INSPECTOR’S REPORT ON LEEDS CITY COUNCIL’S CORE STRATEGY

The Planning Inspector who was asked to examine the Leeds City Council Core Strategy has now submitted his report which can be accessed by clicking on the link further down

  • Then, going down the page until you reach Examination News dated 5th February 2014, then click the coloured text which reads Examination Documents list
  • Then go to the following documents on the list:

ID20 – Letter from the Inspector to the Council dated 31st January 2014.

ID21 – Letter from the Inspector to the Council dated 4th February 2014.

ID22 – Schedule of Main Modifications from the Inspector to the Council.

LCC/10 – Letter from the City Council to the Inspector dated 3 February

http://www.leeds.gov.uk/council/Pages/Core-Strategy—Examination.aspx

In essence he has accepted the Council’s housing numbers, not the lower figure that we as a Group asked for, or the higher figure that the developers asked for. 

There are all sorts of other issues arising out of the letter, some helpful, some not. 

Set out below is a synopsis sent to me today which may be the subject of change as a result of further analysis.  More detailed analysis of the impact will be required. I will keep you advised.

  • The Inspector of the Leeds Core Strategy has now provided some initial feedback to the Council following his inspection in autumn 2013.
  • 39 Inspector Main Modifications (IMMs) have been made, these are changes that the inspector requires of the Council for the plan to be classified as sound. He has also given a number of very brief reasons for his modifications.
  • IMM17 to IMM29 largely refer to employment land and office space.

Key Changes

  • Perhaps the most significant development comes at IMM6 which relates to Spatial Policy 6 in the Core Strategy. SP6 refers to overall housing numbers in Leeds. The Inspector basically agrees to the provision of 70,000 houses (net) between 2012-2028, in line with the numbers put forward by the Council. This rejects the higher figure being argued for by developers but also rejects arguments made by some local Councillors including myself and various local campaign groups, for lower numbers. The Inspector has rejected the proposed ‘step up’ in supply that would have seen a target of 3,660 houses per annum from 2012/13 to 2016/17 increasing to 4,700 up to 2028. This appears to leave no specific annual target to deliver. Doing a basic sum 70,000 divided by 16 leaves the Council with an annual target of 4,375 throughout the life of the plan. The basis for rejecting the annual build rates is simply ‘step up not justified by evidence’.
  • Some important aspects of SP6 remain unchanged such as the preference for brownfield and regeneration sites and those with the least impact on Greenbelt purposes. When linked to SP1 (IMM1), which has been changed but not substantially in meaning, appears to serve clear notice that development should be on brownfield and regeneration sites located within the Main Urban Area and major settlements.
  • IMM1 does remove the word ‘selective’ from the intention to conduct a greenbelt review which might have implications for additional development of the greenbelt. The removal of the word ‘selective’ is also a feature of IMM10 and IMM11.
  • Indeed IMM11 now makes the strategy state that ‘a review of Greenbelt will need to be carried out to accommodate the scale of housing and employment growth identified in SP6’. This section of the Core Strategy already referenced Guiseley, Yeadon, Rawdon and Wetherby and this remains unchanged.
  • IMM5 removes a key paragraph (4.6.7) from the core strategy relating to the phased approach to development (as mentioned above). This makes clear that the inspector rejects the argument for a lower annual housing number over the first 5 years of the strategy. To be fair much of this paragraph referred to the economy as a reason to have a lower number. Since that time it could be argued that the housing market and wider economy has picked up somewhat.
  • IMM13 refers to policy H1 of the Core Strategy which is the managed release of sites. Much of H1 is unchanged in that it specifies that sites should be phased in line with those that best meet certain criteria such as location in regeneration areas, best access to public transport, best access to local services and so on. However, the changes made by the inspector put more emphasis on the maintenance of a 5 year land supply plus the appropriate NPPF buffer. The amendment suggests that the Council should maintain the 5 years supply by releasing subsequent phases of sites to address any shortfall. The NPPF buffer is 5% in normal circumstances but 20% in areas where there has been consistent under supply. All of this could mean that sites that can make more profit for developers can be brought forward to an earlier phase if a 5 year land supply of brownfield or regeneration sites is not in evidence, which will be difficult to achieve.
  • IMM30 appears to contain some errors in that it refers to the wrong core strategy paragraphs. This change focuses on ensuring good design and having regard to existing environments. IMM31 goes on to emphasise high quality design further with the insertion of the word ‘high quality’. Perhaps this will reduce the tendency of housing developers to deliver off the shelf housing estates.
  • IMM32 refers to conservation and paragraphs 5.3.45 and 5.3.46 of the Core Strategy. In this the inspector has inserted a sentence that creates an expectation that developers will, except for the most minor changes, consult with the West Yorkshire Archaeology Advisory Service which contains details of battlefields, archaeological sites, historic parks and gardens and some conservation areas. This should help protect historic areas of the city.
  • IMM34 to IMM38 deal with infrastructure and transport issues. These go largely unchanged by the inspector which means that Policies T1 and T2 of the Core Strategy remain virtually unchanged. This means that where new development does not meet accessibility standards investment will be required to ensure that the standards are met. The accessibility standards are contained in Proposal 12 of the Local Transport Plan.
  • IMM38 specifies that ‘qualitative’ improvements to green space should take place where increased usage of green space results from new residential development.
  • IMM39 inserts the phrase ‘where possible’ in reference to the Council avoiding development in areas with a flood risk. Given recent events in the South West one might think that avoiding development in flood areas should be a priority.

Commentary

  • The planning department are still going through the contents of this feedback from the inspector but it seems clear that the most important developments are around the housing numbers, 5 year land supply and possible changes to the Greenbelt.

I apologise for the technical nature of this update but it needs to be read in conjunction with the original Core Strategy.