H6 2c.

Showing comments and forms 1 to 5 of 5

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 6659

Received: 31/10/2017

Respondent: Cllr Rosita Page

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Provision at Bonham's Lane is not required and the special status of the site should be recognised.

Full text:

I consider the plan not sound and not compliant because;
Access to consultation form was made difficult, it disadvantaged ordinary residents to put forward a view.
Public advertising of the consultation in the local media was very limited.
Access to information for members to make educated decisions was limited , a lot of information was presented via verbal briefings only , some information was deemed as confidential and not provided.
Visions and objectives are good but empty rhetoric, not backed up with strong enough policies to achieve these goals.
The plan appears to focus mainly on the provision of housing rather than placing an additional focus on providing variety and access on suitable housing that will meet the needs and the diversity of residents.
The Harborough District has an above national average of an aging population and a larger focus should have reflected the needs of these residents by ensuring policies advocate more bungalows.
Provision of Extra Care and Specialist Accommodation is not deliverable .Targets are too high and policies remits are confusing.
There are mistakes and discrepancies in supporting information.
Some supporting information was not taken into consideration.
There is no guidance where to find relevant information and what has been superseded by what. The process is messy and confusing.
The Sensitivity Study was commissioned to confirm housing needs alongside employment /logistic options .These were supposed to be allocated across the HMA not just Harborough District.
The Sensitivity Study is not of merit to determine the amount of logistic provision therefore rendering policy BE2 not sound

Comments relating to the following (sections / policies) :

1.2 The Option Consultation: secured an overwhelming public response .The public objected to a major expansion of Magna Park .The Sustainability Appraisal Interim Report 2015 and 2016 rejected an Option of 700 000sqm which echoed demand not need for 3 planning permissions submitted .Officers stated the conclusion of the SAIR would not be affected in the future and Planning officers concurred by stating that approving all 3 application submitted would not be sustainable.
However without evidencing any proper process this evidence was overruled.

1.5 The Duty to Co‐operate: was not fully adhered to by consulting all neighbouring LA's in any of the early stages .There are only notes of DtoC meetings from
May and July 2017. These minutes state foregone conclusions without having followed proper democratic process.

1.7 Supplementary Planning Documents: As well as other evidence has not been readily available throughout the process and parishes and other stakeholder have not been given the timeframe to consider background information. It is not clear what is valid, some reports are superseded, reports are not all in one place and the evidence base is confusing.

2.1 Local Plan Vision and 2.3 Objectives: The vision and objectives are lordable but the policies with in the LP do not reflect the desired aims to achieve these objectives.
To secure a wide range of skilled jobs for an highly educated population has always been a supported council policy.
The objective, stopping young people from leaving the district is not served by focusing mainly on providing unskilled, temporary, low paid jobs in the logistic industry.
A focus on sustainable , diverse and vibrant job market is not possible without creating the opportunities.
Reducing impact of traffic on local communities in Objective 10 is not a deliverable policy in line with the proposal of policy BE2 either and Objective 7 to protect the historic environment is also compromised by policy BE2 . The protection of heritage is highly supported by the NPPF and featured in the draft Growth Plan but the policy is not strong enough . The objectives and policies are contradicting themselves in places .

3.1.2 to 3.14
Recognises a fair geographical spread , long term strategic growth by providing a diverse , fair , economic strategy across the region and Leicestershire placing resources where there is need and higher unemployment Policy BE2 in this LP adds considerable more than the identified long term requirement of non -rail storage /logistic to a already considerable land bank of logistics permissions granted but not build out.
Furthermore BE2 is disadvantaging other operators in other geographical areas by oversaturating the market.

5.1.4: The HEDNA was to identify housing and employment need. However all this important detail of employment /logistic provision and the correlation thereof was omitted until very late in the process .The Sensitivity Study was an add on, not fully commissioned and was not made available until July.
The study has not been objectively assessed , scrutinised , it is confusing , contains flaws and is based on assumption not on evidenced facts.
The scenarios used to underpin the need for 700 000sqm of logistics floor space are disregarding all previous, confirmed evidence , consultation result and a democratic members decision.
The study that alleges 19 % of HD residents work at Magna Park. If to be considered as factual, one needs to be mindful that this has taken over 20 years to achieve.
To raise this to 25 % ( 3000 workers approximately ) in an area of low unemployment (at it's highest 1100) without effective policies and no means of enforcement this seems unachievable.

5.1.9: A buffer of 20% was applied by a proper democratic process to assist other LA's with unmet housing needs in March 17 .This need has not yet been evidenced and was agreed on the provision of 2 letters received ( 5.1.6 )
Not adhering to a proper democratic process the 20% buffer provision was split into 15 % unmet need and 5 % ( 5.1.9 ) to meet the impact of policy BE 2.
The March decision was ignored and these figures were already placed in all the draft Local Plan documents before being agreed by the Executive in September 17.
How can the Local Plan with no provisions and policies to enforce, underpin or secure the ambitious commitment to house Magna Park workers in the district ?

BE1: The Full Council has always voted to encourage and promote knowledge based industries to the district but policies or actions do not actively reflect this ambition.

BE2: Comments from members and residents ignored, evidence flawed, contradiction to previous evidence applied, proper process not followed in order to accommodate a policy that advocates unnecessary ,over allocation of storage, logistic provision to consider with applications submitted which will be decided at a planning meeting before this plan is evaluated.
The applicants stating their proposals are promoted via the LP and that the policy of the emerging plan supports their application.
This policy is ambiguous, will saturate and monopolise the non‐ rail storage and logistic market to the disadvantage of neighbouring authorities. This policy supports greed and does not identify need.

H1: Sets out housing commitment to 2031. The infrastructure document are difficult to access. It should be explained that dwelling should not just be taken as houses but could be apartments /flats. The policy should reflect a need for this provision to aid the accumulation of much required social housing.
It refers in 5.1.8 to 557 per annum or 11140 over the plan period .There is no correlation of the figures.
H1 ( SS1 2a ) states a minimum of 12800 but should state a maximum.
All of this is very confusing and it will be difficult to implement and to achieving a clear basis on which a 5 year housing supply is calculated which is clear and defendable.
Previous housing trajectory identified that no 5 year housing supply has been achieved previously in the Harborough District with a far lower annual housing requirement. It is therefore ambitious and unrealistic to add a 20 % buffer on ONA as this is unlikely to be achieved possibly rendering the Local Plan impotent.

H2: 40 % is not viable or sustainable and will not aid the provision of affordable housing when only up to now only 19 % was achieved and at present only 4000 units are outstanding to be build.

H4: More emphasis needed to ensure specialist housing is provided , policy impossible to achieve and confusing. Is the 10% on top of 40% affordable ?

H6: Provision at Bonham's Lane is not required and the special status of the site should be recognised.GTAA was not an open and public consultation
There would be no requirement for additional Showpeople plots if officers would stop supporting present sites for housing development against planning inspectors advise thus losing the district the existing provisions.
Travelling Showpeople plots have been allocated to non‐ guild members , there have been statements to the fact that there are no further requirements.
5.11.2 refers to the amount of pitches for G/T and showpeople .However, Parish Council 's have unsuccessfully requested up‐dates on occupation of the sites. It is therefore assumed that the illustrated figures are questionable as there have been no detailed evaluations.

Support

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7242

Received: 17/11/2017

Respondent: Kettering Borough Council

Representation Summary:

It is recognised that Policy H6 includes a site for 10 pitches as a reserve site to meet needs arising from any changes to the definition of Gypsy and Travellers or to meet needs of the identified 'unknown' Gypsy and Traveller population. The principle of including a reserve site is supported.

Full text:

Kettering Borough Council would like to make the following comments on the consultation on the Harborough Local Plan 2011 - 2031 Proposed Submission. This is an officer response to the consultation.

Site MH1 - Overstone Park

Kettering Borough Council objected to the outline planning application reference 15/02006/OUT for this site. The Council would like to reiterate the concerns it raised through this objection. The Council does not consider that the site is a suitable location for residential development of the scale proposed. There would undoubtedly be adverse wider landscape impacts associated with the scheme which could not be effectively mitigated against. The proposals, by virtue of the site's open countryside location and remote position relative to Market Harborough's town centre are not considered to constitute sustainable development and raise concerns in terms of the significant negative impact of development on the landscape.
It is noted that this site has been assessed against other alternatives through the Sustainability Appraisal and that this is one of three sites which have been selected as performing most favourably against the assessment criteria.

In the assessment for this site 'Landscape capacity to change' has been identified as high and scored as 'promotes sustainable growth'. The Council disagrees with this assessment. This site is located in a highly visible location which would have adverse impacts on the wider landscape.


Policy H6 - Gypsy, Traveller and Travelling Showpeople Accommodation and the Gypsy and Traveller Accommodation Assessment (GTAA)

Kettering Borough Council was consulted on the GTAA during its preparation but the Council has concerns about the outputs of the study. The GTAA identified that there were 52 unknown households where information was not available as to whether these households meet the planning definition. The GTAA identifies a need for up to 18 pitches for unknown households in the period to 2036; this is made up of new household formulation from a maximum of 52 households. Table B.8 of the Local Plan 2011-2031 identified the need to 2031 on unknown pitches as 13.

It is recognised that Policy H6 includes a site for 10 pitches as a reserve site to meet needs arising from any changes to the definition of Gypsy and Travellers or to meet needs of the identified 'unknown' Gypsy and Traveller population. The principle of including a reserve site is supported.

However, the Council is concerned that there is a significant level of potential need which is unknown at this stage. The Council is concerned that there is potential for there to be more need than sites identified. Given the cross boundary issues between Harborough, Kettering and Daventry Districts, the Council want to ensure that any need which is generated from households within Harborough is fairly represented and provision of pitches to meet need is identified within Harborough District through this Local Plan, and that families are then not required to find sites within neighbouring districts to meet a site shortfall.

Thank you for consulting Kettering Borough Council on this document.

Support

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7501

Received: 10/11/2017

Respondent: National Federation of Gypsy Liaison Groups

Representation Summary:

In H6 we strongly support the recognition in section 2ci and 2cii that allocation of pitches needs to have regard to potential changes affecting those who meet the definition of gypsies and Travellers and to meet the "unknown" need.

Full text:

I am responding to the above consultation on behalf of the National Federation of Gypsy Liaison Groups, with particular regard to Policies H6 and GD3.
In H6 we strongly support the recognition in section 2ci and 2cii that allocation of pitches needs to have regard to potential changes affecting those who meet the definition of gypsies and Travellers and to meet the "unknown" need.
We have the following concerns relating to section 5:
* Criterion a) is unnecessary and unduly restrictive. There will be situations where limited ancillary commercial activity is appropriate and acceptable. If commercial activity would be unacceptable at the particular location for which permission is being sought, then this could be controlled by a planning condition.
* Criterion b) is too restrictive. Sites which are within walking distance of a settlement will usually be unavailable as Gypsy and Traveller sites due to affordability, availability and local opposition. In allocating new sites, it is reasonable for the local authority to first consider
Such locations, but such a rigid approach could prevent suitable sites from coming forward in other suitable locations. Local authorities need to be realistic about the availability of alternatives to the car in accessing local service"
In section 7, we strongly oppose criterion b) which is not in accord which paragraph 22e) of PPTF, which advises against restricting sites to those who have local connections.
Finally, in Policy GD3, there needs to be a recognition that Gypsy and Traveller sites are acceptable outside settlements. This is crucial to the delivery of sufficient sites.

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7640

Received: 17/11/2017

Respondent: Gilmorton Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is no evidence showing the need for the existing site on Bonehams Lane be increased from the present 6 pitches to 16 pitches - an increase of 10 pitches. This site was originally intended for a close family unit and should remain as such.

Full text:

There is no evidence showing the need for the existing site on Bonehams Lane be increased from the present 6 pitches to 16 pitches - an increase of 10 pitches. This site was originally intended for a close family unit and should remain as such.

Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7642

Received: 17/11/2017

Respondent: Gilmorton Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is no evidence showing the need for the existing site on Bonehams Lane be increased from the present 6 pitches to 16 pitches - an increase of 10 pitches. This site was originally intended for a close family unit and should remain as such.

Full text:

There is no evidence showing the need for the existing site on Bonehams Lane be increased from the present 6 pitches to 16 pitches - an increase of 10 pitches. This site was originally intended for a close family unit and should remain as such.