I note that the HEDNA dated January 2017 states (para 12.31)

A 15% adjustment is justified in Harborough and Melton on the basis that there is both a clear case for adjustments to improve affordable housing delivery and the market signals evidence presents these areas as being the more expensive parts of the HMA;

I suggest is not the business of the HEDNA to dictate planning policy, but to inform the housing need and it is up to the Council to implement policies for affordable housing accordingly.

The draft Local Plan states:

5.1.10 Policy H1 provides for delivery of the housing plan requirement, plus an additional 15% contingency in the supply of housing land in order to allow for possible future circumstances affecting the supply of housing in the District, including: * a potential need to help meet demonstrable unmet housing need arising from other local planning authorities within the Leicester and Leicestershire Housing Market Area (HMA); * a slower delivery than expected on housing allocations and/or the strategic development areas; * housing sites gaining planning permission but not delivering completed housing in a timely manner or at the density originally proposed; * changing economic circumstances affecting the take-up of housing; * the non-delivery of housing sites due to site-specific factors; and * in order to provide flexibility and choice in the local housing market.

These reasons seem spurious particularly coming on top of the 15% uplift in HEDNA. The 20% buffer is applied on top of this presumably to counteract the above effects.

The Council has compounded this by applying the new housing requirement as a historic shortfall to be made up in the next 5 years. This is wrong as this is a newly identified need not a historic shortfall so should be applied over the remaining plan period. The introduction to the 5YHLS position statements says that the Sedgefield method allow for any previous shortfall in housing delivery, not newly identified need. This accounts for another 13.5%.

Therefore the basic requirement is being inflated by 1.15x1.15x1.13x1.2 = 1.8% in the next 5 years, and 1.15x1.15=1.3 overall.

It is generally accepted that Plan led policy leads to better and more sustainable development otherwise there would be no point at all in the Local Plan. This being the case, it is unreasonable to drastically and unnecessarily inflate the housing land requirement, particularly given that HDC has evidently struggled to meet its inflated target. I would suggest that the Council has a duty to, as far as possible, enforce a plan led policy, rather than simply allow unplanned development.

I consider that the 15% uplift in the local plan is not justified and I would query whether it is effective or in accordance with national policy or conducive to sustainable development. Therefore it should be removed.