Policy L1 proposes the allocation of land east of Lutterworth as an SDA to deliver a total of 2,750 dwellings of which 1,500 are planned to come forward during the plan period, with the remainder to meet requirements after 2031. In addition to these homes, Section 15 of the Local Plan identifies that Lutterworth has already seen growth of over 260 dwellings since 2011 and that there are around 500 committed dwellings that are not part of the SDA.
Effectiveness
In order to be considered effective, NPPF Paragraph 182 states Local Plans should be deliverable over the plan period.
The current Local Plan consultation was delayed by over 6 months from late 2016 in order to allow for what were described as 'outstanding remaining spatial issues' linked to the proposed SDA to the east of Lutterworth to be resolved, including concerns regarding: the scale of infrastructure investment, impact on a nearby SSSI, traffic impact, landowner cooperation and the potential need to use compulsory purchase powers and assumptions on delivery. During this 6 month delay, the Council undertook further work that was made available to members ahead of an Executive Meeting on 15th May 2017, but not to the general public. This information included further details provided by SDA promoters, conclusions reached on the potential use of compulsory purchase powers and a risk assessment of the SDA which presumably deals with key aspects that could affect its delivery.
Without seeing the additional assessments made available to members, it is far from clear whether the significant issues regarding the delivery of the Lutterworth SDA (i.e. due to the scale of infrastructure investment, lack of landowner cooperation and the potential need to use compulsory purchase powers) have been satisfactorily resolved. This is an important point that will need to be the subject of detailed examination by the appointed inspector. It is beyond the scope of these representations to conduct a detailed assessment of whether the scale of infrastructure and land assembly needed would significantly constrain the delivery of the Lutterworth SDA, but it is clear that there are unanswered questions here and we wish to raise significant concerns regarding the effectiveness and therefore the soundness of the Proposed Submission Local Plan in delivering its planned quantum of development.
To illustrate this point, we refer to industry standard delivery rates as a guide to how many homes are likely to be delivered during the plan period at this SDA. 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 2,000+ dwellings is 6.1 years with an additional 0.8 years from approval to first delivery (i.e. 6.9 years total) and that following the grant of planning permission the average annual build out rate is 161 dwellings per year.
A planning application has yet to be submitted for the Lutterworth SDA and it is clear from the issues surrounding infrastructure provision and compulsory purchase that it could be some time before an application is ready to be submitted. On this basis, 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 2,000+ dwellings of 6.9 years would mean development would not get underway until Autumn 2025. This would leave two thirds of 2025/26 for development and 5 subsequent years in which to deliver an average of 161 dwellings per year until the end of the plan period. As detailed in the table below, this would see Lutterworth East deliver approximately 900 dwellings during the plan period rather than the predicted 1,500.

18/19-App, 19/20-App, 20/21-App, 21/22-App, 22/23-App, 23/24-App, 24/25-App, 25/26-107, 26/27-161, 27/28-161, 28/29-161, 29/30-161, 30/31-161 Total:912

This policy is therefore unsound as it is ineffective. It will fail to deliver the predicted number of homes during the plan period, leaving a shortfall in delivery of circa 600 homes.