 26th and 27th July. Meanwhile, we and others will do our best to represent the views you have given us over the period from 2013 until now. We do have ideas for the Neighbourhood Pan that have come from you and been shaped by urban design and landscape experts, we will try to put this across.