New website
We are excited to announce the launch of the new Leeds.gov.uk website. Find out more information.
Find information about the local plan update pre-submission changes consultation and how you can have your say.
The Leeds Local Plan is made up of a number of documents that contain planning policies that guide the amount and location of development in the Leeds district. It also includes more detailed topic-specific policies that will guide different types of development, and make sure that priorities such as design, green space, heritage, infrastructure, flood risk management are considered during decision making.
We are required to review our planning policies every 5 years, to check they are still working, relevant and fit for purpose, and to identify any policy gaps that may have arisen. Following a review of all our Local Plan policies in 2020, a number of policies requiring update were identified.
In March 2019 Leeds City Council declared a climate emergency with an ambition to work towards carbon neutrality by 2030. Planning policies can help achieve this by:
With this in mind it was decided that this first update of the Local Plan should focus on the role of new and updated planning policies in helping the council to deliver its climate emergency commitments.
In summer 2021 we undertook our first public consultation with some ideas for how Leeds planning policies could change in the future to take account of the climate emergency. This was an early stage of plan making (known as Regulation 18 – Scoping Consultation) and we wanted people’s ideas, opinions, local experiences and evidence to help us shape the plan. Overall, 760 consultation responses were submitted. The vast majority made it clear that they supported the focus of the Plan on the climate emergency and were encouraged by the proposed direction the Plan was taking.
Using the comments and suggestions from the initial consultation, as well as further research and evidence, the supporting text and updated policies for the Local Plan were drafted. A further stage of public consultation took place in late 2022 (known as Regulation 19 – ‘Publication Draft’), with the overall aim of seeking support from the public and other stakeholders on the proposed draft planning policies and supporting text or requesting reasons and/or evidence for any objections. 1474 comments were received from a total of 547 local residents, developers and statutory bodies. There was strong support from local residents for all of the policies proposed, including policies that would make all new buildings in Leeds net zero carbon as soon as possible. Other stakeholders, including the development industry expressed broad support for many aspects of the plan, but also expressed practical concerns regarding their capacity to implement the proposed policies by the date the plan would be adopted.
Thank you to everyone who took part on the Local Plan Update ‘Publication Draft’ consultation. We have carefully considered both the support received and the concerns raised.
The support received from local residents across Leeds gives confidence to our net zero carbon ambitions. However, we must also respond positively to the practical concerns raised by developers and other stakeholders.
We are therefore proposing a range of changes to the proposed Local Plan policies. These include proposing a transition period to January 2027, to allow the development industry time to update their supply chains and construction practices and become familiar with the different energy performance metrics, at which point planning permission will only be granted for fully net zero carbon schemes.
The transition period until January 2027 will not significantly impact our aim to make Leeds net zero carbon by 2030 and we will see better quality development from when the plan is adopted.
Whilst a particular focus of this consultation will be on the proposed transition period, comments are also invited on the rest of the proposed changes to the policies covering the 5 themes of carbon reduction, flood risk, green & blue infrastructure, placemaking and sustainable infrastructure.
The ‘Tracked Changes’ shows the changes that are being proposed, when compared against what we consulted on last year. These changes are itemised and numbered in the ‘Schedule of Changes’. We would request that you quote the number of the change you’re referring to in your comments, so we can better process your comments.
Here is a timeline of the Local Plan Update, showing the stage we are currently at:
Evidence gathering and research |
Issues and options/scoping consultation (Regulation 18) |
Consult on the Publication draft plan (Regulation 19) |
Consult on the pre-submission changes |
Submit draft plan and consultation responses to the Secretary of State |
Examination in Public |
Modify Plan and reconsult if required |
Adopt the Plan |
Monitor and review the Plan |
You cannot make new suggestions at this late stage of the plan-making process and you can’t comment on a policy that hasn’t been changed, but you can comment on the changes we have made to the proposed policies. If you object to any of the changes you will need to provide reasons and/or evidence to support this.
In order for comments to be taken into account we need people to comment on whether they think our policies are ‘legally compliant’ and ‘sound’.
Local Plans are considered ‘sound’ if they are:
The Plan should be prepared to meet our social, economic and environmental requirements
The Plan is based on reasonable and proportionate evidence
The Plan should be deliverable over the plan period, up to 2040
The plan seeks to deliver sustainable development and is consistent with national policy
To view the proposals for the Local Plan Update pre-submission changes consultation the following documents are available:
Background papers:
Due to the technical nature of this consultation we have provided an Executive Summary and some ‘Frequently Asked Questions’ with answers that we hope will make it easier to understand the changes and make comments.
1 An introduction to the draft new and amended policies, their purpose, and the proposed further changes are summarised below. Please read the schedule of changes document for details on all changes being consulted on (and the tracked changed version to assist in seeing where the changes are within the wider document). At this stage of consultation, we are only seeking your comments on the proposed changes.
2 The evidence on climate change mitigation and adaptation warrants a strategic policy (a policy that addresses larger than local issues) in the Core Strategy which works explicitly alongside the other strategic policies to deliver more sustainable development and ensure carbon neutral developments so as to assist in the carbon trajectory of the Council. This policy seeks to provide a strategic underpinning for the Local Plan Update policies.
Change: Inserted a clear reference to the circular economy (which means prioritising the retention of existing structures rather than demolition and re-using / recycling building materials) as an important element of carbon reduction.
3 The Publication draft policies set ambitious but achievable standards, for new development to reduce carbon emissions as far as possible. They do this by:
4 This will be achieved through the following summarised policies:
Change: Changes to EN1 Part B: ‘Operational Energy’ include a transition period to manage the shift towards net zero developments, noting the challenges the development industry has highlighted in delivering net zero developments from adoption. The policy is therefore amended to be a 2-stage one, with developments applying for planning permission after January 2027 being required to meet ambitious energy efficiency standards and being net-zero for operational carbon, either through renewable energy generation on-site or through carbon offsetting contributions to the Council. Development before January 2027 will be required to meet a lower standard of energy efficiency (but still significantly more ambitious than current policies and existing building regulations), and a requirement to maximise renewable energy generation on site, rather than achieve net zero.
Further changes to EN1 Part B have been made as the publication draft version was not considered an effective way of requiring the re-use of buildings and materials, given likely development scenarios.
Change: Policy has altered the previous draft requirement for BREEAM Outstanding standard to now revert back to a minimum of Excellent, as Outstanding was considered unobtainable for all non-residential buildings, given that BREEAM guidance that such buildings should represent the top 1% of all new buildings. However, the policy retains an encouragement and support for Outstanding standards.
Change: Solar Opportunity Areas have been altered to accommodate a larger 7.5km buffer zones to Special Protection Areas at the South Pennine Moors for important bird species, in response to representations from Natural England. Policy also amended to better reflect existing wording within the National Planning Policy Framework. Greater flexibility introduced for new solar development where a proposal is located partially within an Opportunity Area.
Change: Policy wording amended in response to Natural England representations to ensure that heat network applications assess impacts on nationally and internationally designed nature conservation sites.
5 As part of the Council’s aspiration to make Leeds zero carbon by 2030, the Council is committed to ensure that all communities are resilient to the impact of climate change. Flood Risk is one of the most direct impacts of climate change that Leeds faces. It is therefore necessary that up-to-date evidence, best practice and guidance are used to avoid, reduce and mitigate that risk. New policy seeks to achieve this by:
6 This will be achieved through the following summarised policies:
Change: Expand effect of policy so it sets water usage requirements for all new residential developments, not just those over 10 homes. Minor terminology changes to Water 1 for clarity and the insertion of a requirement to undertake a Water Framework Assessment into Water 2 to address comments made by the Environment Agency.
Change: Alterations to reflect the new definition of functional floodplain in National Planning Practice Guidance.
Change: Providing greater clarity by requiring that proposals consider the layout of a site and the relative flood risks across it.
Change: Clarity on what developer contributions may be required to fund, and revisions to terminology in response to representation from the Environment Agency.
Change: Revisions to terminology in response to representation from the Environment Agency.
Change: Clarity that all sources of flooding should be considered.
Change: Providing greater clarity on how the discharge and storage of rainwater should be considered, in response to representation from the Environment Agency.
Change: Further clarity and revised structure of the policy.
7 The following suite of policies seeks to further protect, enhance and increase provision of green (woodland, natures reserves, hedgerows, street trees, public parks etc.) and blue (river corridors. Ponds, becks etc.) infrastructure by:
8 This will be achieved through the following summarised policies:
Change: Removed wording that was repeated separately in Policy G1.
Change: Minor wording changes to strengthen requirements and clarify that Public Rights of Way should be including as part of the GBI assessment.
Change: Provide clarity on the category of trees to be retained (i.e. the policy will not apply to dead or diseased trees).
Change: The policy has been amended to remove Long Established Woodland, which is now proposed to be covered separately through new policy G2C. Further detail has also been provided within G2B to explain the size of buffer distances to the features protected through the policy and how development should be designed to respond to these buffers.
Change: This policy, new for the Pre-submission changes version of the Plan provides protection to long established woodland and provides detailed guidance on how buffer distances to this typology of woodland should operate.
Change: Minor amendments, including to apply a more reasonable limit for contributions to maintenance and management (30 years; previously ‘in perpetuity’), and to clarify that trees should be appropriate for their location, rather than exclusively native. The numbering/lettering of the policies has been changed to now reflect that this is part D, rather than part C, as it was in the original Publication draft.
Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).
Change: Additional wording to highlight the importance of creating spaces that are child-friendly and safe for women and girls. Additional revisions have been made to ensure consistency with the NPPF and ensure that the policy is a key delivery tool of play sufficiency.
Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).
Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).
Change: Amendments to ensure consistency with the National Planning Policy Framework and to address representations raised by Natural England that the policy must be better aligned to the Conservation and Species Regulations 2017 and to explicitly refer to international sites.
Change: No significant change (minor wording additions).
Change: Significant changes, including greater clarity provided through the text to set out what documentation will be expected as part of planning applications and detail on what such documentation should cover.
Change: In response to numerous representations requesting requirements for new bird and bat-friendly features to be integrated into new development, this policy, new for the Pre-submission changes version of the Plan, now sets out a requirement for development to incorporate such features.
Change: Policy has been changed to include the word ‘system’ in the title of the Policy.
9 Our existing Core Strategy has strong policies to encourage development in sustainable locations and to support high standards of design. However, these policies pre-date the climate emergency declaration and the wellbeing impacts of Covid-19, as well as the Connecting Leeds Strategy, with its ambitions for reduced private car dependence. Moreover, national guidance has changed since the Core Strategy was adopted to afford more weight to design largely as a result of what is considered to be poor quality design in many housing schemes. The Council considers that now is the right time to refresh our plan to ensure it is suitably ambitious.
10 The following suite of policies seek to address these issues by:
11 This will be achieved through the following summarised policies:
Change: references to the 20-minute neighbourhood have been deleted to better focus on the aim of creating sustainable places and clarification of the importance of social infrastructure added to the background text.
Change: Amendments to this existing policy are now proposed to be deleted and reconsidered as part of Leeds Local Plan 2040.
Change: No significant changes (reference to Accessibility Standards in Appendices).
Change: Additional wording has been inserted to strengthen requirements for development to be accessible and inclusive for all users. Drafting changes to avoid duplication of certain policy requirements also set out in Policy P10, and clarification that the policy will apply to all development.
Change: Additional wording has been inserted to clarify that new buildings and public realm should be accessible for all users. Some minor changes for clarification, and, as above, elements of this policy have been re-organised to sit within SP1B instead. Changes have been made to recognise the role of design in play sufficiency.
Change: No significant changes (minor wording addition).
12 As part of our aspiration to make Leeds zero carbon by 2030, we want to ensure that our communities are resilient to the impact of climate change. This includes policies that aid the delivery of low emissions transport and improved digital connectivity, to help reduce journeys by car. This involves policies to:
13 This will be achieved through the following summarised policies:
Change: Factual correction relating to locations Mass Transit is likely to connect.
Change: No change.
Change: Draft policy now proposed to be deleted as recent changes to Building Regulations now include similar requirements as those set out in the original draft policy.
Leeds City Council is committed to achieving net zero carbon buildings by 2030. Net zero carbon buildings will meet their own energy needs through onsite renewable generation, or where not possible, provide a financial contribution to generate the remaining energy balance offsite. Proposed policy EN1B (Operational Energy) in the Local Plan Update is an important mechanism for delivering that commitment, however we recognise that building to net zero will be a significant change for many developers.
The responses from our previous consultation showed that whilst there is a lot of support for a net zero policy from a range of stakeholders, some developers have questioned the need for any policy on net zero development, and others have raised concerns about viability (this is assessing whether a site is financially viable i.e. whether the value generated by a development is more than the cost of developing it) and feasibility (whether it can practically be achieved).
The transition period is intended to ensure that the building industry has enough time to adjust to new building practices and technology, address supply chain issues, and prepare for net zero development from 2027. Until 2027 development will not have to pay an offset cost if the development can’t meet net zero but it will be required to achieve high standards of energy efficient and renewable energy generation (measured through what is known as Energy Use Intensity targets (EUIs) and space heating targets). The transition period will give time for developers to become acquainted with these different performance metrics and for the policies to embed whilst still ensuring that Leeds is doing all it can to reduce carbon emissions.
It is important to note that this policy puts in place ambitious targets for new development to be net zero from 2027, representing one of the most ambitious climate change policies in the country, far surpassing current Government requirements.
The Local Plan will be independently tested through examination by the Secretary of State and feasibility and viability are considered in a lot of detail. We think that the introduction of the transition period will ensure that the policy is fully deliverable and will not stall necessary development.
We welcome all your comments on the transition period. If you consider that a transition period is not required and have evidence that the higher standards would be achievable by adoption of the Plan (anticipated to be early 2025) please submit this to us through the current consultation. Alternatively if you support the transition period, or if you think it is too short, please send us your comments (and any relevant evidence) for consideration.
In March 2019 the Council made a climate emergency declaration for the city to be zero carbon by 2030. We have therefore chosen a time frame that gives time for developers to adjust to the policy whilst still allowing us to meet our 2030 climate emergency commitment. A transition period ending by the start of 2027 will ensure that all new development approved from that year will meet the Council’s definition of net zero by 2030.
If the plan is adopted with a transition period to the start of 2027, this date cannot then be changed on an informal basis. The date could only be altered through another Local Plan review process, with at least two consultation periods and examination.
From 2027, for developments to meet the Council’s definition of net zero, they will have to be more energy efficient by meeting the targets in the policy and meet the remaining energy need of the development using onsite renewable energy (solar panels etc). If the developer can demonstrate that this is not achievable then they can pay an offset cost that will be used to help reduce carbon through other projects locally, such as retrofitting council homes with solar panels. Up until 2027 the developer is still expected to do their utmost to meet our net zero standards but where they have demonstrated that this is not achievable, they are not required to pay an offset cost. The result of this is that some buildings that are built before 2027 may not be net zero developments, however the policy will ensure buildings are more energy efficient than current local and national requirements.
This policy puts in place ambitious targets for new development to be net zero from 2027, representing one of the most ambitious climate change policies in the country, and far surpassing current Government requirements.
A building’s energy performance is currently measured against the Building Regulations Part L (Conservation of fuel and power). The core function of Building Regulations Part L is compliance with a series of requirements aimed to reduce heat loss and minimise energy consumption (such as a minimum level of insultation and energy-efficient lighting systems). However, Part L does not accurately reflect the total predicted energy use of a building and also does not report the unregulated energy use *.
Energy Use Intensity targets (EUIs) and space heating standards are performance measuring metrics i.e. measurable data used to track a building’s energy performance. By requiring EUI and space heating demand calculation for all new developments, all the energy use (both regulated and unregulated *) of a development is accounted for, whilst also providing key metrics to accurately measure and monitor developments being net zero in operation.
* Regulated energy is the energy required to power the operational functions such as heating and lighting. Unregulated energy powers appliances such as televisions, laptops and fridges.
Policy EN1B requires developments approved during the transition period (i.e. before January 2027) to still meet higher energy performance standards than currently required under Building Regulations Part L. Developments will still be highly efficient in terms of insultation and the draft policy requires that no new development approved during this period will be allowed a fossil fuel plant (gas or oil boilers etc.) on site. Whilst developments approved after the transition period (from January 2027 onwards) will have an even higher level of energy efficiency and will have to meet their energy demand onsite through onsite renewable energy generation. Due to the lack of fossil fuel plant onsite and the high level of insulation, there should be no need to retrofit new buildings approved during the transition period. These buildings will still be capable of becoming net zero as the national grid decarbonises (decreasing the emissions per unit of electricity generated through increasing renewable energy generation and decreasing the use of fossil fuels).
The concept of “20-minute neighbourhoods” (interchangeable with, in some other examples, “15-minute cities”) is based on the idea of planning our towns and cities to enable people to ‘live locally’ if they wish to. This is not about restricting movement or confining people to certain parts of the city, but reflecting where there are:
Complete neighbourhoods – places that have mixed used and a range of services, facilities and connections which make it possible for you not to use a car for local journeys;
Compact neighbourhoods – places that are accessible within appropriate timeframes, be it a 10, 15, 20 minute or further walk from your home; and
Connected neighbourhoods – places where movement by walking, active travel and public transport makes sense and is easy, safe and welcoming.
The use of the term complete, compact and connected is used within the Town and Country Planning Association Guide on 20-minute Neighbourhoods published in 2021. The guide is based on research across the UK and the world and sets out the ambitions to create complete, compact and connected places. These plain English terms better explain the aims of Leeds Policy SP1A. References to the 20-minute neighbourhood concept are retained in the supporting text and background paper.
This will be the final consultation before the plan is submitted to the Secretary of State for independent examination.
We are consulting again to respond to comments received at previous consultation stages, which have resulted in a range of changes to the proposed new and amended Local Plan policies. Due to the number of changes made, and the significance of some of the changes, we consider it appropriate to undertake a final period of public consultation. All comments received during this consultation period, as well as the previous ones, will be sent to Secretary of State to be considered as part of the examination.
We are only consulting on the changes that have been made to the proposed new and amended Local Plan policies and supporting text at this stage. These are contained in the ‘Schedule of Changes’ document. You cannot make new suggestions at this late stage of the plan-making process and you cannot comment on a policy that hasn’t been changed. All previous comments received at each stage of the process will be submitted to the Secretary of State to be considered as part of the examination, so these comments do not need to be repeated.
The consultation ran for a period of 6 weeks starting on Monday 30 October and finishing on 11 December 2023.
The consultation closed on 11 December 2023.
All representations received within the consultation time period will be submitted to the Secretary of State and considered as part of a Public Examination by an independent Planning Inspector.
The City Council has prepared Pre-Submission Changes to its Leeds Local Plan Update (LPU) prior to submission to the Secretary of State for Independent Examination.
The Leeds Local Plan sets out the authority's approach to planning policy and new development across the Leeds district over the next decade and beyond. Having regard to the objective of the Local Plan Update to update and improve existing policies and make new ones to address climate change, and the climate emergency declaration to achieve net zero emissions by 2030, the scope of the Plan will update and create new policies; making consequential changes, within the Adopted Leeds Core Strategy (amended 2019), the Natural Resources and Waste Local Plan (2013) and Unitary Development Plan (2006) which focus on: carbon reduction, flood risk, green and blue infrastructure including biodiversity and nature conservation), place-making and sustainable infrastructure in order to adapt to and mitigate the impacts of climate change and ensure the delivery of sustainable development within the Leeds Metropolitan District for a period of at least 15 years from Adoption.
The draft plan is based around five topic areas:
Since the consultation on the Publication Draft Policies over autumn (Oct-Dec 2022), we have made a number of changes to the Plan. These changes are the focus of the public consultation. Please note that in this consultation, comments can only be made on the changes to the Publication Draft Plan which are set out in the schedule of changes and whether the resultant Plan it is sound and legally compliant.
If you commented on the Publication Draft Policies in 2022, your representations will still be submitted to the Inspector. Please do not re-submit your comments from the last consultation. Instead, please submit your comments on the Pre-Submission Changes which have subsequently been made.
The dedicated and accessible website will be home to all the information contained within the draft Local Plan. A PDF version of the document will also be available on the website.
You will also be able to access consultation material at libraries and Community Hubs online as well as the Council’s Main Office at Merrion House, 110 Merrion Way, Leeds, LS2 8BB.
It is crucial that we hear from everybody that wants to comment on our plan, making sure we gather the views of as many people, businesses and stakeholders as possible, so the comments gathered represent varied views from all people across the city. We are only seeking your views on the changes to the draft plan at this stage and not seeking comments on wording that has not changed. We have received previous comments on the Publication Draft plan at previous stages of consultation (December 2022) and you do not need to repeat a comment that you have made previously at this stage.
As before, the comments form provided asks you to make your comments in a certain way, this is because the Government Inspector can only consider comments on the soundness or legal compliance of the Plan. This time, the focus is on the Pre-Submission Changes and whether they make the plan sound and/or legally compliant. The form will therefore ask you to clearly highlight the change you are commenting on.
We are asking for people to consider two specific questions when making representations on the Pre-Submission changes to the Local plan:
1) Is the plan legally compliant? Does the plan comply with the relevant legislation and regulations in the way it has been prepared, and in its content?
2) Is the plan ‘sound’? Has the plan been ‘positively prepared?’ Is it robustly justified and evidence-led? Will it be effective in what it sets out to achieve? And is it consistent with national planning policy?
People can have their say on the Local Plan Pre-Submission Changes by using the online response form through the website; alternatively emailing lpu@leeds.gov.uk, or
by writing to: Leeds Local Plan Update Consultation, Policy & Plan Group, Merrion House, 9th Floor East, 110 Merrion Way, Leeds, LS2 8BB.
All representations received within the time period outlined above, will be submitted to the Secretary of State, along with representations the Council has received from previous consultation in 2022 and considered as part of a Public Examination by an Independent Planning Inspector.
Respondents can indicate on the comments from whether they would like to be notified of future stages in the progression of the Council’s Local Plan
Please let us know if you have any requirements in terms of alternative formats or languages and we will make arrangements to make sure your views are registered.
If you are unable to access the consultation material online please contact us on 0113 37 87993 or write to us a: lpu@leeds.gov.uk
The council will review all comments made to us during the consultation period, and consider whether further changes to the Plan are required before submission to Government. The updated draft Local Plan and all comments submitted during this consultation and the Publication Draft consultation, are sent to the Secretary of State for the Department of Levelling Up, Housing & Communities.
They will then appoint an independent Planning Inspector to undertake a ‘public examination’ of the draft Local Plan, who will decide if any changes are needed to the Plan, having taken into account all of the comments received at each stage of the process, before it is adopted.
The examination will include hearing sessions which are held in public so you will be asked when you submit your comments if you would like to attend one of these hearings.
Give feedback and let us know if this page was helpful