Bloor Homes do not object to the principle of the allocation of the Lutterworth East 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.

Most notably, the site promoters have requested that the District Council exercise their compulsory purchase powers in order to deliver the highway crossing over the M1 and associated link road required to serve the development and ensure that there is not an unacceptable severe impact on the local and strategic highway network. However, as yet the Council has not confirmed their commitment in that regard. In any event, this is an extremely lengthy process and there is clearly no certainty in relation to the final outcome. Moreover, the evidence base demonstrates that the viability of the scheme relies on the delivery of further development beyond the plan period.

The evidence base also refers to major environmental issues, including ecological and heritage constraints, which will need to be appropriately addressed through the allocation and application processes. It is also clear that the development will have significant highway impacts and there is no evidence at this stage that they can actually be appropriately addressed (refer to PBA report paras 19.2.3 and 22.3.5).

Moreover, it is 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 2022/23, i.e. within 51/2 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 environmental constraints, infrastructure provision and 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 240dpa 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 L1, 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 Lutterworth SDA.
- The Local Plan 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.
- That should include the allocation of the land off Uppingham Road, Bushby.