Page 15 of the Proposed Submission Local Plan identifies 'Meeting Housing Needs' as a Key Issue for the Local Plan.

Section 1.4 of the Proposed Submission Local Plan identifies the proximity of the Harborough District to the city of Leicester and other Districts within Leicestershire. It is recognised that people travel to work and move house within the identified 'Leicester and Leicestershire Housing Market Area'. It is clear that this relationship should be taken into consideration with the preparation of the plan.

Paragraph 1.5.1 of the Proposed Submission Local Plan explains that the Duty to Cooperate "places a legal duty on local planning authorities, county councils and public bodies to engage constructively, proactively and on an ongoing basis to ensure that significant issues that affect more than one local authority area are addressed adequately within plans. The Harborough Local Plan must therefore consider influences on and the requirements of adjoining areas and how strategic infrastructure is to be delivered."

The National Planning Policy Framework states at paragraph 178 that "The Government expects joint working on areas of common interest to be diligently undertaken for the mutual benefit of neighbouring authorities." Of particular importance is the amount of homes and jobs needed in the area and their distribution.

Paragraph 1.5.2 of the Proposed Submission Local Plan states that Harborough Council has "actively engaged with its strategic partners on an agreed range of strategic priorities throughout the preparation of the plan", and makes reference to separate Duty to Cooperate Statement, 2017.

It is acknowledged that the nine Leicestershire local authorities and the Local Enterprise Partnership (LEP) have worked together to prepare the Leicester and Leicestershire Housing and Economic Development Need Assessment (HENDA) 2017. However, it is apparent from review of the Duty to Cooperate Statement 2017 (page 9) that not all authorities have concluded whether they can plan to meet their own needs or whether they will require assistance from surrounding authorities. To date both Leicester City Council and Oadby and Wigston Borough Council have stated that they will not be able to meet their needs within their administrative boundaries.

Harborough Council's Duty to Cooperate Statement states at paragraph 4.11 that a final Memorandum of Understanding is only expected to be available in January 2018, at which point Harborough Council is expecting to submit its Local Plan for Examination, a point beyond which alterations should not be made to the Local Plan.

The Council explains at paragraph 6.17 of its Duty to Cooperate Statement that "the Local Plan should provide land for an uplift of 20% over OAN, bringing the total housing land provision to 12,800 dwellings. This would allow for a contingency to meet unforeseen circumstances and flexibility to make a contribution towards any unmet needs from other Councils that arise across the Housing Market Area (HMA)."

However, the Council's 6.20 "If in the future, an agreement is reached through the Duty to Cooperate, for Harborough to meet some of Leicester's or Oadby and Wigston's unmet needs, then this would further increase the housing requirement" and therefore it is our interpretation that this would reduce any contingency planning for Harborough's housing need, therefore its ability to respond to slower than expected delivery, non-implementation of existing consents, economic change, and flexibility and choice in the housing market.

It is unclear at this stage whether there will be unmet housing need within the Leicester and Leicestershire Housing Market Area and whether this would be further exacerbated as a result of the Harborough Local Plan progressing ahead of other Local Authorities within the Housing Market Area. This is an unsound basis on which to prepare a Local Plan and therefore the current version of the plan cannot be considered positively prepared, effective or consistent with national policy.

In addition the Government has published a consultation document setting its thoughts for a standardised approach for the calculation of objectively assessed housing need. It maybe that the Council will be required to update its evidence base in light of any new Government Guidance, albeit the consultation document does include allowance for transitional arrangements.