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

Paragraph 5.1.17 of the Proposed Submission Local Plan explains "The scale of new housing to be provided in individual settlements reflects the roles of different places in the settlement hierarchy (see Policy SS1 The spatial strategy). These roles partly reflect the population size of the settlements and their location in respect of other settlements but also relate to the range of activities and services present and, in relation to primary schools, their ability to expand to accommodate the needs generated by new development."

Policy H1 is silent in respect of growth at Broughton Astley, identified as a Key Centre at Policy SS1. There is no supporting evidence within the Sustainability Appraisal 2017 to suggest the Council has considered the potential for Broughton Astley to accommodate additional growth, notwithstanding the recently adopted Neighbourhood Plan..

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.

Paragraph 5.1.10 of the Proposed Submission Local Plan states that "Policy H1 provides for delivery of the housing plan requirement, plus an additional 15% contingency in the supply of housing land in order to allow for possible future circumstances affecting the supply of housing in the District"; albeit that 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 position as explained at paragraph 6.20 of the Duty to Cooperate Statement is "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.