SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas.

Showing comments and forms 1 to 9 of 9

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 5423

Received: 27/10/2017

Respondent: Mrs Jan Butcher

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The wording of the objective is too generic - the proposed Local Plan does meet real local need based on data and is therefore unsound and unjustified. It makes sweeping broad brush assumptions that are used to justify poor decisions which are to the detriment of the rural nature of the district

Full text:

The wording of the objective is too generic - the proposed Local Plan does meet real local need based on data and is therefore unsound and unjustified. It makes sweeping broad brush assumptions that are used to justify poor decisions which are to the detriment of the rural nature of the district

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 5566

Received: 26/10/2017

Respondent: Mr John Martin

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The plan covers a period of 2011 to 2031 but on no occasion have I found there to be any Key Performance Indicators (KPI) within this proposal.
There should be a comprehensive table of intentions set against dates when each of these should be realised. Only by this means can compliance with this plan be determined.

Full text:

The plan covers a period of 2011 to 2031 but on no occasion have i found there to be any Key Perofmance Indicators (KPI) within this proposal.
There should be a comprehensive table of intentions set against dates when each of these should be realised. Only by this meanscan compliance with this plan be determined.

Support

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 5680

Received: 28/10/2017

Respondent: Mrs DL Evans

Representation Summary:

Whilst I am not a fan of expanding our town, I believe that the proposals are making the best of a bad requirement

Full text:

Whilst I am not a fan of expanding our town, I believe that the proposals are making the best of a bad requirement

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 6681

Received: 03/11/2017

Respondent: Rugby Borough Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Matters of employment and housing on Duty to Co-operate should be agreed between relevant authorities to ensure overall need has been properly accounted for and to avoid over-provision. It is queried whether the position of the other HMA authorities on employment and unmet housing need has been agreed between appropriate authorities and if the Duty to Co-operate has been satisfied.

Full text:

Dear Harborough District Council,

Thank you for the opportunity to comment on your proposed Local Plan. Please see below the consultation response on behalf of Rugby Borough Council, which is given at Officer level.


Comments on the proposed plan:

It is not clear from the plan or supporting evidence how the impact of the proposals on the highway network and transport outside of the Leicestershire boundary has been considered and what the likely effects will be. The Jacobs Preliminary Impact Assessment 2016 appears to exclude areas outside of Leicestershire, even though there are main routes adjoining or crossing into neighbouring counties (in Rugby Borough's case the A5 and A426, which are near to the Magna Park and Lutterworth proposals), and analysis is not apparent in other documents. It is queried whether sufficient consultation has taken place with Warwickshire County Council Highways Authority to ensure the local plan's implications on cross-county matters have been taken into account.

In addition to the effect on the connected road network, it should be considered how the proposals for growth in Rugby Borough's proposed Local Plan (currently being examined by the Planning Inspectorate) have been taken into account. Further consultation with Warwickshire County Council is encouraged.

It is unclear in the Jacobs Preliminary Transport Assessment 2016 how the figures used in the assessment relate to the local plan targets. Clarification should be given as to how the total amount of growth proposed in the plan has been tested in the assessment and appropriate mitigation identified.

The August 2017 Magna Park Employment Growth Sensitivity Study is welcome, although it is queried whether the position of the other HMA authorities on employment and unmet housing need has been agreed between appropriate authorities and if the Duty to Co-operate has been satisfied. It should be ensured that the draw of employment from surrounding areas as a result of the expansion of Magna Park has been fully considered and also factored in by other authorities, in order to ensure there would not be over provision in the market area as a whole. It is acknowledged that within the plan that the expansion of Magna Park will result in an increase to the overall housing requirement from 532 to 557 dwellings per annum to align the housing with the employment growth and that this will also meet some unmet need from elsewhere in the HMA. However, it is not clear the position of unmet need across the HMA as it is also noted within the plan that Leicester City Council have stated they will have unmet housing need but that the extent is not yet established.

Overall, Harborough District Council has progressed its local plan, and this progress is noted and welcomed. It should be ensured that the impacts of the proposals on cross boundary matters have been fully considered, and that due regard has been given to Rugby Borough's proposed growth. Matters of employment and housing on Duty to Co-operate should be agreed between relevant authorities to ensure overall need has been properly accounted for and to avoid over-provision.

Support

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 6687

Received: 03/11/2017

Respondent: North West Leicestershire District Council

Representation Summary:

I can confirm that we have reviewed your Local Plan - Submission documents and do not wish to make any comments at this consultation stage.

Full text:

I can confirm that we have reviewed your Local Plan - Submission documents and do not wish to make any comments at this consultation stage.

Regards,

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 6711

Received: 06/11/2017

Respondent: Oadby and Wigston Borough Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Paragraph 1.5.4 This paragraph needs to ensure that the wording reflects the time periods of the Leicester and Leicestershire Strategic Growth Plan appropriately. The Strategic Growth Plan covers the period to 2050, however treats the period's pre 2031 and post 2031 very differently. Pre 2031, the housing and employment Objectively Assessed Needs for the Leicester and Leicestershire HMA, set out within the HEDNA, will be delivered through each of the local authorities individual Local Plan's. The Strategic Growth Plan therefore focuses on the period post 2031, for which it identifies a notional housing need.

Full text:

Consultation: Harborough Local Plan Proposed Submission

Thank you for consulting the Council on the Harborough Local Plan Submission consultation.

Please find the Council's comments set out below.

The District of Harborough is located within the Leicester and Leicestershire Housing Market Area and as such Harborough District Council and Oadby and Wigston Borough Council have a duty to co-operate over the preparation of each other's Local Plan under the 'Duty to Co-operate'. Under the Duty to Cooperate, Oadby and Wigston Borough Council, Leicester City Council, Harborough District Council and Leicestershire County Council have produced a joint piece of evidence base relating to highway capacity and infrastructure. Through this work, it has been acknowledged by all parties that certain growth areas within Harborough District will impact the highway infrastructure within the Borough. There is an agreed approach for dealing with the impacts, which will be set out in a Joint Statement. The Borough Council advises that the Joint Statement is submitted to the Inspector once it has been agreed by all parties involved.

Paragraph 1.5.4 suggests that the Leicester and Leicestershire Strategic Growth Plan outlines the amount and location of future growth from 2031 to 2036 and will set out broad aspirations for growth up to 2050. This paragraph needs to ensure that the wording reflects the time periods of the Leicester and Leicestershire Strategic Growth Plan appropriately. The Strategic Growth Plan covers the period to 2050, however treats the period's pre 2031 and post 2031 very differently. Pre 2031, the housing and employment Objectively Assessed Needs for the Leicester and Leicestershire HMA, set out within the HEDNA, will be delivered through each of the local authorities individual Local Plan's. The Strategic Growth Plan therefore focuses on the period post 2031, for which it identifies a notional housing need.

The Harborough Local Plan Spatial Strategy makes provision for the development of a minimum of 12,800 new homes between 2011 and 2031. This is above the Objectively Assessed Need for the District of Harborough of 10,640 new homes over the same period, as identified in the Housing and Economic Needs Assessment. The Spatial Strategy also makes provision for upwards of 58 hectares of employment land between 2011 and 2031. It distributes housing and employment growth across the District, however identifies Market Harborough, Scraptoft, Lutterworth and Broughton Astley as key locations for growth. This is supplemented by more limited amounts of growth in the more rural parts of the District. Policy SS1 Spatial Strategy is consistent with the evidence base relating to the wider Leicester and Leicestershire Housing Market Area and as such, is supported by Oadby and Wigston Borough Council.

The Local Plan also demonstrates Harborough District Council's commitment to meeting its requirements for housing, employment and other development and infrastructure. The Plan states that the Council will commence a partial or full review of the Local Plan no later than five years from the date of adoption, or earlier...where collaborative working with other planning authorities, including those within the Leicester & Leicestershire Housing Market Area (HMA), establishes objectively the need for further provision of housing and/or employment land within the Harborough District and there is insufficient flexibility already provided for within the Plan. The Harborough Plan also sets out that the District Council will commence a partial or full review of the Local Plan no later than five years from the date of adoption, or earlier...where the Leicester and Leicestershire Strategic Growth Plan sets out a scale and spatial distribution of development for Harborough District which is significantly different to that set out in the Local Plan and there is insufficient flexibility already provided for within the Plan.


Yours sincerely,

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7216

Received: 17/11/2017

Respondent: Mr Stuart Fraser

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

I feel that the city of Leicester should provide housing for its own population as there is much unused/unoccupied land in the city. Neighbouring Local Authourities should also use their own land for development and not encrouch onto Harborough District territory. This is to preserve Harborough's territory as a green space for the health and recreation of the whole Counties population.

Full text:

I feel that the city of Leicester should provide housing for its own population as there is much unused/unoccupied land in the city. Neighbouring Local Authourities should also use their own land for development and not encrouch onto Harborough District territory. This is to preserve Harborough's territory as a green space for the health and recreation of the whole Counties population.

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7400

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Duty to Cooperate statement published alongside the Proposed Submission Plan refers to a new Memorandum of Understanding (MOU) which is being prepared by the Leicester and Leicestershire authorities and is likely to be completed in January 2018. With unmet need having already been identified within the HMA, the distribution of this unmet need will need to be addressed through both the SGP and updated MOU. There are therefore still considerable
uncertainties regarding the distribution of housing growth across the HMA and Harborough District Council may still be required to accommodate a proportion of the identified unmet housing need.
As the Harborough District Plan is being advanced before these issues have been fully resolved, this is considered to be an unsound basis upon which to prepare the Harborough District Local Plan.

Full text:

Refer to attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7633

Received: 31/10/2017

Respondent: Cllr Rosita Page

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The Duty to Cooperate was not fully adhered to by consulting all neighbouring LA's in any of the early stages. There are only notes of DtoC meetings from
May and July 2017. These minutes state foregone conclusions without having followed proper democratic process.

Full text:

I consider the plan not sound and not compliant because;
Access to consultation form was made difficult, it disadvantaged ordinary residents to put forward a view.
Public advertising of the consultation in the local media was very limited.
Access to information for members to make educated decisions was limited , a lot of information was presented via verbal briefings only , some information was deemed as confidential and not provided.
Visions and objectives are good but empty rhetoric, not backed up with strong enough policies to achieve these goals.
The plan appears to focus mainly on the provision of housing rather than placing an additional focus on providing variety and access on suitable housing that will meet the needs and the diversity of residents.
The Harborough District has an above national average of an aging population and a larger focus should have reflected the needs of these residents by ensuring policies advocate more bungalows.
Provision of Extra Care and Specialist Accommodation is not deliverable .Targets are too high and policies remits are confusing.
There are mistakes and discrepancies in supporting information.
Some supporting information was not taken into consideration.
There is no guidance where to find relevant information and what has been superseded by what. The process is messy and confusing.
The Sensitivity Study was commissioned to confirm housing needs alongside employment /logistic options .These were supposed to be allocated across the HMA not just Harborough District.
The Sensitivity Study is not of merit to determine the amount of logistic provision therefore rendering policy BE2 not sound

Comments relating to the following (sections / policies) :

1.2 The Option Consultation: secured an overwhelming public response .The public objected to a major expansion of Magna Park .The Sustainability Appraisal Interim Report 2015 and 2016 rejected an Option of 700 000sqm which echoed demand not need for 3 planning permissions submitted .Officers stated the conclusion of the SAIR would not be affected in the future and Planning officers concurred by stating that approving all 3 application submitted would not be sustainable.
However without evidencing any proper process this evidence was overruled.

1.5 The Duty to Co‐operate: was not fully adhered to by consulting all neighbouring LA's in any of the early stages .There are only notes of DtoC meetings from
May and July 2017. These minutes state foregone conclusions without having followed proper democratic process.

1.7 Supplementary Planning Documents: As well as other evidence has not been readily available throughout the process and parishes and other stakeholder have not been given the timeframe to consider background information. It is not clear what is valid, some reports are superseded, reports are not all in one place and the evidence base is confusing.

2.1 Local Plan Vision and 2.3 Objectives: The vision and objectives are lordable but the policies with in the LP do not reflect the desired aims to achieve these objectives.
To secure a wide range of skilled jobs for an highly educated population has always been a supported council policy.
The objective, stopping young people from leaving the district is not served by focusing mainly on providing unskilled, temporary, low paid jobs in the logistic industry.
A focus on sustainable , diverse and vibrant job market is not possible without creating the opportunities.
Reducing impact of traffic on local communities in Objective 10 is not a deliverable policy in line with the proposal of policy BE2 either and Objective 7 to protect the historic environment is also compromised by policy BE2 . The protection of heritage is highly supported by the NPPF and featured in the draft Growth Plan but the policy is not strong enough . The objectives and policies are contradicting themselves in places .

3.1.2 to 3.14
Recognises a fair geographical spread , long term strategic growth by providing a diverse , fair , economic strategy across the region and Leicestershire placing resources where there is need and higher unemployment Policy BE2 in this LP adds considerable more than the identified long term requirement of non -rail storage /logistic to a already considerable land bank of logistics permissions granted but not build out.
Furthermore BE2 is disadvantaging other operators in other geographical areas by oversaturating the market.

5.1.4: The HEDNA was to identify housing and employment need. However all this important detail of employment /logistic provision and the correlation thereof was omitted until very late in the process .The Sensitivity Study was an add on, not fully commissioned and was not made available until July.
The study has not been objectively assessed , scrutinised , it is confusing , contains flaws and is based on assumption not on evidenced facts.
The scenarios used to underpin the need for 700 000sqm of logistics floor space are disregarding all previous, confirmed evidence , consultation result and a democratic members decision.
The study that alleges 19 % of HD residents work at Magna Park. If to be considered as factual, one needs to be mindful that this has taken over 20 years to achieve.
To raise this to 25 % ( 3000 workers approximately ) in an area of low unemployment (at it's highest 1100) without effective policies and no means of enforcement this seems unachievable.

5.1.9: A buffer of 20% was applied by a proper democratic process to assist other LA's with unmet housing needs in March 17 .This need has not yet been evidenced and was agreed on the provision of 2 letters received ( 5.1.6 )
Not adhering to a proper democratic process the 20% buffer provision was split into 15 % unmet need and 5 % ( 5.1.9 ) to meet the impact of policy BE 2.
The March decision was ignored and these figures were already placed in all the draft Local Plan documents before being agreed by the Executive in September 17.
How can the Local Plan with no provisions and policies to enforce, underpin or secure the ambitious commitment to house Magna Park workers in the district ?

BE1: The Full Council has always voted to encourage and promote knowledge based industries to the district but policies or actions do not actively reflect this ambition.

BE2: Comments from members and residents ignored, evidence flawed, contradiction to previous evidence applied, proper process not followed in order to accommodate a policy that advocates unnecessary ,over allocation of storage, logistic provision to consider with applications submitted which will be decided at a planning meeting before this plan is evaluated.
The applicants stating their proposals are promoted via the LP and that the policy of the emerging plan supports their application.
This policy is ambiguous, will saturate and monopolise the non‐ rail storage and logistic market to the disadvantage of neighbouring authorities. This policy supports greed and does not identify need.

H1: Sets out housing commitment to 2031. The infrastructure document are difficult to access. It should be explained that dwelling should not just be taken as houses but could be apartments /flats. The policy should reflect a need for this provision to aid the accumulation of much required social housing.
It refers in 5.1.8 to 557 per annum or 11140 over the plan period .There is no correlation of the figures.
H1 ( SS1 2a ) states a minimum of 12800 but should state a maximum.
All of this is very confusing and it will be difficult to implement and to achieving a clear basis on which a 5 year housing supply is calculated which is clear and defendable.
Previous housing trajectory identified that no 5 year housing supply has been achieved previously in the Harborough District with a far lower annual housing requirement. It is therefore ambitious and unrealistic to add a 20 % buffer on ONA as this is unlikely to be achieved possibly rendering the Local Plan impotent.

H2: 40 % is not viable or sustainable and will not aid the provision of affordable housing when only up to now only 19 % was achieved and at present only 4000 units are outstanding to be build.

H4: More emphasis needed to ensure specialist housing is provided , policy impossible to achieve and confusing. Is the 10% on top of 40% affordable ?

H6: Provision at Bonham's Lane is not required and the special status of the site should be recognised.GTAA was not an open and public consultation
There would be no requirement for additional Showpeople plots if officers would stop supporting present sites for housing development against planning inspectors advise thus losing the district the existing provisions.
Travelling Showpeople plots have been allocated to non‐ guild members , there have been statements to the fact that there are no further requirements.
5.11.2 refers to the amount of pitches for G/T and showpeople .However, Parish Council 's have unsuccessfully requested up‐dates on occupation of the sites. It is therefore assumed that the illustrated figures are questionable as there have been no detailed evaluations.