The Leeds Local Plan consists of a number of documents, but the two key ones are
- The Core Strategy – which gives the strategic policies and housing targets.
- The Site Allocation Plan – which says where houses, employment, green space, retail are to be sited.
The current Leeds Core Strategy (CS) was adopted in November 2014; but there was an update adopted in September 2019 which primarily changed the housing target from 70,000 net (2012 – 2028) to 51,952 net (2017-2033). (In relative terms the annual housing target in the 2014 CS was 4,700 per annum, from 2017-28; this has now changed to 3,247pa 2017-33)
The Leeds Site Allocation Plan (SAP) was adopted in June 2019 to support the CS 2014 housing target. This was successfully challenged legally with regards the exceptional circumstances to change the Green Belt boundary to meet housing need. The judgement said Leeds City Council should put 37 GB sites back into Green Belt and consider their allocated housing land supply again. A subsequent review of housing land in Autumn 2020 found the City had 6.8 years housing land supply and a district wide surplus of 11,000 housing units up to 2028. There was thus no exceptional circumstances to change the Green Belt boundary. LCC recommended that the 37 Green Belt sites were removed from the SAP 2019. This modification to the SAP was put to a public consultation in Winter 2021.
SO WHERE ARE WE NOW ?
1. SAP 2019 Remittal
For the SAP Green Belt sites to be returned to Green Belt, modifications to the SAP have to be approved by a Planning Inspector. The date for the planning hearing has not yet been set.
The Full Leeds Council have now agreed to modify the SAP so that 37 Green Belt sites are returned to Green Belt. These modifications have been put to the Planning Inspectorate and there will be a Planning Hearing where an Inspector will decide if this change makes the SAP sound. The Council and local community groups will argue that it is sound; developers and other interested parties will argue that it is not. (Details of responses to the SAP Review are in a report from March 2021 here. This includes a detailed analysis of objections developers and others will raise and an LCC response 3.7 – 3.66)
2. Core Strategy Update
A Core Strategy update is underway that could have implications for Aireborough’s 3% housing target. This 3% share is a key reason why our Green Belt remains under threat.
There have been important changes in Leeds City Council’s Strategy since 2014, most notably the declaration of a Climate Change Emergency to achieve a target of net zero carbon emissions by 2030. This policy direction affects many aspects of strategic planning eg green space provision, biodiversity, energy provision, transport, and so the planning policies in the Core Strategy are being reviewed. The review is called the Local Plan Update (LPU). There will be a public consultation on the scope of the review and proposed areas of importance after the local elections on 6 May 2021. Papers on that consultation and proposed policy changes are here, item 59. One of the areas we are particularly interested in are changes to the strategic policy that gives Aireborough a housing target of 3% of the overall LCC target, despite our role in green infrastructure and flood protection, and the issues with transport and pollution. The LPU will have consideration for Government’s emerging proposals on reforms to the Planning System see below.
3. Changes to Government Model for Housing Need Targets
Both Government national and Leeds local housing targets threaten Aireborough’s Green Belt. The Government now sets the housing target with a 35% urban uplift, Leeds City Council will be responsible for where it is distributed.
In July 2018 the Government introduced a standard model for calculating housing need in Local Authority (LA) areas. Before that all LA’s had used their own models. Called the Standard Method, the Government consulted on changes to this in Autumn 2020 to support building the right houses in the right place. The proposals met with strong objections, particularly in semi-urban areas of southern England where proposals led to large housing target increases. Therefore, in December 2020 the Government changed tack; it announced that housing need would be met by adding a 35% uplift to the current standard method for the 20 most populated Cities in England . This includes Leeds where on current figures this means an increase from 3,247 houses pa, to 3,763 pa.
The rationale is to build on brownfield sites, near infrastructure, where travel to work reduces carbon emissions, but it moves away from the idea of localism and objectively assessed housing need targets. An initial issue is also that the current standard method is based on 2014 housing need projections, a lot has changed since then !! Another, is that many of the Cities affected are the ones with a Green Belt purposefully designed to stop urban sprawl !! New Planning Guidance stresses that the uplift should come from brownfield urban areas and not from surrounding areas, however this is weak. Figures are said to be both undeliverable and unsustainable by industry experts conversely there is no extra Green Belt protection, which is what is really needed.
It will be left to LA’s to distribute these housing target and justify its decision. LCC’s response to these changes in their March SAP Remittal report is as follows
3.26 It is noted that there has been no shift in Government policy as a result of the pandemic. Indeed during the pandemic, on 16 December 2020, the Government changed the way local housing needs are to be calculated and amended national planning guidance to build-in an uplift of 35% for the 20 most populated cities in England as part of their commitment to the levelling up agenda and priority for brownfield land use in city centres. This is entirely consistent with the Council’s approach.
With an Aireborough Housing Target of 3% of the LCC total, our classification as an urban area, relatively little brownfield left to develop, and a purposefully tight Green Belt, this puts Aireborough Green Belt back in line for potential development in the future if Leeds City Council choose to allocated it under exceptional circumstances. As a new housing target was adopted in 2019, and there has just been a housing land supply review, we do not expect targets and distribution to change immediately, but changes will be considered before 2024.
4. Government Planning System Changes
Planning in Aireborough may, or may not become more democratic. We’ve been here before !!
Throughout Autumn 2020 the Government have been consulting on their proposals for Planning for the Future. Although many fear that the proposals will reduce the ability of communities to object to planning applications, there is also a corresponding increase in community involvement at a strategic ie Local Plan level. We can see both the potential for building better places in the proposals, and the areas where there are fears that community will lose rights on individual planning applications. We commend the proposals that would get rid of the current tedious process, allow creativity to flow, and involve more communities in democratic decisions. But, we can see the threats to democratic accountability in planning and changes that are moving away from localism – we’ve seen this tussle between competing interests before with the original National Planning Policy Framework (NPPF) in 2012 !!