H2 clause 2

Part 2 of the policy seeks a tenure split of about 75% social rented and about 25% low cost home ownership products or a variation of the two, to be justified by reference to the latest assessment of affordable housing need. 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. However, the principle of broadening the scope of intermediate housing to incorporate "low cost home ownership products" is supported as it includes a broader range of products.

A flexible approach to the type of affordable housing that could be provided could ensure that the Council's percentage policy requirement is met in scenarios where there might otherwise be a viability issue and would help increase the choice of products available to those in housing need. This would accord with the HEDNA, which states that "in applying [tenure mix requirements] to individual development sites regard should be had to the nature of the development site and character of the area, and to up-to-date evidence of need as well as the existing mix and turnover of properties at the local level" (paragraph 12.49).

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.

Refer to attached document.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.

We have previously responded to the early draft policies consultation on the Local Plan in 2016. We have not included the Affordable Housing Statement appended to that consultation response, but it is important to state that rent to buy homes, as delivered by Rentplus, are an important component in responding to local housing needs and in meeting aspirations for home ownership, in partnership with local planning authorities and Registered Providers. Details of completed and forthcoming schemes can be viewed on the Rentplus website www.rentplus-uk.com.

The flexibility of this policy sets out in terms of tenure split is very positive, and should enable developers such as Rentplus to bring forward appropriate housing proposals that respond to local needs. The policy should allow for the full range of affordable housing tenures and models, including rent to buy which has been highlighted for some time in a raft of Government consultations as one part of the solution to the affordable housing crisis. This most recently included the Government's Housing White Paper (2017) which sets out the proposed changes to the NPPF to update the definition of affordable housing.
A wide range of circumstances mean that many households cannot save for a mortgage deposit, and being homed in a current affordable house or private rented sector accommodation no longer meets their needs or aspirations. The Government's proposals, and specifically the rent to buy model that Rentplus delivers aims to 'plug the gap' created by this problem. The rent to buy homes are allocated as with other affordable housing tenures through the local choice based lettings scheme and targeted lettings plans. The Rentplus model provides homes at an affordable rent for those expected to purchase in 5, 10, 15 or 20 years with a 10% gifted deposit to assist purchase.

The reference in the policy to 'low cost home ownership' is preferable to 'intermediate' but should be amended to 'affordable home ownership' to more fully reflect the current and proposed definition of affordable housing as set out in the NPPF. This terms will more effectively allow developments to include the full range of affordable home ownership options, including rent to buy, which assists a great number of families into housing that enables them to save to purchase their home.
As the Government's housing policy is anticipated to change in early 2018 it is important for the council to adapt its policies to remain effective through flexibility and responsiveness to local and national change, to ensure it can be found sound.

The delivery of rent to buy housing reduces the pressure on other affordable housing, freeing up social rented and affordable rented housing for those with greater priority needs - one recently occupied Rentplus scheme was 30% filed by households previously living in social and affordable rented properties, releasing those homes for families in need. Residents have been delighted to finally access housing that not only meets the basic need for a good quality house but also their aspiration to own their own home - one Rentplus family has said:
"Our dream has long been to own our own home but with the high costs of renting combined with the need to save thousands of pounds for a deposit it's never been in reach for us. This model is ideal for our needs as we have the certainty of living in the home which we will one day own and the reduction in rent is making a huge difference to our lives."

To ensure Policy H2 can be found sound at examination we recommend that the policy include the above recommended change to the terminology on affordable home ownership options, and to include further reference within the supporting text to the full range of these. This may directly reference rent to buy, starter homes and build to rent to provide clarity as the Government has provided clear indication that these tenures are to be formally defined in the next iteration of the NPPF.

Without this we consider the policy will quickly become outdated and inconsistent with national planning policy, and ineffective in encouraging sufficient development diversity to meet local housing needs.

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.