SS1 clause 2a. enable housing development during 2011-2031 comprising:

Policy SS1 of the draft Local Plan identifies a target to deliver 12,800 homes over the plan period or 640 per annum. This responds to the objectively assessed need for 532 homes per annum identified in the Leicester and Leicestershire HEDNA, January 2017 with an allowance for 25 homes per annum to address the needs of employees at Magna Park and a contingency of 15% (or 83 homes per annum).

It is therefore necessary to consider each of these three elements to reach a conclusion on the housing requirement. The overall approach of the HEDNA broadly reflects the approach advocated in the NPPG. However, a number of the specific assumptions would either benefit from clarification or are not supported as described below:
1) Table 1 identifies that the population growth of the HMA was consistently under-estimated during the intercensal years, owing to unattributable population change (UPC). This is broadly recognized as being attributable to two factors, namely a potential misenumeration in one or other of the Census's (with either the 2001 Census under-estimating the actual population or the 2011 Census over-estimating the actual population) or an error in the estimated migration flows during the intervening years. It is impossible to attribute the UPC to one or the other of these factors, and so a large number of consultants preparing HEDNA's (including Neil McDonald who is quoted as a reliable source within the HEDNA) assume that 50% of the UPC is attributable to each factor. Such an approach has also been supported by numerous Local Plan Inspectors (including Inspector Pratt at the Stroud Local Plan examination). If such an approach was applied in Leicestershire, then this would uplift the population growth across the HMA by circa 742 people per year. However, the current approach of the HEDNA is equivalent to assuming that 100% of the UPC is attributable to errors within one of the Census's without any justification in support of this.
2) In paragraph 2.26, a number of sensitivity tests are identified. The first relates to rebasing the projection to 2015 and the second relates to applying a longer term migration trend. It is however, unclear whether the second sensitivity test also rebases the projection to 2015, which is required in order to align with the most recent evidence as required by the NPPG (2a-017).
3) Paragraph 4.48 identifies that the HEDNA has assumed the economic growth which occurred between 2011-15 and then projected forward the economic need from 2015 onwards. This in effect assumes that the objectively assessed need was met in full over the period 2011-15, which is clearly not the case given that the Council acknowledge that they have a record of persistent under delivery (as set out in the 5 Year Housing Land Supply Position Statement 2016/17). Any shortfall which arose during this period should therefore be added to the identified objectively assessed need across the plan period.
4) In paragraph 5.15, it is identified that changes are made to the commuting rates identified by the 2011 Census. However, the HEDNA does not identify which source (if any) the data comes from to make such an adjustment. It only alludes to "published data on jobs and population growth". This cannot be relied upon without the necessary reference as it is not justified in any way. Furthermore, data on jobs and population growth does not provide the necessary information about how those people and jobs interact through commuting. The only publicly available information on commuting rates is taken from the Census and this has the added advantage of being comprehensive as all households are legally required to submit returns. It would be virtually impossible to justify any adjustment from the comprehensive and robust figures provided by the Census in the absence of a comprehensive collection of primary data such as a survey with a high response rate (i.e. a new local Census).
5) In paragraphs 5.18 to 5.32, various sources for the employment rates are considered. It is identified that the OBR rates take account of the participation rates of different cohorts. These cohort-specific participation rates are a key determinant of the likely future workforce owing to the significant variance in participation of various cohorts (for example, a 16 or 64 year old is far less likely to be in full time employment than a 45 year old). The OBR rates also estimate the impacts of specific policy factors such as the change to retirement ages. These therefore provide robust and credible rates as relied upon by the Government. However, the HEDNA dismisses these and instead relies upon Experian rates which simply assume 80% participation without any justification and without taking any account of the participation rates of different cohorts, all of which is inconsistent with the Government's analysis (prepared by the OBR). Such an assumption relies upon a fundamental change in participation rates across all cohorts. In particular this requires that older people continue to work for a far longer period, regardless of their health and their ability to undertake more manual tasks. This departure from current rates is clearly a policy-on adjustment which should not be used to inform the objectively assessed need.

The preceding analysis suggests that the objectively assessed need of 532 homes per annum, identified by the Council is not robust and that it should be increased. Indeed, the DCLG have recently published the "Planning for the right homes in the right place" consultation which suggests that the objectively assessed need for Harborough should be 540 homes per annum. Whilst this is subject to consultation and as such it should not be afforded significant weight, this provides an indication of the Government's position on the objectively assessed need.

The Council have then identified a policy-on uplift to meet the needs of the employees of Magna Park. This is to be welcomed as it ensures that the employment development will be able to operate sustainably.

The Council then include a contingency of 15%. This contingency is identified to address the unmet needs of neighbouring authorities, to ensure that the objectively assessed need is delivered, and to provide choice and flexibility to the market as set out in paragraph 5.1.10 of the draft Local Plan.

The unmet needs of neighbouring authorities is unknown at present, although a final Memorandum of Understanding is due to be published in January 2018 which will detail the distribution across the authorities. This will be necessary to demonstrate that the duty to cooperate has been met. Pegasus Group therefore reserve the right to make further representations once this is available.

However, in the interim, the Emerging Options consultation for Leicester City identifies a housing requirement which produces a shortfall of between 7,900 and 15,000 homes (or 395 to 750 per annum). These unmet needs of Leicester City are likely to be most sustainably met within the authorities which neighbour the City, namely Blaby, Oadby & Wigston, Harborough and Charnwood. If as a broad proxy it was assumed that each of these were required to meet a quarter of the unmet needs of Leicester City, this would produce an additional requirement for 99 to 188 homes per annum in each authority. This compares to the contingency of 83 homes per annum identified in the draft Local Plan, which is also required to provide flexibility and to ensure that the objectively assessed need is provided for. This alone (although based on a very crude distribution) suggests that the housing requirement proposed in the draft Local Plan will be insufficient to meet the identified objectively assessed needs (which in themselves are under-estimated) and the unmet needs of Leicester City across the HMA.

However, the proposed housing requirement is supposed to fulfil these requirements as well as provide contingency to ensure delivery and provide choice and flexibility to the market. Whilst both of these objectives are supported, it is clear from the preceding analysis that the proposed housing requirement provides absolutely no contingency (or at the very best a much reduced contingency) once the objectively assessed needs are robustly determined and an appropriate allowance for the unmet needs of Leicester City is included. The result of this is that the housing requirement of the Local Plan is unlikely to be delivered and that there is no additional choice and flexibility available to the market.

It is not clear that all houses designed, built, planning submitted, planning approved etc prior to the date of the finalisation of this plan have or will be incorporated into the total numbers proposed..
This plan is for the period 2011 to 2031

The number of dwellings given is an approximate number with no means of checking when or how this target has been reached

The Co-op supports the Council's aim of delivering a minimum of 12,800 dwellings over the Plan period.

CPRE Leicestershire believes these housing figures are too high. Please see attached document.

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.

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,

The Local Plan period has set to cover the period up to 2031, with an estimated adoption date for the plan stated as being October 2018. This would give a 13-year plan period, even if that adoption date can be maintained. Paragraph 157 of the NPPF requires 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.

It is very likely that the emerging Leicester & Leicestershire Strategic Growth Plan will raise questions about the distribution of housing within the Leicester Housing Market Area, highlighting the unmet housing need within Leicester City, that will require HDC to make further housing allocations to ensure that the Duty to Cooperate can be demonstrated.

A new memorandum of understanding (MOU) with neighbouring authorities is due to be signed in January 2018 prior to this plan being examined. This new MOU may alter the basis of the previous MOU because of the unmet needs Leicester City Council have identified. The Harborough Local Plan is not considered to be sound in its current form.

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.

The landowners of Whetstone Pastures, duly object to the failure of the Council to recognise the potential to:

* Identify land within Whetstone Pastures as a future logistics park; and more over
* Recognise the ability of land within Whetstone Pastures to deliver a new Garden Village as part of a large strategic allocation extending over the administrative boundaries of both Blaby and Harborough.

2 On this basis objections are duly made insofar as SS1 - The Spatial Strategy is not 'sound' insofar as it is not:

* Positively Prepared as it fails to meet objectively assessed development needs and infrastructure requirements, including, where they arise, potentially making an appropriate contribution towards meeting unmet requirements from neighbouring authorities;
* Justified in that the plan is not based on the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
* Effective in that the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy as the plan does not enable the delivery of sustainable development in accordance with the policies in the NPPF.

3 With regard to SS1 it is submitted the following strategic priorities of the Local Plan (pp. 9) are not fully met:

* SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas;
* SP2: Assisting other local authorities to meet their unmet housing need; and
* SP3: Meeting regional and national demand for strategic distribution (logistics) development.

4 This is predicated on the basis that:

* Policy H1 - fails to make provision for sufficient new housing for the Plan period;
* Policy BE1 - fails to make provision for sufficient new business development for the Plan period; and
* Policy BE2 - fails to identify land at Whetstone Pastures as a potential logistics park.

5 Policies H1, BE1 and BE2 are effectively drafted on the basis of Harborough meeting its own objectively assessed needs. Accordingly, the draft Plan fails to recognise the wider needs of its neighbours as established in January 2017 when the Leicester and Leicestershire Authorities (including Harborough and Blaby) and LLEP jointly published its HEDNA which identifies the future quantity of housing and employment land needed in Leicester and Leicestershire up to 2031 and 2036.

6 The HEDNA has identified an Objectively Assessed Need for 117,900 dwellings between 2011 and 2036 across Leicester and Leicestershire. The need for larger more strategic warehousing and distribution units across Leicestershire is set out in the Leicester and Leicestershire Strategic Distribution Study 2015 (updated in 2017).

7 Leicester City Council has indicated that there will be unmet housing need within the City. A letter from Leicester City Council to all the other local planning authorities in the HMA dated 13th February 2017 stated that;

"the scale of the need [OAN] set out in the HEDNA is of such magnitude that it is concluded that there will be an unmet need arising in the city'. An additional letter sent on the same day to the Planning Inspector for the examination of the North West Leicestershire Local Plan set out 'our formal declaration of unmet housing need arising in the city."

8 In addition to setting out the future housing and employment requirement the document recognises that there is a need for all authorities within the Leicester and Leicestershire Housing Market Area to work collaboratively to account for the distribution of any identified unmet need.

9 On the basis of the foregoing local authorities have a statutory Duty to Cooperate over such matters and to identify how any such needs would be met. A Memorandum of Understanding (MoU) is currently being prepared by the 9 local authorities within the HMA (including Harborough). This document will identify how any unmet housing needs will be accommodated and will be signed by each authority as a binding agreement.

10 Given that the unmet needs of Leicester City Council should be addressed within the period of the Harborough emerging Local Plan the landowners are very concerned that there is no flexibility within the Plan to demonstrate how Harborough will accommodate unmet need through policies H1, BE1 and BE2 to meet this need.

Harborough DC - New Local Plan Options

11 The Council will be aware of representations made to Harborough DC - New Local Plan Options document (2015) by Nathaniel Lichfield & Partners (NLP) on behalf of Prologis UK Limited (Prologis). The representations principally related to proposals for a new logistics park on land between junctions 20 and 21 of the M1.

12 In broad terms the landholding related to an area in excess of 185 ha to the east and west of the proposed new M1 junction 20a (Whetstone Pastures Estate). The land is located to the south east of Cosby and west of Willoughby Waterleys. The Estate straddles the administrative boundaries of both Harborough and Blaby.

13 At the time of the submission the landowners and Prologis were promoting:
A new motorway Junction 20a on the M1 to relieve congestion at Junction 21 and to help remove an obstacle to further economic development;
* A new motorway service area to replace the existing Leicester Forest East motorway service area allowing for the managed motorway programme to be introduced; and
* A new 370,000 sq m logistics park on approximately 80 ha next to the proposed Junction 20a that would deliver over 6,000 high quality jobs in a wide range of roles.

14 Representations were duly made and recorded as follows:

* New Local Plan Options (September 2015), (rep. ID 2680 / 4242); and
* 'Sustainability Appraisal - Second Interim Report Appraising Options for Strategic Distribution Growth (February 2016) (rep ID 5327 / 5326 and 5245).

15 The representations were endorsed by the landowners in a follow up written submission lodged by Strutt & Parker on the 28th June 2016.

A New Garden Village

16 Since these submissions Blaby District Council, with the support of Leicestershire County Council and the Leicester and Leicestershire Local Enterprise Partnership (LLEP), made a submission in response to the Department for Communities and Local Government (DCLG) and Home and Communities Agency's (HCA) invitation for Garden Village proposals in July 2016.

17 The proposed Garden Village would be focused around a new M1 junction at 20a. The total site area would extend to approximately 400 hectares and would include the 185 hectares previously identified for the logistics park. Whilst the majority of the site falls within the administrative boundary of Blaby some 15% of the southern part of the landholding lies in Harborough. Please see attached map for more detail.

18 Whilst the bid was not successful the HCA in their individual letter of response went on to encourage the continued pursuit of the Garden Village idea:

"The HCA is responsible for delivering the Garden Villages Programme for the DCLG and we recognise the potential of your proposal. We would like to have a conversation with you around how we can best support you in progressing your Garden Village ambitions. There is scope for us to offer support from our planning Team ATLAS, from delivery specialists in our teams and in HCA's Land Team. We hope to open another round of Garden Village Funding in 2017/2018 and offer guidance in preparing applications."

19 Blaby District Council are continuing to work with the landowners to deliver a shared vision for the Garden Village proposals.

20 The proposals are at an early stage. However, the Local Authority and landowners have a shared goal to develop the ideas into fully-fledged proposals over the next 12-24 months. In broad terms it is envisaged that the Garden Village would offer a unique opportunity to deliver truly sustainable strategic growth; comprising of a new community, large scale employment opportunities and considerable benefits for the surrounding highways network. Specifically the plans would ensure:

* The delivery of a new M1 Junction (J20a):
* Approximately 280,000 sqm employment and logistics park; and
* In excess of 3,500 homes.

It is envisaged that this sustainable new community would deliver facilities including schools, healthcare and sports, and green and blue infrastructure, new local shops and other community facilities, all set within an attractive landscaped network of streets and parks. All this on a site located approximately 5km from the major commercial hub of Leicester City Centre.

Policy SS1 sets out the spatial strategy for HDC up to 2031, including directing development to appropriate locations in accordance with the proposed settlement hierarchy. Parts 1a-1f are generally supported, insofar as they seek to direct growth to the most sustainable locations in the district in accordance with relevant provisions of the NPPF. This includes development to part of the Leicester Principal Urban Area, Sub-regional Centres, Key Centres, and rural centres including the Kibworths. A summary of this settlement hierarchy is set out as follows:
* Leicester Principle Urban Area (Scraptoft, Thurnby & Bushby) ;
* Sub regional centre - Market Harborough ;
* Key centres - Lutterworth & Broughton Astley ;
* 7 rural centres - including the Kibworths;
* 16 selected rural villages ;
* Other villages, rural settlements & countryside (where development is strictly controlled).

This policy seeks to enable housing and commercial development over the plan period, including a minimum 12,800 dwellings. This includes circa 7,915 dwellings through completions or commitments, including through neighbourhood plan allocations. The Plan proposes circa 1,500 dwellings in a strategic development area (SDA) east of Lutterworth, and an additional 1,200 dwellings at the Scraptoft North SDA, and circa 1,170 dwellings allocated elsewhere in the Plan.

Bullet 3 to Policy SS1 outlines that the Plan will bring forward strategic development areas at East of Lutterworth and Scraptoft North, and ensure that they become well-planned, high quality living environments and that they support the maintenance and improvement of employment areas, shopping centres and community facilities both within them and nearby.

Whilst our client does not wish to explicitly comment on the merits or otherwise of individual sites proposed for allocation, a key issue of soundness for any local plan is whether the proposed housing allocations are deliverable and likely to result in the required level of completions.

The experience of strategic allocations is that there is a very long lead in period before housing completions commence. Reliance on only two strategic allocation potentially reduces the robustness of the plan in the event that either of these allocations is not developed as anticipated in the local plan policies.

The advantage of relying on more than two strategic allocations, is that whilst such sites are unlikely to contribute to supply in the short term such as five year supply, there is a greater likelihood of strategic allocations making a significant contribution to housing completions for the remainder of the plan period including helping to meet the unmet need arising from both Leicester City Council or Oadby & Wigston District Council.

To ensure that the plan is positively prepared and stands the best chance of meeting identified housing need, the Council should consider the allocation of developable reserve sites together with a suitable mechanism to allow their release during the plan period, as may be necessary.

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.