Manor Oak Homes are actively involved in the development
of the Kibworths and are committed to enabling the sustainable development of the parishes to help meet the local area's housing, employment, education and community infrastructure needs. It is in this context that Manor Oak Homes are making these representations as they seek to ensure that the Local Plan provides for the sustainable development needs of the area. As currently drafted they do not believe that the draft plan proposes the most appropriate strategy when considered against reasonable alternatives and based on proportionate evidence, nor is effective as it will not ensure the delivery of the required level of development over the plan period.
Manor Oak Homes welcome the Council's proposal to meet the District's full Objectively Assessed Housing Need (OAHN) of 10,640 dwellings (2011-2031), plus a small uplift to respond to the Magna Park Growth Sensitivity Study and an additional 15% contingency. While they are supportive however of a strategy that includes SDAs, they have concerns regarding the extent to which the Lutterworth and Scraptoft SDA's will deliver new housing during the plan period in accord with the Council's assumptions and consider that the decision not to give the
Kibworths a minimum housing target fails to recognise its sustainability and that allocating further land for housing offers the opportunity to resolve current infrastructure constraints i.e education. In this context, they have significant concerns regarding the effectiveness and therefore the soundness of the Proposed Submission Local Plan in delivering the proposed housing requirement (in accordance with NPPF Paragraph 182).
While Manor Oak Homes are disappointed that an SDA to the west of the Kibworths is not being proposed by the emerging plan, they accept that a number of parcels of land within it now have planning permission and represent commitments such that the remainder cannot provide the scale of additional development required of an SDA.
They are surprised though that given the relative sustainability of the land to the west of the Kibworths as demonstrated by its positive performance when the proposed SDA was assessed as part of the Sustainability Appraisal accompanying the Harborough Local Plan: Options Consultation Paper - September 2015, and the positive conclusions drawn regarding the sustainability of the Kibworths in determining a number of recent planning applications there, that the plan does not set a minimum housing requirement for the settlement. Manor Oak Homes do not therefore wish to object to the proposed allocation of land at Scraptoft and Lutterworth as SDA's but they are concerned by the overly optimistic assumptions being made by the emerging plan regarding their delivery and believe that there is a need to allocate additional land for housing. So far as new housing
should be directed where it can best respond to local needs and thereby promote sustainable patterns of development, they further believe the plan has erred in not setting a minimum housing requirement for the
Kibworths and that additional housing land should be allocated there.

Policy H1 states that in addition to the delivery of existing commitments and completions and the allowance for windfalls, land for a minimum of 4,660 new homes will be provided during the plan period to 2031 in the following locations:
1. Scraptoft SDA - 1,200 dwellings in accordance with Policy SC1;
2. Market Harborough - a minimum of 1,140 dwellings on three allocations;
3. Lutterworth SDA - 1,500 dwellings in accordance with Policy L1;
4. Fleckney - a minimum of 295 dwellings, including one allocated site for 130 dwellings;
5. Rural Centres - a minimum of 10 dwellings in Billesdon, 35 in Great Glen and 65 in Houghton on the Hill; and 6. Selected Rural Villages - minimum targets set of between 10-50 dwellings for specific villages.

The level of development proposed meets the District's full Objectively Assessed Housing Need (OAHN) of 10,640 dwellings (2011-2031), plus a small uplift to respond to the Magna Park Growth Sensitivity Study and an additional 15% contingency in the supply of housing land 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.
Manor Oak Homes consider that this policy is unsound as it is not positively prepared, justified or effective.

Positively Prepared and Justified

As outlined at Enclosure 1, the Kibworths is by far the largest of the Rural Centres and should actually be considered to be a Key Centre due to its size and its role providing key retail, service and employment infrastructure. In this context, Manor Oak Homes consider that the decision not to give the Kibworths
a minimum housing target fails to recognise its sustainability and that allocating further land for housing offers the opportunity to resolve current infrastructure constraints i.e. education.

Policy H1 sets minimum housing targets for the majority of the settlements in the district, with the exception of Broughton Astley (which is set to deliver significant housing through its made neighbourhood plan), the Kibworths and several settlements that are considered too small to accommodate growth. The Kibworths is therefore the only settlement above the level of very small villages not to be set a minimum housing target. Section 17 of the draft plan explains the reason for this decision stating that: "Given the high number of commitments already in place, there is no minimum target set for the Kibworths in the Local Plan."

This decision leaves by far the largest of the Rural Centres, and one that actually performs as a Key Centre, as having fewer homes proposed to be allocated than the majority of the Selected Rural Villages. We question the sustainability of this approach and the justification behind this decision. The Local Plan states that there have been over 400 dwellings completed since 2011 in the Kibworths and there are planning commitments for nearly 450 further homes. This level of development is given as the reason for not planning for further sustainable growth, but further investigation shows that the Council has not based this decision on a thorough consideration of reasonable alternatives as required by NPPF Paragraph 182 for the Local Plan to be considered sound.

First and foremost, the Local Plan identifies the level of housing completions since 2011 in the Kibworths as significant in demonstrating that the Kibworths are already meeting their share of development. This is not the case, however, as this high level of delivery is primarily a result of the build out of Land off Wistow and Warwick Road that was allocated for development by Policy KB/1 of the Harborough District Local Plan adopted in April 2001. The delivery of these homes is therefore not a sign of the Kibworths meeting a proportion of current needs, but rather the much-delayed development of a site that was allocated to meet the needs of the district in the previous plan period that ended in 2006. Conversely, the delivery of 400 dwellings since 2011 is actually therefore a sign of past under delivery which the Kibworths is only just catching up with. Recent housing commitments that have come forward due to the Council's inability to demonstrate a five-year housing land supply are a further demonstration of this need to catch up with past under delivery.

Secondly, the Proposed Submission document identifies the level of committed development in the Kibworths as further justification for not allocating any additional land. This indicates a short-sighted decision-making process that fails to assess reasonable alternatives fully or fairly and therefore fails to assess the sustainability of the Kibworths as a location for growth. As outlined in the cover letter to these representations, the Kibworths was identified in the Harborough Local Plan: Options Consultation Paper (2015) as a potential option for a Strategic Development Area (SDA) of up to 1,200 dwellings. The Kibworth SDA option was then shortlisted as one of four preferred options for assessment, before a decision was made to allocate land at Lutterworth and Scraptoft North as the Council's proposed SDAs. In this respect, the approach that has been taken by the Council has been one of extremes - either the Kibworths are allocated with an SDA or they receive no additional development at all. There has been no assessment of the needs of the settlement, nor any recognition of how additional development at a smaller scale to the previously proposed SDA could still achieve many of the benefits of the SDA that are desperately needed, most notably a new primary school site (as detailed further at Enclosure 6).

Effectiveness

As outlined, the provision for housing set out at Policy H1 proposes to deliver a 15% contingency uplift on the OAHN in order to allow for possible future circumstances affecting the supply of housing in the district. We welcome and support this proposed strategy to deliver an uplift on the OAHN, but raise concern regarding one of the stated reasons for this contingency i.e. "a slower delivery than expected on housing allocations and/or the strategic development areas".
Manor Oak Homes consider that it is prudent to include a contingency to provide a buffer against unforeseen circumstances that cannot reasonably be predicted or planned for (e.g. economic factors and potential unmet need elsewhere in the HMA), but such a buffer should only be used when circumstances affecting housing need or delivery are genuinely unpredictable. As is explained at Enclosures 3 and 4, Manor Oak Homes consider that the two SDAs are likely to fail to deliver the predicted number of homes during the plan period resulting in a shortfall against the plan requirement of circa 1,050 homes. This shortfall would account for the majority of the 15% uplift and would leave very little flexibility in the housing supply to meet truly unpredictable circumstances. Policy H1 cannot therefore be considered to represent an effective policy in accordance with NPPF Paragraph 182 as it will not deliver the level of development proposed alongside an adequate buffer to account for unforeseen circumstances.