Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7618

Received: 17/11/2017

Respondent: Armstrong Rigg Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy SC121 relating to Scraptoft North Strategic Development Area is unsound so far as it will fail to deliver the predicted number of homes during the plan period, which is likely to result in a shortfall against the plan requirement of circa 450 homes (Enclosure 3);

Full text:

Policy SC1 - Scraptoft North Strategic Development Area
Policy SC1 proposes to allocate land at Scraptoft North to deliver 1,200 homes during the plan period. In addition to these homes, Section 13 of the Local Plan identifies that Scraptoft, Thurnby and Bushby have already seen growth of over 260 dwellings since 2011 and that there are about 700 committed dwellings not forming part of the SDA.
Effectiveness In order to be considered effective, NPPF Paragraph 182 states Local Plans should be deliverable over the plan period. Based on industry standard delivery rates, Manor Oak Homes consider that the Council is overly ambitious in its expectation that 1,200 homes will be delivered on this site during the plan period. A report last year from Lichfields (http://lichfields.uk/media/1728/start-to-finish.pdf) identifies that the average planning approval period for schemes of 1,000-1,500 dwellings is 4.8 years with an additional 0.9 years from approval to first delivery (i.e. 5.7 years total) and that following the grant of planning permission the average annual build out rate is 105 dwellings per year.
A planning application has yet to be submitted for the Scraptoft SDA and considering the late addition of land to the north of Scraptoft as a potential SDA in the Local Plan's preparation, we consider the very earliest date that a planning application is likely to be submitted for the site would be the planned date of adoption for the Local Plan in October 2018. If an application were submitted in October 2018, the industry average approval time for a scheme of 1,000-1,500 dwellings of 5.7 years would mean development would not get underway until Summer 2024. This would leave 7 years in which to deliver an average of 105 dwellings per year until the end of the plan period. As detailed in the table below, this would see Scraptoft North deliver approximately 750 dwellings during the plan period, well below the 1,200 dwellings upon which the emerging plan is based.
18/19 - APP, 19/20-App, 20/21-App, 21/22 App, 22/23-App, 23/24-App, 24/25-105, 25/26-105, 26/27-105, 27/28-105, 28/29-105, 29/30-105, 30/31-105, Total: 735

This policy is unsound as it is clearly ineffective in that it will fail to deliver the predicted number of homes during the plan period, leaving a shortfall in delivery of circa 450 homes.