PDW04550 Outer South West Subject: Site in the plan EG2...

16
PDW04550 Outer South West EG2-21 - Lingwell Gate Lane, Thorpe No Agree with proposed use? No Consider the plan sound? Positively prepared Effective Justified Consistent with NPPF Please refer to letter reference ST/mw 425 Changes required to make sound: HMCA\Topic: Subject: Site in the plan Ref: Site: Test of soundness addressed: Soundness Issues Legal compliance Don't know Consider the plan legally compliant? Local Development. Scheme Statement of community involvement Consultation of statutory bodies Duty to co-operate Legal compliance issues addressed: Planning and Compulsory Purchase Act Sustainability appraisal Town and Country Planning Regs Future updates Take part in public examination? Be informed of submission to examination? Be informed of adoption of the plan? n/a Comments on legal compliance:

Transcript of PDW04550 Outer South West Subject: Site in the plan EG2...

PDW04550 Outer South West

EG2-21 - Lingwell Gate Lane, Thorpe

NoAgree with proposed use?

NoConsider the plan sound?

Positively prepared Effective Justified Consistent with NPPF

Please refer to letter reference ST/mw 425

Changes required to make sound:

HMCA\Topic:

Subject: Site in the plan

Ref:

Site:

Test of soundness addressed:

Soundness

Issues

Legal compliance

Don't knowConsider the plan legally compliant?

Local Development. Scheme Statement of community involvement Consultation of statutory bodiesDuty to co-operate

Legal compliance issues addressed:

Planning and Compulsory Purchase Act Sustainability appraisal Town and Country Planning Regs

Future updates

Take part in public examination? Be informed of submission to examination? Be informed of adoption of the plan?

n/a

Comments on legal compliance:

Submitter details

Megan

Wilmott

7th Floor

Fountain Precinct

Balm Green

Sheffiled

S1 2JA

Title

Forename

Surname

Address 1

Address 2

Address 3

Town

PostCode

PDP04147Ref

Miss

Agent details

Title

Forename

Surname

Address 1

Address 2

Address 3

Town

PostCode

Ref

T +44 114 272 9750 F +44 114 272 9772

7th Floor Fountain Precinct Balm Green Sheffield S1 2JA

KnightFrank.co.uk

Knight Frank LLP is a limited liability partnership registered in England with registered number OC305934.

Our registered office is 55 Baker Street London W1U 8AN where you may look at a list of members' names.

Forward Planning and Implementation

Leeds City Council

The Leonardo Building

2 Rossington Street

Leeds

LS2 8HD

Ref: ST/mw 425

16 November 2015

Dear Sir / Madam

Leeds Local Plan – Site Allocations Plan Publication Draft Consultation (September-November 2015)

Land at Thorpe Lower Lane, Thorpe On The Hill, Leeds.

Knight Frank is instructed by our client, Britannia Refined Metals Limited (BRM), to submit representations

for the above site towards Leeds’ current public consultation on the Site Allocations Plan Publication Draft

document, which runs from 22 September to 16 November 2015.

The Leeds Site Allocations Plan Publication Draft document sets out the sites that the Council has identified

as preferred development locations, in order to meet the housing and employment targets that the Council

must meet for each settlement over the next 15 years. Upon adoption, the document will form a part of the

Leeds Local Plan.

Within the Site Allocations Plan Publication Draft document, the Council identifies our client’s site as

‘Identified Employment Land’ (LPA reference EG1-61) to the west and as an ‘Allocation for Employment’ (ref

EG-21) to the east. A map of our client’s land ownership can be found at Appendix 1.

The Site

The site, as a whole, measures approximately 5.3ha and is located to the east of the rural settlement of

Thorpe On The Hill. Access to the site is presently achieved off the A654 Thorpe Lower Lane to the north,

which bounds the site along this perimeter. To the west, the site is bordered by an area of tree lined,

Greenfield land, beyond which lies Lingwell Gate Lane. The site is also located within close proximity of both

the M1 and M62 to the south east, offering excellent access to the wider region and beyond.

The westernmost section of the site is currently safeguarded for general waste purposes within the Adopted

Natural Resources and Waste Plan (2013), and immediately abuts an allocated employment site (ref E4.40)

adjacent Lingwell Gate Lane. To the east, the site comprises designated Green Belt.

To the west, the site comprises relatively flat, vacant Brownfield land which was previously used by Britannia

Refined Metals Ltd for the collection and recycling of lead. The factory closed in 2002 and the site has since

been cleared of built form, although a significant area of hard standing is still present. Significant land

contamination issues are known to exist. In the intervening period, the site has been marketed and occupied

by one tenant and subsequently Knight Frank has robust market evidence to suggest the site is no longer

Page 2

suitable for such a use and that there is no market demand. The site comprises a significant proportion,

although not all of, the EG1-61 ‘Identified Employment Land’ designation.

To the east, the site comprises vacant Greenfield land, situated within the designated Green Belt.

Planning History

On behalf of our client, Knight Frank previously submitted a Pre-Application enquiry to Leeds City Council in

February 2011, in respect of the redevelopment of the westernmost edge of the site for residential

development, now allocated as EG1-61 within the Site Allocations Plan Publication Draft. Alongside this

enquiry, an indicative site layout was submitted to the Council which illustrates that up to 60 units could be

accommodated within this section of the site alone. A sketch masterplan can be found at Appendix 2 for

reference.

Current Allocation

Whilst the policies contained within the Core Strategy Development Plan (2014) have replaced a significant

number of policies contained within the Leeds Unitary Development Plan Review (UDP, 2006), until the Site

Allocations Plan is adopted, the UDP Proposals Map remains a part of Leeds’ Local Development Plan.

The UDP Proposals Map (Revised to include the Natural Resources and Waste Plan 2013), identifies that

westernmost section of the site, which abuts allocated employment land bordering Lingwell Gate Lane, is

safeguarded for general waste purposes.

Whilst the UDP Proposals Map remains a part of the Local Development Framework at present, UDP Policy

WM4: Recovery of Waste has been replaced by Policy WASTE 2 of the Leeds Natural Resources and

Waste Development Plan Document (2013).

Policy WASTE2 states, ‘Existing waste management sites shown on the Policies Map are safeguarded for

continued use during the plan period. Increases in capacity or other improvements at these sites will be

acceptable provided that the requirements of WASTE 9 are demonstrated. Applications for change of use

must demonstrate that there is either no longer a need to retain the site for waste management purposes or

there is an overriding case for the proposed development that outweighs the need to retain the site for waste

management purposes’.

The UDP Proposals Map also identifies that the easternmost section of the site comprises Green Belt land.

As such Core Strategy Policy SP10 (Green Belt) is directly applicable and states, ‘A review of the Green

Belt will need to be carried out to accommodate the scale of housing and employment growth identified in

Spatial Policy 6 and Spatial Policy 9, as well as an additional contingency to create new Protected Areas of

search (to replace those in the UDP which will be allocated for future development). The review will generally

consider Green Belt release around:

i. The Main Urban Area (Leeds City Centre and shrouding areas forming the main urban and

suburban areas of the City);

ii. Major settlements of Garforth, Guisley/Yeadon/Rawdon, Morley, Otley, Rothwell and Wetehrby;

iii. Similar settlements (listed in Table 1: Settlement Hierarchy.

Exceptionally, sites unrelated to the Main Urban Area, Major Settlements and Smaller Settlements could be

considered, where they will be in sustainable locations and are able to provide a full range of local facilities

and services and within the context of their Housing Market Characteristic Area, are more appropriate in

meeting the spatial objectives of the Plan than the alternatives in the Settlement Hierarchy. Otherwise

review of the Green Belt will not be considered to ensure its general extent is maintained.

Page 3

In assessing whether sites in the Green Belt review should be allocated for development,, the following

criteria will be applied:

iv. Sites will be assessed against the purposes of including land in Green Belts identified in national

guidance (National Planning Policy Framework). These are:

to check the unrestricted sprawl of large built-up areas;

to prevent neighbouring towns merging;

to assist in safeguarding the countryside from encroachment;

to preserve the setting and special character of historic towns; and

to assist in urban regeneration

Proposed Allocation

The Interactive Map of Sites (2015), which forms a part of the Leeds Site Allocation Plan Publication Draft,

identifies our client’s site as a mix of both ‘Identified Employment’ (reference EG1-61) to the west,

understood to have arisen from the site’s historic industrial use, and ‘Allocated Employment’ (reference EG-

21) the east.

Soundness of the Leeds Site Allocations Plan Publication Draft

It is understood that as this consultation relates to the Site Allocations Publication Draft, the representations

which are received will be considered alongside the submitted Site Allocations document which will be

examined by an Independent Planning Inspector appointed by the Secretary of State. As such, at this

juncture, only comments which relate to document’s soundness; legal compliance and the duty to cooperate

will be considered, in accordance with the Planning and Compulsory Purchase Act 2004 (as amended).

The purpose of our representation is to object to the inclusion of our client’s land as both an ‘Identified

Employment’ and ‘Allocated Employment site within the Site Allocations Publication document. As such, we

do not wish to comment on issues surrounding the duty to cooperate or legal compliance at this stage.

With regard to the content of this document and the site’s and policies contained within, it is considered that

the Publication document is not ‘sound’ for the reasons set out below.

Positively Prepared

Paragraph 182 of the National Planning Policy Framework (NPPF) states that, ‘the plan should be prepared

based on a strategy which seeks to meet objectively assessed development and infrastructure requirements,

including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent

with achieving sustainable development’.

This site has been vacant since 2002, within which period it has been marketed for both sale and lease, with

robust evidence of little interest or demand for the site for its allocated purpose. Whilst the site has been let

to one tenant in this intervening period and has been subject to one offer of purchase from an aggregates

sorting firm, it is understood that the sale the land fell through due to concerns over run-off water associated

with this process and the impacts the could have with contaminants in the land. Feedback on the site from

prospective buyers, has cited accessibility issues in relation to the motorway network and contamination as

the key barriers to sale.

As such, we do not consider retaining the site for ongoing employment use will help the Council in terms of

meeting the City’s economic development needs, the site is more likely to remain vacant and not contribute

to delivering sustainable development.

Page 4

Justified

Paragraph 182 of the NPPF states that, ‘the plan should be the most appropriate strategy, when considered

against the reasonable alternatives, based on proportionate evidence’.

With reference to Leeds’ Site Allocations Plan Sustainability Appraisal Publication Draft (September 2015),

this site is considered only for employment purposes which it is argued is predicated on the fact that the site

has historically been used for such purposes. The Sustainability Appraisal clearly states within its

assessments, that the site is derelict and unsightly and does not offer the opportunity to increase social

inclusion and community cohesion. It does not appear that the site has been assessed for residential use,

The Council have therefore failed to consider all reasonable alternatives for the site, despite the historic

nature of its vacancy and market evidence of it being surplus to demand .

In addition, with reference to the Council’s Site Allocations Plan and Aire Valley Leeds Area Action Plan

Employment Background Paper (September 2015), it is clearly stated within Appendix 1 that the site has

been allocated for employment due to historic consents on the land and the existing UDP allocations, thus

indicating that no alternative options for this site have been considered.

Finally, the eastern most edge of allocation EG1-61 (Brownfield land) falls within the designated Green Belt

land in part and as such paragraph 80 of the NPPF id directly relevant. This states one of the purposes of

the Green Belt as being assisting in urban regeneration, by encouraging the recycling of derelict and other

urban land. It is therefore asserted that Council have failed in their duty to justify that this can only be

achieved for the purposes of employment development.

Effective

Paragraph 182 of the NPPF states that, ‘the plan should be deliverable over its period and based on

effective joint working on cross-boundary strategic priorities’.

As referred to above, the site has been vacant since 2002 and marketed for sale or lease. Our market

testing and local knowledge indicates that the site is very unlikely to be attractive to the market and be

delivered for the proposed use.

Consistent with National Policy

Paragraph 182 of the NPPF states that, ‘the plan should enable the delivery of sustainable development in

accordance with the policies in the Framework.

This site is considered to be a sustainable location, in line with NPPF Paragraph 85 which advises that ‘when

defining boundaries, local planning authorities should ensure consistency with the Local Plan strategy for

meeting identified requirements for sustainable development’.

With reference to paragraph 22 of the NPPF, ‘Planning policies should avoid the long term protection of sites

allocated for employment use where there is no reasonable prospect of a site being used for that purpose.

Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used

for the allocated employment use, applications for alternative uses of land or buildings should be treated on

their merits having regard to market signals and the relative need for different land uses to support

sustainable local communities.

Considering that there is a wealth of evidence to demonstrate that there is no recent market interest in this

site for employment purposes, inclusion of the site as an allocation for such proposes is considered to be

wholly inconsistent with national policy as set out within the NPPF (2012), in this regard. We are not aware

of any evidence that the proposed allocation is likely to be delivered and indeed the Sustainability Appraisal

appears to confirm the allocation is based on historic use only.

Page 5

Conclusion

Our client is actively promoting the site’s allocation for residential use, contrary to the recommendations of

the Leeds Site Allocations Publication Draft document.

With regard to the contents of the emerging Development Plan Document (DPD) and the site’s and policies

contained within, the document is considered to be unsound as it is not positively prepared, in line with up to

date marketing information, which indicates that the site is surplus to demand for employment purposes

within this locality.

The allocations contained within this site are also considered to be inadequately justified as the site has not

been considered for any other purposes other than employment, by virtue of the legacy of its historic land

use. The site’s sustainable location, by virtue of its excellent transportation links and accessibility to local

services has been overlooked and the Plan is therefore inconsistent with national planning policy.

We would welcome the opportunity to discuss this site further with the Council and to be involved in later

stages of the consultation/Examination process in due course. Please do not hesitate to contact me directly

with any questions or queries you may have in relation to this representation, or any other matter. We wish to

be kept informed of the Site Allocations document’s progress.

Yours faithfully

Megan Wilmott Senior Planning Consultant [email protected] T 0114 272 9750 M 0746 872 9119

Page 6

Appendix 1: Site Location Plan

Page 7

Appendix 2: Indicative Residential Layout

T +44 114 272 9750 F +44 114 272 9772

7th Floor Fountain Precinct Balm Green Sheffield S1 2JA

KnightFrank.co.uk

Knight Frank LLP is a limited liability partnership registered in England with registered number OC305934.

Our registered office is 55 Baker Street London W1U 8AN where you may look at a list of members' names.

Forward Planning and Implementation

Leeds City Council

The Leonardo Building

2 Rossington Street

Leeds

LS2 8HD

Ref: ST/mw 425

16 November 2015

Dear Sir / Madam

Leeds Local Plan – Site Allocations Plan Publication Draft Consultation (September-November 2015)

Land at Thorpe Lower Lane, Thorpe On The Hill, Leeds.

Knight Frank is instructed by our client, Britannia Refined Metals Limited (BRM), to submit representations

for the above site towards Leeds’ current public consultation on the Site Allocations Plan Publication Draft

document, which runs from 22 September to 16 November 2015.

The Leeds Site Allocations Plan Publication Draft document sets out the sites that the Council has identified

as preferred development locations, in order to meet the housing and employment targets that the Council

must meet for each settlement over the next 15 years. Upon adoption, the document will form a part of the

Leeds Local Plan.

Within the Site Allocations Plan Publication Draft document, the Council identifies our client’s site as

‘Identified Employment Land’ (LPA reference EG1-61) to the west and as an ‘Allocation for Employment’ (ref

EG-21) to the east. A map of our client’s land ownership can be found at Appendix 1.

The Site

The site, as a whole, measures approximately 5.3ha and is located to the east of the rural settlement of

Thorpe On The Hill. Access to the site is presently achieved off the A654 Thorpe Lower Lane to the north,

which bounds the site along this perimeter. To the west, the site is bordered by an area of tree lined,

Greenfield land, beyond which lies Lingwell Gate Lane. The site is also located within close proximity of both

the M1 and M62 to the south east, offering excellent access to the wider region and beyond.

The westernmost section of the site is currently safeguarded for general waste purposes within the Adopted

Natural Resources and Waste Plan (2013), and immediately abuts an allocated employment site (ref E4.40)

adjacent Lingwell Gate Lane. To the east, the site comprises designated Green Belt.

To the west, the site comprises relatively flat, vacant Brownfield land which was previously used by Britannia

Refined Metals Ltd for the collection and recycling of lead. The factory closed in 2002 and the site has since

been cleared of built form, although a significant area of hard standing is still present. Significant land

contamination issues are known to exist. In the intervening period, the site has been marketed and occupied

by one tenant and subsequently Knight Frank has robust market evidence to suggest the site is no longer

Page 2

suitable for such a use and that there is no market demand. The site comprises a significant proportion,

although not all of, the EG1-61 ‘Identified Employment Land’ designation.

To the east, the site comprises vacant Greenfield land, situated within the designated Green Belt.

Planning History

On behalf of our client, Knight Frank previously submitted a Pre-Application enquiry to Leeds City Council in

February 2011, in respect of the redevelopment of the westernmost edge of the site for residential

development, now allocated as EG1-61 within the Site Allocations Plan Publication Draft. Alongside this

enquiry, an indicative site layout was submitted to the Council which illustrates that up to 60 units could be

accommodated within this section of the site alone. A sketch masterplan can be found at Appendix 2 for

reference.

Current Allocation

Whilst the policies contained within the Core Strategy Development Plan (2014) have replaced a significant

number of policies contained within the Leeds Unitary Development Plan Review (UDP, 2006), until the Site

Allocations Plan is adopted, the UDP Proposals Map remains a part of Leeds’ Local Development Plan.

The UDP Proposals Map (Revised to include the Natural Resources and Waste Plan 2013), identifies that

westernmost section of the site, which abuts allocated employment land bordering Lingwell Gate Lane, is

safeguarded for general waste purposes.

Whilst the UDP Proposals Map remains a part of the Local Development Framework at present, UDP Policy

WM4: Recovery of Waste has been replaced by Policy WASTE 2 of the Leeds Natural Resources and

Waste Development Plan Document (2013).

Policy WASTE2 states, ‘Existing waste management sites shown on the Policies Map are safeguarded for

continued use during the plan period. Increases in capacity or other improvements at these sites will be

acceptable provided that the requirements of WASTE 9 are demonstrated. Applications for change of use

must demonstrate that there is either no longer a need to retain the site for waste management purposes or

there is an overriding case for the proposed development that outweighs the need to retain the site for waste

management purposes’.

The UDP Proposals Map also identifies that the easternmost section of the site comprises Green Belt land.

As such Core Strategy Policy SP10 (Green Belt) is directly applicable and states, ‘A review of the Green

Belt will need to be carried out to accommodate the scale of housing and employment growth identified in

Spatial Policy 6 and Spatial Policy 9, as well as an additional contingency to create new Protected Areas of

search (to replace those in the UDP which will be allocated for future development). The review will generally

consider Green Belt release around:

i. The Main Urban Area (Leeds City Centre and shrouding areas forming the main urban and

suburban areas of the City);

ii. Major settlements of Garforth, Guisley/Yeadon/Rawdon, Morley, Otley, Rothwell and Wetehrby;

iii. Similar settlements (listed in Table 1: Settlement Hierarchy.

Exceptionally, sites unrelated to the Main Urban Area, Major Settlements and Smaller Settlements could be

considered, where they will be in sustainable locations and are able to provide a full range of local facilities

and services and within the context of their Housing Market Characteristic Area, are more appropriate in

meeting the spatial objectives of the Plan than the alternatives in the Settlement Hierarchy. Otherwise

review of the Green Belt will not be considered to ensure its general extent is maintained.

Page 3

In assessing whether sites in the Green Belt review should be allocated for development,, the following

criteria will be applied:

iv. Sites will be assessed against the purposes of including land in Green Belts identified in national

guidance (National Planning Policy Framework). These are:

to check the unrestricted sprawl of large built-up areas;

to prevent neighbouring towns merging;

to assist in safeguarding the countryside from encroachment;

to preserve the setting and special character of historic towns; and

to assist in urban regeneration

Proposed Allocation

The Interactive Map of Sites (2015), which forms a part of the Leeds Site Allocation Plan Publication Draft,

identifies our client’s site as a mix of both ‘Identified Employment’ (reference EG1-61) to the west,

understood to have arisen from the site’s historic industrial use, and ‘Allocated Employment’ (reference EG-

21) the east.

Soundness of the Leeds Site Allocations Plan Publication Draft

It is understood that as this consultation relates to the Site Allocations Publication Draft, the representations

which are received will be considered alongside the submitted Site Allocations document which will be

examined by an Independent Planning Inspector appointed by the Secretary of State. As such, at this

juncture, only comments which relate to document’s soundness; legal compliance and the duty to cooperate

will be considered, in accordance with the Planning and Compulsory Purchase Act 2004 (as amended).

The purpose of our representation is to object to the inclusion of our client’s land as both an ‘Identified

Employment’ and ‘Allocated Employment site within the Site Allocations Publication document. As such, we

do not wish to comment on issues surrounding the duty to cooperate or legal compliance at this stage.

With regard to the content of this document and the site’s and policies contained within, it is considered that

the Publication document is not ‘sound’ for the reasons set out below.

Positively Prepared

Paragraph 182 of the National Planning Policy Framework (NPPF) states that, ‘the plan should be prepared

based on a strategy which seeks to meet objectively assessed development and infrastructure requirements,

including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent

with achieving sustainable development’.

This site has been vacant since 2002, within which period it has been marketed for both sale and lease, with

robust evidence of little interest or demand for the site for its allocated purpose. Whilst the site has been let

to one tenant in this intervening period and has been subject to one offer of purchase from an aggregates

sorting firm, it is understood that the sale the land fell through due to concerns over run-off water associated

with this process and the impacts the could have with contaminants in the land. Feedback on the site from

prospective buyers, has cited accessibility issues in relation to the motorway network and contamination as

the key barriers to sale.

As such, we do not consider retaining the site for ongoing employment use will help the Council in terms of

meeting the City’s economic development needs, the site is more likely to remain vacant and not contribute

to delivering sustainable development.

Page 4

Justified

Paragraph 182 of the NPPF states that, ‘the plan should be the most appropriate strategy, when considered

against the reasonable alternatives, based on proportionate evidence’.

With reference to Leeds’ Site Allocations Plan Sustainability Appraisal Publication Draft (September 2015),

this site is considered only for employment purposes which it is argued is predicated on the fact that the site

has historically been used for such purposes. The Sustainability Appraisal clearly states within its

assessments, that the site is derelict and unsightly and does not offer the opportunity to increase social

inclusion and community cohesion. It does not appear that the site has been assessed for residential use,

The Council have therefore failed to consider all reasonable alternatives for the site, despite the historic

nature of its vacancy and market evidence of it being surplus to demand .

In addition, with reference to the Council’s Site Allocations Plan and Aire Valley Leeds Area Action Plan

Employment Background Paper (September 2015), it is clearly stated within Appendix 1 that the site has

been allocated for employment due to historic consents on the land and the existing UDP allocations, thus

indicating that no alternative options for this site have been considered.

Finally, the eastern most edge of allocation EG1-61 (Brownfield land) falls within the designated Green Belt

land in part and as such paragraph 80 of the NPPF id directly relevant. This states one of the purposes of

the Green Belt as being assisting in urban regeneration, by encouraging the recycling of derelict and other

urban land. It is therefore asserted that Council have failed in their duty to justify that this can only be

achieved for the purposes of employment development.

Effective

Paragraph 182 of the NPPF states that, ‘the plan should be deliverable over its period and based on

effective joint working on cross-boundary strategic priorities’.

As referred to above, the site has been vacant since 2002 and marketed for sale or lease. Our market

testing and local knowledge indicates that the site is very unlikely to be attractive to the market and be

delivered for the proposed use.

Consistent with National Policy

Paragraph 182 of the NPPF states that, ‘the plan should enable the delivery of sustainable development in

accordance with the policies in the Framework.

This site is considered to be a sustainable location, in line with NPPF Paragraph 85 which advises that ‘when

defining boundaries, local planning authorities should ensure consistency with the Local Plan strategy for

meeting identified requirements for sustainable development’.

With reference to paragraph 22 of the NPPF, ‘Planning policies should avoid the long term protection of sites

allocated for employment use where there is no reasonable prospect of a site being used for that purpose.

Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used

for the allocated employment use, applications for alternative uses of land or buildings should be treated on

their merits having regard to market signals and the relative need for different land uses to support

sustainable local communities.

Considering that there is a wealth of evidence to demonstrate that there is no recent market interest in this

site for employment purposes, inclusion of the site as an allocation for such proposes is considered to be

wholly inconsistent with national policy as set out within the NPPF (2012), in this regard. We are not aware

of any evidence that the proposed allocation is likely to be delivered and indeed the Sustainability Appraisal

appears to confirm the allocation is based on historic use only.

Page 5

Conclusion

Our client is actively promoting the site’s allocation for residential use, contrary to the recommendations of

the Leeds Site Allocations Publication Draft document.

With regard to the contents of the emerging Development Plan Document (DPD) and the site’s and policies

contained within, the document is considered to be unsound as it is not positively prepared, in line with up to

date marketing information, which indicates that the site is surplus to demand for employment purposes

within this locality.

The allocations contained within this site are also considered to be inadequately justified as the site has not

been considered for any other purposes other than employment, by virtue of the legacy of its historic land

use. The site’s sustainable location, by virtue of its excellent transportation links and accessibility to local

services has been overlooked and the Plan is therefore inconsistent with national planning policy.

We would welcome the opportunity to discuss this site further with the Council and to be involved in later

stages of the consultation/Examination process in due course. Please do not hesitate to contact me directly

with any questions or queries you may have in relation to this representation, or any other matter. We wish to

be kept informed of the Site Allocations document’s progress.

Yours faithfully

Megan Wilmott Senior Planning Consultant [email protected] T 0114 272 9750 M 0746 872 9119

Page 6

Appendix 1: Site Location Plan

Page 7

Appendix 2: Indicative Residential Layout