H2 clause 1

I believe that at least 50% of any new housing should be council-owned council housing, so that the very serious current housing problem can at least be properly addressed by one of our local councils.

Support/ Sound.
There is a need for affordable housing within Harborough District and the proposed level of 40% for schemes of more than 10 houses in the District would go someway towards meeting this. Priority for affordable housing should be given to those with connections with the settlement or have previously moved away from the settlement.

CPRE Leicestershire supports this policy.

The provision of affordable housing is supported. However, it is recommended that the Council simply make reference to the latest assessment of affordable housing need rather than specifying the tenure split in the policy. It is also suggested that the policy provide additional flexibility for large scale developments that would be delivered over numerous phases, in order to allow a reasonable degree of flexibility within each phase.

Does the percentage stated take into account the number of affordable houses NOT to be built on the Linden Homes site? On the SDA overall 40% would amoun to about 600 dwellings but the percenatge needed to reach this target is now considerably higher. Linden Homes development was allowed with NO affordable housing

The proposed Policy requires 40% affordable housing for all residential development proposals of 10 or more homes district wide. However, the supporting 2016 Viability study states that within the Lutterworth, Market Harborough and Blaby border areas, the viability threshold for affordable homes is 30%.

Table 3.7 within the Viability study supports the adopted Core Strategy Policy CS3 stating "A minimum of 40% of the total number of dwellings will be affordable within the two highest value sub-market areas of Harborough Rural South West and Harborough Rural North and Central. In the remaining three sub-market areas (i.e. Lutterworth, Market Harborough and Blaby Border Settlements), a minimum of 30% of the total number of dwellings will be affordable." The study offers no evidence to suggest a change in this current position.

The NPPF paragraph 173 states that "careful attention should be paid to viability and costs in plan-making" and that "the scale of development identified in the Plan should not be subject to such scale of obligations and policy burdens that their ability to be developed viably is threatened". Therefore, in order for the Policy to be considered consistent with national policy it must be altered to accommodate the affordable homes' viability variations noted across the district.

There is insufficient affordable housing and low cost purchase housing the 40% should be maintained except in very exceptional circumstances and viability assessments thoroughly checked

40% affordable/social housing on the Burnmill farm development site is not suitable for this site. It is not in keeping with the surrounding houses and the distance to any amenities will make it difficult for some of the residents to obtain what they need. It will inevitably mean increased car journeys for the simplest of tasks

Currently the Alvington Way estate has no affordable housing and because of this is a desirable area to live.

It is welcomed that the affordable housing requirement set out in Policy H2 includes provision for different level of affordable housing or tenure split where there are demonstrable viability considerations. The Council will be aware that whether a development is viable or not can change over time due to a multitude of factors. Therefore, whilst paragraph 5.3.9 of the supporting text cites the recent evidence, "Local Plan Viability Assessment, 2017" as justification, the Council should amend the text to recognise that this evidence is a snapshot in time.

In addition, it is recommended that the Council simply make reference to the latest assessment of affordable housing need rather than specifying the tenure split in the policy.

HARBOROUGH LOCAL PLAN 2011-2031
PROPOSED SUBMISSION CONSOLIDATED COMMENTS

General Comment

The document is generally well written and constructed but, unfortunately, the precision of policies in earlier development plans has been displaced by policies with discursive descriptions which are open to many interpretations. A case in point is the exchange of the precision of Policy HS8-Limits to Development for three interrelated and imprecise policies GD2, GD3 and GD4.

1.0 Title

As the Local Plan, when adopted, will apply to the entire district of Harborough, it is suggested that the title should be:

'Harborough District Local Plan 2011-2031.'

2.0 Provision of Copies of the Local Plan

The adopted Statement of Community Involvement (SCI), published in March 2015, states at paragraph 1.3:

'The purpose of this Statement of Community Involvement is to explain how the Council will actively seek to engage all sectors of the community and encourage widespread and continual involvement with its plan making and development management processes.'

Having in mind this declared objective of 'widespread and continual involvement', we would appreciate an explanation how our Parish, which has five Councillors one Clerk, and some 390 residents are meant to share the single document of the Local Plan we have in our possession.

3.0 Specified Methods of Consultation

At page 2 of the Local Plan document the District Council seeks to prescribe the specific methods by which representations may be made. It states:

'All representations must be submitted via the online consultation portal or the representation form.'

The reason advanced for this restriction is that other forms of response would need to be inputted to the Consultation Portal. Many in the community are likely to conclude that this difficulty is of the District Council's own making.

However, not only is this wholly unreasonable constraint hostile to the central aim of engaging the community in the plan making activity, it appears to be contrary to the relevant regulations which state:

'representations may be made in writing or by way of electronic communications.' and:

'In preparing local plans Local Planning Authorities must take into account any representations made to them.'

We are, of course, aware of the District Council's much-vaunted 'Strategic Planning Consultation Portal', and the endeavours of the Council to constrain consultees to employ this facility when making comments. While this may be convenient for officers of the Council, this is not necessarily the case for the great majority of the residents of the District. It is only of value if residents possess the necessary equipment, prowess and inclination to interrogate a computer display in the hope of discovering a particular element of interest in a large and complex document. Many will simply regard the 'Strategic Planning Consultation Portal' as yet another barrier to meaningful involvement. On the face of it, Members have allowed themselves to become brainwashed by over-zealous officers without questioning the practicalities of the Consultation Portal, and whether it fulfils the objectives of community engagement. Like many other internet-based systems the Consultation Portal notionally hits the target but, regrettably, misses the point.

4.0 Time Allowed for Consultation

For several reasons the time taken to prepare the Local Plan has greatly exceeded the timetable set out in the original Local Development Scheme (LDS). Even since the programme published in August 2016, the projected date for completion has receded by some 12 months. Although it is rarely constructive to compound delays in the execution of a programme, when set in the perspective of the preparation of the Local Plan, an exercise that has been characterized by almost chronic delay, it is difficult to accept that in the determination of the period allowed for consultation, the District Council has chosen the minimum value set out in the relevant regulation.

It is likely that the combination of the strict limitation of copies and the minimum time allowed for the consultation process, will convince the residents of the Harborough District that, despite the high-flown aspirational text of the Statement of Community Involvement, in practise, the primary objective of the District Council is to stifle consultation.

5.0 Lack of Consistency with the NPPF and the Question of Soundness

As you will be aware, the NPPF prescribes the content of a Local Plan as follows:

'Local Plan: The plan for the future development of the local area, drawn up by the local planning authority in consultation with the community. In law this is described as the development plan document adopted under the Planning and Compulsory Purchase Act 2004. Current core strategies or other planning policies which under the regulation would be considered to be development plan documents, form part of the Local Plan. The term includes old policies which have been saved under the 2004 Act.'

That the Core Strategy, adopted in 2011, and all the policies saved from the former Local Plan form part of the Local Plan is acknowledged by Harborough District Council. This is evidenced in the letter, dated 18 November 2013, sent to this Council from Mrs Verina Wenham, Head of Legal and Democratic Services. A copy of this communication was sent to you with our letter of 10 July 2017.

At Part A of the Local Plan, paragraph 1.1.3 it states:

'The Local Plan entirely replaces:

* Harborough District Local Development Plan Core Strategy 2006-2028 (adopted in 2011); and
* Harborough District Plan 2001 (Retained Policies)

The statement from Part A, quoted above, is explicitly inconsistent with the content of the Local Plan, as prescribed in the NPPF, as it is clear that the documents claimed to be 'replaced', actually form part of the Local Plan. As the proposed Local Plan is manifestly inconsistent with the NPPF, it cannot be claimed to be 'sound'. Doubtless the Inspector appointed to examine the Local Plan will wish to explore this issue.

6.0 Housing

In recognition of the national importance of housing the NPPF cites at paragraph 47:

'..local planning authorities 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...'

For the avoidance of misunderstanding, 'objectively' may be defined as: 'without bias'

The primary source of data used as basis for the housing numbers in the Local Plan is the Housing and Economic Development Needs Assessment prepared by G L Hearn, dated January 2017. This is but one of the many assessments produced by Hearn over the years. An earlier Assessment was used as the basis of the housing requirements used in the Core Strategy, adopted in 2011.

G L Hearn is a prominent consultancy owned by Capita. It claims it has a 'client base that includes landowners, developers, investors, Regional Development Agencies and local authorities.'

The Planning Director of G L Hearn, appointed in November 2016 has a role which includes:

'working with national and regional housebuilders, along with promoters-whilst building on GL Hearn's mixed-use capability...'

As the Hearn organization appears to be enmeshed with the housebuilding industry the question of the potential for conflicts of interest must arise. Only individuals with little or no understanding of the realities of commercial business would be sanguine about G L Hearn being capable of providing housing assessments that are prepared 'objectively'. In reality, Chinese Walls do not exist in business. On several occasions we have raised the issue of the impartiality of Hearn, and advocated the use of an entity whose independence is beyond doubt, such as a university. Each time we have broached the matter the District Council has sought to dismiss any concerns. To compound these worries is the relationship between G L Hearn and the commissioning local authorities as this appears to be unduly cosy. For example, the arrangements for the selection of G L Hearn for the performance of this contract have been questioned as they seemed to be somewhat irregular: one issue was the absence of a list of qualified bidders. .
These two matters, which are clearly inimical to the requirement that the need for housing is 'objectively assessed', deserve the attention of Members of the Council.
Should there be uncertainty about this issue Members should, perhaps give consideration to the following:

In 2011 the residents of the Harborough District were assured that the number of dwellings needed between 2011 and 2031 was 350dpa. A total of 7000 in the Plan Period. This number remains in the present adopted Development Plan for the Harborough District.

Residents, in the absence of any convincing explanation, are now being asked to believe that this number has increased to 557dpa, an uplift of almost 60%. A total of 11140 in the Plan Period.

Either the figure in the 2011 assessment was wildly understated or the present assessment value is grossly overstated. Members need to address this matter and arrive at a rational view. Ultimately, there may no alternative to seeking determination of the assessment from an organization whose impartiality is beyond reproach. Until this is done the integrity of the Local Plan and, indeed of the District Council, must remain in doubt.

6.1 Page 53: paragraph 5.1.4 Increase of Housing due to Magna Park Expansion

This paragraph asserts that to house the new workers required to resource the expansion at Magna Park more dwellings will be required, and this is quantified at an additional 25 dwellings per annum. This brings the total to 557dpa.

We are aware that officers of the Council appear to have an apparent penchant to increase house numbers given the slightest excuse for doing so, but in this case they appear to be explicitly disregarding the advice of G L Hearn.

In relation to Table 89, the one used for arriving at the 'Objectively Assessed Need' of 532dpa, the GL Hearn Report states:

' The conclusions recognise that there is no need to adjust upwards the assessed need to support economic growth when the demographic and economic-led projections are compared with one another at the HMA level, and that economic growth in individual authorities could therefore be supported by agreeing an alternative distribution of housing provision through the Duty to Cooperate.'


6.2 Affordable Dwellings

As you will be aware there is widespread interest in the topic of Affordable Dwellings, an interest that has been tragically heightened by the recent disaster at Grenfell Tower.

The annual need for affordable houses is defined in the Local Plan as 206 dpa.

The record shows that the delivery of affordable dwellings in the Harborough District has consistently fallen short of the annual target. During the last 5 years the maximum number of affordable dwellings delivered in any one year has been 85.

The Core Strategy required that 40% of the total dwellings in the highest sub-market areas, and 30% in the balance of the sub-market areas, should be affordable. Likewise, the Local Plan prescribes that 40% of all dwellings on sites of more than 10 dwellings should be affordable.

Unfortunately, the strategy of securing affordable dwellings solely by means of the spin-off from market housing developments has proved to be ineffective. The record in the last 5 years shows that, of the total number of dwellings completed, only some 16% were classed as affordable.

There is a patent need for the District Council to abandon its present passive strategy and establish a significantly more proactive and effective strategy for delivering affordable dwellings. Incidentally, the Hearn Report demonstrates that, in the light of experience, the strategy- to which the District Council has been wedded for many years- is neither effective nor sustainable.)

the G L Hearn Report of January 2017 also notes at paragraph 7.31:

'Firstly, it should be noted that there are additional mechanisms for delivery of affordable housing beyond provision through planning obligations on mixed-tenure development schemes.' These include:

Building Council Homes- following reform of the HRA funding system, Councils can bring forward affordable housing themselves.

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.

Support all these criteria.

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.

40% should be a minimum with a higher percentage on large sites to meet the national need for young and old single people, young families and those retiring and wanting to downsize.

Is 40% affordable housing viable or deliverable? This amounts to 1,100 affordable housing units for the proposed Lutterworth East development.

Is 40% affordable housing viable or deliverable? This amounts to 1,100 affordable housing units for the proposed Lutterworth East development.

Thurnby and Bushby Parish Council supports as sound.

Bloor Homes fully support the provision of affordable housing as an integral part of housing development in order to meet the affordable housing needs of the District. However, the viability and deliverability of development sites cannot be compromised by over ambitious requirements to deliver affordable housing.
The Residential Options Viability Interim Report dated April 2016 by Aspinall Verdi indicates that the impact on the viability of development based on the proposed affordable housing requirement of between 30 - 40% (subject to location within District) is significant, requiring policy trade-offs between affordable housing provision and infrastructure. The cumulative impact of policy requirements within the Submission Plan will, therefore, result in the provision of affordable housing at the majority of sites being routinely negotiated on the grounds of viability, thereby considerably slowing the delivery of development. The Viability Report also highlights the effect of the proposed requirements on the viability of the SDAs. Given the reliance on SDAs to meet the full and objectively assessed needs of the District, Policy H2 is unlikely to effectively deliver the level of affordable housing required to meet identified needs with significant socio-economic consequences for the District.

The provision in Part 5 of the policy to enable the Council to consider a different level or mix of affordable housing in order to make the development viable is, therefore, welcomed by Bloor Homes. However, the NPPF is quite clear (paragraphs 158 and 173-174) that the onus is on the local authorities to demonstrate that policy requirements (cumulatively) are achievable and do not render development unviable. The viability implications of the requirements within the policy must, therefore, be considered at this stage before the targets are set to ensure the delivery of sustainable development. If a consequent reduction in the target will result in a shortfall in provision of affordable housing to meet identified needs then additional development allocations will be required to boost supply.
It is also important that affordable housing provision reflects site and location specific variables and the changing needs of the District over the plan period, both in terms of quantum and tenure. Provision must, therefore, be based upon the most up to date evidence available, including the monitoring of market activity over the plan period to identify the ability of developers to deliver affordable housing across the differing locations within the District.
In light of that, the proposed affordable housing tenure mix of 75% affordable / social rent and 25% intermediate is unduly prescriptive. The Government's proposals for Starter Homes as set out in the Housing White Paper alongside other affordable home ownership and rented tenures as a means of boosting the provision of affordable housing across the District should also be considered. This broadening of the approach to housing mix will allow for greater flexibility and will in turn assist in ensuring delivery.

Soundness:
For the reasons set out above, Bloor Homes object to Policy H2, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure affordable housing requirements are not prohibitive to the delivery of sustainable development.

Proposed Changes:
To remedy the flaws in the soundness of the plan:
- The policy should include Affordable Housing quantum and mix requirements that do not undermine the viability of schemes and delay / prevent sustainable development; and
- The policy should include sufficient flexibility to allow development to respond to site-specific constraints, evidence of need and the provision of other forms of affordable housing.

Is 40% affordable housing viable or deliverable? This amounts to 1,100 affordable housing units for the proposed Lutterworth East development.

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.

1.2. On behalf of Westleigh Partnerships Limited we are seeking to work with Harborough District Council in promoting the Land south of Grange Lane, Thurnby (Appendix 1 of attached) for residential development.

2.1. The proposed development site comprises a grassland field located south of Grange Lane, to the west of the village centre of Thurnby, as shown outlined in red in Appendix 1.

2.2. The site covers an area of approximately 1.36ha (3.36 acres) and consists of a single field of broadly flat arable land, marked by clearly defined boundaries. The site is bound by residential development on three sides; to the north by Grange Lane, to the east by Firs Farm and Court Road, and to the west by The Spinneys. The southern boundary is marked by mature hedgerow, beyond which lies open countryside. The site lies adjacent to the Thurnby and Bushby Conservation Area, as designated in 1977.

2.3. Thurnby is a compact village that benefits from a number of local services and facilities including a Primary School, a Public House, a Co-Operative Supermarket and the Church of St. Luke.

2.4. Furthermore, the village also lies within close proximity to further services and employment opportunities located in Leicester (approx. 4.9 miles), Oadby (approx. 3.3 miles), Great Glen (approx. 5.2 miles) and Billesdon (approx. 4.9 miles).

2.5. The site is considered to have good access to public transport links; the nearest bus stop is located opposite the St. Luke's Church of England Primary School, which is approximately 0.2 miles to the east of the site entrance. The bus stop is served by the Arriva 56 bus service, which runs between Leicester, Scraptoft and Thurnby from 7am - 7pm from Monday to Friday, and from 8am - 6pm on Saturdays, with buses calling at the stop every 30 minutes. The bus route provides access to Leicester Rail Station, where frequent connections are available to Birmingham, Nottingham, London St. Pancras, Sheffield and Lincoln.

2.6. We consider that the site has capacity to deliver up to 28 residential dwellings, including vehicular access, car parking, landscaping and drainage. Any development of the site could deliver a mix of dwelling types and sizes, including bungalows, terraced, semi-detached and detached dwellings ranging in size from 2 to 5 bedrooms, including a proportion of affordable housing subject to viability.

2.7. Any development scheme would be sensitively designed to protect the residential amenity of properties to the north, east and west of the site by limiting development to two storeys, where possible and providing additional planting within the site boundaries.

2.8. Therefore, we consider the site is in a sustainable location, close to a number of services and employment, and is highly accessible. It represents an opportunity to deliver a high quality development that will make a valuable contribution towards meeting the District's development needs.


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 to a wide range of employment opportunities and local services and facilities. As outlined above, Thurnby benefits from a good functional relationship with Leicester and the facilities and services available in the city. As such, we support its identification as part of the Leicester Principal Urban Area where development should support the regeneration and development objectives of Leicester City and Oadby and Wigston Borough.

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.

3.4. We support the proposed strategy for locating growth within or contiguous to the built up area of settlements, as outlined in Policy GD2: Settlement Development. We consider that the proposed development at Land South of Grange Lane is of an appropriate scale that reflects the size of Thurnby and the level of service provision. It is considered that the site is visually and physically well connected to the village and services within the village are within an appropriate walking distance. Development of the site for up to 28 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. The site is bound on three sides by residential development and as such development of the site would not impact on the separation of settlements.


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. Any development of the Land South of Grange Lane, Thurnby would be positively prepared to ensure the provision of a high quality and inclusive development. Any scheme would seek to ensure that it makes a positive contribution to the local character and respects the site's edge of settlement location.

3.6. We are strongly opposed to the allocation of our site within the proposed Thurnby/Leicester/Oadby Green Wedge, as identified by Policy GD7: Green Wedges.

3.7. We consider that the proposed development site does not perform the functions of a green wedge, as outlined above, and therefore propose its removal from the Thurnby/Leicester/Oadby Green Wedge. The primary function of the proposed green wedge is to prevent the merging of settlements. However, the proposed development site is bound on three sides by existing residential development; as such the built form of the village already encroaches on the separation of Thurnby and Leicester beyond that which is proposed by development of this site, and likewise to the south between Thurnby and Oadby. Thus, development of this site would not contribute to the merging of settlements.

3.8. Furthermore, in respect of the function of the Green Wedge to guide the development form, as stated above the site is bound on three sites by existing residential development and the current built form of the village extends further west and south than the proposed site boundaries. As such, development of the Land south of Grange Lane, Thurnby would be complimentary to the existing built form of the village.

3.9. With regards to Green Wedges providing access to the open countryside, the proposed development site is currently under private ownership and as such the site cannot be used as a local green space, nor can it currently provide access to the open countryside to the south. As such, development of the site would lead to the site being a greater asset to the community, as it would enable the local community to access Bushby Brook and the open countryside with greater ease.

3.10. Additionally, the site is not currently used for recreational purposes; the site is located in close proximity to Manor Field Park and the community scout hall, both of which are more suitable recreation locations. Therefore, it is considered that the proposed development site at Land south of Grange Lane, Thurnby does not perform the functions of a Green Wedge site and as such we proposed removal of the site from the allocated Green Wedge.

3.11. 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 previously outlined, any development scheme for Land South of Grange Lane, Thurnby would be positively prepared to ensure a high quality and inclusive development design. Any proposal would be designed to protect the residential amenity of existing properties located to the north, east and west of the site by strengthening the landscaping of the site's boundaries and limiting development height to 2 storeys.

3.12. 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 development within the Leicester PUA is to be located within a single Strategic Development Area [SDA] on land north of Scraptoft. Given the high level of infrastructure that is required to be implemented prior to the delivery of housing at large strategic developments, such as the proposed SDA, there are often substantial delays between their initial identification and the first delivery of housing. Therefore, we believe it would be beneficial for the Local Plan to identify a number of smaller housing sites that could assist in the short-term delivery of housing in the PUA. In this light, we are proposing the allocation of Land South of Grange Lane, Thurnby for residential development. The site represents a sustainable development that is suitable, available, achievable and viable and can be delivered now.

3.13. With regards to Policy H2: Affordable Housing, we support the requirement for residential development to provide a proportion of affordable housing on site. As previously stated, the clients have stated their willingness to meet this requirement, subject to the appropriate viability assessment.

3.14. 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 scheme at Land South of Grange Lane, Thurnby would deliver a mix of property types and sizes, including bungalows, terraced, semi-detached and detached dwellings ranging in size from 2 to 5 bedrooms.

3.15. 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 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 not located in an area at risk of flooding.

4.1. We consider the proposed development site at Land South of Grange Lane, Thurnby has the capacity to accommodate up to 28 dwellings with associated vehicular access, car parking, landscaping and drainage. Any development scheme could provide a mix of dwelling types and sizes and could be positively prepared to preserve and enhance the village's character and distinctiveness.

4.2. We fully support many of the objectives and policies contained within the Proposed Submission Draft of the Harborough Local Plan 2011-2031. However, to ensure that the strategy for delivering new housing is robust, we propose the allocation of the land south of Grange Lane, Thurnby for residential development. We are concerned that the Draft Local Plan proposes to locate all new development in the Leicester PUA within a single Strategic Development Area. Given the level of infrastructure provision required at developments of this scale, there can often be substantial delays between their initial identification and the first delivery of housing. As such, we believe in would be beneficial for the plan to identify a number of smaller sites, such as Grange Lane, Thurnby, which can come forward in the short-term to assist in the immediate need for housing delivery in the PUA.
4.3. In this light, we are strongly opposed to the identification of our site as part of the Thurnby/Leicester/Oadby Green Wedge. We consider that the proposed development site does not perform the function of a Green Wedge that are clearly set out within Policy GD7 of the Draft Local Plan.

4.4. We consider that the site represents an opportunity to deliver a sustainable, available, achievable and viable source of housing 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.

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.

Policy H2 - Affordable Housing sets out that a 40% affordable housing will be required on housing sites of more than 10 dwellings, or with a combined gross floorspace of more than 1,000 square metres, or of more than 0.5 hectares. Policy H2 notes that where on-site provision is demonstrated to be impractical, off-site commuted sums of an equivalent value will be made in lieu of on-site provision.

A Local Plan Viability - Residential Options Viability Interim Report was published in April 2016. This report established that viability varies between 30-40%. Whilst our clients support the mechanism for providing affordable housing and the potential for off-site commuted sums where necessary, we consider that a policy requirement which better reflects the stated viability range of 30-40% as per the evidence base may be more suitable.

The proposed affordable housing tenure mix is described as 75% affordable/social rent and 25% intermediate housing. We consider this to be unnecessarily prescriptive. This policy should be reworded to reflect greater flexibility so as not to unduly preclude delivery. We note with interest the Government's proposals for Starter Homes as set out in the Housing White Paper. This indicated that the delivery of starter homes may be considered as part of a mixed package of affordable housing, alongside proposed affordable ownership and tenure splits. Wording which better reflects this emerging position would ensure greater appropriateness and soundness of this policy.

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.