H5 clause 2

Part 2 of this Policy refers to development providing a mix of housing types, which is informed by up-to-date evidence of housing need. William Davis Ltd object to the wording of this policy as need is not the only consideration that should be taken into account when assessing any given site. The NPPF notes at paragraph 50 that in addition to future demographic trends and market trends, the size, type tenure and range of housing that is required in particular locations should also reflect local demand. As it stands, therefore the Policy is inconsistent with national policy and is unsound. The demand and character of any area within a district varies greatly, which will play a major role in determining what housing mix is appropriate. This Policy should therefore be altered to enable adaptability and flexibility in response to local market demand and the character of the area.

1.4. This submission supports the proposed allocations of Land at Northampton Road, Market Harborough for employment and residential uses as identified on the Proposals Plan.

2.1. We have made Harborough District Council aware of the site's availability for development through various submissions, including the 'Call for Sites' as part of the Strategic Housing Land Availability Assessment.

2.2. The SHLAA 2016 identified the site as being suitable and deliverable over 6-15 years.

2.3. The proposed development site has partially been previously allocated for employment land uses. Saved Policy MH5 of the Harborough District Local Plan 2001 allocated 11.2 ha of Land East of Northampton Road (now known as Compass Point) for B1, B2 and B8 uses. The proposed allocation in Policy MH6 of the Draft Local Plan 2011-2031 broadly relates to this allocation, but excludes the area already development and land allocation for residential development in Policy MH2.

3.1. The proposed development site has a total site area of approximately 18.69 ha (46.2 acres) and is located on the southern edge of Market Harborough, east of Northampton Road, as shown outlined in red in Appendix 1.

3.2. The site comprises of three separate agricultural fields with clearly defined boundaries marked by mature hedgerow. The site is bordered to the north and east by the Brampton Valley Way, to the west by existing development at the Compass Point Business Park and ongoing residential development and to the south by open countryside.

3.3. The site is located in close proximity to a number of services and facilities located in Market Harborough town centre (Sub-Regional Centre). Services include GP Surgeries, St. Luke's Hospital, Dentists, a Library and a Museum, a Theatre, Post Offices, Food Stores, Primary Schools, Welland Park Middle School, Robert Smyth Academy, and a number of public houses and local businesses.

3.4. Furthermore, the town is well served in respect of public transport links including a railway station which provides connections to London St. Pancras, Leicester and Nottingham. There is a regular local bus service (No. 44) which serves the surrounding local villages to bring people into Market Harborough. There are also bus services to Leicester (X3/X7), Northampton (X7), Kettering (X17/18) and Lutterworth (58), which operate on an hourly basis.

3.5. We consider that the site has the capacity to accommodate a mix of residential and employment land uses, as follows:

3.5.1. It is considered that the allocated residential development site (Land East of Blackberry Grange), identified in red on the Proposals Plan could facilitate the development of approximately 350 dwellings, including associated vehicular access, pedestrian links, public open space, car parking, landscaping and drainage. Any proposed development scheme would provide a range of property types and sizes, including a proportion of affordable housing, subject to viability assessment.

3.5.2. The site also has the capacity to accommodate approximately 2.3 ha of employment land, which could provide floor space for Use Class B1 facilities, associated parking, servicing and landscaping to complement to existing Class B employment land uses at the Compass Point Business Park.

3.5.3. Any development of the site could be sensitively designed to protect the residential amenity of the neighbouring residents to the west of the site through the retention and enhancement of existing boundary vegetation. Furthermore, any development scheme would be comprehensively designed with consideration given to balancing the demands of the proposed residential development in comparison to the existing and proposed employment land uses; to ensure that all land users enjoy an appropriate level of amenity.

3.6. Therefore, we consider the site to be in a sustainable location, close to a wide range of services and facilities, and highly accessible. It provides a good opportunity to make a valuable contribution towards meeting the Borough's development needs.

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

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

4.3. In respect of Policy GD1: Achieving Sustainable Development, we strongly support the inclusion of the Policy in the Draft 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. 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 scheme at Land at Northampton Road would be underpinned by the findings of a comprehensive Landscape and Visual Impact Assessment which would identify key viewpoints of and within the site. In addition, any design would be positively prepared to ensure that it provides a high quality and inclusive design that maintains a sense of place and reflects the distinctiveness of the town.

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 at Northampton Road, Market Harborough would be positively prepared to ensure a high quality and inclusive development design. Any scheme would be sensitively designed to protect the residential amenity of the neighbouring residents to the west of the site through the retention and enhancement of the existing boundary vegetation. Furthermore, any development scheme would be comprehensively designed with significant regard given to ensuring the demands of the proposed residential development are balance with the requirements of existing and
proposed employment land uses; to ensure that all land users experience an appropriate level of amenity.

4.6. 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. In addition, we fully support the allocation of our land at Northampton Road, Market Harborough for residential development up around 350 dwellings as set out by Part 2(b) of the Draft Policy. As previously stated, we consider the site has the capacity to deliver approximately 350 dwellings with associated vehicular access, pedestrian links, public open space, car parking, landscaping and drainage.

4.7. In this light, we fully support the allocation of our land at Northampton Road, Market Harborough for residential development as outlined in Policy MH2: East of Blackberry Grange. As outlined above, we consider the site has the capacity to deliver approximately 350 dwellings with associated vehicular access, pedestrian links, public open space, car parking, landscaping and drainage.

4.8. In respect of the criteria for development outlined within the policy, any development of the site could be comprehensively designed using masterplanning to give consideration to the balanced demands of the proposed residential allocation in comparison to the existing and proposed employment land uses; to ensure that all land users benefit from an appropriate level of amenity. This could include the provision of open space and recreational facilities across the site, including the western boundary shared with the existing and proposed employment use. Furthermore, any development scheme would be underpinned by the results of a Landscape and Visual Impact Assessment which would identify the key views of and within the site, to ensure that the proposed masterplan is sensitive to the site's location adjacent to the Brampton Valley Way.

4.9. Furthermore, it is considered likely that any application for development on the site would be supported by a wide range of technical reports, and that the findings would contribute the proposed masterplan. These reports would include a Phase 1 Ground Investigation, an Archaeological Desk Based Assessment, and a Preliminary Ecological Appraisal and Protected Species Surveys. In addition to these reports, the application would be supported by a comprehensive Flood Risk Assessment and Drainage Strategy which would outline a surface water and foul water drainage strategy to ensure that the site is not at risk of flooding and does not increase the risk of flooding elsewhere.

4.10. 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, our clients have stated their willingness to meet this requirement, subject to the appropriate viability assessment.

4.11. We fully support the objectives of Policy H5: Housing Density, Mix and Standards and the requirement for new development schemes to deliver a range of housing types and sizes. Any development of Land at Northampton Road, Market Harborough 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.

4.12. In respect of Policy BE1: Provision of New Business Development, we fully support the recognition that the development requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy enables. We fully support the allocation of land at Compass Point Business Park, Northampton Road for the development of 5ha of employment land use. As previously outlined, we consider that our clients land at Northampton Road has the capacity to accommodate 2.3ha of 5h allocation for employment land; the site could provide floor space for Use Class B1 facilities, associated parking, servicing and landscaping to complement the existing Class B land uses at the Business Park.

4.13. In this light, we fully support the allocation of our land at Northampton Road, Market Harborough for Use B1 employment development, as identified by Policy MH6: Compass Point Business Park. As previously stated, we consider that our client's land at Northampton Road has the capacity to provide approximately 2.3 ha of employment land, towards the total 6ha allocation. This land could be used to provide floor space for Use Class B1 facilities, associated parking, servicing and landscaping to complement the existing employment land uses located at the Compass Point Business Park.

4.14. In respect of the site specific criteria for development outlined within the policy, as previously outlined, any development for the site could be comprehensively designed using masterplans to ensure consideration is given to the balancing demands of the proposed and existing employment land uses in comparison to the proposed residential allocation; to ensure that all land uses experience an appropriate level of amenity. For example, this could include the provision of a landscape buffer along the northern boundary of the site, adjacent to the existing residential development and between the proposed employment and residential allocations. Furthermore, any development scheme would seek to ensure it provides a high quality and inclusive design that is in keeping with the scale, character and appearance of the existing Compass Point Business Park.

4.15. In addition, it is considered likely that any application for development at Land at Northampton Road would be underpinned by a wide range of technical reports and that the findings of these reports would contribute to the proposed masterplan. These reports would include a Phase 1 Ground Investigation, an Archaeological Desk Based Assessment, and a Preliminary Ecological Appraisal and Protected Species Surveys. In addition, the application would be supported by a Flood Risk Assessment and Drainage Strategy which would outline an appropriate surface water and foul water drainage strategy to ensure that the site is not at risk of flooding and does not increase the risk of flooding elsewhere.

4.16. 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 with the exception a small watercourse that serves as a tributary to the River Jordan. Any development scheme at the
site would be underpinned by a comprehensive Flood Risk Assessment and Drainage
Strategy which would ensure the development is not at risk of flooding and would not increase the risk of flooding elsewhere.

4.17. Finally, with regards to 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 of the NPPF. As previously outlined, 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.

5.1. We consider the proposed development site at Land at Northampton Road, Market Harborough has the capacity to accommodate approximately 350 dwellings, including associated vehicular access, pedestrian links, public open space, car parking, landscaping and drainage. Any development scheme could be designed to provide a range of dwelling types and sizes, including a proportion of affordable housing subject to viability. The site also has the capacity to accommodate approximately 2.3 ha of employment land, which could provide for space for Use Class B1 facilities, associated parking, servicing and landscaping to complement the existing employment uses at Compass Point Business Park.

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 allocation of Land at Northampton Road for the development of around 350 dwellings as part of Policy H1 and for 5ha of employment land as part of Policy BE1.

5.3. We consider that the potential constraints of this site can be positively addressed and considered throughout the design process; for example any development scheme could be comprehensively designed to ensure that the demands of the proposed residential allocation in comparison to the existing and proposed employment land uses are appropriately balanced, to ensure that all land users benefit from an appropriate level of amenity.

5.4. The represents a suitable, available, achievable and viable source of housing land which can deliver a range of real and desired public benefits, now.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

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.