SAP Consultation (Period January 15th – February 26th 2018)

The revisions to the Site Allocations Plan (SAP) are out for consultation during the period January 15th to February 26th 2018. The Save Parlington Action Group invites you to add your name to a campaign to object to the proposed new town in the Parlington Estate, Aberford.

The form may be submitted by anyone, it is not a requirement of the consultation method to be a resident of Leeds. People from as far afield as Indonesia and South Africa have expressed their concern over the proposals to build a new town in the historic green belt of Parlington.

Please advise your friends and relatives for them to add their details all adults are eligible, as are all adult members of one household. The more people we get the harder it will be to proceed with the town. A number of people have submitted the form more than once, maybe due to over enthusiasm! Please don’t as it will only be deleted before being sent to Leeds City Council.

Number or Name and Street Address
District
Please enter your email, so we can follow up with you.

Below is a transcript of the letter which will accompany the listing of objections, raised from this form.

Leeds SAP Revised Submission Draft Consultation Policy and Plans Group
The Leonardo Building,
2 Rossington Street,
Leeds LS2 8HD

Dear Mr Feeney,
Revised Submission Draft Plan – Specifically MX2-39/BL1-42 Parlington Estate
I have given my name and address on the reverse of this letter to indicate that, due to the reasons below, I believe that despite amendments Leeds Site Allocations Plan (SAP) with Parlington Estate in it still fails all four tests of soundness;

Leeds City Council (LCC) states that it requested a delay to Public Examination of its SAP in order to amend its approach “to ensure no unnecessary release of Green Belt sites in the Plan”. LCC’s Broad Location Methodology does NOT ensure this with respect to Parlington Estate and the ONE HMCA. Throughout the amended Plan documentation are references to development of the whole MX2-39 site and the capacity for 5,000 houses. The “Site” of 792 houses is referred to as “the first phase” and the “Broad Location” as “subsequent phases”. LCC has split the site in two, and claims that the Broad Location can be “saved” when the housing requirement is reduced. However, LCC also appears to view the release of future phases at Parlington as a necessary part of the development of the settlement. Local residents will either be stuck with a highly unsustainable settlement of 792 houses or the release of the Broad Location for houses that are no longer needed and
the unnecessary loss of highly valuable, irreplaceable Green Belt.

Even before concluding its Core Strategy Selective Review LCC acknowledges that it is aware that a revised target for housing need in Leeds will be greatly reduced. The Inspector has asked: “is there potential that land may be released from the Green Belt … that may not have been necessary had the selective review concluded first?”. MX2-39 is allocated to Phase 1 and contributes 350 houses to meet the future 5 year land supply. However, the 5 year land supply is based on the inflated and now discredited annual housing target. If the selective review had already concluded, LCC’s 5 year land supply requirement would be lower and no Green Belt sites would need to be released this early in the Plan period. In addition, LCC has admitted that it will actually exceed this overstated target by 5% by 2022/23 (5% of 47,643 homes is 2,382 houses). This over- allocation means LCC is unnecessarily releasing sites such as MX2-39 from the Green Belt. The Broad Location Methodology therefore fails to protect Green Belt sites from unnecessary release. LCC also details that there is a total of 13,272 homes delivered or under construction and total non-Green Belt allocated sites of 43,769, LCC is therefore aware that it will not have to release ANY Green Belt sites in order to meet the housing need for Leeds.

LCC claims that “sites on brownfield land are within phase 1…on phasing” although this is not a true statement for the ONE HMCA. Brownfield Site HG2-24 at Keswick Lane has been deleted as an identified site and re-designated a ‘Broad Location’ yet LCC state that Broad Locations “are a pool of sites, which remain in the Green Belt” Similarly a mixed site HG2-25 at Bramham has also been deleted as an identified site and re-designated as a Broad Location. By LCC’s own definition neither of these sites should be allocated as a Broad Location but should be moved to phase 1 allocated sites.

Since the submission of the draft SAP in May, Parlington Estate has been listed by Historic England as a Grade II Historic Park and Garden. Regardless of any request for a review by landowners with a pecuniary interest the listing remains in force. LCC should therefore be appraising the site as such and not disregard the listing as it appears to be doing.
In summary:

  • The Plan is STILL NOT POSITIVELY PREPARED for reasons that include its failure to align with the Adopted Core Strategy, failure to apply LCC’s own sustainability appraisal and its lack of a transport infrastructure plan;
  • The Plan is STILL NOT JUSTIFIED because a reduced site of 792 houses on MX2-39 has not been considered against reasonable alternative strategies and the site is no longer a strategic site;
  • The Plan is STILL NOT EFFECTIVE because MX2-39 has no inherent infrastructure – to deliver a single house will require a full provision of infrastructure and will therefore not be deliverable within the plan period;
  • The Plan is STILL NOT CONSISTENT WITH NATIONAL PLANNING POLICY because 792 houses on MX2-39 will be unable to economically support vital services, will be car dependent and therefore unsustainable.

Finally, I would like all future correspondence regarding Leeds SAP from either LCC or the Programme Officer to be sent through Save Parlington Action Group rather than to myself directly.

Yours Faithfully
On behalf of the named person(s) listed Overleaf

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