Plan Period
The current plan period for the Proposed Submission Harborough Local Plan runs to 2031. It is currently anticipated that the Local Plan will be adopted by October 2018. That programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which relies in order to meet identified development needs (notably the Strategic Development Areas).

Even if it is adopted by October 2018, there will not be a 15-year horizon to the end of the plan period. This does not accord with the National Planning Policy Framework (NPPF) which states that local plans should "be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date" (NPPF, paragraph 157, point 2). Given that objectively assessed development needs (OAN) have been assessed for the period to 2036, the plan period should be extended to 2036 to ensure that the Local Plan has a time horizon in excess of 15 years and longer term development requirements, including an adequate level of future housing and the infrastructure required to support that, can be provided for.

Policy Part 1
The proposed settlement hierarchy set out in Policy SS1 and the principle that this should be used to manage planned growth and direct development to appropriate locations in a sustainable manner is supported. Specifically, the identification of the Principal Urban Area (PUA), including Scraptoft, Thurnby and Bushby at the top of the hierarchy as a focus for housing and employment growth in the District is welcomed. This approach reflects the locality's accessibility to higher order facilities, services and employment opportunities, and the level of infrastructure available to support future growth and development to meet the identified housing needs of the District, as well as assist in meeting the unmet needs of Leicester.

In this regard, it is paramount that the policy then seeks to enable all opportunities for the delivery of sustainable development at the PUA as a means of boosting the supply of housing in accordance with paragraph 47 of the NPPF. As set out below, however, Part 2 of this policy potentially restricts development in the most sustainable location in the District.

Policy Part 2a
Part 2a of the policy proposes a requirement to provide a minimum of 12,800 dwellings over the plan period to 2031. However, as noted above, the current plan period does not provide a 15-year time horizon and should, therefore, be extended to 2036. The proposed development requirements will need to be increased accordingly, but a separate objection to Policy H1 has also highlighted critical concerns in relation to the identification of an appropriate housing requirement and the allocation of sufficient sites to meet that requirement. Notably, the unmet housing needs arising in Leicester and Oadby & Wigston have not been addressed, and the plan is consequently fundamentally unsound in that regard. Addressing those matters will result in a further uplift in the housing requirement in the District and necessitate the allocation of additional housing sites in accordance with the proposed spatial strategy set out in Part 1 of the Policy.

More specifically, the following matters must be addressed:

ii & iii. The proposed allocation of Strategic Development Areas (SDAs) in the HLP is not objected to in principle. Notably the Scraptoft North SDA is within the Leicester PUA and, therefore, reflects the proposed settlement hierarchy that underpins the plan's spatial strategy. However, there is a significant over reliance on their delivery in order to meet the identified needs of the District. The combined quantum of development provided by the two sites provides over 55% (2,700 dwellings) of the total housing supply for the plan period (excluding sites already completed or committed). Moreover, it is extremely unlikely that the SDAs will deliver the scale of development currently assumed by the HLP within the plan period (as explained more fully in the objection to Policy H1). There is, therefore, a significant risk that the identified development needs will not actually be met, and it is imperative that is mitigated through the allocation of a wider portfolio of sites in appropriate locations that accord with the Local Plan's spatial strategy. Given that the Leicester PUA (Scraptoft, Thurnby and Bushby) is positioned at the top of the settlement hierarchy, that should be the first location to consider for the identification of additional sites to be allocated for development.

iv. The reference to the allocation of other sites to meet the identified development needs is supported. However, as a result of the proposed allocation of the SDA, the HLP currently excludes the allocation of any other development sites at the PUA. That is objected to as the distribution of development requirements throughout the District does not reflect the spatial strategy that is purported to underpin the HLP. That, however, can be remedied through the allocation of additional development sites to accommodate the increase in the housing requirements that would result from addressing the concerns highlighted above.

The clear merit of directing future growth to this locality is recognised throughout the HLP and reflected in the proposed Settlement Hierarchy (as set out above). Indeed there are opportunities to allocate smaller development sites at the PUA that would make an extremely valuable contribution to meeting the District's identified development needs, and would of course also be very well placed to address the identified unmet need arising in the City. One such site is the land off Uppingham Road, Bushby that adjoins the committed development site at Charity Farm, and is also controlled by Bloor Homes (further detail is provided in the objection to Policy H1).

Part 4
The aspiration to ensure that the quantity and location of development within and adjoining the Leicester PUA safeguards the identity of the communities of Scraptoft and Thurnby/Bushby is recognised. However, the requirements of the policy are unclear in terms seeking to ensure that development "supports regeneration and development objectives in the neighbouring City of Leicester and Oadby and Wigston Borough". As stated above in relation to Part 2 of the policy, it is paramount that the HLP allocates sufficient brownfield and greenfield land to meet the fully identified needs of the District, and positively address the identified unmet needs of Leicester and Oadby & Wigston. The HLP currently fails to do that, and is therefore, fundamentally unsound. However, there are sustainable sites available on the edge of the PUA that are clearly well-placed to address that need including, as noted above, land off Uppingham Road, Bushby.

Part 9
The intent to "strictly control development in the countryside" is objected to. This suggests the imposition of a pre-NPPF style "blanket" protection of the countryside and constraint on development that clearly does not comply with the policy requirements of the NPPF. The NPPF no longer uses the language of seeking to protect the countryside simply because it is countryside, but instead in trying to balance the need for development, it refers to recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it (at paragraph 17 point 5). As such it does not preclude development in the countryside and it would be inappropriate for the HLP to seek to do so.

Indeed, this part of the policy creates a policy tension with Policy GD2, which is not helpful in terms of guiding the decision maker when determining planning applications. Part 9 of the policy should, therefore, be omitted.

Soundness
For the reasons set out above, Bloor Homes object to Policy SS1, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs, including unmet development requirements arising in Leicester, will be met within the plan period;
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
- is not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Revise policy as follows:
- The plan period should be extended to 2036.
- Part 2: the housing requirement should be increased to reflect the extended plan period to 2036 and the concerns raised in the objection to Policy H1.
- Part 2: include reference to the allocation of additional sites, most notably at Scraptoft, Thurnby and Bushby, given the PUA's position within the settlement hierarchy and relationship to Leicester.
- Part 4: requires further clarification of the specific development requirements of this policy to support the regeneration and development objectives in the neighbouring City of Leicester and Oadby & Wigston Borough.
- Part 9: delete.