GD2 clause 1

Pegasus Group support the principles established by the first part of this policy, namely that sustainable development is supported both within and adjacent to the built-up area. This is necessary to provide the necessary unallocated development requirements of the draft Local Plan in accordance with paragraph 47 of the NPPF.

Object to this proposal but if it is carried, in addition to the criteria set out, a stipulation that Green Wedge Land must not be developed also needs to be included.

My clients are supportive of the encouragement given to the development of land within or contiguous with the existing built up area of the settlements listed, particularly in respect of the Rural Centre of Fleckney where my clients own land at High Street (see attached location plan). This site has been consistently promoted for residential development throughout the preparation of the Core Strategy and Local Plan and it is currently being considered by the Neighbourhood Plan Group where it is understood that it is favoured because it is well located in relation to services and facilities.

We support the principle of replacing the limits to development with this policy, it will add in-built flexibility to the Plan to enable sustainable development to come forward in appropriate locations.

This policy effectively provides a framework for considering potential windfall sites. By specifying that appropriate development is acceptable adjacent to the existing or committed built up areas of Rural Centres, the Plan should be regarded as being positively prepared and flexible.

However, because of the requirement for the policy to not significantly exceed the housing targets set out at Policy H1 of the Local Plan, DWH does not support the policy. Further comment is provided in relation to Policy H1 itself.

Policy GD2 is supported. By specifying that appropriate development is acceptable adjacent to the existing or committed built up areas of Key Centres, such as Lutterworth, it ensures that the Plan is positively prepared and provides flexibility as the Plan can respond to changing needs. Other local authorities have similar policies to this in recently adopted local plans.
This policy is in effect to provide a framework for considering potential windfall sites, adding flexibility and ensuring District meets its housing target. Therefore, where there are sites that are known now that meet the criteria in the policy these should be allocated. For instance, Land South of Lutterworth Road, Lutterworth meets the criteria in the policy:
* As a scheme for approximately 90 units, it is of a scale that reflects the size of Lutterworth which has range of services;
* It is physically and visually connected to the town, and this can be further enhanced through improved cycling and walking connectivity;
* It respects the form and character of the area as it is physically contained, surrounded by existing or committed development on three sides;
* Natural boundaries can be retained and enhanced; and
* The site does not diminish in anyway the separation with neighbouring settlements given its strong boundaries

On behalf of Alice and Anthony Constable Maxwell, owners of land off Theddingworth Road, Husband Bosworth, where a development of up to 24 new homes, new access and public open space is proposed. Planning and Design Practice Ltd wish to comment as follows:

We support the potential within Policy GD2 for development which is physically and visually connected to and respects the form and character of existing settlements. This enables the Plan to be positively prepared and sufficiently flexible to make allowance for appropriate new developments on the edge of settlements, subject to the scrutiny of the planning application process. We also support the wording of the remainder of the policy, which is measured and will ensure that developments which come forward are appropriate in location and form.

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.

A fair distribution of housing.

Support as sound. However, it is felt that paragraph 1 is unclear and needs revisiting. Thurnby and Bushby Parish Council makes the general point that as worded it could give rise to unwarranted development which exceeds settlement allocation across the district. The only circumstance under which development should be allowed, is if allocated housing numbers are not being delivered.

The aspiration of Policy GD2 to enable the development of unallocated sites in sustainable locations that accord with the Local Plan's spatial strategy is welcomed. Bloor Homes particularly support the principle of permitting development within or contiguous with the existing or committed built up area of the PUA. This is particularly significant in light of the concerns highlighted in their objection to Policies SS1 and H1 in relation to the housing requirements and the number, nature and location of the housing allocations proposed to meet the housing requirements; notably the failure to allocate any sites other that the proposed SDA at the PUA that is positioned at the top of the proposed settlement hierarchy.

However, the policy should not be seen as an alternative to allocating sufficient appropriate development sites in the Local Plan. A plan led approach is required by the NPPF to provide the necessary certainty that the identified development needs will be provided for in appropriate locations.

As paragraph 4.3.7 of the Local Plan acknowledges, in order to meet the development needs of all settlements and conform to the NPPF's presumption in favour of sustainable development, it is imperative that a criteria-based approach that is responsive to local circumstances is followed to allow sufficient flexibility. In this regard, the criteria proposed within the policy is considered generally appropriate, albeit that they need to be considered in the context of the site's specific circumstances.

This ridicules the allocation of sites through Neighbourhood Planning and seems to offer any sites around a selected rural village as potential for building. Where sites have been allocated in Neighbourhood Plans including reserve sites there should be no open invitation to develop further.

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.

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

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

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

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

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

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

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

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

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


3.2. We support the proposed spatial strategy for growth set out in Policy SS1: Spatial Strategy. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are within close proximity to a wide range of employment opportunities and local services and facilities. As outlined above, Thurnby benefits from a good functional relationship with Leicester and the facilities and services available in the city. As such, we support its identification as part of the Leicester Principal Urban Area where development should support the regeneration and development objectives of Leicester City and Oadby and Wigston Borough.

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

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


3.5. With regards to Policy GD5: Landscape and Townscape Character we fully support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness. Any development of the Land South of Grange Lane, Thurnby would be positively prepared to ensure the provision of a high quality and inclusive development. Any scheme would seek to ensure that it makes a positive contribution to the local character and respects the site's edge of settlement location.

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

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

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

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

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

3.11. We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As previously outlined, any development scheme for Land South of Grange Lane, Thurnby would be positively prepared to ensure a high quality and inclusive development design. Any proposal would be designed to protect the residential amenity of existing properties located to the north, east and west of the site by strengthening the landscaping of the site's boundaries and limiting development height to 2 storeys.

3.12. In respect of Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. However, we are concerned that development within the Leicester PUA is to be located within a single Strategic Development Area [SDA] on land north of Scraptoft. Given the high level of infrastructure that is required to be implemented prior to the delivery of housing at large strategic developments, such as the proposed SDA, there are often substantial delays between their initial identification and the first delivery of housing. Therefore, we believe it would be beneficial for the Local Plan to identify a number of smaller housing sites that could assist in the short-term delivery of housing in the PUA. In this light, we are proposing the allocation of Land South of Grange Lane, Thurnby for residential development. The site represents a sustainable development that is suitable, available, achievable and viable and can be delivered now.

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

3.14. We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver a range of housing types and sizes. Any development scheme at Land South of Grange Lane, Thurnby would deliver a mix of property types and sizes, including bungalows, terraced, semi-detached and detached dwellings ranging in size from 2 to 5 bedrooms.

3.15. Finally, in respect of Policy CC3: Managing Flood Risk, we fully support the objectives of this policy in line with Paragraphs 14 and 100 of the NPPF. Given the presumption in favour of sustainable development is the golden thread running through national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site is not located in an area at risk of flooding.

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

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

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

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

On behalf of Mr and Mrs Sandercock we are seeking to work with Harborough District Council in promoting the Land off Station Road, North Kilworth (Appendix 1 of attached) for residential development. The subject site lies outside the Limits to Development identified within the Neighbourhood Plan, where development is strictly controlled. The proposed development site has a total site area of approximately 0.61 ha (1.5 acres) and is located on the eastern edge of North Kilworth, a village within the Harborough District of Leicestershire.

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

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

We support the proposed strategy for locating growth within or contiguous to the built up area of Selected Rural Villages, such as North Kilworth, outlined in Policy GD2: Settlement Development. We consider that the proposed development at Land off Station Road is of an appropriate scale that reflects the size of the village and the level of service provision. It is considered that the site is physically well connected to the village and the proposals include the provision of a footpath along the north of Station Road to assist with the functional connectivity between the site and the village centre. A development of 10 units would be an appropriate scale for the village and could be designed in a manner that respects and enhances the local character and distinctiveness. Any development of the site would seek to retain the existing natural boundary, with the exception of the site entrance and the footpath entrance. Development of the site would not impact on the separation of settlements, as the site is bound to the east by existing residential development.

With regards to Policy GD5: Landscape and Townscape Character we fully support the requirement for new development to be sensitive to the landscape setting and the settlement's distinctiveness. Any development of the Land off Station Road, North Kilworth would be positively prepared to ensure the provision of a high quality and inclusive development design. Any scheme would seek to ensure that it makes a positive contribution to the local character and respects the site's rural context.

We fully support the objectives of Policy GD8: Good Design in Development, good planning and good design are inseparable and we are pleased that this has been identified by this policy. As stated above, any development scheme at Land off Station Road, North Kilworth would be positively prepared to ensure a high quality and inclusive design. Any proposal could be designed to protect the residential amenity of existing properties located to the east and west of the site through the retention of the existing boundary hedgerow and enhancement with additional planting.

In respect of Policy H1: Provision of New Housing, we fully support the recognition that the housing requirements outlined in this policy are a minimum and the level of flexibility that this element of the policy provides. However, we are concerned that the policy does not identify a minimum residential requirement for North Kilworth. The village is identified within Policy SS1: Spatial Strategy as a Selected Rural Village, which is considered to be an appropriate location for growth. All of the Selected Rural Villages, with the exception of North Kilworth, have an identified minimum requirement in Policy H1, and as such abstaining from allocating a minimum requirement for North Kilworth should be considered to be unjustified.

With regards to Policy H2: Affordable Housing, we support the requirement for residential developments of more than 10 dwellings to provide 40% of affordable housing on site. As previously stated, the clients are willing to meet this requirement, subject to the completion of the appropriate viability assessment.

We fully support the requirement of Policy H5: Housing Density, Mix and Standards for new development schemes to deliver a range of housing types and sizes. Any development at Land off Station Road, North Kilworth would provide a mix of property types and sizes, including a mix of 2 to 4 bedroom dwellings which would include a mix of bungalows, semi-detached and detached houses.

Finally, in respect of Policy CC3: Managing Flood Risk, we fully support the objectives of the policy in line with Paragraphs 14 and 100 of the NPPF. Given that the presumption in favour of sustainable development is the golden thread running through the national and local planning policy, it is logical that this translates into development being located in areas that are not at high risk of flooding, and that schemes do not increase the risk of flooding elsewhere. With reference to the Environment Agency Flood Map for Planning, the proposed development site is located within Flood Zone 1.

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.