Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7126

Received: 17/11/2017

Respondent: Bloor Home Ltd

Agent: Define

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Soundness
Policy SC1 is considered unsound on the basis that it:
- is not justified in that it is has not fully acknowledged the practical constraints to development within the SDA;
- is not effective in that the SDA 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.

Full text:

Bloor Homes do not object to the principle of the allocation of the Scraptoft SDA. However, they do have serious concerns in relation to its deliverability within the plan period that are not addressed in either the Submission Plan or the supporting evidence base. As a consequence the proposed allocation and the Submission Plan that relies on its delivery to ensure that the identified housing needs for the District are met in accordance with the NPPF is currently unsound. They also object to the allocation of this SDA at the exclusion of any other appropriate sites in this highly sustainable location at the Leicester PUA and the over reliance on the SDAs in general in terms of meeting the District's identified housing needs (as also set out in the objections to Policies SS1 and H1).

Notably the delivery of the Scraptoft SDA requires the prior relocation of the golf course within the site. That will inevitably affect the timescale for the SDA's delivery, as the new course will need to be constructed and opened before the club can relocate and release the site for development. However, there is no evidence of a new site being identified, how will it be funded, or when it will be delivered.

It is, therefore, apparent that the Local Plan Housing Trajectory incorporates entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDA. That indicates that the Council anticipate the first completions being delivered in the period 2021/22, i.e. within 41/2 years.

Bloor Homes' objection in relation to Policy H1 clearly demonstrates why that will not be achieved, and that a more realistic assumption of delivery from 2025/26 should be assumed. Even then there is a significant risk that the resolution of the site specific landownership issues highlighted above will further delay delivery. Thereafter a robust view on the rate of delivery also needs to be taken. The assumed rate of delivery (rising to around 175dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Clearly the recalibration of the housing trajectory will have a significant impact on the housing land supply position in the District and its ability to meet the identified housing need. That will need to be addressed through the allocation of additional development sites before the Local Plan can be found sound.


Soundness
For the reasons set out above, Bloor Homes object to Policy SC1, which is considered unsound on the basis that it:
- is not justified in that it is has not fully acknowledged the practical constraints to development within the SDA;
- is not effective in that the SDA 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.

Proposed Change
To remedy the flaws in the soundness of the plan:
- The housing trajectory should reflect a realistic timescale for the delivery of the Scraptoft SDA;
- The Local Plan should then identify sufficient deliverable and developable supply of housing land to meet the identified housing need in sustainable locations in the District, notably at the PUA; and
- That should include the allocation of the land off Uppingham Road, Bushby.