Scoping Consultation 2023

Scoping Consultation - Leeds Local Plan

Introduction

This document sets out how Leeds City Council has involved the community and other stakeholders in the early stages of preparation (“Scoping”) of the Leeds Local Plan 2040 (“the Plan”). It shows how the Council has complied with Regulation 18 of the Town and Country Planning (Local Development) (England) 2012 Regulations and how it has undertaken engagement is accordance with the 2012 Regulations. 

In accordance with regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012, this document set out: 

1. Which bodies and persons the Council invited to make representations  
2. How those bodies and persons were invited to make representations   
3. A summary of the main issues raised by the representations made; and,
4. How any representations made have been taken into account. 

This document summarises the process involved in preparing and conducting consultation on the Plan. This document covers the engagement and consultation undertaken at Regulation 18 stage on the scope of the Plan between 10^th February and 24^th March 2023. It also provides a summary of the outcomes of this stage of consultation, and how the representations received informed the next stage in the Plan preparation process, namely “Issues & Options”. 

The Council’s Statement of Community Involvement (SCI) sets out how Leeds City Council should undertake consultation and engagement on Local Plan documents, detailing how we will comply with statutory requirements and to help ensure that the consultation and engagement that we undertake is inclusive.  

An overview of the consultation and engagement undertaken to date are set out in the table below: 

To aid informed consultation and engagement the Council published a range of background papers and resources, which can be found via this link.

Topic 1 – Spatial strategy

Topic 2 – Housing

Topic 3 – Economic development

Topic 4 – Role of city and local centres

Topic 5 – Minerals & waste

Topic 6 – Transport & connectivity

Topic 7 – Other topic areas

Leeds Local Plan 2040 Scoping Consultation Document pdf

Leeds Local Plan 2040 Sustainability Scoping Report pdf

Leeds Local Plan 2040 Scoping Consultation Summary Document pdf

Leeds Local Plan 2040 Call for Sites

Background

The Leeds Local Plan sets the land use and spatial planning framework for how Leeds will develop. The current Leeds Local Plan is a set of five Development Plan Documents (DPDs): 

1. The Core Strategy (2014), with selective review (2019). 
2. Site Allocations Plan (2019) 
3. Aire Valley Leeds Area Action Plan (2017) 
4. Natural Resources and Waste Local Plan (2013) 
5. Saved policies of the Unitary Development Plan Review (2006) 

The Local Plan and 20 made Neighbourhood Plans together form the Statutory Development Plan, which is used, alongside the National Planning Policy Framework, to 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, such as housing, employment, minerals and waste etc., and make sure that priorities such as design, green space, heritage, infrastructure and flood risk management are considered during decision making.

Local Authorities are required by the Town and Country Planning Act (England) Regulations 2012 to review the policies that make up the Local Plan, every five years.  

In 2019/2020 Leeds Local Plan Review was carried out, focusing on the out-of-date policies in the adopted Leeds Local Plan and considering whether they were still relevant (in line with the updated National Planning Policy Framework), whether the evidence base had changed or needed refreshing or whether changes in local circumstances related to the Council Priorities around the Climate Emergency, Leeds Inclusive Growth Strategy, Health and Well-being and infrastructure (e.g. HS2) needed to be reflected. The policies identified as in need of updating were wide in scope. See Appendix 1 – Local Plan Review Report 2020.

Following this Local Plan Review and informed by declarations made at Full Council, the review of policies and detailed discussions with the Development Plan Panel, it was proposed that the Local Plan for Leeds should be updated in 2 stages:

1. Policies that directly relate to addressing the climate emergency (including carbon reduction, flood risk, green and blue infrastructure, place-making and sustainable infrastructure) are being addressed through the Local Plan Update - Your Neighbourhood Your City Your Planet.
2. Other policy areas regarding the future growth of the City and where sustainable development should best take place will be addressed through the Leeds Local Plan 2040.

 It is intended that there are 3 main stages of consultation for Leeds Local Plan 2040:

1. Regulation 18 ‘Scoping’ – A high-level consultation, detailing the issues as we see them, some possible ways we think we could address these issues, and asking people whether they agree. This includes a Call for Sites, targeted at both landowners and communities, to see what sites may be available and any suggested uses. Some potential topic areas were suggested in the consultation material, based on policies that the Local Plan Review identified as requiring update, as well as possible policy gaps which were suggested in previous consultations. Little detail/evidence was presented at this stage to leave it open for views, comments and suggestions.
2. Regulation 18 ‘Issues & Options’ – Based on the comments received from the Scoping Consultation more detailed policy areas and potential options will be presented for consultation, along with some of the evidence base and potential sites from the Call for Sites.
3. Regulation 19 ‘Publication Draft’ – All comments received during both Regulation 18 consultations, as well as evidence and research undertaken, will be used to shape proposed policies and potential allocations which will then be put forward as a Publication Draft for comments before submission and examination in public.

Consultation Principles

Involving local people, businesses, and other stakeholders and partners is essential for good planning and to achieve the city that we all want. Topics such as the spatial strategy, housing, economic development, transport and green belt are important to everyone who lives, works and has an interest in Leeds. These considerations were at the heart of the planning, delivery and assessment of consultation on the Leeds Local Plan 2040. The stakeholders we engaged with during the Regulation 18 Scoping consultation period were: 

Leeds City Council adopted a new Statement of Community Involvement in November 2022, and this document was used to undertake consultation on the Leeds Local Plan 2040. A combination of face-to-face opportunities and online resources were used to appeal to the variety of different stakeholders. We also embedded the use of plain English, accessibility, inclusion and choice within the consultation, in line with guidance contained in the SCI.

Our aims for this consultation were: 

• Ensuring that the consultation represents value for money and that we are making the best use of officer time. 
• Removing barriers to consultation so we can support participation from individuals, groups and neighbourhoods right across the city. 
• Make sure the information we provide leads to ‘quality’ comments that will influence the direction of travel for the Leeds Local Plan 2040.  
• Consider how we can achieve the 3 targets set out in the Statement of Community Involvement during this consultation. 
• Look to simplify the Leeds Local Plan, reducing the number of development plan documents to make it easier for officers, developers and communities to understand what is and isn’t acceptable for new development in the District. 
• Provide confidence to everyone taking part in the consultation that their feedback will be fully considered and responded to in a timely manner.

In accordance with the SCI and consultation good practice, the following principles were used to guide consultation on the Leeds Local Plan 2040 throughout the plan preparation process to help us hear as many views as possible and use those views to influence the Plan:

Trust

• Commitment to working with partners and communities in a blended way 
• There will be honesty about what can and can’t be influenced and achieved 
• Officers will consult with residents/other stakeholders in a respectful manner 

Timely

• Local Plan consultations will be at a time when proposals are at a formative stage to give people maximum opportunity to influence outcomes (‘frontloading’) 
• An adequate length of time will be allocated for the consultation period 
• All relevant information will be provided in a timely fashion 

Visible

• There will be clarity about the aims, purpose and scope of the consultation 
• The use of plain English at all times will ensure accessible consultations 
• Consultation and engagement activity will be promoted as widely as possible, as well as targeted to those most affected where necessary 

Inclusive

• Consultations will be open and accessible to engage with different sectors of the community 
• There will be a commitment to eliminating discrimination and advancing equal opportunities

Transparent

• The results of each consultation will be used to show how it has influenced decisions 
• The findings of the consultation, meaningful feedback and outcomes will be easily accessible 
• Value for money will be achieved by ensuring that consultation is effective and proportionate to the issues being considered and the communities affected 

For the first time the SCI also introduced targets to enable us to assess whether we are increasing our reach with engagement within different communities around the district. These targets were used to help us plan our consultation activity during Leeds Local Plan 2040 preparation, as well as facilitating reflection on the success of different approaches during the consultation period and making changes where necessary

Target 1 – To achieve responses from every Ward on district-wide plan-making consultations. 

Target 2 – To receive positive feedback on consultations that we undertake on plan-making (feedback will be used to help secure a positive trend in people’s satisfaction levels over the 5-year SCI period). 

Target 3 – There will be a year-on-year increase in consultation and engagement by young people (under 25’s) between 2022 and 2027. 

Equality

We directly targeted a range of community groups and organisations, including organisations representing a range of social groups including people from minority backgrounds, faith groups, gypsies / travellers / travelling showpeople, people with disabilities. These groups were wider and more diverse than the protected characteristic groups identified in the ‘Equality Act 2010’. The aim of the consultation was to allow all an opportunity to participate in and have access to the Local Plan process. Equality considerations have also been an integral part of policy formulation from the outset. 

A range of engagement techniques were used, to ensure that the consultation was as inclusive as possible including: 

• Translation/other formats available for all documents on request 
• The use of accessible venues 
• Ensuring consultations were advertised using a wide range of ways, via social media and more traditional methods to make it more accessible for all. 
• Use of different formats such as web videos, face to face and smart surveys for consultation. 
• Involvement with trusted ambassadors, such as Leeds Gypsy and Traveller exchange.

Scoping Consultation (Regulation 18)

The first regulatory milestone in the preparation of a Development Plan Document such as the Leeds Local Plan 2040, is an initial stage of public consultation known as ‘Regulation 18’ or ‘Scoping’ consultation. The purpose of this stage is to ascertain views on what matters the Plan will need to consider and address i.e. its scope in order to achieve its identified objectives.  The regulations specify that, as part of the plan preparation process, we must invite representations (comments/suggestions) on what the Plan ought to contain.   

 The scoping consultation was an opportunity for the Council to share its proposed direction of travel with the public, businesses and consultation bodies and ask for people’s ideas, opinions, local experiences and evidence to help us shape the plan. Whilst being mindful of the need not to pre-judge the outcome of the consultation, it was considered that it would be helpful to respondents if there was some direction provided by the Council based on the policies areas that we knew required updating, with provision of some initial topics as a means of generating responses to the Plan at this early stage.  It was hoped that this approach would help focus comments and help stimulate debate. However it was made clear that these were initial topic areas and the consultation provided opportunity to agree /disagree with any part of the material and raise other views, suggestions and evidence. 

 The Leeds Local Plan 2040 Regulation 18 Scoping consultation took place for 6 weeks, between 10^th February and 24^th March 2023. Well in advance of the start of the consultation an engagement strategy was prepared where we considered how we could ensure that the methods used for promotion, information and consultation were as effective, far-reaching and inclusive as possible. We also looked at the feedback and lessons learned from previous planning consultations and made sure we acted upon those during the LLP2040 consultation. A number of objectives were used to focus our activity during the consultation period: 

• Reflect on what has worked well or not in recent planning consultations to refine our online and offline methods. 
• Develop digital content which provides an improved user-experience, including clear, accessible and informative web pages, videos and surveys that cater for all needs, whether people are knowledgeable about planning issues or not. 
• Provide engaging ‘offline’ events that are easily accessible to help people get involved who are not digitally connected or comfortable using this medium to inform themselves or submit comments. 
• We will actively seek comments from all wards across the District in order to achieve Target 1 of the SCI. This will include considering the best ways to engage with different communities. 
• By considering Plain English in all documents, and providing choice in our consultation material, response forms and events we will try to increase the positive feedback we receive in line with Target 2 of the SCI. 
• We will actively seek comments from all groups across Leeds and from those that are typically under-represented in planning consultations e.g. young people in line with Target 3 of the SCI, but also members of inner-city/more deprived communities, BAME communities, Gyspy/Traveller community etc.  
• We will demonstrate, in a form that is readily accessible and easily understood by the whole community, how the plan reflects the views and opinions expressed during the consultation process, and where those views cannot legitimately be taken into account, explain why that is the case

Consultation Material

The consultation material used to inform people included the Scoping Consultation Document presenting the range of topics we thought should be considered through the Leeds Local Plan 2040. These were also condensed down into a ‘Summary’ version, to give people choice over how much time they wished to commit to learning about the Plan. The material was accessed via a campaign webpage in two formats:

• HTML format – an accessible web-based format which can be used on e-readers and translated into different languages using the relevant software. The html format is also mobile phone/tablet-friendly, which means the text fits the size of the screen and can be easily scrolled.
• Pdf format – a graphically designed version of the full and summary material was produced that could be downloaded and printed. The material was designed to be more engaging and visually appealing with the use of colour, photographs and other graphics.

Publicity

There was a detailed publicity and communications strategy which used a clear graphic across the campaign and printed material for consistency and branding.  The methods used to publicise the consultation included:

• GovDelivery bulletin to everyone on the Planning consultation database (including residents, businesses, Council Officers, Ward Members, statutory consultees, neighbouring authorities etc.), reaching 2054 contacts
• Two media releases were issued at different stages of the campaign, signposting to the website. Coverage was secured in a number of local media websites and newspapers including Yorkshire Evening Post, Leeds Live, Wharfedale Observer, Leeds Star, Caring Together, Leeds Climate, Doing Good Leeds, South Leeds Live and The Telegraph & Argus
• Posters were designed and printed, and distributed to all libraries and Community Hubs around the Leeds district, as well as Kirkgate Market. E-posters were made available for groups / forums who were willing to distribute
• Email bulletins via Youth Council, Youth Parliament, Voice & Influence Networks, Localities Networks, Equalities Network, the Universities. These networks were used to reach diverse communities in Leeds.
• Use of Leeds City Council social media channels/networks for promotion (Facebook, Twitter, LinkedIn). Included Equality Network, Community Committees, Children & Families, Age Friendly Network. Total reach of 1,026,139
• Paid for/organic social media posts via Facebook, Twitter, LinkedIn and paid for digital advertising. Boosted Facebook posts were used to target specific Wards in advance of webinars and consultation events. Users across Facebook and Instagram within Leeds reaching just under 200,00 unique users. Generating 8132 click throughs to the survey/ website.
• Promotion of consultation during any public meetings taking place during the consultation period, including Neighbourhood forums / Parish & Town Councils and Community committees.

Consultation Programme

A variety of different face to face events were organised to reach a range of different stakeholders throughout the District:

• Face to face drop-in events at Merrion Centre, Kirkgate Market and Trinity Leeds.
• Internal department meetings with Transport Strategy, Influencing Travel Behaviour Team, Cultural Programmes Team and Culture & Economy Connect.
• Attendance at meetings with various Parish Councils and Neighbourhood Forums.
• Briefing at Leeds College of Building.
• Engagement event at Garforth academy Sixth Form.
• Event with Leeds Involving People and members of the neurodiverse community.
• Attendance at Outer North East Town & Parish Council forum
• University of Leeds Masters in Sustainability Consultancy talk.
• Outer Northwest Youth Summit.
• Meeting with Leeds Deaf Forum.
• Meeting at Otley Town Hall.

Consultation Reponses

There were a number of ways for people to make comments on the Scoping material:

• A full response form, and also 7 separate topic response forms if someone is only interested in one or two topics. The full response form also has ‘skip logic’ embedded which allows people to skip some of the more technical questions if they wish. 
• A young persons survey, available online or by paper copy taken to various events
• Via the dedicated LLP2040 email address. 
• A postal address was provided. 
• Officers recorded informal comments at online / in-person events. 
• A telephone number was made available for queries. 

All comments received were entered into a database to enable analysis. 

In total 1004 submissions were made during the consultation period which related to the Leeds Local Plan 2040 Scoping consultation stage. The method in which people chose to submit their comments is set out below:

• Smart Survey - 747 submissions (75% of total)
• Email Responses - 225 submissions (22% of total)
• Young person's survey - 32 submissions (3% of total)