SS1 clause 1. manage planned growth to 2031 in accordance with the following settlement hierarchy:

The Consortium strongly supports the Council's spatial strategy for distribution of growth. It is clear that Harborough District Council has arrived at the most appropriate strategy, in accordance with national policy, to deliver the development requirements of the area. The spatial strategy closely aligns with the objectives of higher level strategic plans such as the Strategic Growth Plan and the Strategic Economic Plan.

Leicester & Leicestershire's emerging Strategic Growth Plan (SGP) recognises the M1 as a major corridor and one of the plan's objectives is to maximise the potential of transportation corridors to deliver sustainable development and enable the creation of an integrated public transport network. Furthermore, the spatial options include identifying development through growth corridors and employment led growth. Harborough Local Plan's settlement hierarchy recognises Lutterworth as a Key Centre with capacity to expand and facilities to support growth. The town's location is unique within the district, being close to the M1 and A5 corridors and close to existing and planned employment growth. Therefore, strategic development in this area would accord with the emerging SGP.

In addition, the Strategic Economic Plan (SEP) identifies South West Leicestershire as a priority growth area to deliver the economic goals for the sub region. The M1 and A5 are essential economic corridors for the sub region and important nationally. There is already substantial business investment and evidence identifies further job growth here in the future. Thus, in order to support their strategy the Local Enterprise Partnership is focussing investment in infrastructure in this area. Hence, through the spatial strategy of the Harborough Local Plan, strategic development of Lutterworth and the surrounding environs, including Magna Park, is essential to the delivery of this priority growth area in the SEP.

Alternate spatial strategies that the Council have considered, such as focussing strategic growth around Rural Centres such as the Kibworths, would not deliver the aims and objectives of either the emerging Strategic Growth Plan or the Strategic Economic Plan of focussing growth around the greatest opportunities for increased economic development linked to key transport corridors and infrastructure investment. Such dispersal of strategic growth to more remote settlements would also not help to achieve a sustainable pattern of development as required by the Framework.

Alternate spatial strategies would not therefore achieve sustainable development by failing to ensure that sufficient land of the right type is in the right place to support growth.

On behalf of Mr and Mrs Sellers we wish to make the following observations on the
Harborough Local Plan Proposed Submission Draft Consultation.

4.2. We support the proposed spatial strategy for growth set out in Policy SS1: Spatial Strategy. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are within close proximity to a wide range of employment opportunities and local services and facilities. As outlined above, we consider Great Easton to be a sustainable location with a wide range of services and facilities, and as such we support its identification as a Selected Rural Village, which is expected to support residential development of an appropriate scale.

4.3. In respect of Policy GD1: Achieving Sustainable Development, we strongly support the inclusion of this Policy within the Harborough Local Plan in line with Paragraph 14 of the NPPF. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of the District.

4.4. We support the proposed strategy for locating growth within or contiguous to the built up area of Selected Rural Villages, such as Great Easton, as outlined in Policy GD2: Settlement Development. We consider that the proposed development at Land rear of 22 Broadgate is of an appropriate scale that reflects the size of the village and the level of service provision. The site is visually and physically well connected to the village and services within the village centre are within an appropriate walking distance. It is considered that a development of up to 8 units would be of an appropriate scale for the village and can be designed in a manner that respects and enhances the local character and distinctiveness. A development scheme could be designed to provide views through the site, from Broadgate, to the open countryside to the north.

4.5. With regards to Policy GD5: Landscape and Townscape Character we fully support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness. The site to the rear of 22 Broadgate, Great Easton is bound to the east and west by existing and proposed residential development, and as such development of the site would be viewed as a continuation of development within the village envelope. Any development scheme would be positively prepared to ensure that the site provides a high quality and inclusive development design that makes a positive contribution to the local character and distinctiveness of Great Easton.

4.6. We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As stated above, any development proposal at Land rear of 22 Broadgate, Great Easton would be positively prepared to ensure a high quality and inclusive design. Any design scheme would maintain and enhance the existing boundary features to ensure that the views and residential amenity currently experienced to the south, east and west of the site are retained. The site would also seek to include an area of Public Open Space which could be positioned to enable key views of the open countryside, seen through the site from Broadgate, to be preserved.

4.7. In respect of Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. We support the identification of Great Easton as an appropriate location for the delivery of a minimum of 30 dwellings. As previously outlined, we consider that the proposed development of Land rear of 22 Broadgate for up to 8 dwellings would be an appropriate scale of development for the village, and would deliver a scheme that could make a positive contribution to the character and distinctiveness of Great Easton.

4.8. We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver a range of housing types and sizes. Any development of Land rear of 22 Broadgate could deliver a mix of property types including semi-detached and detached houses ranging in size from 3 to 4 bedrooms.

4.9. With regards to Policy HC1: Built Heritage, we support the requirement to protect, conserve and enhance local heritage assets in line with Paragraph 134 of the NPPF. The previously submitted application was supported by a Heritage Statement which found that the proposed development would result in a low adverse impact on 22 Broadgate and would not amount to substantial harm to the significance of the asset. The Statement also found that the proposals would have a negligible impact on the setting of 22 Broadgate. Members concerns with the previous application related to the heritage impact of the proposed access; as such the clients are currently pursuing the potential of securing an alternative access point for the site, which would overcome these concerns. There were no concerns about the principle of development on the site from a heritage perspective.

4.10. Finally, in respect of Policy CC3: Managing Flood Risk, we fully support the objectives of this policy in line with Paragraphs 14 and 100 of the NPPF. Given that the presumption in favour of sustainable development is the golden thread running through the national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site not located in an area at risk of flooding. We consider the proposed development site at Land rear of 22 Broadgate, Great Easton has the capacity to accommodate a small scale residential development scheme comprising up to 8 dwellings with associated vehicular access, car parking, landscaping and drainage. Any development scheme would provide a mix of dwelling types and sizes.

5.2. We fully support many of the objectives and policies contained within the Proposed Submission Draft of the Harborough Local Plan 2011-2031. In particular, we support the identification of Great Easton as a Selected Rural Village, which is to accommodate a minimum of 30 new dwellings to assist in meeting the District's housing needs.

5.3. Any development proposal for Land rear of 22 Broadgate would be positively prepared to ensure high quality and inclusive design. The scheme would maintain and enhance the existing boundary features to ensure that the views and residential amenity currently experienced to the south, east and west of the site are retained. The site would also seek to include an area of Public Open Space, positioned to enable key views of the open countryside to be preserved.

5.4. Therefore, the site represents an opportunity to deliver a suitable, available, achievable and viable source of housing land that can be developed now.

5.5. Andrew Granger & Co. would like to remain involved throughout the preparation of the Harborough Local Plan 2011-2031 and therefore request to be informed of any future consultation opportunities and when the document is submitted for Examination.

Support hierarchy.

Lutterworth and Magna Park are close to the M1, M69, A14 and M6 and are the best choice for major developments.
Housing has been fairly distributed around the Rural Centres.

Comments on the Harborough Local Plan Submission Draft

4.1. On behalf of the Carr Family we wish to make the following observations on the
Harborough Local Plan Proposed Submission Draft Consultation.

4.2. We support the proposed spatial strategy for growth set out in Policy SS1: Spatial Strategy. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are within close proximity of a wide range of employment opportunities and local services and facilities. As outlined above, we consider Great Glen to be a sustainable location with a wide range of services and facilities, and as such we consider to be appropriately identified as a Rural Centre, where development is expected to meet the needs of the settlement and the surrounding area. As such, we propose the formal allocation of Land off London Road, Great Glen for residential development to assist in meeting these needs.

4.3. In respect of Policy GD1: Achieving Sustainable Development, we strongly support the inclusion of this Policy within the Harborough Local Plan in line with Paragraph 14 of the NPPF. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of the District.

4.4. We support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness, as outlined in Policy GD5: Landscape and Townscape Character. Any development at Land off London Road, Great Glen would be positively prepared to ensure the provision of a high quality and inclusive development design. The scheme would seek to ensure that it respects the site's rural context and make a positive contribution to the local character.

4.5. We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As stated above, any development scheme at Land off London Road, Great Glen would be positively prepared to ensure a high quality and inclusive design. Any proposal would be designed to protect the residential amenity of existing properties located to the east and west of the site through the retention of the existing boundary hedgerow and enhancement with additional planting. Any development would seek to utilise materials that are complementary to the local vernacular to ensure that the development is well integrated into the local street scene.

4.6. With regards to Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. We support the identification of Great Glen as an appropriate location to support residential development, however we consider that the village has the capacity to accommodate a greater quantum of development than the 35 dwelling minimum requirement proposed. As previously outlined, Great Glen has a wide range of key services and facilities, including a GP, a Primary School, Leicester Grammar
School, a Convenience Store and a Post Office. The village also benefits from good connectivity to higher order settlements such as Leicester, Oadby and Market Harborough and the services and employment opportunities available in these settlements. It is an attractive settlement where people want to live, and therefore we consider it to be an appropriate location for the delivery of a greater quantum of new homes. In this light, we are proposing the formal allocation of Land off London Road, Great Glen as a strategic residential development. As outlined above, we consider the site has the capacity for a first phase of up to 150 dwellings which will assist in the delivery of new homes to meet both the District's needs and any unmet needs arising from Oadby and Wigston Borough or Leicester City.

4.7. In respect of Policy H2: Affordable Housing, we support the requirement for residential developments of more than 10 dwellings to provide 40% of affordable housing on site. As previously stated, our clients have stated their willingness to meet this requirement, subject to the appropriate viability assessment.

4.8. We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver a range of housing types and sizes. Any development at Land off London Road, Great Glen would deliver a mix of property types and sizes, including bungalows, terraced, semi-detached and detached dwellings ranging in size from 1 to 5 bedrooms.

4.9. In respect of Policy HC1: Built Heritage, we support the requirement to protect, conserve and enhance local heritage assets in line with Paragraph 134 of the NPPF. Where a proposal will result in less than substantial harm to a designated heritage asset, Paragraph 134 of the Framework requires this harm to be weighed against the public benefits of a development scheme.

4.10. It is considered that the proposed development of Land off London Road, Great Glen would result in a range of social, economic and environmental benefits which contribute to the provision of a sustainable development.

Social Benefits
Housing Provision: Great Glen is considered to be an appropriate location for residential development; development of the site would result in the delivery of a first phase of up to 150 dwellings, including a range of housing types and sizes, which would assist in the delivery of new homes in the District High Quality Design: The proposed development would be positively prepared to ensure a high quality and inclusive development design that would be informed by a number of technical reports, to ensure that it makes a positive contribution to the character of the
village.

Economic Benefits
Affordable Housing Provision: The site has the capacity to deliver up to 40% affordable housing on site, which would include the provision of starter homes to enable young people to remain in the village.

Environmental Benefits
-Additional Tree Planting: Any development of the site would seek to retain the boundary trees and hedgerow that define the site and would also include extensive additional planting within the site.
-On site surface water attenuation: Any application for development on the site would be supported by a Drainage Strategy which outlines how surface water would be managed on the site. The strategy would detail the appropriate measures which will ensure the development of the site does not increase the risk of flooding elsewhere.

4.11. With regards to Policy CC3: Managing Flood Risk, we fully support the objectives of the policy in line with Paragraphs 14 and 100 of the NPPF. Given that the presumption in favour of sustainable development is the golden thread running through the national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site is located within Flood Zone 1.

4.12. In respect of Policy IN1: Infrastructure Provision, we support the requirement for development proposals to make appropriate contributions to local infrastructure where necessary to support the proposal, in line with Paragraph 204 in the NPPF.
The clients are willing to enter into discussions with Harborough District Council in respect of planning obligations to be secured within a Section 106 Agreement.

5. Conclusion
5.1. We consider the proposed development site at Land off London Road, Great Glen has the capacity to accommodate a strategic residential development comprising a first phase of up to 150 dwellings with associated vehicular access, public open space, car parking, landscaping and drainage. Any development scheme would provide a mix of dwelling types and sizes, and would provide a proportion of affordable housing, subject to viability.

5.2. We fully support many of the objectives and policies contained within the Proposed Submission Draft of the Harborough Local Plan 2011-2031. In particular, we support the identification of Great Glen as a Rural Centre, which is to accommodate development to meet the needs of the settlement and the surrounding area.

5.3. In light of this, we consider that the village has the capacity to accommodate a greater quantum of development than the 35 dwelling minimum requirement proposed in Policy H1: Provision of New Housing. Great Glen has a wide range of key services and facilities, and also benefits from good connectivity to higher order settlements such as Market Harborough, Oadby and Leicester, and the services and employment opportunities available in these settlements. It is an attractive place where people want to live and work, and therefore we consider it to be an appropriate location for the delivery of a greater quantum of new homes.

5.4. As such, we are proposing the formal allocation of Land off London Road, Great Glen for a strategic residential development to assist in the delivery of new homes to meet the District's needs and any unmet needs arising from Oadby and Wigston Borough and Leicester City.

5.5. Andrew Granger & Co. would like to remain involved throughout the preparation of the Harborough Local Plan 2011-2031 and therefore request to be informed of any future consultation opportunities and when the document is submitted for Examination.

Plan Period
The current plan period for the Proposed Submission Harborough Local Plan runs to 2031. It is currently anticipated that the Local Plan will be adopted by October 2018. That programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which relies in order to meet identified development needs (notably the Strategic Development Areas).

Even if it is adopted by October 2018, there will not be a 15-year horizon to the end of the plan period. This does not accord with the National Planning Policy Framework (NPPF) which states that local plans should "be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date" (NPPF, paragraph 157, point 2). Given that objectively assessed development needs (OAN) have been assessed for the period to 2036, the plan period should be extended to 2036 to ensure that the Local Plan has a time horizon in excess of 15 years and longer term development requirements, including an adequate level of future housing and the infrastructure required to support that, can be provided for.

Policy Part 1
The proposed settlement hierarchy set out in Policy SS1 and the principle that this should be used to manage planned growth and direct development to appropriate locations in a sustainable manner is supported. Specifically, the identification of the Principal Urban Area (PUA), including Scraptoft, Thurnby and Bushby at the top of the hierarchy as a focus for housing and employment growth in the District is welcomed. This approach reflects the locality's accessibility to higher order facilities, services and employment opportunities, and the level of infrastructure available to support future growth and development to meet the identified housing needs of the District, as well as assist in meeting the unmet needs of Leicester.

In this regard, it is paramount that the policy then seeks to enable all opportunities for the delivery of sustainable development at the PUA as a means of boosting the supply of housing in accordance with paragraph 47 of the NPPF. As set out below, however, Part 2 of this policy potentially restricts development in the most sustainable location in the District.

Policy Part 2a
Part 2a of the policy proposes a requirement to provide a minimum of 12,800 dwellings over the plan period to 2031. However, as noted above, the current plan period does not provide a 15-year time horizon and should, therefore, be extended to 2036. The proposed development requirements will need to be increased accordingly, but a separate objection to Policy H1 has also highlighted critical concerns in relation to the identification of an appropriate housing requirement and the allocation of sufficient sites to meet that requirement. Notably, the unmet housing needs arising in Leicester and Oadby & Wigston have not been addressed, and the plan is consequently fundamentally unsound in that regard. Addressing those matters will result in a further uplift in the housing requirement in the District and necessitate the allocation of additional housing sites in accordance with the proposed spatial strategy set out in Part 1 of the Policy.

More specifically, the following matters must be addressed:

ii & iii. The proposed allocation of Strategic Development Areas (SDAs) in the HLP is not objected to in principle. Notably the Scraptoft North SDA is within the Leicester PUA and, therefore, reflects the proposed settlement hierarchy that underpins the plan's spatial strategy. However, there is a significant over reliance on their delivery in order to meet the identified needs of the District. The combined quantum of development provided by the two sites provides over 55% (2,700 dwellings) of the total housing supply for the plan period (excluding sites already completed or committed). Moreover, it is extremely unlikely that the SDAs will deliver the scale of development currently assumed by the HLP within the plan period (as explained more fully in the objection to Policy H1). There is, therefore, a significant risk that the identified development needs will not actually be met, and it is imperative that is mitigated through the allocation of a wider portfolio of sites in appropriate locations that accord with the Local Plan's spatial strategy. Given that the Leicester PUA (Scraptoft, Thurnby and Bushby) is positioned at the top of the settlement hierarchy, that should be the first location to consider for the identification of additional sites to be allocated for development.

iv. The reference to the allocation of other sites to meet the identified development needs is supported. However, as a result of the proposed allocation of the SDA, the HLP currently excludes the allocation of any other development sites at the PUA. That is objected to as the distribution of development requirements throughout the District does not reflect the spatial strategy that is purported to underpin the HLP. That, however, can be remedied through the allocation of additional development sites to accommodate the increase in the housing requirements that would result from addressing the concerns highlighted above.

The clear merit of directing future growth to this locality is recognised throughout the HLP and reflected in the proposed Settlement Hierarchy (as set out above). Indeed there are opportunities to allocate smaller development sites at the PUA that would make an extremely valuable contribution to meeting the District's identified development needs, and would of course also be very well placed to address the identified unmet need arising in the City. One such site is the land off Uppingham Road, Bushby that adjoins the committed development site at Charity Farm, and is also controlled by Bloor Homes (further detail is provided in the objection to Policy H1).

Part 4
The aspiration to ensure that the quantity and location of development within and adjoining the Leicester PUA safeguards the identity of the communities of Scraptoft and Thurnby/Bushby is recognised. However, the requirements of the policy are unclear in terms seeking to ensure that development "supports regeneration and development objectives in the neighbouring City of Leicester and Oadby and Wigston Borough". As stated above in relation to Part 2 of the policy, it is paramount that the HLP allocates sufficient brownfield and greenfield land to meet the fully identified needs of the District, and positively address the identified unmet needs of Leicester and Oadby & Wigston. The HLP currently fails to do that, and is therefore, fundamentally unsound. However, there are sustainable sites available on the edge of the PUA that are clearly well-placed to address that need including, as noted above, land off Uppingham Road, Bushby.

Part 9
The intent to "strictly control development in the countryside" is objected to. This suggests the imposition of a pre-NPPF style "blanket" protection of the countryside and constraint on development that clearly does not comply with the policy requirements of the NPPF. The NPPF no longer uses the language of seeking to protect the countryside simply because it is countryside, but instead in trying to balance the need for development, it refers to recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it (at paragraph 17 point 5). As such it does not preclude development in the countryside and it would be inappropriate for the HLP to seek to do so.

Indeed, this part of the policy creates a policy tension with Policy GD2, which is not helpful in terms of guiding the decision maker when determining planning applications. Part 9 of the policy should, therefore, be omitted.

Soundness
For the reasons set out above, Bloor Homes object to Policy SS1, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs, including unmet development requirements arising in Leicester, will be met within the plan period;
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
- is not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Revise policy as follows:
- The plan period should be extended to 2036.
- Part 2: the housing requirement should be increased to reflect the extended plan period to 2036 and the concerns raised in the objection to Policy H1.
- Part 2: include reference to the allocation of additional sites, most notably at Scraptoft, Thurnby and Bushby, given the PUA's position within the settlement hierarchy and relationship to Leicester.
- Part 4: requires further clarification of the specific development requirements of this policy to support the regeneration and development objectives in the neighbouring City of Leicester and Oadby & Wigston Borough.
- Part 9: delete.

APPENDIX
HARBOROUGH LOCAL PLAN 2011 TO 2031 PROPOSED SUBMISSION
LEICESTERSHIRE COUNTY COUNCIL RESPONSE

Transport

1. Leicestershire County Council, in its role as Local Highway Authority (LHA), has been working closely with Harborough District Council as part of the Local Plan making process. As such, the LHA is content that the draft submission document is appropriately evidenced and also appropriately deals with transportation considerations at this stage in the planning process.

2. Subject to Harborough District Council's continued commitment to the policies and delivery approaches set out within the document, the LHA supports the submission of the Local Plan and looks forward to working with Harborough District Council in its delivery.

Education

3. Policies F1, MH2 and MH3 include no reference to securing suitable contributions for educational facilities. It may be that the intention is that these are covered by Policy IN1 - Infrastructure Provision, however whilst this policy refers to the Leicestershire Planning Obligations Policy (LPOP), it only does so in terms of waste, it does not refer to education.

4. Policies L1 and SC1 refer to delivery of Primary Schools 'soon after 300 dwellings'. The County Council would normally, and has with Harborough District Council, requested that the intended provision be available for opening in the September prior to the occupation of 300 dwellings.

Ecology

5. It is acknowledged that the de-declaration of the Scraptoft Local Nature Reserve is also currently being consulted on, and that its de-declaration would enable land to come forward for development as part of the Scraptoft North Strategic Development Area (SDA). The County ecologist has and continues to be actively involved, working through an approach which ensures the retention and management of areas of ecological value whilst enabling the release of some land for future development. This may involve the designation of a Local Wildlife Site.

Waste Management

6. The Local Plan needs to recognise that Waste Management considers proposed developments on a case-by-case basis and, when it is identified that a proposed development will have a detrimental effect on the local civic amenity infrastructure, appropriate projects to increase the capacity to offset the impact have to be initiated. Contributions to fund these projects are requested in accordance with Leicestershire's Planning Obligations Policy and the Community Infrastructure Legislation Regulations.

Economic Growth

7. The County Council supports the new employment land allocated in association with the Lutterworth SDA and recognises a similar approach is not necessarily appropriate with the Scraptoft North SDA with opportunities to access existing B use employment sites and proximity and ease of access to the City for employment.

8. The proposed portfolio of B use employment land in the Local Plan, which will provide the opportunity to deliver a range of jobs and economic prosperity in the District and wider area, is supported.

9. The County Council supports the approach taken to strategic storage and distribution (strategic B8 use) at Magna Park in the Local Plan, which has been informed by recent evidence commissioned by Harborough District Council. In particular, it supports additional strategic distribution proposals at Magna Park needing to meet the six criteria set out within the second part of Policy BE2, which sets a limit of 700,000 square metres for non-rail-served strategic B8 use in the Plan period.

10. The emphasis on the vitality and viability of the town centres is supported, and the regeneration emphasis on Lutterworth town centre although it is considered there is scope to strengthen this further, beyond the focus on vacant units absorbing identified need in Lutterworth town centre.

Strategic Assets

11. Comments from Strategic Assets are made in relation to the County Council's role as landowner. Its main interests in Harborough District are:

* land at Misterton County Farms Estate which forms part of the East of Lutterworth SDA (for which a separate detailed collaborative response will be submitted on behalf of the landowner consortium), and;
* potential smaller scale sites within Market Harborough, Lutterworth and rural settlements throughout the District.

12. Query whether the settlement hierarchy requires further consideration, to enable settlements which are better serviced than others in the same tier of the hierarchy to be more clearly distinguished and potentially receive more development.

13. In general terms the distribution of housing across the settlement hierarchy is supported; however, considers that there needs to be more clarity regarding the future housing needs of key settlements and seeks more flexibility for future housing numbers for smaller settlements.

14. The allocation of the East of Lutterworth SDA as a preferred strategic housing allocation is, in particular, strongly supported. The Objectively Assessed Need (OAN) supported by the Housing and Economic Development Needs Assessment (HEDNA) should therefore inform and provide strategic guidance to the development of later SPDs and Neighbourhood Plans. In considering the distribution of housing in the lower tiers of the hierarchy the Plan needs to demonstrate that those key centres and rural centres with neighbourhood plans will deliver housing numbers based on the current OAN rather than those contained within existing plans which were based on an earlier, much lower, OAN. Without this clarity the methodology could be open to criticism.

15. The integration of the social element of housing for older people and specific groups should be incorporated within the quantum and mix of affordable housing in order to mitigate any negative effect on site viability.

16. The County Council requests that planning consents at Airfield Business Park, Market Harborough (BE1.1a (ii)) and the land south of Lutterworth / Coventry Road, Lutterworth (BE1.1b (ii)) should be shown as existing commitments. Further, the consented site at Gaulby Road, Billesdon (a former highways depot), should also be shown as a commitment.

17. Whilst recognising the desire to concentrate strategic distribution at Magna Park, the proposal in Policy BE2.2 to allocate sites capable of delivering units of at least 9,000 sqm is seen as logical, as is the desire to stimulate economic growth by delivering sites that meet regional and sub-regional demand.

18. Policy BE3 on existing employment areas is supported; BE3.1 being seen as of particular relevance in ensuring that development meets the needs/demands of the wider sub-regional market in addition to local businesses in order to attract inward investment.


19. The allocation of both convenience and comparison retail floor space within the Lutterworth East SDA in Policy RT1 is supported, as is the additional provision within Lutterworth town centre which will complement the development of the new local centre and maintain a balance across the expanded community.

20. Policy L1- East of Lutterworth SDA is strongly supported. Being situated in the M1 corridor within one of the priority areas for economic growth in the Strategic Economic Plan it is clear that Lutterworth should be the focus of major strategic development within the District. The East of Lutterworth SDA is seen to meet best the criteria set out in Key Issues section of the plan and compliments the further development of Magna Park. Further, it is confirmed that the site, which is recognised as the most sustainable location for major development within the district, is available, being owned by a consortium of willing landowners, deliverable and capable of supporting a viable development.

21. Policy L2 - Land south of Lutterworth Road/Coventry Road. Outline planning consent has been granted and accordingly it should be regarded as an existing commitment for the purposes of the Local Plan.

3.1. On behalf of Mr and Mrs Welton we wish to make the following observations on the Harborough Local Plan Proposed Submission Draft Consultation.

3.2. We support the proposed spatial strategy for growth set out in Policy SS1: Spatial Strategy. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are within close proximity of a wide range of employment opportunities and local services and facilities. As outlined above, we consider Market Harborough to be a sustainable location with a large number of key services and facilities and as such we support its identification as the Sub-Regional Centre, which is expected to be a focus for development.

3.3. In respect of Policy GD1: Achieving Sustainable Development, we strongly support the inclusion of this Policy in the Harborough Local Plan in line with Paragraph 14 of the NPPF. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of the District. We consider that the proposed development at Land off Harborough Road, Market Harborough should be viewed favourably in respect of the economic, social and environmental strands that comprise sustainable development.

3.4. We support the proposed strategy for locating growth within or continuous to the built-up area of settlements as identified in Policy GD2: Settlement Development. We consider that the proposed development of Land off Harborough Road, Market Harborough reflects the size of the town and level of service provision available. It is considered that the site is visually well connected to the town; the site is bound to the east by existing residential properties and is located less than 185 metres from a large-scale committed development to the north-east. The proposed development would enhance the local character and would include the retention of the site's natural boundary features.

3.5. With regards to Policy GD5: Landscape and Townscape Character we fully support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness. The proposed development at Land off Harborough Road has been positively prepared with the provision of a high quality and inclusive design at the core of the development objectives. As outlined previously, the materials selected for the scheme are considered to be well related to the site's rural location and will complement the natural features of the site to create a unique, high quality development.

3.6. We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As stated above, the proposed development at Land off Harborough Road has been positively prepared with the desire to provide a unique, high quality and innovative scheme at the core of the development's objectives. The proposals have given significant consideration to utilising materials that reflect the rural character of the site and complement the site's natural boundaries and features. The siting of the proposed development will ensure that the proposals have a limited impact on the existing residential properties to the east of the site, or the occupied businesses on the northern part of the site. It is considered that the proposed design scheme appropriately delivers a high quality, low energy residential development that will enhance the local character and distinctiveness.

3.7. In respect of Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. We support the identification of Market Harborough as an appropriate location for the delivery of a minimum of 1,140 new dwellings. As previously outlined, we consider that the proposed development of Land off Harborough Road for 15 new 2-bedroom low energy apartments is an appropriate scale for the town, and will deliver a scheme that makes a positive contribution to the character and distinctiveness of Market Harborough.

3.8. With regards to Policy H2: Affordable Housing, we support the requirement for residential developments of more than 10 dwellings to provide 40% of affordable housing on site. In relation to the proposed development of 15no. 2-bedroom low-energy apartments at Land off Harborough Road, the clients are will to meet this requirement subject to the appropriate viability assessments.

3.9. We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver housing at an appropriate density and include a range of dwelling types and sizes. The proposed development at Land off Harborough Road has been designed to provide new dwellings at a density that is considered to respect the rural nature of the site's location on the western edge of Market Harborough. The scheme will provide a mix of 2 bedroom apartments ranging from approximately 1,000 sq. ft. to 1,200 sq. ft.

3.10. In relation to Policy RT4: Tourism and Leisure we support the identification of Market Harborough as a focal point for tourism development. The proposed development at Land off Harborough Road, Market Harborough will likely serve to enhance the attractiveness of the District for visitors due to the unique nature of the proposed low-energy development. As outlined above, the client's intend to make arrangements with Harborough District Council for the organisation of a series of open days during the construction period to allow people to visit the site and learn more about the materials and techniques being used in the development, and how they can be utilised elsewhere.

3.11. We fully support the objectives of Policy CC1: Mitigating Climate Change in line with Paragraphs 93 and 94 of the Framework. The proposed development at Land off Harborough Road will serve to demonstrate how residential developments can be delivered in a low energy manner. The central aim of the development is to deliver homes that require no additional power or heat; in order to achieve this the development includes the following design features:
-Passive House design techniques
-Highly insulated and well-sealed, high density fabric - provides high thermal mass and limited heat loss
-Limited windows to southern facing elevations
-Stepped 3-storey units to shade southern and western elevations from low angle sunlight
-Orientation of roofs within 20 degrees of due south to optimise rooftop photovoltaic panels to provide electricity.
-Localised high capacity batteries to provide continuous power
-High efficiency exhaust air heat exchanges within each dwelling - provides heating and hot water from the warm air extracted by kitchens and bathrooms.
-Any surplus energy generated by the development will be supplied to the National -Grid or used to charge electric vehicles.

3.12. Finally, in respect of Policy CC3: Managing Flood Risk, we fully support the objectives of this Policy in line with Paragraphs 14 and 100 of the NPPF. Given that the presumption in favour of sustainable development is the golden thread running through national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site is predominately located within Flood Zone 1. The area to the south of the siting for the proposed apartment unit is located within Flood Zone 3; this area will be left undeveloped. Initial investigations have been undertaken by the client to ensure that the proposed development would not be at risk of flooding; as such it is proposed that the internal finish flood level will be 83.6 metres..
We consider the proposed development site at Land off Harborough Road, Market Harborough has the capacity to accommodate a low energy residential development comprising up to 15no. 2 bedroom apartments. The scheme has been designed using Passive House techniques to deliver homes which can be operated without any power or heating bills.

4.2. We fully support many of the objectives and policies contained within the Proposed Submission Draft of the Harborough Local Plan 2011-2031. In particular, we support the identification of Market Harborough as the Sub-Regional Centre which is to be a focus for new development, including a minimum of 1,140 new dwellings to assist in meeting the District's housing needs.

4.3. The proposed development at Land off Harborough Road will serve to enhance the attractiveness of the District to visitors due to its unique character and function as a low-energy development. The client's intend to make arrangements with Harborough District Council to utilise this opportunity, by organising a series of open days during the construction period to enable people visit the site and learn more about the materials and techniques that are being used in the development and how they could be utilised in other schemes.

4.4. Therefore, the site represents an opportunity to deliver a scheme that will enhance the District's attractiveness and identity whilst providing a suitable, available, achievable and viable source of housing land that can be developed now.

4.5. Andrew Granger & Co. would like to remain involved throughout the preparation of the Harborough Local Plan 2011-2031 and therefore request to be informed of any future consultation opportunities and when the document is submitted for Examination.

Refer to attached document.

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.

Dear Tess,

Thank you for providing Natural England with the opportunity to comment on the Harborough Local Plan 2011-2031 Proposed Submission document in accordance with Regulation 19 of the Town and Country Planning (Local Development) (England) Regulations 2012 and on the Status of Scraptoft Local Nature Reserve.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Harborough Local Plan 2011-2031: Proposed Submission
We have already provided comments on previous iterations of the Local Plan and have nothing further to add here except to welcome the commitment to continue to liaise with Natural England, the Environment Agency, the Lead Local Flood Authority and other stakeholders over the mitigation measures to protect the integrity of Misterton Marshes SSSI from any impacts arising from the proposed East of Lutterworth Strategic Development Area. As a statutory consultee, we would also expect to be consulted on the associated planning applications.

Harborough Local Plan Habitats Regulations Assessment (HRA)
Natural England welcomes the Habitats Regulations Assessment (HRA) for the Harborough Local Plan and considers that the scope of the report, its methodology and conclusions meet the requirements of the Habitats Directive and associated guidance. Natural England concurs with the report's conclusion that the Harborough Local Plan will not have a likely significant effect on any European Site either alone or in combination with other plans and projects. Therefore an Appropriate Assessment is not required.

Harborough Local Plan Sustainability Appraisal (SA)
We note and welcome the completion of a Sustainability Appraisal (SA) for the Harborough Local Plan 2011-2031 Proposed Submission. We are pleased to note that our comments in relation to the potential Strategic Development Area at Lutterworth and its potential impact on Misterton Marshes SSSI appear to have been taken into account.

Scraptoft Local Nature Reserve (LNR)
Please refer to our previous comments on the proposed de-declaration of Scraptoft Local Nature Reserve (LNR).

We hope that you find these comments helpful. We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us. For any queries relating to the specific advice in this letter only please contact me on 02080261940. For any new consultations, or to provide further information on this consultation please send your correspondences to consultations@naturalengland.org.uk.

Kind regards

On behalf of Mr and Mrs Sandercock we are seeking to work with Harborough District Council in promoting the Land off Station Road, North Kilworth (Appendix 1 of attached) for residential development. The subject site lies outside the Limits to Development identified within the Neighbourhood Plan, where development is strictly controlled. The proposed development site has a total site area of approximately 0.61 ha (1.5 acres) and is located on the eastern edge of North Kilworth, a village within the Harborough District of Leicestershire.

We support the proposed spatial strategy for growth set out in Policy SS1: Spatial Strategy. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are within close proximity to a wide range of employment opportunities and local services and facilities. As outlined above, we consider North Kilworth to be a sustainable location with a wide range of services and facilities, and as such we consider it appropriate for identification as a Selected Rural Village, which are expected to accommodate an appropriate scale of residential development.

In respect of Policy GD1: Achieving Sustainable Development, we strongly support the inclusion of this Policy in the Harborough Local Plan in line with Paragraph 14 of the NPPF. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of the District.

We support the proposed strategy for locating growth within or contiguous to the built up area of Selected Rural Villages, such as North Kilworth, outlined in Policy GD2: Settlement Development. We consider that the proposed development at Land off Station Road is of an appropriate scale that reflects the size of the village and the level of service provision. It is considered that the site is physically well connected to the village and the proposals include the provision of a footpath along the north of Station Road to assist with the functional connectivity between the site and the village centre. A development of 10 units would be an appropriate scale for the village and could be designed in a manner that respects and enhances the local character and distinctiveness. Any development of the site would seek to retain the existing natural boundary, with the exception of the site entrance and the footpath entrance. Development of the site would not impact on the separation of settlements, as the site is bound to the east by existing residential development.

With regards to Policy GD5: Landscape and Townscape Character we fully support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness. Any development of the Land off Station Road, North Kilworth would be positively prepared to ensure the provision of a high quality and inclusive development design. Any scheme would seek to ensure that it makes a positive contribution to the local character and respects the site's rural context.

We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As stated above, any development scheme at Land off Station Road, North Kilworth would be positively prepared to ensure a high quality and inclusive design. Any proposal could be designed to protect the residential amenity of existing properties located to the east and west of the site through the retention of the existing boundary hedgerow and enhancement with additional planting.

In respect of Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. However, we are concerned that the policy does not identify a minimum residential requirement for North Kilworth. The village is identified within Policy SS1: Spatial Strategy as a Selected Rural Village, which is considered to be an appropriate location for growth. All of the Selected Rural Villages, with the exception of North Kilworth, have an identified minimum requirement in Policy H1, and as such abstaining from allocating a minimum requirement for North Kilworth should be considered to be unjustified.

With regards to Policy H2: Affordable Housing, we support the requirement for residential developments of more than 10 dwellings to provide 40% of affordable housing on site. As previously stated, the clients are willing to meet this requirement, subject to the completion of the appropriate viability assessment.

We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver a range of housing types and sizes. Any development at Land off Station Road, North Kilworth would provide a mix of property types and sizes, including a mix of 2 to 4 bedroom dwellings which would include a mix of bungalows, semi-detached and detached houses.

Finally, in respect of Policy CC3: Managing Flood Risk, we fully support the objectives of the policy in line with Paragraphs 14 and 100 of the NPPF. Given that the presumption in favour of sustainable development is the golden thread running through the national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site is located within Flood Zone 1.

I write on behalf of Bidwells' client, the landowners for a site on land off Longgrey, Fleckney. The eastern part of the site (2.1ha) has previously been promoted under the emerging Local Plan (SHLAA reference: A/FK/HSG/10). I enclose with this response a Site Location Plan (reference: A.50,691) of the land at Longgrey, Fleckney. I also enclose with this representation a completed response form. We welcome this opportunity to comment on the Draft Submission of the Harborough Local Plan 2011-2031 (the Local Plan).
We consider the Local Plan as drafted is not sound under the 'test of soundness' in the NPPF. The plan has not been positively prepared, it is not justified or effective and it is not consistent with the NPPF. Paragraph 157 of the NPPF requires Local Plans to allocate sites to promote development, bringing forward new land where necessary, and provide detail on form, scale access and quantum where appropriate.
The Local Plan as drafted does not allocate sites sufficiently in locations such as Fleckney and hence it does not comply with the NPPF. Where relevant suggestions for changes to the plan to address the concerns in respect of soundness are
identified in these representations.
Part A: Strategy and General Policies
3. Sustainable Settlements
Policy SS1 The Spatial Strategy
Part 1 of Policy SS1 seeks to direct growth to the most appropriate locations according to the settlement hierarchy. Part of the Leicester Principal Urban Area (PUA) is identified under limb 'a' and the Sub-regional Centre of Market Harborough is identified under limb 'b'. Fleckney is identified within the fourth tier (part 1, limb 'd' of Policy SS1) of the settlement hierarchy as a Rural Centre along with Billesdon, Great Glen, Houghton on the Hill, Husbands Bosworth, The Kibworths and Ullesthorpe. Part 2, limb 'a' of Policy SS1 identifies a housing provision for a minimum of 12,800 dwellings (Use Class C3) during the period 2011-2031. This includes provision for "about 790 dwellings on non-allocated sites or sites to be allocated in neighbourhood plans for Rural Centres and Selected Rural Villages" under limb sub-limb 'v' of limb 'a'. Part 7 of Policy SS1 states that Fleckney (along with other Rural Centres) are to operate as Rural Centres providing housing, business, retail, leisure and community facilities to serve their needs and those of surrounding areas.
Paragraph 17 of the NPPF identifies one of the core planning principles is "to take account of the different roles and character of different areas...recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it." Furthermore, guidance contained within the NPPG highlights that all settlements can play a role in delivering sustainable development so blanket policies restricting housing development in some settlement and preventing other settlements from expanding should be avoided. We consider that the distribution of housing identified under Policy SS1 should be well balanced to meet both the housing needs of urban and rural communities.
We are supportive of the allocation of housing for Rural Centres. We consider that Fleckney represents a sustainable village with good access to local amenities and services. The settlement is ideally placed to deliver some level of housing growth for the District in order to meet local housing need and support village amenities and services. It is noted that Policy H1 identifies provision of a minimum of 295 dwellings at Fleckney with further consideration below.
Object: Change Required: Allocate housing towards sustainable locations in accordance with the settlement hierarchy and ensure a balanced distribution of housing to meet the need of urban and rural communities.
4. General Development Policies
GD1: Achieving Sustainable Development
A positive approach to development within the District is welcomed. It is also welcomed that applications will be approved without delay where possible.
Support: No changes required
GD2: Settlement Development
The principle of development on sites within or adjoining the existing or committed built up area is welcomed. Notwithstanding this, further consideration to the implementation of this policy may be required. It would be useful to have an indicative level of development for growth or for an acceptable level of provision within a settlement. It is also suggested that provision for development which facilitates the delivery of services or facilities is considered acceptable within or adjacent to the settlement boundary. Redevelopment of previously developed land is welcomed; however, consideration of the viability implications of PDL should be considered depending on the site specifics.
Support: Change proposed
GD8: Good Design in Development
We consider that the aspiration for good design within developments as set under the policy is welcome.
Support: No change required
Part B - Key Topics
5. Housing
H1: Provision of New Housing
The District is within the Leicester and Leicestershire Housing Market Area (HMA) and Functional Economic Market Area (FEMA) of Leicestershire. The nine Leicestershire local authorities have jointly prepared the Leicester and Leicestershire Housing and Economic Development Need Assessment (HEDNA) 2017 as part of their Duty to Cooperate responsibilities. Within the HEDNA, Leicester City Council and Oadby and Wigston Borough have both declared an unmet housing needs. The HEDNA was subject to further testing via the process of the preparation of local plans. North West Leicestershire District Council (NWLDC) was the first authority to consider the HEDNA and the Inspectors report was published on the 13 October 2017. The Inspector found that the HEDNA provided a robust justification for the stated housing and employment land requirements of the NWLDC Local Plan; however, he also stated that the outstanding concern is whether NWLDC should accommodate some of the unmet needs of the City of Leicester and the Borough of Oadby and Wigston, but these needs will not be clarified until the Strategic
Growth Plan is finalised at some time in the future. In the case of NWLDC, they have confirmed that they will review their local plan once the extent of the future Strategic Growth Plan has been provided, leading to an early review.
Paragraph 47 of the National Planning Policy Framework (NPPF) states that LPAs should:
"Use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing in the housing market area, ..."
The NPPF therefore clearly states that allowances should be made to accommodate any identified unmet housing need should it exist within the HMA. Although the Local Plan acknowledges that there is an unmet housing need from Leicester City Council and Oadby and Wigston Borough Council, the figure of 557 dwellings per annum has been used to calculate the housing requirement. This relates to the 532 dpa within the HEDNA with an additional 25dpa following the Magna Park Employment Growth Sensitivity Study (2017).
A 15% contingency in the supply of housing land has been added to the housing requirement. This contingency needs to accommodate any provision for the unmet housing need of other authorities within the HMA. The supporting text under paragraph 5.1.10 states that the contingency is not only to provide for the potential need of unmet housing need arising from other LPAs, roles also include allowances for a slower than expected delivery of the housing allocations, failure of permitted sites to deliver, changing economic circumstances and to provide flexibility and choice in the local housing market.
Although it is currently out for consultation and can therefore hold limited weight, the long awaited 'Planning for the right homes in the right places: consultation proposals' identifies both Leicester City and Oadby and Wigston Borough Councils as having a potentially large uplift on their local assessment of housing need. This could result on additional pressure for districts such as Harborough to provide for the wider area. The provision of a contingency is welcomed. However, it is suggested that a contingency of just 15% will fail to meet the targets of Policy H1 insofar as it will not meet the FOAN for the market area as well as the other objectives of the contingency including providing for potential unmet need, lack of delivery from housing allocations and permitted sites and changing economic circumstances. It is noted that HDC published their 5 Year Housing Land Supply statement (1 April 2017 to 31 March 2022) on 12 July 2017. This statement accepted that the Council's current 5-year housing land supply position to be 4.45 years. In view of the Council's current five-year housing land supply position, it is considered that additional deliverable sites for residential development will need to be brought forward through site allocations in the Local Plan.
Policy H1 identifies land for a minimum of 4,660 new homes during the plan period to 2031, in addition to the delivery of existing commitments and completions and the allowance for windfalls. Part 4 of Policy H1 states that at Fleckney, a minimum of 295 dwellings, including (only) the allocation land at Arnesby Road - about 130 dwellings in accordance with Policy F1. Paragraph 5.1.15 of the Local Plan states that "Policy H1 identifies the approximate number of homes to be provided in or adjoining each settlement in the settlement hierarchy. These homes will be provided on a range of sites, including on land specifically allocated for housing within the policy in the larger settlements." Paragraph 5.1.16 further states that "Each
allocated site has been assessed through the SHLAA and identified as either deliverable within the first 5 years of the plan period or developable later within the plan period." In addition, paragraph 5.1.17 states that "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. In selecting the scale of housing to be provided in each settlement, account has been taken of fundamental constraints on development, such as flood risk, and the supply of potential development sites in the Strategic Housing Land Availability Assessment (SHLAA). It also included further detailed consideration of villages where the Sustainability Appraisal (SA) of this
Local Plan identified potential sensitivity, or where the SHLAA sites were considered to conflict with the criteria in Policy GD2 Settlement development. Each settlement figure is a residual figure, taking account of existing commitments and previous completions within the settlement. For this reason there are relatively few dwellings required to be found in Rural Centres, where a large number of planning applications have been recently approved." Paragraph 5.1.18 further states that "the Local Plan also makes provision for smaller housing sites. Provision of smaller sites will be made through: the delivery of existing small site commitments; 'windfall' sites and small sites identified in the SHLAA that accord with policies GD2 'Settlement Development' and GD4 'New Housing in the Countryside'; and housing allocations in neighbourhood plans."
Whilst Policy H1 identifies provision for a minimum of 295 dwellings at Fleckney, only provision for 130 dwellings at 'land at Arnesby Road' has been identified within the policy. Policy H1 it does not fully identify where provision for all of the 295 dwellings will be allocated at Fleckney. For Policy H1 to allocate this level of housing for Fleckney, we consider that both Policy H1 and the Policies Map should identify where this housing provision is to be delivered by specifying it within the policy text and identifying its location as a housing allocation in the Policies Map. HDC published their Strategic Housing Land Availability Assessment (SHLAA) 2015 Update in May 2016. Appendix E 'Scored Settlement Maps' identifies the eastern part of the site (2.1ha) as SHLAA reference:A/FK/HSG/10 and is developable in the next 6 to 10 years for 35 dwellings. The remaining western part of the site is not identified in the SHLAA. It should also be noted that there is no 'made' or advanced emerging draft Neighbourhood Plan for Fleckney.
In view of the above findings, it is unclear under Policy H1 exactly how Fleckney will meet all of its provision for a minimum of 295 dwellings as identified under the policy. We consider that the SHLAA has demonstrated additional land that is deliverable and developable and additional provision for housing should be identified at Fleckney. The land off Longgrey, Fleckney is ideally suited to meet additional growth requirements for the village under a housing allocation in the Local Plan.
There are no known constraints to the proposed residential development of the site. Safe access to the site can be achieved off Longgrey and the site is located close to local amenities and services in Fleckney. It is considered that landscape enhancements will help mitigate any potential landscape and visual impact from the proposed development. An illustrative masterplan/layout plan can be provided in due course to provide details of proposed layout and design to show how residential development of the site can be delivered. In view of the above, the site represents an achievable, suitable and deliverable site to support the necessary housing growth for the District. The proposed development will contribute towards the Council's
housing requirements and expected further unmet need from Leicester City and Oadby and Wigston Borough. Residential development of the site can be delivered and achieved within the forthcoming five year period, which will contribute significantly towards the Council's five-year supply and help towards addressing their current shortfall.
Changes Required: Ensure the housing requirements meet the FOAN for the market area and other objectives of the contingency identified above including providing for potential unmet housing need from Leicester City Council and Oadby and Wigston Borough Council, lack of delivery from housing allocations and permitted sites and changing economic circumstances; identify the site off Longgrey, Fleckney as a housing allocation.
H2: Affordable Housing
The allowance of off-site affordable housing is welcomed where it is not possible to provide an on-site contribution. There is a clear need for affordable housing within the District; however, it is important that the affordable housing requirement does not restrict development within the District. Part 5 of the policy is welcomed as
there will be instances where the high level of affordable housing provision is not feasible given the market values or site-specific concerns. The latest evidence base for affordable housing is contained within the Local Plan Viability Interim Report
- Residential Options Viability, prepared by Aspinall Verdi and published April 2016. This report demonstrates that viability varies between 30% - 40%. We consider that there is no justification for the Council to apply the higher figure of 40% affordable housing provision as a blanket figure across the whole District when their latest evidence base suggests otherwise.
Policy CS3 of the adopted Core Strategy recognised the need for different areas of the District to provide lower affordable housing requirements. This helped enable developers to provide high quality developments whilst compensating for lower market values within these areas. It is recommended that a similar aspect of this policy is incorporated into Policy H2. Policy H2 needs to consider the level of
affordable housing requirements to ensure that an effective viability of the Local Plan can be undertaken as required by the NPPF. We also consider that Policy H2 should consider the Government's proposals for Starter Homes. A proposed affordable housing tenure mix of 75% affordable/social rent and 25% low cost home ownership is too prescriptive and could prevent the delivery of Starter Homes coming forward. We consider that proposed residential and associated development of the land off Longgrey, Fleckney is suitable to provide an element of affordable housing provision in order to help meet the District's affordable housing need.
Object: Recommend amendments - it is suggested that the previous affordable housing policy within the adopted Core Strategy is retained.
H5: Housing Density, Mix and Standards
The provision of high quality housing, suitable to the needs and aspirations of an area is strongly supported. Notwithstanding this, the practicalities of housing provision needs to be carefully considered to ensure that unnecessary delays in housing delivery are not experienced. It is important to remember that development
cannot only provide for existing demand, it can also address the aspirations of an area. For example, young families could be attracted to an area through the provision of family accommodation whereas the elderly would have different housing requirements. It is recommended that Policy H5 is amended to include variations to the policy where evidence is provided to support any deviation. The required housing mix density for housing developments in different locations
across the District needs to reflect the market in these locations and the local housing need. It is not necessary to require adherence to Building Regulations within a development plan policy and therefore this reference should be omitted.
We consider that proposed residential and associated development of the land off Longgrey, Fleckney is suitable to provide a mix of housing size, types and tenure in order to help meet the District's mix of market and affordable housing need.
Object: Suggested amendment proposed to accommodate deviation from the policy in exceptional circumstances; omission of reference to Building Regulations
8.Heritage and Community Assets
HC1: Built Heritage
This policy needs to be changed to more accurately reflect the heritage guidance in the NPPF. Paragraph 126 of the NPPF states that: "Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats."
The requirement to adhere to the NPPF guidance is especially relevant to developments proposals which are considered to lead to less than substantial harm to the significance of heritage assets under paragraph 134 of the NPPF.
In this situation, it is necessary to assess the public benefits of the proposed development and then depending on the outcome of this assessment to undertake a balancing exercise under paragraph 14 of the NPPF. This policy does not accurately reflect the heritage guidance in the NPPF as therefore it does not represent
a positive strategy for heritage assets. Object: Change required to reflect heritage guidance in the NPPF to ensure there is a positive strategy for heritage assets.
12. Implementation, Monitoring and Review
IMR1: Monitoring and Review of Local Plan
An early review of the Local Plan is welcomed given the uncertainty of housing numbers within the HMA and pending changes to Government guidance on calculating housing requirements and changes to the NPPF. It is necessary to provide greater clarity and certainty on the timing for a review of the Local Plan.
Support: Suggest clarity and certainty on the timing for a review of the Local Plan.
Conclusion Our client welcomes this opportunity to comment on the emerging Local Plan. As it stands the plan is not sound and hence there are a number of changes required to the plan. We would be grateful if Harborough District Council could confirm receipt of this representation and continue to keep us informed as to the subsequent stages of the Local Plan.