SP2: Assisting other local authorities to meet their unmet housing need.

The liason with adjacent Councils seems to be inadequate.
Significant benefits could be realised by more close and more frequent inter action with for example Daventry District Council

Harborough is already about to develop outside of the bowl in which it is sited. Further development should only be what is required of our area, not others.

Other Local Authority areas should provide housing for their population within their own districts.

On behalf of my client, Richborough Estates, I write to submit representations to the consultation on the Harborough District Local Plan: Submission Version. These representations relate to land Richborough is currently promoting for residential development at Kimcote Road, Gilmorton. The site was subject to a recent outline planning application for up to 43 houses (ref 17/00885/OUT), which now has a resolution to grant planning consent following the meeting of Planning Committee on 3 October 2017.
We support the strategic priorities identified in the Local Plan, and in particular the objective of meeting housing needs for both Harborough District and the wider Leicester and Leicestershire Housing Market Area (HMA). However, the local planning authority must ensure that the strategy taken to meeting these priorities takes full account of the most recent evidence of housing need for the HMA, and in particular the fact that both Leicester City and Oadby and Wigston District Councils have confirmed that they will not be able to meet their full needs within their own administrative areas.
If the Harborough Local Plan is to be adopted in advance of the extent of unmet need being confirmed, or its distribution between the remaining authorities in the HMA being agreed, a firm policy commitment must be made to undertake a prompt review of the Local Plan to address these matters at the earliest possible opportunity. In the meantime, and in anticipation of the role Harborough is expected to play in meeting unmet need in the HMA, it would be prudent for the overall level of development and range of identified sites to be increased. Such an approach will ensure that the Local Plan is sound at the time of examination, and capable of providing the certainty and plan-led approach which is required.
The distribution of development set out in Policy SS1 The Spatial Strategy, and in particular the identification of Selected Rural Villages (SRVs) to accommodate appropriate levels of growth, is supported. However, consideration should be given to the allocation in the Local Plan of sites across all tiers of the settlement hierarchy for which growth is planned. For SRVs where options for growth are limited, and/or Neighbourhood Plans which allocate housing sites are not being taken forward, the allocation of sites in the Local Plan will ensure the delivery of sufficient levels of development across the full range of the settlement hierarchy. This will reduce the risk of certain settlements and tiers of the hierarchy not making their required contribution to meeting Harborough's housing requirements, and ensure that the plan is both effective and positively prepared. The failure to make such allocations could risk the plan not being found sound.
We broadly support the distribution of development as defined in Policy H1 Provision of New Housing, and the proposed levels of development in the SRVs being expressed as minima. We also support the identification of Gilmorton as a SRV, which correctly reflects the range of services and facilities available in the village and confirms its sustainability and suitability as a location for growth.
The deliverability of Richborough Estates' site at Kimcote Road is demonstrated by the Planning Committee's resolution to grant planning consent on 3 October 2017, subject to completion of a Section 106 agreement which is now close to being finalised. It is anticipated that the site will be marketed before the end of 2017, to enable to swift submission of reserved matters and commencement of delivery on this sustainable site in 2018.
I trust these representations are of assistance and will be taken into consideration. If you have any queries or require any further information then please do not hesitate to contact me.

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.