Introduction and have your say

Find information about the local plan update pre-submission changes consultation and how you can have your say.

The pre-submission consultation closed on Monday 11 December 2023.

About the Local Plan

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.

Why focus on climate change

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:

  • supporting developments that shape places in ways that contribute to radical reductions in greenhouse gas emissions (for example - reducing the need to travel by car)
  • minimising vulnerability and improving resilience (for example - by avoiding places that flood and dealing with water)
  • encouraging more careful use of resources (for example - by making homes more efficient)
  • supporting the move towards renewable and low carbon energy (for example - wind or solar)

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.

What we have already done

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. 

Current consultation

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:

Timeline of the local plan changes in full, provided as text below
Local Plan Update timeline

Previous stages

Local Plan Update timeline - Previous stages
Evidence gathering and research
Issues and options/scoping consultation (Regulation 18)
Consult on the Publication draft plan (Regulation 19)

Current stage

Local Plan Update timeline - Current stage
Consult on the pre-submission changes

Upcoming stages

Local Plan Update timeline - Upcoming stages
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

What can you influence

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:

Positively prepared

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

Consistent with National Policy

The plan seeks to deliver sustainable development and is consistent with national policy

Consultation documents

To view the proposals for the Local Plan Update pre-submission changes consultation the following documents are available:

Background papers:

Helpful guidance

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.

Summary of the Local Plan Update Pre-Submission Changes

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.                      

Overall Approach

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.                       

  • New Strategic Policy SP0: Climate Change Mitigation and Adaptation: The Policy is a statement of ambition that will drive the aspiration to achieve a reduction of carbon emissions to net zero by 2030, whilst tackling the biodiversity emergency and promoting health and well-being. It will aim to reduce climate change and increase adaptability.

    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.                      

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:                      

  • Requiring that from 2028 most new applications (with stated exceptions) achieve a net zero standard in their operational use (the heating, lighting and other energy demands of a building once occupied), by maximising energy efficiency, reducing energy demand and making use of renewable energy.
  • Requiring that all major applications calculate the whole life cycle carbon emissions of their proposals (including the carbon emissions from the materials, construction of the development, repair and refurbishment during use, in-use emissions, deconstruction at the end of life of the development and the reuse of the building and / or materials), to understand the impacts of all stages of development, rather than just its occupation and operation.
  • Requiring that all major development meet a sustainable construction standard, therefore allowing for high standards of construction.
  • Identifying opportunity areas for renewable energy generation and establishing criteria for the successful determination of planning applications for such uses, as well as energy storage facilities.
  • Encouraging developments to make use of a range of sustainable energy and heating technologies, where connections to the District Heating Network are not possible.

4 This will be achieved through the following summarised policies:                      

  • Replacement Policy EN1: Carbon Reduction: A new strategic policy that requires a) new development to be net zero for operational carbon from 2027 and b) that whole life cycle calculations of carbon will be carried out by developers.

    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.                      

  • New Policy EN2: Sustainable Design And Construction: A new strategic policy that requires new development to meet a high-quality sustainable construction standard of Home Quality Mark 4 or BREEAM Excellent.

    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.                      

  • New Policy EN3: Renewable Energy Generation: A new strategic policy that seeks to identify and support opportunities for renewable sources of energy generation and energy storage within the district in the context of national planning policy. The policy identifies opportunity areas for renewable energy on a map and requires that all applications within this area are assessed so that they limit impacts on ecology and landscape.

    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.                      

  • Amended Policy EN4: District Heating: The amendments to this existing policy prioritise low carbon heat solutions for new developments that lie outside of district heating network zones.

    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.                      

  • Flood risk

    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:                      

    • Reflecting the latest Strategic Flood Risk Assessment (SFRA) modelling and avoiding development in areas at highest risk of flooding, whilst recognising that these are often brownfield sites with existing buildings which are already developed. The policy goes further than the current policy in resisting new development in vulnerable areas based on our updated flood risk evidence.
    • Ensuring that all developments consider flood risk by carrying out a flood risk assessment and to reflect climate change allowances, which are mapped and available for developers to use.
    • Ensuring that in circumstances where flood risk to development is unavoidable, the safety of the development and its users is secured.
    • Ensuring that where areas of the District are protected by flood defences, developers have regard to residual risks associated with a potential breach and overtopping of the flood alleviation scheme or other defence, whichever is the worst case scenario.
    • Requiring that all developments manage water sustainably, through the establishment of a surface water drainage discharge hierarchy.

    6 This will be achieved through the following summarised policies:                       

    • Amended Water 1 and Water 2: A re-packaging of existing Natural Resources and Waste policies to be incorporated into the Core Strategy, covering water efficiency and the protection of water quality.

      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.                      

    • Replacement Natural Resources and Waste Policy Water 3: Functional Floodplain: A new strategic Core Strategy policy providing an approach to protecting the functional floodplain from unsustainable development.

      Change: Alterations to reflect the new definition of functional floodplain in National Planning Practice Guidance.                      

    • Amended Policy Water 4: Land at Increased Risk of Flooding: A revised policy amended to incorporate a requirement to consider the impact of climate change on future levels of flood risk.

      Change: Providing greater clarity by requiring that proposals consider the layout of a site and the relative flood risks across it.                      

    • Amended Natural Resources and Waste Policy Water 6: Flood Risk Assessments: Amendments require that the latest Government climate change allowances are considered in Flood Risk Assessments that accompany new development.

      Change: Clarity on what developer contributions may be required to fund, and revisions to terminology in response to representation from the Environment Agency.                      

    • New Policy Water 6A: Safe Access And Egress: A new strategic Core Strategy policy ensuring that safe routes are available for occupiers of development in time of flood

      Change: Revisions to terminology in response to representation from the Environment Agency.                      

    • Replacement Natural Resources and Waste Policy 5: Residual Risk: A new strategic Core Strategy policy requiring an assessment of residual risk (e.g. of defences failing) for development in defended land (areas where the risk of flooding is reduced due to the presence of flood alleviation schemes / defences).

      Change: Clarity that all sources of flooding should be considered.                      

    • Replacement Natural Resources and Waste Policy Water 7: Sustainable Drainage: A new strategic Core Strategy policy associated with the design of new developments and managing surface water discharge via a hierarchy of storage, infiltration (the soaking of water into the ground) and attenuation (the slowing down of surface flows before their transfer downstream) before any discharge into water courses. It also requires Sustainable Drainage (such as ponds and swales) that benefits biodiversity.

      Change: Providing greater clarity on how the discharge and storage of rainwater should be considered, in response to representation from the Environment Agency.                      

    • New Water Policy 8: Porous Paving and Loss of Front Gardens

      Change: Further clarity and revised structure of the policy.                      

    Green and Blue Infrastructure (GBI)

    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:                      

    • Requiring planning applications to consider GBI at the earliest stage with the aim of protecting, maintaining, enhancing and extending GBI where appropriate.
    • Requiring applications to include GBI assessments.
    • Enhancing protections for existing trees and hedgerows.
    • Requiring ambitious targets for tree replacement and additional planting to ensure that Leeds overall tree canopy is increased.
    • Requiring a further consideration of new Green Space provision to ensure it is being directed to the right locations and in the right form.
    • Establishing clear criteria for how the quality of Green Space should be considered as part of new planning applications.
    • Establishing clear policy on how applications should adequately consider the future maintenance of new GBI provision.
    • Establishing clearer definitions of Green Space and how it will be protected through development.
    • Requiring local food production and wider encouragement for sustainable food production.
    • Establishing further protections for the Leeds Habitat Network and a locally specific clarification of how Biodiversity Net Gain should be addressed in Leeds.

    8 This will be achieved through the following summarised policies:                      

    • Replacement Spatial Policy 13: Protecting, Maintaining, Enhancing and Extending Green and Blue Infrastructure: A new strategic policy that sets an ambition for the protection, maintenance, enhancement, and expansion of green and blue infrastructure (including green space networks).

      Change: Removed wording that was repeated separately in Policy G1.                      

    • Replacement Policy G1: Protecting, Enhancing and Extending Green and Blue Infrastructure: A new strategic policy that requires all new development to carry out a green and blue Infrastructure assessment.

      Change: Minor wording changes to strengthen requirements and clarify that Public Rights of Way should be including as part of the GBI assessment.                      

    • New Policy G2A: Protection of Trees, Woodland and Hedgerows: A strategic policy which seeks to retain all woodlands, trees and hedgerows or ensure that their loss has been considered through development appraisal. Recognises the role of trees in capturing carbon as well as amenity and habitat.

      Change: Provide clarity on the category of trees to be retained (i.e. the policy will not apply to dead or diseased trees).                      

    • New Policy G2B Ancient Woodland, Ancient Trees, and Veteran Trees: A strategic policy which seeks to protect ancient woodland, long established woodland, ancient trees and veteran trees and avoid loss of irreplaceable habitats. Recognises the role of trees in capturing carbon as well as amenity and habitat.

      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.                      

    • New Policy G2c: Long Established Woodland.

      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.                      

    • New Policy G2D: Tree Replacement: A strategic policy which recognises the role of trees in capturing carbon and establishes a methodology for calculating and requiring tree replacement (where necessary), based on carbon sequestration.

      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.                      

    • Amended Policy G4A: Green Space Improvement and New Green Space Provision: Amended part of policy clarifies the approach to the provision of greenspace, explaining the consideration regarding delivery on-site, off-site or as commuted sums, which will now cover the City Centre.

      Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).                      

    • New Policy G4B: Quality of New Green and Blue Space: A strategic policy associated with the design and quality of new green space.

      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.                       

    • New Policy G4C: Maintenance of Green Space: A strategic policy establishing clear criteria for the maintenance of green space.

      Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).                      

    • Replacement Policy G6: Protection of Existing Green Space: A new strategic policy associated with the definition and protection of green space.

      Change: No significant change (inclusion of reference to ‘blue’ space in the proposed policy).                      

    • New Policy G8A: Protection of Important Species and Habitats: This new policy specifically looks at protecting the natural environment and includes references to the implications of climate change upon the natural environment.

      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.                       

    • New Policy G8B: Leeds Habitat Network: This policy clarifies the role of the Leeds Habitat Network and establishes the requirements of new development with regard to the protection, enhancement and expansion of the network.

      Change: No significant change (minor wording additions).                      

    • New Policy G9: Biodiversity Net Gain: This policy specifically looks at protecting the natural environment and applying measures within the Environment Act 2021, by clarifying how the application of the 10% biodiversity net gain requirement will apply in Leeds.

      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.                       

    • New Policy G10: Biodiversity Enhancements For Species.

      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.                      

    • New Policy F1: Food System Resilience: A strategic policy that supports food resilience and food growing opportunities as part of new developments.

      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:                      

    • Establishing a broad consideration of good design to ensure that the highest design standards are being achieved in Leeds.
    • Establishing clear principle for high quality placemaking.
    • Reflecting the 20-minute neighbourhood concept into planning policy by defining its meaning in Leeds and requiring that new development be directed to sustainable locations.
    • Ensuring that the wider determinates of health (housing, employment, education, green space, air quality, transport, climate change and social and community networks) are taken into account in development so as to increase life expectancy and narrow health inequalities.

    11 This will be achieved through the following summarised policies:                      

    • New Policy Sp1a: Complete, Compact And Connected Places: This strategic policy relates to supporting the long-term sustainability of communities through encouraging growth in locations that are highly accessible to services including public transport and greenspace. It recognises the role of the provision of key services in serving a key function as well as reducing car use and promoting active travel. The policy complements the current spatial strategy as set out in the Core Strategy 2019.

      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.                      

    • Amended Spatial Policy 1: Location Of Development:

      Change: Amendments to this existing policy are now proposed to be deleted and reconsidered as part of Leeds Local Plan 2040.                      

    • New Policy EN9 – Drive Thru Development: A strategic policy which seeks to reduce ‘Drive-thru’ restaurants development, outside of town centres to reduce air pollution and encourage active travel.

      Change: No significant changes (reference to Accessibility Standards in Appendices).                      

    • New Policy SP1B: Achieving Well-designed Places: A strategic policy associated with the design and layout of new developments and quality of place achieved through appraisal of environmental, economic, and social matters.

      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.                      

    • Replacement Policy P10: Development Principles For High-quality Design & Healthy Place Making: This policy established clear and precise requirements for the design of new developments from a development principles and high quality design perspective, for the purposes of climate change mitigation, adaptation and health and wellbeing, as well as environmental harmony.

      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.                      

    • New Policy P10A: The Health Impacts of Development: A strategic policy which seeks to reduces the causes of ill health and health inequalities by ensuring healthier environments, lifestyles and impacts that development can deliver including access to services. The policy is concerned with the design and assessment of new developments and requires development proposals for largescale development to be accompanied by a Health Impact Assessment.

      Change: No significant changes (minor wording addition).                      

    • Sustainable Infrastructure

      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:                      

      • Help plan for significant investment in transport infrastructure in Leeds (including supporting the Combined Authority’s vision for Mass Transit and subsequent business case to Government, as well as helping plan for the outcome of the Government’s study on how HS2 trains will arrive at Leeds from the East Midlands as outlined in the Integrated Rail Plan), which is proposed over the coming years, by facilitating and supporting these works, and in ensuring that they come forward in a manner with maximises their potential benefits and minimises or mitigates any potential adverse impacts.

      13 This will be achieved through the following summarised policies:                      

      • New Policy SP11A: Mass Transit and Rail Infrastructure: A strategic policy setting ambition and support for a Yorkshire mass transit system and rail infrastructure improvement schemes which will deliver improved connectivity by public transport. The policy is supportive of mass transit in principle and sets conditions to ensure that environmental impacts are minimised but does not identify a preferred route.

        Change: Factual correction relating to locations Mass Transit is likely to connect.                      

      • New Policy SP11B: Leeds Station: A strategic policy which supports growth of the station and sets criteria for it to be developed in a manner which is well designed and fits within its surroundings and historic environment.

        Change: No change.                      

      • New Policy DC1: Digital Connectivity:

        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.                      


Why have we introduced a transition period?

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.                      

Why did we choose that timeframe?

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.                        

What impact will it have on developments reaching net zero?

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.                      

Why does the policy favour Energy Use Intensity targets (EUIs) rather than Building Regulations (Part L) as a measure of performance?

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.                      

Will developments approved before 2027 be required to retrofit to bring them up to net zero?

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).                      

Why have we replaced the term “20-minute Neighbourhoods” with Complete Compact Connected places”?

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.                      

Why are we consulting on this Plan again?

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.                      

What can I comment on as part of this consultation?

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.

Further information can be found on our Statement of Representation

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:                     

  • Carbon reduction - changing the way buildings are built, and how we generate renewable energy.
  • Flood risk - making our communities resilient to the impact of flooding, one of the most direct impacts of climate change that Leeds faces.
  • Green & Blue infrastructure - making the most of our green spaces and natural environment, to help improve the health and well-being of our citizens.
  • Place-making – guiding new development to places that offer the best opportunities for active travel and public transport, health & well-being and making the best use of communities’ assets to create complete, compact and connected places where people want to live, work and play.
  • Sustainable infrastructure – integrating low emissions transport and, helping reduce journeys by car.

Period for submission of Comments

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.                      

The Pre-Submission Changes consultation will run for a period of 6 weeks starting on Monday 30th October and finishing on Monday 11th December 2023.                     

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.                     

How to view the documents

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.                     

Key points to consider when making a representation

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?                     

Submitting your comments

People can have their say on the Local Plan Pre-Submission Changes by using the online response form through the website; alternatively emailing, or                     

by writing to: Leeds Local Plan Update Consultation, Policy & Plan Group, Merrion House, 9th Floor East, 110 Merrion Way, Leeds, LS2 8BB.                     

All comments should be received by Monday 11 December 2023.                      

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.                     

Notification Request

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:                     


What happens after the consultation

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.