Land Supply & Housing Trajectory
To accord with the NPPF, the Local Plan must facilitate a continual supply of both market and affordable housing from a "portfolio" of deliverable development sites based on a robust spatial development strategy, with sufficient flexibility to make sure that the identified full OAN for the District and the unmet need arising in Leicester needs are met even if key developments do not proceed as currently anticipated. That will ensure a rolling 5 year housing land supply is maintained, that the overall housing requirements are met within the plan period (NPPF para. 47) and that everyone actually has the opportunity of a decent home.

However, the Submission Plan fails to allocate sufficient housing sites to meet even the identified housing requirement, let alone what the stated requirement should be in light of the matters highlighted above. Notably Policy H1 does not allocate specific sites at the Rural Centres or Selected Rural Villages, instead seemingly relying on Policy GD2 to facilitate delivery of the required development on unallocated sites (the housing trajectory indicates circa 800 dwellings plus over 200 dwellings on windfall sites). However, that approach does not reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the identified housing needs as required the NPPF (para 150-151). There is no certainty that there are deliverable or developable sites available in those locations (as required by NPPF para. 47). Policy GD2 should only be used to complement Policy H1 in this regard, and not used as an alternative to the allocation of appropriate sites.

Moreover, as highlighted in Bloor Homes' objection to Policy SS1 there is an over reliance in the Local Plan on a small number of development locations (the SDAs) to provide the majority of the required housing, which creates a significant risk that the identified housing need will not be met in the plan period if one or both of those sites fails to come forward as anticipated. That concern is only exacerbated when the specific issues in relation to the deliverability of both proposed SDAs, as set out in the objections to Policies CS1 and L1, are considered.

Notwithstanding that, entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDAs have been embedded in the Local Plan Housing Trajectory (Appendix G). That indicates that the Council anticipate that the Lutterworth SDA will deliver its first completions in the period 2022/23, i.e. 51/2 years away from this date. Annual completions are then expected to significantly increase to circa 240 dpa. The first completions at the Scraptoft SDA are expected even earlier in the period 2021/22, i.e. only 41/2 years away from now. Annual completions then expected to increase to circa 180 dpa. On that basis, the Housing Trajectory indicates that the SDAs are expected to deliver a total of 2,702 dwellings in the period to 2031.

In order to achieve that, this Plan will first need to be submitted, examined and, if found sound, adopted. The District Council's Local Development Scheme currently anticipates that the Plan will be adopted by October 2018, but that programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which the Local Plan relies in order to meet identified development needs. Adoption during 2019 does, however, appear feasible subject to the issues highlighted in these representations being appropriately resolved.

Outline planning applications will then need to be prepared, submitted and approved. The very detailed allocation policies in the Submission Plan clearly highlight the scale and complexity of that process for each of the SDAs. Notably, the Policies SC1 and L1 require the prior preparation and agreement of comprehensive Masterplans that have been considered via an independent design review. That is perfectly understandable, but will take time to do given the range of issues that need to be addressed (as highlighted by the allocation policies). Furthermore, given the scale and nature of the sites, the planning applications submissions will need to be accompanied by robust Environmental Statements and Transport Assessments. The outline application preparation process should, therefore, be expected to take 1 to 2 years. The determination of those applications, including the signing of the associated Section 106 Agreements to secure the infrastructure required to support the development, should also be excepted to take 1 to 2 years.

Following the grant of outline planning permission, the sale (if promoted by the landowner) / purchase (if promoted by the developer) of the land needs to be finalised in light of a detailed cost & revenue planning exercise (which is even more complicated if multiple landowners are involved). Reserved Matters submissions will then need to be prepared, submitted and approved, conditions discharged and other (highway and drainage) consents secured to deliver the site. That process will take at least 2 years.

The developers resources (labour, equipment and materials) will then need to be mobilised before the development can begin. That commonly takes around 6 months. Site preparation and enabling works (e.g. infrastructure provision) then takes place prior to the construction of the actual homes and their delivery to the market. The first completions are then usually provided 6 months following the start on site. However, on strategic sites where major upfront infrastructure and site preparation is required, it is often 9-12 months form start on site to first legal completions.

This view of the likely timescales for delivery of the SDAs is supported by the various nationwide studies of the delivery of housing on strategic sites that have been published in recent years. Moreover, the folly of the District Council's delivery assumptions is clearly evidenced by the experiences of other Local Authorities in the HMA that have similarly sought to rely on the delivery of strategic urban extensions (SUEs) in excess of 1000 dwellings in their post NPPF Development Plan Documents in order to meet identified housing needs and are now needing to manage a shortfall in the housing land supply in their area.

Charnwood
The Charnwood Borough Core Strategy was adopted in November 2015 after the Inspector concluded that the delivery assumptions in relation to the 3 strategic urban extensions were optimistic but realistic. The Housing Trajectory indicated that the West Loughborough and North East Leicester sites were expected to deliver completions from 2016/17 and the North of Birstall site was expected to deliver completions from 2017/18. However, none of those sites have come forward as expected. The current position is as follows:

- An outline planning application for the development of the West Loughborough site was submitted in September 2014, and the Borough Council resolved to grant permission a year later in September 2015. However, a Section 106 Agreement has not yet been finalised and so planning permission has not yet been granted over 3 years following the submission of the planning application.
- An outline planning application for the development of the North East Leicester site was submitted in December 2013, and the Borough Council resolved to grant permission a little under a year later in November 2014. However, planning permission was not actually granted until August 2016. Now, over a year later, there is still no sign of the site's development.
- An outline planning application for the development of the North Birstall site was submitted in August 2016, but there is no clear indication when it will be determined.

Clearly the Core Strategy's housing trajectory was entirely unrealistic and now, only 2 years following its adoption, the Borough Council have indicated that there is a shortfall in their 5 year housing land supply.

Blaby
The Blaby District Core Strategy was adopted in February 2013, and relies on the delivery of the Lubbesthorpe SUE to meet the vast majority of the identified housing needs. The Housing Trajectory indicated that the SUE was expected to deliver housing completions from 2014/15. That was considered sound by the Inspector on the basis that the District Council has resolved to grant outline planning permission for the development of the site in September 2012 (following submission of the application 19 months earlier in February 2011).

Planning permission was not, however, actually granted until 16 months later in January 2014. Various Reserved Matters and condition discharge approvals have followed and development has now began, but only 2 completions were recorded by 2016/17. That was over 2 years later than the Core Strategy Trajectory had assumed and the anticipated rate of delivery is now much lower. Consequently, the District Council are now in the process of preparing a Delivery DPD that seeks to allocate additional sites close to the PUA to remedy the growing shortfall in the housing land supply.

Hinckley & Bosworth
The Hinckley and Bosworth Core Strategy was adopted in December 2009 and allocated 2 strategic urban extensions in Earl Shilton and Barwell. The housing trajectory anticipated first completions on both sites in 2012/13. That was followed by the Earl Shilton and Barwell Area Action Plan in September 2014 that sought to facilitate the delivery of the SUEs.

An outline planning application for the delivery of the Barwell SUE was subsequently submitted in February 2015 and the Borough Council resolved to grant permission in June 2016. However, 2 years 9 months later planning permission has still not actually been granted.

A planning application for the development of the Earl Shilton SUE has not yet been submitted.

As a consequence of the ongoing delays in the delivery of these sites, the Borough Council allocated the Hinckley West strategic urban extension in its Site Allocations DPD. That was adopted in July 2016. By that time, the Borough Council had resolved (in June 2016) to approve an outline planning application that had been submitted in over 17 months earlier in February 2015. The submission of the outline application had been quickly followed (in May 2015) by a full application for the development of the first 2 phases and the Borough Council resolved to approve that in August 2016. However, the planning permissions have not yet been formally granted.

Leicester
The Ashton Green SUE was first allocated for development in the Leicester Local Plan adopted in 2006, and reallocated in the Core Strategy that was adopted in July 2014. That assumed that the first completions on the site would be delivered in 2017/18 on the basis that an outline planning permission was granted in January 2014 (following submission in June 2010 and resolution to approve in March 2011). It is understood that a developer partner has not yet been secured, and consequently there is no sign that the site will be delivered in the foreseeable future.

Harborough Housing Trajectory
Based on the conservative analysis of the required timescales to deliver the SDAs set out above, the Submission Plan should assume the first delivery of housing completions at the SDAs a minimum of 6 years post the likely adoption of the Local Plan in 2019; i.e. in the 2025/26 period. Even then there is a significant risk that the resolution of the site specific environmental constraints, infrastructure provision and landownership issues highlighted in the objections to Policies L1 and SC1 and will further delay delivery.

Thereafter a robust view on the rate of delivery needs to be taken. The assumed rate of delivery for the Lutterworth SDA in particular (rising to around 240dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Notwithstanding that, the delay in delivery alone will mean that the Lutterworth SDA will only provide 518 dwellings in the period to 2031 and the Scraptoft SDA will only provide 634 dwellings, resulting in a total shortfall of 1,152 dwellings in the plan period.

Consequences
Consequently Bloor Homes are very concerned that the District Council are not seeking to meet the FOAN across the HMA in accordance with the NPPF or allocating sufficient land to meet the identified housing need. This must be remedied in the Submission Draft Local Plan as the consequences of not planning to meet the identified need would be dire.

The Housing Strategy for England "Laying the Foundations" states in paragraph 1 that a "thriving, active but stable housing market that offers choice, flexibility and affordable housing is critical to our economic and social wellbeing." It continues to highlight (paragraph 5) that "we have not built enough homes for more that a generation and the credit crunch has simply compounded this challenge", and (paragraph 8) that "without urgent action to build new homes, children will grow up without the same opportunities to live near their families, young people will struggle to get a place to call their own and older people will not have the choice and support they need." Furthermore, paragraph 9 states: "Housing is crucial for our social mobility, health and wellbeing - with quality and choice having an impact on social mobility and wellbeing from an early age, and our homes accounting for about half of all household wealth. Social housing should provide support for those who need it, when they need it, and should help vulnerable people to live independently. And opportunities for wealth must be open to all, with housing choices helping rather than hindering people's ability to build assets and find employment."

More recently the Housing White Paper presents startling facts and figures that highlight the acute socio-economic effects of a continued undersupply of housing in the country. Average house prices have rocketed compared to earnings, home ownership in the under 35s has significantly decreased and rental costs are continuing to escalate. The under supply of housing is also having a severe negative impact on the economy in terms of labour mobility, the construction industry, economic spend and increasing housing benefit costs.

A key element of addressing this negative cycle is a focus on "planning for the right homes in the right places" as espoused by the NPPF. The District Council must, therefore, increase the housing requirement established in Policies SS1 and H1 and propose additional development allocations accordingly to ensure that the identified housing needs are actually met.