We object to the exclusion of Broughton Astley from this policy; no new development is directed to this settlement, which is one of the most sustainable in the district.
There is no doubt that Broughton Astley is a sustainable settlement; policy SS1 The Spatial Strategy lists Broughton Astley as a Key Centre, alongside Lutterworth. These two settlements sit third in the hierarchy after the Leicester Principle Urban Area (PUA) and Market Harborough. Appendix F defines Key Centres as "Settlements capable of sustaining expansion, infill and redevelopment on a scale which reflects their good levels of services, facilities and employment."

Policy H1 Provision of new housing, allocates sites in the PUA, at Market Harborough and Lutterworth and the lower order settlements, but none for Broughton Astley. Little explanation is provided in the Plan; paragraph 3.1.10 states that a neighbourhood plan has been made and allocates "more than enough housing land to meet its needs." Similarly, the Sustainability Appraisal states that "The settlement has a made Neighbourhood Plan, which includes site allocations expected to deliver dwellings in excess of any target for the settlement under the preferred option. In addition to completions and commitments no dwellings are required to be found."
The quantum of Broughton Astley's housing need is not specified in the Plan. Furthermore, no evidence is presented in the Plan to explain whether Broughton Astley, as one of the most sustainable settlements in the District, can accommodate more development to meet a share of the District's needs.
Firstly, we contend that the Plan should contain a clear explanation as to why this Key Centre is not considered able to accommodate any more new dwellings. Without such an explanation the evidence base is neither robust nor transparent and therefore fails to satisfy paragraph 182 of the National planning Policy Framework (NPPF) which requires Local Plans to be "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence".
Further growth at Broughton Astley and its ability to accommodate it have not been considered through the plan preparation process at all. The Options Consultation Document, 2015 contained 9 different options and combinations of options, however, none of these included any development at all at Broughton Astley. The Sustainability Appraisal does not consider the effect of development at Broughton Astley, with the explanation given that "the settlement strategy is already determined in the Neighbourhood Plan, hence effects are neutral across the board". Therefore, it would appear that the development strategy was determined prior to the Sustainability Appraisal being undertaken. As such, the reasonable alternatives have not been considered, nor is the evidence proportionate.
Secondly, modest growth at Broughton Astley would not be out of keeping with the scale of the settlement, its place in the settlement hierarchy or in comparison to other settlements.
According to the Sustainability Appraisal, there were/are 619 completions and commitments for Broughton Astley between 2011 and 2017.
Lutterworth, which occupies the same level of the settlement hierarchy had 753 completions and commitments between 2011 and 2017 with 1,500 dwellings proposed for allocation, a total of 2,253 dwellings. It is appreciated that this is a Strategic Development Area, but it provides a useful context for comparison of the 619 dwellings committed or delivered at Broughton Astley.
The Rural Centre of Fleckney, which occupies a lower level of the settlement hierarchy than Broughton Astley is proposed for 295 dwellings, three other Rural Centres a total of 110 ranging from 10 to 65 dwellings each and the Selected Rural Villages, at the bottom of the hierarchy, a total of 415 ranging from 10 to 50 dwellings. These are all minimum requirements.
In this context, it would not be inappropriate to direct a modest level of new development towards Broughton Astley.
Thirdly, preventing growth of a sustainable settlement is contrary to the NPPF which requires the planning system to play an active role in guiding sustainable solutions. Paragraph 15 is clear that "policies in Local Plans should follow the approach of the presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay. All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally."
The exclusion of Broughton Astley from policy H1 is not in accordance with other policies within the Plan. Specifically, paragraph 5.1.12 states that housing land is provided in accordance with the settlement hierarchy and strategic aims of Policy SS1 Spatial Strategy. This is not the case as Policy SS1 seeks to "direct development to appropriate locations" and lists Broughton Astley as a Key Centre, suitable for development.
Whilst proposed policies SS1v and GD2 do allow for development in addition to those allocated, however, the lack of a housing target for Broughton Astley leaves a question mark over how these policies apply.
There does not appear to be any specific provision within the Plan for any development at Broughton Astley at all, meaning the Plan lacks flexibility and will actively prevent sustainable development from coming forward.
Broughton Astley has an ageing population, with Primethorpe Ward having seen an overall decrease in population. This decline cannot be reversed without development and the benefits that it can bring. Many lower order settlements are also reliant on Broughton Astley for services, specifically the doctor's surgery and primary school. Without development to fund expansion and improvements, these services could struggle to continue to serve the settlement and rural hinterland.
The moratorium of growth proposed for Broughton Astley does not promote sustainable patterns of development and as such, is contrary to national policy so fails to accord with paragraph 182 of the NPPF.