CC1 clause 1a

Despite the proposed Policy being in line with the central Government's overall objectives for mitigating against climate change, there has been no evidence to show the Policy has been subject to the required viability tests, in accordance with paragraph 173 of the NPPF. Therefore, these can be considered unsound.

Bloor Homes broadly support the aspiration of this policy. However, the policy must be sufficiently flexible to allow for location and context-specific considerations to be taken into account in the delivery of development. For instance, it might not be feasible or viable for specific mitigation measures, such as renewable energy, to be incorporated into a specific development scheme.

Bloor Homes has adopted a holistic fabric first approach in their house type design as an alternative to renewable energy infrastructure, which seeks to reduce each dwelling's inherent energy demand. The approach also includes the installation of water saving appliances to aid water efficiency, highly efficient gas condensing boilers to reduce fuel costs, and gas savers and waste water heat recovery systems to reduce carbon emissions. This fabric first approach has a number of clear benefits, notably that it is built into the property for its whole life and achieves the aim of reducing CO2 emissions. In comparison to renewable technologies there is no maintenance required, and it avoids the concern as to whether the technologies are actually being used.

Part 1 of the policy should, therefore, allow greater flexibility by including reference to the potential inclusion of alternative measures to mitigate climate change. As with Part 2 of Policy CC1 in relation to SDAs, reference should also be made within Part 1 to the associated impact on the viability of development in demonstrating what measures can be incorporated into a scheme.

Soundness:
Bloor Homes object to Policy CC1, which is considered unsound on the basis that it:
- is not effective as a means of ensuring development mitigates climate change without unduly restricting the viability and/or delivery of development.

Proposed Changes:
To remedy the flaws in the soundness of the plan the policy should be reworded include reference to "alternative measures, such as a fabric first approach, as appropriate to the site and demonstrated by the developer to meet overarching climate targets".

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.

Harborough Local Plan 2011-2031: Proposed Submission Representation
17 November 2017


1. Gazeley UK Ltd are the developer of Magna Park - Harborough District's single largest employer and the focus of Policy BE2 in the Proposed Submission Local Plan (PSLP). Gazeley are also the applicant for an extension to Magna Park to provide a further 419,800 sq m of strategic distribution floorspace together with a range of ancillary uses, including an Innovation Centre, Logistics Institute of Technology and Railfreight Shuttle and Terminal. The ancillary uses are aimed both at creating the efficiencies of the logistics cluster that Magna Park stands to become and at capturing the benefits that would follow for the industry, its employees, local communities and the environment. Almost uniquely in the sector, Magna Park is proactively managed by Gazeley. That fact, coupled with the concentration at Magna Park of blue chip logistics businesses, generates the opportunities that Gazeley's extension proposals would realise.

2. Gazeley welcome and support Harborough's PSLP. The PSLP provides a welcome strategic platform for achieving the ambitions for Magna Park, and in particular for ensuring that Harborough's economy, communities and environment gain accordingly.

3. This representation sets out the basis for Gazeley's support for the PSLP, together with suggested amendments to Policies GD3, HE1 and BE2.2. The change to GD3 is needed to make it consistent with BE2.2; the change to HE1 is needed to bring the policy into line with NPPF 132-135; and the changes to BE2 are suggested to strengthen the policy's expectation that large scale distribution development around Magna Park should create a valuable logistics industry cluster that will benefit local communities as well as the economy and in all other ways constitute sustainable development as defined by NPPF 15-149.

The PSLP policies Gazeley particularly welcome

4. Gazeley particularly welcome the following policies for the reasons explained.

* SS1 The Spatial Strategy and the accompanying written statement, because of:

i. the recognition of the significant role the district plays in the strategic distribution sector because of its competitive advantages (strategic infrastructure, land, labour and cluster efficiencies)

ii. the recognition of Magna Park's role in the significance of the sector for the district, county and region

iii. the recognition that with more employment in the district, there is a chance that out- commuting for work could reduce (no chance otherwise) - and in that context note the wide range of occupations in strategic distribution and the sector's a good match with the district's skill set;

iv. the consistency with the Strategic Economic Plan for the Leicester and Leicestershire Local Enterprise Partnership (LLEP) and with the Midlands Engine for Growth strategy;

v. the use made of the extensive evidence base commissioned by LLEP, the Leicestershire authorities and HDC on the strategic distribution sector; and

vi. the acknowledgement that the evidence is a projected need for a minimum quantum of 608,000 sq m in the county to 2031, provided in market-facing locations, offering development plots of a scale and with the flexibility required to meet the increasing size needs of the sector, with sequential approach to site selection starting with a first preference for extensions to existing sites.

* CC1 - Mitigating Climate Change, because of the obligations CC1 places on major developments to provide and use renewable energy, minimise resource consumption and reduce carbon emissions.

Policy not sound as drafted: Policy GD3 Development in the Countryside

5. Policy GD3 is not sound as drafted, but solely because it fails to account for Policy BE2.2, the delivery of which will require development in the countryside for a use which Policy GD3 precludes.

6. Policy BE2.2 is not accompanied by a site allocation, but requires the development of land in the countryside to deliver the up to 700,000 sq m of strategic distribution floorspace that BE2.2 locates next to Magna Park. Therefore, as drafted, GD3 is neither positively prepared nor effective.

7. To make GD3 sound, we suggest simply adding a new criterion 'j.' to refer to BE2.2, and to renumber the remaining criteria in GD3 as follows: criterion j., and renumber the remaining criteria as follows:

8. Should a site or sites ultimately be allocated for Policy BE2.2, then the change to Policy GD3 would clearly not be necessary.

Policy BE2 Strategic Distribution: sound but would benefit from setting a higher bar for what would constitute sustainable development

9. Gazeley welcome policy BE2 and its criteria-based approach, and in particular the recognition of the particular merits of the Magna Park location in meeting the needs of a growing and dynamic logistics sector for which Harborough has compelling competitive advantages.

10. Nonetheless - and with regard to the sheer scale of development that is promoted by BE2, the concentration of an additional 700,000 sq m of strategic distribution space on land that extends or adjoins Magna Park and the concerns of local communities (voiced since the first planning permissions were granted for Magna Park) - Gazeley take the view that the policy is less ambitious than it should be. Magna Park itself is already unique: its existing size (some 772,000 sq m of large B8 units); its occupation solely by blue chip companies; its dominance by national distribution centres; and the high share of the site given to landscape, habitat and woodland (Gazeley planted over a million trees to create the publicly accessible Magna Wood). Magna Park is also in the open countryside but close not just to the strategic highway network but to a small town and many smaller rural villages. These factors, together with the prospect of a further 700,000 sq m of large B8 units, combine to present a singular opportunity for Harborough - not just to meet the floorspace needs of the logistics sector in an optimal location, but in doing so also to optimise the economic efficiencies for the competitive growth of the industry by promoting Magna Park as the centre of a logistics cluster and, at the same time, setting a new bar for socially responsible and environmentally sustainable logistics development.

11. The key challenges to the logistics industry's competitive growth are, alongside securing an adequate supply of optimally located land, its image, the availability of suitably skilled and qualified labour, and its environmental footprint. These are all closely related: the ability of the industry to grow productively as well as sustainably is fundamentally dependent on attracting and providing people with the skills needed to drive up innovation in the sector, reduce the costs of the supply chain, improve its value to end users and minimise its environmental effects. The sector's ability to do this is, in turn, fundamental to the performance of UK plc, including environmentally.

12. These considerations create the opportunity for policy BE2 to drive and support the singular opportunity to build on the standing and scale of the existing Magna Park and to both drive and capture the benefits of the logistics cluster that BE2 is capable of creating. A cluster is a group of similar and related firms in a defined geographic area that shares common markets, technologies, worker skill needs, and which are linked by buyer-seller relationships. Clusters are drivers of economic efficiencies, innovation and productivity resulting from competition and inter- trading between firms and the further efficiencies entailed in resources, factor inputs, labour skills and markets.

13. The logistics industry has particular features of its operation that makes it particularly well-placed to secure the economic benefits of clustering. One feature of this is pure geography. There are a limited number of optimal locations with supporting infrastructure from which logistics operators can most efficiently fulfil demand. Magna Park is one. But there are also particular operational advantages for logistics from cluster activity. Moving between large centres of freight activity rather than highly dispersed centres lowers transportation costs and almost certainly creates greater reliability as well. In any competitive cluster environment these costs savings get passed on to the logistics operator's customers and hence lower costs across the economy as a whole.

14. Logistics clusters also tend to encourage value-added activities such as product differentiation, repair and servicing - and increasingly, amongst the more innovative, also various forms of 'trialling' of new systems of supply change management and other forms of R&D and its application. Long and complex manufacturing supply chains, for example, mean that firms often have to respond quickly to changing technologies, fashions and consumer tastes to stay relevant to the market. The closer and later this can be done to point of delivery to market, the greater the competitive edge for the selling firm. Logistics clusters provide the ideal base to perform such value added functions. Thus the notion, particularly in the Golden Triangle, that the National Distribution Centres that tend to dominate the occupier base, 'only' do stock-holding and distribution is incorrect, and increasingly so.

15. The other merit of the scale of development promoted by BE2 is the cost savings achievable in the development process itself. For example, shared infrastructure means the costs of providing it are lower per unit of occupation. The margins achieved can be diverted to less commercial, but nonetheless needed and valued services to the cluster are greater. Gazeley, for example, is capturing those margins to promote, as part of its application to extend Magna Park:

* a Logistics Institute of Technology (LIT) in partnership with Aston University and North Warwickshire and South Leicestershire to address the industry's rising needs for more skilled, better qualified labour and for the kinds of applied research innovations needed to continue to drive the industry's sustainable, competitive, growth;

* an 'innovation centre' to supply easy-in, easy-out small business space to encourage new firms to start up and grow on the back of the out-sourcing opportunities the Park provides and the output of the applied research functions;

* a Driver Training Centre to address the shortage of skilled and professional HGV drivers;

* a railfreight shuttle - using low or no carbon fuelled traction units - to provide and 'on- demand' service to nearby DIRFT and on-site container storage, to overcome these hurdles to the take-up of railfreight by Magna Park's largely road-based distribution firms;

* an HGV park, fuelling station and vehicle wash;

* a 70 ha country park and meadow supported by public car parks, public lavatories and shared use of the innovation centre's café - targeted on local communities but also occupiers' employees;

* the dual use of the LIT's campus facilities, including playing fields, with the community and again with Magna Park employees;

* a Local Heritage Centre to exhibit and explain the history of the site's habitation in its landscape and the economic forces that have shaped both, with focuses that include parts of the Key Stages 1 (heritage) and 2 (climate change) curriculum; and

* the re-use of a non-designated heritage asset on the site as a conferencing centre and marketing suite.

16. The value that the logistics cluster is able to return to the economy, environment and local communities is very significantly increased by the addition of these complementary uses. Yet the market - in the absence of the kinds of margins that large scale schemes create - could not and would not be able to deliver these wider uses. Though these uses deliver public benefits in line with policy, constraints on the public finances make it unlikely that funding for such uses will be forthcoming for the foreseeable future.

17. Their delivery at Magna Park is made possible for Gazeley by the sheer scale of the extension scheme, the existing concentration at Magna Park of blue chip logistics businesses to provide an initial customer base for these complementary uses and by Gazeley's proactive engagement with partner bodies for their delivery. The commercial return for Gazeley is achieved by the competitive advantages gained from attracting the industry's best and most socially responsible occupiers.

18. Finally - and again in recognition of how firmly Magna Park is already embedded in the community which hosts it - Gazeley convene and chair a 'Community Liaison Group' which meets quarterly to listen and respond to the concerns of local parish councils and residents groups, operates a community fund of £20,000 per year which awards project funds on a competitive basis to local schools, community groups and charities and hosts annually a family fun day at Magna Park open to the wider community as well as the Park's employees.

19. With all of this in mind, Gazeley suggest the amendments and additions to policy BE2 that are set out below. We also request that a site allocation(s) be made (which if done would obviate the change requested to policy GD3). The certainty of a site allocation(s) would, in Gazeley's view, greatly assist the industry and local communities.

20. The amendments proposed to policy BE2.1 acknowledge the cluster benefits of the concentrating logistics businesses around Magna Park and the consequences for the growth of related but ancillary activities that support or are spun out of the cluster; and the amendments to BE2.2 aim to take advantage of the scale of the development(s) to benefit the community and local environment as well as the wider economy. While it is appreciated that additional criteria are covered by development management policies in other parts of the Proposed Submission Local Plan, these are generic. The scale and nature of the BE2 development and its concentration at Magna Park merits in Gazeley's view a more specific set of criteria.
BE2.1 As drafted)

BE2.1a (As drafted)

BE2.1b. any new building or the change of use of an existing building is only for Class B8, ancillary uses to Class B8 only, or for a use for which a location as part of the Magna Park logistics cluster is necessary and beneficial

BE2.1c. the proposal for any non-strategic storage and distribution use is small-scale, proportionate in scale and function to Magna Park's strategic storage and distribution use and ancillary to the use of individual plots

BE2.2 Additional development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted where it would:
BE2.2a form an extension of, or be on a site adjoining, Magna Park;
BE2.2b support or at least have no adverse impact on the viability and deliverability of existing or further Strategic Rail Freight Interchanges (SFRIs) within or serving neighbouring authorities and Leicestershire;
BE2.2c increase employment opportunities for local residents, including training and apprenticeships;
BE2.2d include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District;
BE2.2e not lead to severe traffic congestion anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside; and
BE2.2f ensure 24 hour operations do not have an unacceptable environmental, community or landscape impact
BE2.2e: mitigate significant adverse impacts on the not lead to severe traffic congestion anywhere on the nearby strategic and local road network to achieve nil detriment or better particularly the A5, whether within Harborough District or outside;
BE2.2f include measures to encourage car-sharing, cycling and sustainable alternatives to private car use;
BE2.2g include measures for regular community liaison;
BE2.2h include measures for publicly accessible green infrastructure;
BE2.2i optimise the bio-diversity of the site and its capacity to sequester greenhouse gases;
BE2.2j make use of optimal technologies for the construction of buildings and their operation to reduce resource consumption and optimise the use of renewable energy sources;
BE2.2k achieve the highest practicable environmental standards for buildings;
BE2.2l adopt a design approach to the buildings, materials and lighting to minimise the visibility of the buildings during the day and at night time;





BE2.2m site buildings and service infrastructure to respect the character of the landscape;
BE2.2n site gatehouses, yards and HGV circulation routes so that visual intrusion and noise beyond the site is minimised; and
BE2.2o mitigate landscape and visual impacts using, in particular, tree planting and other species that will optimise carbon sequestration.

Local plan consultation response.

10.1.3 New built development should be designed to reduce carbon emissions as close to zero as practicable. Design and Access Statements accompanying planning applications for major developments should identify cost effective approaches to low carbon development, which will be guided by the energy hierarchy. This requires that the design of any development should consider use of the following energy options in priority order:
* passive design considered first as a means to reduce emissions,
* then the energy efficient design of building services, including decentralised energy networks,
* and finally, including renewable energy at building or site level.

Commercial volume developers will always engineer a way in which they can deliver housing at the maximum profitability to themselves. With the Council having been barred in law, by the deregulation bill, from specifying higher building specifications they should instead develop a robust model by which to appraise developer viability assessments to ensure that they do not over inflate their costs in order to escape their moral responsibilities.
With the potential for rules regarding Councils building/commissioning housing there should be a provision to ensure the Council will always develop to the highest thermal standards to BRE's Home Quality Mark sustainability standard: http://www.homequalitymark.com

There should be a provision for all new builds to produce at least 15% of their energy requirements onsite. Commercial developments should require a 40% BER improvement, this means that they will probably have to incorporate one or a combination of the following:
a) highly insulated building fabric
b) photovoltaic arrays
c) a CHP unit or connection to an existing District Heat Network

Local authorities can require commercial refurbishments to meet BREEAM Refurbishment and Fit-Out standards, as a minimum BREEAM 'Very Good' is recommended: http://www.breeam.com/refurbishment-and-fit-out

The following sustainability requirements are recommended for inclusion in Local Plans: Considerate Constructors Scheme registration, cycle storage standards, minimum daylighting standards, ecological mitigation and enhancement, environmental impact of materials, external lighting (low energy), flood risk assessments (FRA) and site waste management plans (SWMP).

The above requirements can be implemented through a Sustainability Checklist. Applicants would be required to must submit a completed sustainability checklist when a planning application is made. Richmond Upon Thames Council has successfully operated such a checklist for a number years (London Borough of Richmond Upon Thames (2016) Sustainable Construction Checklist. Available at: http://www.richmond.gov.uk/scc_spd_guidance_0116.pdf).

The majority of the homes in Harborough District are of a low thermal performance and their improvement will perhaps make the biggest contribution. For refurbishment planning applications, the BREEAM for Domestic Refurbishment standard can be applied if included in the Local Plan or associated guidance. As a minimum it is recommended that housing undergoing refurbishment achieves a BREEAM 'Very Good' rating: http://www.breeam.com/index.jsp?id=1182 and the Passive Haus Enerphit standard introduced to householders as an option.
Can a provision be made within Council tax banding to support higher standard buildings?

10.3.3 The Planning for Climate Change: Renewable Energy Opportunities study, May 2008 found that wind turbines, biomass plants (including combined heat and power), solar thermal heating, photovoltaic energy, and energy from waste all have a potential to be utilised and developed within the District. The assessment identified wind energy as a noteworthy source of potential renewable energy generation for the District.
This definition should exclude incineration and Energy from waste solutions. These are not only detrimental to the health of the local population through the emissions of dioxins they also have the legacy of toxic fly ash that needs to be land filled as well as creating a need for large volumes of rubbish which diverts potential waste streams from the local recycling industry.

10.3.6 Community owned energy is an important means of engaging communities with their own energy generation. Community owned energy projects are encouraged within the District. A local community energy company has been set up as part of the Sustainable Harborough Challenge, called Harborough Energy, specifically to enable community owned renewable energy projects. The first two solar projects were commissioned in 2016.
There was some confusion at the beginning of this project, it was called simply "Sustainable Harborough"

11 Infrastructure IN1 Infrastructure provision
1. Major development will be permitted where there is, or will be when needed, sufficient infrastructure capacity to support and meet all the requirements arising from it, including those away from the site and its immediate vicinity, whether within Harborough District or outside.
2. Direct provision and/or financial contributions towards meeting all the eligible costs of infrastructure directly required by a major development (or cumulatively with other major developments within Harborough District or outside) will be sought from the scheme promoter whenever this is necessary. Planning obligations under Section 106 of the Town and Country Planning Act 1990 (as amended) will be required taking into account the viability of the development. This will be in addition to the affordable housing requirement as set out in Policy H2.

Is there a mechanism included to gather contributions from developers who phase their developments in such a way as to avoid developer contributions but cumulatively place a great burden on the local facilities.

11.3.5 The Council is anxious to ensure that both the occupiers and users of new development, and those elsewhere who may be affected by it indirectly, will not be subjected to below acceptable standards of air quality. Therefore, in controlling the potential impact of development upon air quality, the Council will require an effective air pollution mitigation strategy if a development proposal would be likely to either:
* have a moderate adverse, or worse, impact upon air quality within an existing Air Quality Management Area (AQMA) whether the proposal is inside or outside of that AQMA; or
* contribute directly or indirectly to the declaration of another AQMA be it in this district or an adjoining one.

This clause can only be met if monitoring of the local area has been undertaken for 1 year to establish a baseline. For instance, HDC only has a single monitoring point in the settlement of Harborough. Who knows what affects development will have around the town without a baseline.
Developers should be made to provide the council with the funding to gather this information and the viability assessments should include a worst case provision for mitigation should it be needed.