H1 Opening sentence

Pleased to see exclusion of The Kibworths from this list of Rural Centres being allocated more housing. The Kibworths have accepted over 1,000 either already constructed and occupied, being constructed or with outline planning permission.

However, there needs to be an extra explanatory paragraph giving reasons why The Kibworths,, despite being the largest Rural Centre, has not had any further houses allocated in the Local Plan to 2031.

My objection is the 'maths'
you say 12800 new homes over twenty years, 8140 effectively 'sorted' leaving 4660?
Simply divide 8140 by the six years already expired and multiply by 20 and the total is a staggering 27133! Even if you halve this you are dramatically out!
You have politely positioned the bulk of increase in the 'west' and away from the loveliness of the Harborough / Uppingham / Thurnby Triangle and your assumptions for housing and social housing growth do not include for current European workers to bring there relatives. (as happened with the Commonwealth in the late 20th century. Simple maths demonstrate the need for planning in a growth area

The Consortium support the Council's approach to the provision of new housing being specified as a minimum figure and identifying a housing supply over and above the District's own needs to address unforeseen circumstances and unmet needs elsewhere. The Settlement Hierarchy is the most appropriate strategy to deliver growth co-locating strategic housing and economic development in those areas with the greatest propensity to give access to services and facilities by sustainable modes of transport, aligned with the investment strategies of the sub-regional economic bodies.

The quoted housing numbers will need to be reviewed in the light of the recent five year housing land calculation methodology statement and the phasing of release will need to allow for the inevitable delay in the provision of housing numbers from the several large strategic sites, upon which the LPA are relying, but which will inevitably lag, thereby resulting in an increased short and medium term housing land need. As a consequence additional short and medium term housing lands will need to be identified.

The quoted housing numbers will need to be reviewed in the light of the recent five year housing land calculation methodology statement and the phasing of release will need to allow for the inevitable delay in the provision of housing numbers from the several large strategic sites, upon which the LPA are relying, but which will inevitably lag, thereby resulting in an increased short and medium term housing land need. As a consequence additional short and medium term housing lands will need to be identified.

We object to the exclusion of Broughton Astley from this policy; no new development is directed to this settlement, which is one of the most sustainable in the district.
There is no doubt that Broughton Astley is a sustainable settlement; policy SS1 The Spatial Strategy lists Broughton Astley as a Key Centre, alongside Lutterworth. These two settlements sit third in the hierarchy after the Leicester Principle Urban Area (PUA) and Market Harborough. Appendix F defines Key Centres as "Settlements capable of sustaining expansion, infill and redevelopment on a scale which reflects their good levels of services, facilities and employment."

Policy H1 Provision of new housing, allocates sites in the PUA, at Market Harborough and Lutterworth and the lower order settlements, but none for Broughton Astley. Little explanation is provided in the Plan; paragraph 3.1.10 states that a neighbourhood plan has been made and allocates "more than enough housing land to meet its needs." Similarly, the Sustainability Appraisal states that "The settlement has a made Neighbourhood Plan, which includes site allocations expected to deliver dwellings in excess of any target for the settlement under the preferred option. In addition to completions and commitments no dwellings are required to be found."
The quantum of Broughton Astley's housing need is not specified in the Plan. Furthermore, no evidence is presented in the Plan to explain whether Broughton Astley, as one of the most sustainable settlements in the District, can accommodate more development to meet a share of the District's needs.
Firstly, we contend that the Plan should contain a clear explanation as to why this Key Centre is not considered able to accommodate any more new dwellings. Without such an explanation the evidence base is neither robust nor transparent and therefore fails to satisfy paragraph 182 of the National planning Policy Framework (NPPF) which requires Local Plans to be "the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence".
Further growth at Broughton Astley and its ability to accommodate it have not been considered through the plan preparation process at all. The Options Consultation Document, 2015 contained 9 different options and combinations of options, however, none of these included any development at all at Broughton Astley. The Sustainability Appraisal does not consider the effect of development at Broughton Astley, with the explanation given that "the settlement strategy is already determined in the Neighbourhood Plan, hence effects are neutral across the board". Therefore, it would appear that the development strategy was determined prior to the Sustainability Appraisal being undertaken. As such, the reasonable alternatives have not been considered, nor is the evidence proportionate.
Secondly, modest growth at Broughton Astley would not be out of keeping with the scale of the settlement, its place in the settlement hierarchy or in comparison to other settlements.
According to the Sustainability Appraisal, there were/are 619 completions and commitments for Broughton Astley between 2011 and 2017.
Lutterworth, which occupies the same level of the settlement hierarchy had 753 completions and commitments between 2011 and 2017 with 1,500 dwellings proposed for allocation, a total of 2,253 dwellings. It is appreciated that this is a Strategic Development Area, but it provides a useful context for comparison of the 619 dwellings committed or delivered at Broughton Astley.
The Rural Centre of Fleckney, which occupies a lower level of the settlement hierarchy than Broughton Astley is proposed for 295 dwellings, three other Rural Centres a total of 110 ranging from 10 to 65 dwellings each and the Selected Rural Villages, at the bottom of the hierarchy, a total of 415 ranging from 10 to 50 dwellings. These are all minimum requirements.
In this context, it would not be inappropriate to direct a modest level of new development towards Broughton Astley.
Thirdly, preventing growth of a sustainable settlement is contrary to the NPPF which requires the planning system to play an active role in guiding sustainable solutions. Paragraph 15 is clear that "policies in Local Plans should follow the approach of the presumption in favour of sustainable development so that it is clear that development which is sustainable can be approved without delay. All plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally."
The exclusion of Broughton Astley from policy H1 is not in accordance with other policies within the Plan. Specifically, paragraph 5.1.12 states that housing land is provided in accordance with the settlement hierarchy and strategic aims of Policy SS1 Spatial Strategy. This is not the case as Policy SS1 seeks to "direct development to appropriate locations" and lists Broughton Astley as a Key Centre, suitable for development.
Whilst proposed policies SS1v and GD2 do allow for development in addition to those allocated, however, the lack of a housing target for Broughton Astley leaves a question mark over how these policies apply.
There does not appear to be any specific provision within the Plan for any development at Broughton Astley at all, meaning the Plan lacks flexibility and will actively prevent sustainable development from coming forward.
Broughton Astley has an ageing population, with Primethorpe Ward having seen an overall decrease in population. This decline cannot be reversed without development and the benefits that it can bring. Many lower order settlements are also reliant on Broughton Astley for services, specifically the doctor's surgery and primary school. Without development to fund expansion and improvements, these services could struggle to continue to serve the settlement and rural hinterland.
The moratorium of growth proposed for Broughton Astley does not promote sustainable patterns of development and as such, is contrary to national policy so fails to accord with paragraph 182 of the NPPF.

There appear to be no references to North Kilworth

Policy H1 states that in addition to existing completions and commitments, a minimum of 4,600 new homes will be provided up to 2031. In the Rural Centres only a further 110 dwellings are proposed, the majority of these in Houghton on the Hill.

DWH notes that scenarios of extremely high levels of housing development or no housing development in Kibworth were tested during the latter stages of the Local Plan assessment process (final spatial alternatives). Whilst there has been a high level of completions and commitments in Kibworth over the plan period so far, it is considered that Policy H1 could be more flexible in enabling additional development in Kibworth to come forward to meet local housing need, i.e. to contribute towards a housing land supply shortfall, to take account of lapse rates on committed developments in the Rural Centres or committed sites in the Rural Centres that prove to be undeliverable or undevelopable.

It is considered that in these circumstances, a modest amount of additional development should be permitted in Kibworth. David Wilson Homes site at Smeeton Road (site reference A/KB/HSG/15) could deliver in the region of 150-170 dwellings. The site is assessed in the Council's SHLAA where it was considered to be suitable, available and achievable for residential development and deliverable in accordance with the NPPF definition (i.e. in 0-5 years). The Sustainability Appraisal which forms part of this consultation considers that the only factor where mitigation is likely to be required (as opposed to may) or where there is an unavoidable impact is access to a railway station, which is comparable across the majority of sites in the Rural Centres.

The Sustainability Appraisal identifies the low levels of development at Great Glen, Ullesthorpe, (under SDA options) and Kibworth (Options B and D) as a key issue (p.130), concluding that this "could lead to less positive effects on health, wellbeing, housing and economy (than relying on completions and commitments alone)." In relation to this issue, the SA considers that:

"...an increase in growth at Great Glen and Kibworth would not be expected to have significant negative effects upon the built and natural environment. However, it would generate positive effects in these settlements, whilst mitigating negative effects at more sensitive locations (For example South Kilworth).

Under options 3 (Scraptoft North) and 6 (Lutterworth East), it ought to be possible to increase housing delivery in Kibworth (given its role as a Rural Centre) without significantly affecting the built or natural environment. This would help to generate more positive effects on well-being, housing and economy should the preferred approach be option 3 or 6 (which involve no/low growth at Kibworth and Great Glen)."

The SA also confirms that there is current highways assessment taking place that will impact on the amount of development which can take place along the A6 including the Kibworths (p.255). As a result, it may be possible to accommodate additional housing development in Kibworth which reflects its status as one of the larger Rural Centres. A more flexibly worded policy in relation to future housing development in Kibworth is recommended.

Marrons Planning has concerns that the housing trajectory at Appendix G would not ensure a 5 year housing land supply on adoption and consider that in order to significantly boost the supply of housing, this should be addressed by the Local Plan prior to submission to the Secretary of State.

I note that the draft local plan assigns a minimum of 35 houses to Great Glen.

However, policy H1 states

In addition to delivery of existing commitments and completions and the allowance for windfalls, land for a minimum of 4,660 new homes will be provided during the plan period to 2031 in the following locations:

Existing commitments implies inclusion of include Oaks Road 17/00579/OUT which the planning committee resolved to approve in July. This is an outline application for 170 dwellings.

However the draft local plan also states:

5.1.12 Housing land is provided in accordance with the settlement hierarchy and strategic aims of Policy SS1 Spatial strategy . The sources of housing land supply are set out at Table B.1 below. Policy H1 includes slightly rounded figures.

Table B1 includes 'Commitments (with planning permission or allocated through neighbourhood plans, as at 31 March 2017).

The Committee resolved to approve Oaks Road in July 2017, 170 houses in Great Glen after the March cut off date.

I believe that H1 is in error and therefore not Justified, effective or consistent with national policy. I suggest that it should be reworded to say '..existing commitments and completions since 31 March 2017'.

As further background and justification to the above:

Prior to the issue of the Local Plan in September, the Council consulted on several options for Great Glen from 0 to 166 houses, which were whittled down to 4, assigning between 0 and 64 houses to Great Glen. Whilst these plans were in development approximately 70 further dwellings have been approved in Great Glen including 15/00607/OUT (5 Dwellings), 15/00916/OUT (40 dwellings) and 16/01302/OUT (19 Dwellings).
The submission version of the Great Glen Neighbourhood Plan noted that:

A report agreed by the District Council Executive in September 2016 set a residual target for Great Glen of 5 additional dwellings up to 2031, a figure which has been exceeded through Planning Applications approved since the cut-off for calculating the residual housing target (March 2016) with a total of nine additional dwellings having secured planning permission since this time. In discussions with the District Council and the community as part of the preparation of this Neighbourhood Plan, it was agreed that the housing target for Great Glen has been exceeded.

The submission version of the plan was reviewed by the Council for several weeks before passing it on to the inspector (in May 2017 this year) confirming that the Council considered that the emerging local plan should not include additional large housing development in Great Glen.

It is difficult to see how the Council could have gone from a position of requiring 64 houses in Great Glen (about 70 of which have been consented) coming on top of the 305 houses now virtually complete on Stretton Road.and confirming in May that further large housing development in Great Glen was not planned, to a position where Great Glen is required to accept a minimum of 205 houses on top of the 70 constructed or under construction.

I therefore submit that the housing allocation for Great Glen in the Local Plan does not in fact allow for the 170 houses consented on Oaks Road or, probably, anything else committed since 31 March 2017.

I note that the HEDNA dated January 2017 states (para 12.31)

A 15% adjustment is justified in Harborough and Melton on the basis that there is both a clear case for adjustments to improve affordable housing delivery and the market signals evidence presents these areas as being the more expensive parts of the HMA;

I suggest is not the business of the HEDNA to dictate planning policy, but to inform the housing need and it is up to the Council to implement policies for affordable housing accordingly.

The draft Local Plan states:

5.1.10 Policy H1 provides for delivery of the housing plan requirement, plus an additional 15% contingency in the supply of housing land in order to allow for possible future circumstances affecting the supply of housing in the District, including: * a potential need to help meet demonstrable unmet housing need arising from other local planning authorities within the Leicester and Leicestershire Housing Market Area (HMA); * a slower delivery than expected on housing allocations and/or the strategic development areas; * housing sites gaining planning permission but not delivering completed housing in a timely manner or at the density originally proposed; * changing economic circumstances affecting the take-up of housing; * the non-delivery of housing sites due to site-specific factors; and * in order to provide flexibility and choice in the local housing market.

These reasons seem spurious particularly coming on top of the 15% uplift in HEDNA. The 20% buffer is applied on top of this presumably to counteract the above effects.

The Council has compounded this by applying the new housing requirement as a historic shortfall to be made up in the next 5 years. This is wrong as this is a newly identified need not a historic shortfall so should be applied over the remaining plan period. The introduction to the 5YHLS position statements says that the Sedgefield method allow for any previous shortfall in housing delivery, not newly identified need. This accounts for another 13.5%.

Therefore the basic requirement is being inflated by 1.15x1.15x1.13x1.2 = 1.8% in the next 5 years, and 1.15x1.15=1.3 overall.

It is generally accepted that Plan led policy leads to better and more sustainable development otherwise there would be no point at all in the Local Plan. This being the case, it is unreasonable to drastically and unnecessarily inflate the housing land requirement, particularly given that HDC has evidently struggled to meet its inflated target. I would suggest that the Council has a duty to, as far as possible, enforce a plan led policy, rather than simply allow unplanned development.

I consider that the 15% uplift in the local plan is not justified and I would query whether it is effective or in accordance with national policy or conducive to sustainable development. Therefore it should be removed.

Whilst the Settlement Hierarchy is supported as the most appropriate strategy to deliver growth and rightly identifies Lutterworth as a Key Centre able to deliver growth, an objection is lodged in so far as the policy does not allocate sufficient land to ensure a 5 year housing land supply on adoption. Furthermore, the policy does not boost significantly the supply of housing in accordance with the NPPF.

Trajectory

Based on the Housing Trajectory as shown in Appendix G of the Local Plan, the Council would not have a 5 year housing land supply on adoption. From a base date of 2017, and using the 'Sedgefield' approach, supply would be 4.93 years with a 5% buffer or 4.31 years with a 20% buffer. A base date of 2018 would result in 5.31 years with a 5% buffer or 4.65 years with 20%. Projecting a further year forward to an adoption in 2019 would result in 5.73 years with a 5% buffer and 5.01 years with a 20% buffer. As it stands, due to the Council's record of persistent under delivery against the District's OAN of 557dpa since 2011, it is considered that a 20% buffer is necessary.

Given the above, it is considered both appropriate and necessary for Harborough to allocate further sites that can deliver completions within the first five years. Not only will this ensure choice and competition in the market for land, in accordance with the NPPF, it will also support the Local Plan strategy and existing supply identified in H1. It will also further ensure that the Council can clearly demonstrate the realistic prospect of a 5 year housing supply on adoption of the Plan.

Land South of Lutterworth Road, Lutterworth

Land South of Lutterworth Road, Lutterworth is a site that could help address these issues. The Council's existing evidence base is supportive of development at this site, and further technical work undertaken addresses any remaining potential concerns. The SEELA 2017 identified the site as suitable, available and achievable, however further employment land allocations are not necessary beyond those already identified in the Local Plan. It is in this context that the Plan should consider the relative merits of the site for residential development. HLM consider the site to be suitable, the land is available now and a viable scheme can be delivered. The Illustrative Masterplan submitted with these representations demonstrates how a scheme of up to 90 dwellings could successfully be achieved.

Landscape

The Council's Landscape Character Assessment and Capacity Study for Lutterworth, suggests the landscape capacity for change is medium high for this particular site. Overall, the Council's assessment identified the parcel as one of the most suitable sites in Lutterworth.

The Landscape Assessment concluded that the separation of development from Lutterworth and proximity to M1 meant that commercial or industrial development could be appropriate. It is considered that residential development would be more suitable, given its proximity to residential development to the west, and the highway arrangements that mean the principal access is from the south. The Landscape and Visual Review submitted with these representations demonstrates how the site could be developed, recognising key features, amenity and landscape character.

In addition, the site would be surrounded by existing and committed development on 3 sides, to the north, east and west, and would not draw out the urban form of Lutterworth any further southwards.

Highways

The SEELA 2017 states that the Highway Authority suggests access off Swinford Road to the south of the site is most appropriate and this is the proposed access that HLM is intending to use to secure development. Reference is made in the SEELA to safety concerns as Swinford Road is currently 60mph and pedestrian and cycle access is poor. This year, HLM have undertaken technical work in liaison with the Highway Authority (HA) and Highways England (HE). The HA consider access arrangements to be acceptable in principle. And the HA and HE consider improvements to existing links to the town centre for pedestrians and cyclists acceptable in principle. Furthermore, significant improvements are programmed to the Frank Whittle Roundabout, including for non vehicular users as part of the delivery of the East of Lutterworth SDA. The highways access drawing and technical note on pedestrian crossings options for Lutterworth Road illustrate the progress made to date and how HDC's concerns can be satisfactorily addressed.

Accessibility and Other Mitigation

Land South of Lutterworth Road is in a sustainable location; it has good connectivity to the town centre and key facilities and will be in relative close proximity to the East of Lutterworth SDA. This is demonstrably shown in the submitted 'Site and Its Context' and 'General Connectivity' Plans.

Other mitigation measures, such as those necessary for noise, pollution and ecology can be addressed, and necessary conditions could be imposed to secure these at the planning application stage.

Delivery

HLM is actively preparing a planning application, which will be submitted in the near future. As outlined above, the site's physical constraints and offsite infrastructure requirement can be addressed satisfactorily and quickly. Overall the site is realistically viable and deliverable. Therefore, it is possible that the site in its entirety could contribute towards the Council's 5 year land supply.

Conclusion

Overall, the strategy and policies in the Local Plan and the Council's evidence base should lead to the support for an allocation of Land South of Lutterworth Road. The housing requirement is specified as a minimum figure, the site is within a sustainable location, where further settlement development is acceptable in principle and is suitable, available now and can be delivered in full within 5 years. An allocation will support the delivery of the plan, boost short term supply and allow time for SDAs to be realised.

Finally, it is understood that the Council will be updating the SHLAA prior to the submission of the Local Plan. Land South of Lutterworth Road should be considered in this process, having regard to evidence submitted with these representations and points raised above.

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:

Policy H1- UNSOUND- POSITIVELY PREPARED comment:

Whilst fully supportive of the identification of Husbands Bosworth as a "natural centre" and the "approach to development" as set out by table D21, we believe that a target number of dwellings should be identified for Husbands Bosworth, as is the case for the similarly ranked settlements of Billesdon, Great Glen and Houghton on the Hill.
This would ensure consistency with the "approach to development" at table D21and also policy GD2, in the sense that both potentially allow for development that is physically and visually connected to an existing rural centre settlement.
It would also ensure a consistent approach to similarly ranked settlements, and help the Plan to be more 'positively prepared.'
To support our assertion that there is development land available at Husbands Bosworth we attach a draft planning application including supporting technical documents, for a development of 24 houses, new access and open space at land off Theddingworth Road.

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.

There is too much traffic in Market Harborough already. More houses will bring more cars. Schools are already stretched, doctors cannot cope with the amount of patients they have.

We consider it is misleading to specify minimum (or maximum) numbers of dwellings in Rural Centres and Selected Rural Villages, because the suitability of sites should be assessed on their relative sustainability, taking account of the settlement's position in the hierarchy. All Rural Centres, including Ullesthorpe, should be seen as a focus for further rural development.

Objectively Assessed Need & Housing Requirements
A central tenet of the NPPF is the provision of sufficient housing to meet the needs of present and future generations and, in doing so, to widen the choice of housing (paragraphs 7 and 9). To achieve that it requires (paragraph 14) "local planning authorities should positively seek opportunities to meet the development needs of their area", that "Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change", and set out a "clear strategy for allocating sufficient land" (paragraph 17). Delivery is underpinned by paragraph 47, which seeks to significantly boost the supply of housing requiring local planning authorities to "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".

In terms of the required evidence base, the NPPF requires (para. 159) local planning authorities to prepare a Strategic Market Housing Assessment (SHMA) to assess their full housing needs, and that the SHMA should identify the scale and mix of housing and the range of tenure that the local population is likely to need over the plan period. That should meet household and population projections, address the needs for all types of housing and cater for housing demand in the area. The housing requirement set out in Policies SS1 and H1 is derived from the Housing and Economic Development Needs Assessment (HEDNA) published in January 2017. That concluded that the Objectively Assessed Need (OAN) for Harborough District for the period 2011-2031 is 532dpa and for the period 2011-2036 is 514 dpa.

However, the HEDNA does not take account of the proposed major extension to Magna Park within the M6, M69 and M1 triangle (700,000m2 of B8 floor space) in the period to 2031. The Council's Magna Park Employment Growth Sensitivity Study 2017 concludes that in order to align this employment growth and housing provision, the housing requirement should be increased by 25dpa above the HEDNA OAN figures. That should be appropriately reflected in the housing requirements established in Policies SS1 and H1.

Bloor Homes' objection to Policy SS1 highlights that the plan period for the Local Plan should extend to 2036 to reflect the NPPF's requirements for a minimum of 15 year time horizon post its adoption. The minimum housing requirements in Policies SS1 and H1 should, therefore, also be increased accordingly to reflect the extended plan period.

It is inevitable that there will be a delay to at least some of the identified development sites in the Submission Plan coming forward and/or the rate of their delivery will not be high as currently anticipated. That inevitability should be addressed at the outset rather than monitored and managed. The proposal to incorporate an uplift of 20% above the OAN into the housing requirement in Policies SS1 and H1 is therefore, supported. That approach reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the HMA's housing needs as required the NPPF (para 150-151). However, the uplift must be applied to the true OAN (i.e. the HEDNA OAN plus the recommended uplift to reflect the growth of Magna Park) and across the extended plan period to 2036.

Moreover, the housing requirement uplift should not be used as both a contingency guarding against a shortfall in delivery in the District and a potential contribution to unmet needs arising elsewhere in the Housing Market Area (HMA). Unmet needs arising in the wider HMA must be directly addressed as set out below, and should form an specific part of the overall housing requirement with a shortfall contingency uplift applied to the total requirement.

Unmet Need & the Duty to Cooperate
The Duty to Cooperate (DTC), introduced by the Localism Act 2011, requires the Council to engage "constructively, actively and on an on-going basis to maximise the effectiveness of Local and Marine Plan preparation in the context of strategic cross boundary matters" (NPPG). The NPPF requires (para 181) that authorities "demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts". The demonstration of effective cooperation in reality means a positive outcome to these strategic planning discussions, even if agreement is not secured on all issues. Compliance with the duty to cooperate is central to ensure that a Council delivers sustainable development (NPPF paras 150-151) and meets its full objectively assessed needs for market and affordable housing in the HMA (NPPF para 47), including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council has not prepared a Local Plan that is compliant with the DTC in terms of the housing requirement proposed in Policies SS1 and H1. It is apparent that the Council have sought to engage with the other Local Authorities in the HMA (the "HMA Authorities") during the preparation of the Plan. However, it is also clear that there has not yet been a positive outcome to that engagement that will ensure that (market and affordable) housing needs in the HMA, identified in an up to date objective assessment, will be properly identified and then effectively provided for.

The Duty to Cooperate Paper sets out the Council's engagement with the HMA Authorities and others, including in the preparation of various studies most notably the HMA wide HEDNA. It highlights the intention is to agree a new "final" Memorandum of Understanding (MOU) between the HMA Authorities by January 2018 and for it to inform the preparation of the emerging Strategic Growth Plan that will guide growth across the HMA. In the meantime, the Submission Plan suggests that the 20% uplift in the housing requirement will provide for a potential unmet need arising elsewhere in the HMA in the future.

However, as set out above, that uplift provides an appropriate mitigation strategy within the Local Plan for unforeseen circumstances in relation to the housing land supply required to meet the District's own needs. It cannot be considered to provide for unmet housing needs arising elsewhere in the District under the DTC.

Moreover, it is very clear that there is already an unmet need arising in Leicester City that needs to be positively addressed now. Shortly after the publication of the HEDNA, Leicester City Council wrote to North West Leicestershire District Council in the context of the examination of its Local Plan, formally declaring an unmet need arising in the City. The reasons given refer to substantial increase in the OAN for the City over the same period compared to the 2014 SHMA (now over a third of the total OAN for the HMA arises within the city), and that the densely urbanised nature of the city, flood constraints and tightly drawn boundaries, limits the amount of land available for development. The letter eschews precisely defining the scale of unmet need, but the Appendix to it highlights that there is already a shortfall of 2,917 dwellings of completions compared to need in the period from 2011, and if completions were to remain relatively consistent, then there would be a shortfall of nearly 11,840 dwellings against the HEDNA OAN by 2031. It later highlights that even if all of the total capacity in the draft SHLAA is developed out in that period, then there would still be a shortfall of 8,834 dwellings against the HEDNA OAN by 2031 (although that is clearly seen as a minimum figure). Oadby & Wigston Borough Council also indicated a potential unmet need arising in the period post 2031.

This is clearly a critical matter that all of the Planning Authorities in the HMA need to address as part of their obligations under the DTC through the preparation of their Local Plan Reviews. It is not appropriate to seek to defer this issue to a review of this Local Plan, particularly because the "Final" MoU is apparently imminent and the currently proposed housing requirement would, therefore, be effectively out of date before the Local Plan is even adopted. Nor is it necessary to wait for the preparation of the Strategic Growth Plan, as that is a non-statutory plan that will consider options for guiding growth in the HMA over the period 2031 to 2050. The identified unmet need in Leicester is arising now (as highlighted by the City Council's letter referred to above) and needs to be addressed now in this Local Plan, otherwise it is fundamentally unsound. A failure to do so will only continue the great uncertainty going forward as to how much development should take place and where, and ultimately lead to a situation where housing needs in the City continue to be ignored.

Land Supply & Housing Trajectory
To accord with the NPPF, the Local Plan must facilitate a continual supply of both market and affordable housing from a "portfolio" of deliverable development sites based on a robust spatial development strategy, with sufficient flexibility to make sure that the identified full OAN for the District and the unmet need arising in Leicester needs are met even if key developments do not proceed as currently anticipated. That will ensure a rolling 5 year housing land supply is maintained, that the overall housing requirements are met within the plan period (NPPF para. 47) and that everyone actually has the opportunity of a decent home.

However, the Submission Plan fails to allocate sufficient housing sites to meet even the identified housing requirement, let alone what the stated requirement should be in light of the matters highlighted above. Notably Policy H1 does not allocate specific sites at the Rural Centres or Selected Rural Villages, instead seemingly relying on Policy GD2 to facilitate delivery of the required development on unallocated sites (the housing trajectory indicates circa 800 dwellings plus over 200 dwellings on windfall sites). However, that approach does not reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the identified housing needs as required the NPPF (para 150-151). There is no certainty that there are deliverable or developable sites available in those locations (as required by NPPF para. 47). Policy GD2 should only be used to complement Policy H1 in this regard, and not used as an alternative to the allocation of appropriate sites.

Moreover, as highlighted in Bloor Homes' objection to Policy SS1 there is an over reliance in the Local Plan on a small number of development locations (the SDAs) to provide the majority of the required housing, which creates a significant risk that the identified housing need will not be met in the plan period if one or both of those sites fails to come forward as anticipated. That concern is only exacerbated when the specific issues in relation to the deliverability of both proposed SDAs, as set out in the objections to Policies CS1 and L1, are considered.

Notwithstanding that, entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDAs have been embedded in the Local Plan Housing Trajectory (Appendix G). That indicates that the Council anticipate that the Lutterworth SDA will deliver its first completions in the period 2022/23, i.e. 51/2 years away from this date. Annual completions are then expected to significantly increase to circa 240 dpa. The first completions at the Scraptoft SDA are expected even earlier in the period 2021/22, i.e. only 41/2 years away from now. Annual completions then expected to increase to circa 180 dpa. On that basis, the Housing Trajectory indicates that the SDAs are expected to deliver a total of 2,702 dwellings in the period to 2031.

In order to achieve that, this Plan will first need to be submitted, examined and, if found sound, adopted. The District Council's Local Development Scheme currently anticipates that the Plan will be adopted by October 2018, but that programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which the Local Plan relies in order to meet identified development needs. Adoption during 2019 does, however, appear feasible subject to the issues highlighted in these representations being appropriately resolved.

Outline planning applications will then need to be prepared, submitted and approved. The very detailed allocation policies in the Submission Plan clearly highlight the scale and complexity of that process for each of the SDAs. Notably, the Policies SC1 and L1 require the prior preparation and agreement of comprehensive Masterplans that have been considered via an independent design review. That is perfectly understandable, but will take time to do given the range of issues that need to be addressed (as highlighted by the allocation policies). Furthermore, given the scale and nature of the sites, the planning applications submissions will need to be accompanied by robust Environmental Statements and Transport Assessments. The outline application preparation process should, therefore, be expected to take 1 to 2 years. The determination of those applications, including the signing of the associated Section 106 Agreements to secure the infrastructure required to support the development, should also be excepted to take 1 to 2 years.

Following the grant of outline planning permission, the sale (if promoted by the landowner) / purchase (if promoted by the developer) of the land needs to be finalised in light of a detailed cost & revenue planning exercise (which is even more complicated if multiple landowners are involved). Reserved Matters submissions will then need to be prepared, submitted and approved, conditions discharged and other (highway and drainage) consents secured to deliver the site. That process will take at least 2 years.

The developers resources (labour, equipment and materials) will then need to be mobilised before the development can begin. That commonly takes around 6 months. Site preparation and enabling works (e.g. infrastructure provision) then takes place prior to the construction of the actual homes and their delivery to the market. The first completions are then usually provided 6 months following the start on site. However, on strategic sites where major upfront infrastructure and site preparation is required, it is often 9-12 months form start on site to first legal completions.

This view of the likely timescales for delivery of the SDAs is supported by the various nationwide studies of the delivery of housing on strategic sites that have been published in recent years. Moreover, the folly of the District Council's delivery assumptions is clearly evidenced by the experiences of other Local Authorities in the HMA that have similarly sought to rely on the delivery of strategic urban extensions (SUEs) in excess of 1000 dwellings in their post NPPF Development Plan Documents in order to meet identified housing needs and are now needing to manage a shortfall in the housing land supply in their area.

Charnwood
The Charnwood Borough Core Strategy was adopted in November 2015 after the Inspector concluded that the delivery assumptions in relation to the 3 strategic urban extensions were optimistic but realistic. The Housing Trajectory indicated that the West Loughborough and North East Leicester sites were expected to deliver completions from 2016/17 and the North of Birstall site was expected to deliver completions from 2017/18. However, none of those sites have come forward as expected. The current position is as follows:

- An outline planning application for the development of the West Loughborough site was submitted in September 2014, and the Borough Council resolved to grant permission a year later in September 2015. However, a Section 106 Agreement has not yet been finalised and so planning permission has not yet been granted over 3 years following the submission of the planning application.
- An outline planning application for the development of the North East Leicester site was submitted in December 2013, and the Borough Council resolved to grant permission a little under a year later in November 2014. However, planning permission was not actually granted until August 2016. Now, over a year later, there is still no sign of the site's development.
- An outline planning application for the development of the North Birstall site was submitted in August 2016, but there is no clear indication when it will be determined.

Clearly the Core Strategy's housing trajectory was entirely unrealistic and now, only 2 years following its adoption, the Borough Council have indicated that there is a shortfall in their 5 year housing land supply.

Blaby
The Blaby District Core Strategy was adopted in February 2013, and relies on the delivery of the Lubbesthorpe SUE to meet the vast majority of the identified housing needs. The Housing Trajectory indicated that the SUE was expected to deliver housing completions from 2014/15. That was considered sound by the Inspector on the basis that the District Council has resolved to grant outline planning permission for the development of the site in September 2012 (following submission of the application 19 months earlier in February 2011).

Planning permission was not, however, actually granted until 16 months later in January 2014. Various Reserved Matters and condition discharge approvals have followed and development has now began, but only 2 completions were recorded by 2016/17. That was over 2 years later than the Core Strategy Trajectory had assumed and the anticipated rate of delivery is now much lower. Consequently, the District Council are now in the process of preparing a Delivery DPD that seeks to allocate additional sites close to the PUA to remedy the growing shortfall in the housing land supply.

Hinckley & Bosworth
The Hinckley and Bosworth Core Strategy was adopted in December 2009 and allocated 2 strategic urban extensions in Earl Shilton and Barwell. The housing trajectory anticipated first completions on both sites in 2012/13. That was followed by the Earl Shilton and Barwell Area Action Plan in September 2014 that sought to facilitate the delivery of the SUEs.

An outline planning application for the delivery of the Barwell SUE was subsequently submitted in February 2015 and the Borough Council resolved to grant permission in June 2016. However, 2 years 9 months later planning permission has still not actually been granted.

A planning application for the development of the Earl Shilton SUE has not yet been submitted.

As a consequence of the ongoing delays in the delivery of these sites, the Borough Council allocated the Hinckley West strategic urban extension in its Site Allocations DPD. That was adopted in July 2016. By that time, the Borough Council had resolved (in June 2016) to approve an outline planning application that had been submitted in over 17 months earlier in February 2015. The submission of the outline application had been quickly followed (in May 2015) by a full application for the development of the first 2 phases and the Borough Council resolved to approve that in August 2016. However, the planning permissions have not yet been formally granted.

Leicester
The Ashton Green SUE was first allocated for development in the Leicester Local Plan adopted in 2006, and reallocated in the Core Strategy that was adopted in July 2014. That assumed that the first completions on the site would be delivered in 2017/18 on the basis that an outline planning permission was granted in January 2014 (following submission in June 2010 and resolution to approve in March 2011). It is understood that a developer partner has not yet been secured, and consequently there is no sign that the site will be delivered in the foreseeable future.

Harborough Housing Trajectory
Based on the conservative analysis of the required timescales to deliver the SDAs set out above, the Submission Plan should assume the first delivery of housing completions at the SDAs a minimum of 6 years post the likely adoption of the Local Plan in 2019; i.e. in the 2025/26 period. Even then there is a significant risk that the resolution of the site specific environmental constraints, infrastructure provision and landownership issues highlighted in the objections to Policies L1 and SC1 and will further delay delivery.

Thereafter a robust view on the rate of delivery needs to be taken. The assumed rate of delivery for the Lutterworth SDA in particular (rising to around 240dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Notwithstanding that, the delay in delivery alone will mean that the Lutterworth SDA will only provide 518 dwellings in the period to 2031 and the Scraptoft SDA will only provide 634 dwellings, resulting in a total shortfall of 1,152 dwellings in the plan period.

Consequences
Consequently Bloor Homes are very concerned that the District Council are not seeking to meet the FOAN across the HMA in accordance with the NPPF or allocating sufficient land to meet the identified housing need. This must be remedied in the Submission Draft Local Plan as the consequences of not planning to meet the identified need would be dire.

The Housing Strategy for England "Laying the Foundations" states in paragraph 1 that a "thriving, active but stable housing market that offers choice, flexibility and affordable housing is critical to our economic and social wellbeing." It continues to highlight (paragraph 5) that "we have not built enough homes for more that a generation and the credit crunch has simply compounded this challenge", and (paragraph 8) that "without urgent action to build new homes, children will grow up without the same opportunities to live near their families, young people will struggle to get a place to call their own and older people will not have the choice and support they need." Furthermore, paragraph 9 states: "Housing is crucial for our social mobility, health and wellbeing - with quality and choice having an impact on social mobility and wellbeing from an early age, and our homes accounting for about half of all household wealth. Social housing should provide support for those who need it, when they need it, and should help vulnerable people to live independently. And opportunities for wealth must be open to all, with housing choices helping rather than hindering people's ability to build assets and find employment."

More recently the Housing White Paper presents startling facts and figures that highlight the acute socio-economic effects of a continued undersupply of housing in the country. Average house prices have rocketed compared to earnings, home ownership in the under 35s has significantly decreased and rental costs are continuing to escalate. The under supply of housing is also having a severe negative impact on the economy in terms of labour mobility, the construction industry, economic spend and increasing housing benefit costs.

A key element of addressing this negative cycle is a focus on "planning for the right homes in the right places" as espoused by the NPPF. The District Council must, therefore, increase the housing requirement established in Policies SS1 and H1 and propose additional development allocations accordingly to ensure that the identified housing needs are actually met.

Land to the North of Uppingham Road, Bushby
Bloor Homes are a house building company who have an interest in land off Uppingham Road, Bushby. Some of that land already benefits from a planning permission and reserved matters approval for the delivery of 275 dwellings, and development of the site will commence in 2018.

However, given the concerns raised in this objection and in that submitted in relation to Policy SS1, Bloor Homes are of the view that the PUA could and should accommodate further development in order to ensure the District's Housing Needs are met and to meet a proportion of the unmet housing need stemming from Leicester within the plan period. The PUA is positioned at the top of the proposed settlement hierarchy that underpins the Submission Plan, and further development at Thurnby and Bushby (over and above that already committed and the proposed allocation of the SDA) would entirely accord with Harborough's established development strategy and housing objectives.

In that context there is additional land available adjacent to the committed site that would be an entirely appropriate development allocation for accommodating an element of that further growth on the edge of the PUA.

The site assessments and masterplanning that has been undertaken to underpin an imminent outline planning application submission have confirmed that the site is suitable and deliverable in NPPF terms. The location benefits from having good access to Leicester via the A47, providing access to an extensive range of higher order services, facilities and employment opportunities. Some key services (such as convenience store, primary schools, post office and GP surgery) are also provided within Thurnby and Bushby (and new additional retail provision will be made as part of the committed site). It is, therefore, entirely appropriate to locate new development in this sustainable location.

Bloor Homes' aspiration for the development of the site is to deliver a high quality housing development that respects its relationship with the surrounding urban form and sensitive environmental and cultural features. In that light, the development proposals for the site have evolved through an iterative masterplanning exercise that has taken into account the requirements of the various technical and environmental assessments, and best urban and landscape design practice. Whilst the development of the site would inevitably result in the loss of agricultural fields on the edge of the settlement, the Masterplan seeks to ensure that the proposals respond to the surrounding landscape character by retaining and enhancing boundary hedgerows and trees within the site wherever possible, and by providing new public open space with additional tree hedgerow planting to ensure a soft transition between the built development and open countryside. Within that context the Masterplan demonstrates that the site has the capacity to deliver a further 125 dwellings.

Local Plan Review
Policy IMP1 sets out the circumstances where a review of the Local Plan would be undertaken. However, a review mechanism is an inappropriate and ineffective response to the fundamental matters of soundness set out above (and in the response to Policy SS1) that need to be directly addressed now before the Local Plan can be found sound. Moreover, such a "commitment" to a Review cannot be enforced if the Council decide, for whatever reason, not to honour the commitment in the policy (e.g. a failure to agree a new MOU that addresses unmet need arising elsewhere).

Whilst a similar review mechanism was endorsed by the North West Leicestershire Local Plan Inspector to address some similar issues, the trigger for the review there is the agreement of a MoU demonstrating a requirement to address an unmet need and that is apparently due in January 2018. A short delay in the submission of the Local Plan will allow the distribution of the development needs to be understood and then agreed ensuring that the unmet needs that are already arising in Leicester are appropriately provided for within the HMA, including Harborough District, in accordance with the requirements of the NPPF.


Soundness:
For the reasons set out above, Bloor Homes object to Policy H1, which is considered unsound on the basis that it:
- has not been positively prepared as it is not based on a strategy that will ensure that the objectively assessed housing needs, including unmet development requirements arising in Leicester, will be met within the plan period;
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies;
- is not effective in that some allocation sites will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Proposed Change:
To remedy the flaws in the soundness of the plan:
- Policy H1 should identify a housing requirement for a plan period to 2036 (to provide a 15-year time horizon).
- That requirement should reflect the up to date, full and objectively assessed needs for housing and economic development within the District and wider HMA, based on the findings of the HEDNA and the Final MOU between the HMA Authorities that addresses the likely unmet need arising in Leicester City and Oadby & Wigston.
- The housing trajectory should reflect a realistic timescale for the delivery of the SDAs.
- The Local Plan should then identify sufficient deliverable and developable supply of housing land / sites to meet that need in sustainable locations in the District, notably at the PUA.
- That should include the allocation of the land off Uppingham Road, Bushby.

APPENDIX
HARBOROUGH LOCAL PLAN 2011 TO 2031 PROPOSED SUBMISSION
LEICESTERSHIRE COUNTY COUNCIL RESPONSE

Transport

1. Leicestershire County Council, in its role as Local Highway Authority (LHA), has been working closely with Harborough District Council as part of the Local Plan making process. As such, the LHA is content that the draft submission document is appropriately evidenced and also appropriately deals with transportation considerations at this stage in the planning process.

2. Subject to Harborough District Council's continued commitment to the policies and delivery approaches set out within the document, the LHA supports the submission of the Local Plan and looks forward to working with Harborough District Council in its delivery.

Education

3. Policies F1, MH2 and MH3 include no reference to securing suitable contributions for educational facilities. It may be that the intention is that these are covered by Policy IN1 - Infrastructure Provision, however whilst this policy refers to the Leicestershire Planning Obligations Policy (LPOP), it only does so in terms of waste, it does not refer to education.

4. Policies L1 and SC1 refer to delivery of Primary Schools 'soon after 300 dwellings'. The County Council would normally, and has with Harborough District Council, requested that the intended provision be available for opening in the September prior to the occupation of 300 dwellings.

Ecology

5. It is acknowledged that the de-declaration of the Scraptoft Local Nature Reserve is also currently being consulted on, and that its de-declaration would enable land to come forward for development as part of the Scraptoft North Strategic Development Area (SDA). The County ecologist has and continues to be actively involved, working through an approach which ensures the retention and management of areas of ecological value whilst enabling the release of some land for future development. This may involve the designation of a Local Wildlife Site.

Waste Management

6. The Local Plan needs to recognise that Waste Management considers proposed developments on a case-by-case basis and, when it is identified that a proposed development will have a detrimental effect on the local civic amenity infrastructure, appropriate projects to increase the capacity to offset the impact have to be initiated. Contributions to fund these projects are requested in accordance with Leicestershire's Planning Obligations Policy and the Community Infrastructure Legislation Regulations.

Economic Growth

7. The County Council supports the new employment land allocated in association with the Lutterworth SDA and recognises a similar approach is not necessarily appropriate with the Scraptoft North SDA with opportunities to access existing B use employment sites and proximity and ease of access to the City for employment.

8. The proposed portfolio of B use employment land in the Local Plan, which will provide the opportunity to deliver a range of jobs and economic prosperity in the District and wider area, is supported.

9. The County Council supports the approach taken to strategic storage and distribution (strategic B8 use) at Magna Park in the Local Plan, which has been informed by recent evidence commissioned by Harborough District Council. In particular, it supports additional strategic distribution proposals at Magna Park needing to meet the six criteria set out within the second part of Policy BE2, which sets a limit of 700,000 square metres for non-rail-served strategic B8 use in the Plan period.

10. The emphasis on the vitality and viability of the town centres is supported, and the regeneration emphasis on Lutterworth town centre although it is considered there is scope to strengthen this further, beyond the focus on vacant units absorbing identified need in Lutterworth town centre.

Strategic Assets

11. Comments from Strategic Assets are made in relation to the County Council's role as landowner. Its main interests in Harborough District are:

* land at Misterton County Farms Estate which forms part of the East of Lutterworth SDA (for which a separate detailed collaborative response will be submitted on behalf of the landowner consortium), and;
* potential smaller scale sites within Market Harborough, Lutterworth and rural settlements throughout the District.

12. Query whether the settlement hierarchy requires further consideration, to enable settlements which are better serviced than others in the same tier of the hierarchy to be more clearly distinguished and potentially receive more development.

13. In general terms the distribution of housing across the settlement hierarchy is supported; however, considers that there needs to be more clarity regarding the future housing needs of key settlements and seeks more flexibility for future housing numbers for smaller settlements.

14. The allocation of the East of Lutterworth SDA as a preferred strategic housing allocation is, in particular, strongly supported. The Objectively Assessed Need (OAN) supported by the Housing and Economic Development Needs Assessment (HEDNA) should therefore inform and provide strategic guidance to the development of later SPDs and Neighbourhood Plans. In considering the distribution of housing in the lower tiers of the hierarchy the Plan needs to demonstrate that those key centres and rural centres with neighbourhood plans will deliver housing numbers based on the current OAN rather than those contained within existing plans which were based on an earlier, much lower, OAN. Without this clarity the methodology could be open to criticism.

15. The integration of the social element of housing for older people and specific groups should be incorporated within the quantum and mix of affordable housing in order to mitigate any negative effect on site viability.

16. The County Council requests that planning consents at Airfield Business Park, Market Harborough (BE1.1a (ii)) and the land south of Lutterworth / Coventry Road, Lutterworth (BE1.1b (ii)) should be shown as existing commitments. Further, the consented site at Gaulby Road, Billesdon (a former highways depot), should also be shown as a commitment.

17. Whilst recognising the desire to concentrate strategic distribution at Magna Park, the proposal in Policy BE2.2 to allocate sites capable of delivering units of at least 9,000 sqm is seen as logical, as is the desire to stimulate economic growth by delivering sites that meet regional and sub-regional demand.

18. Policy BE3 on existing employment areas is supported; BE3.1 being seen as of particular relevance in ensuring that development meets the needs/demands of the wider sub-regional market in addition to local businesses in order to attract inward investment.


19. The allocation of both convenience and comparison retail floor space within the Lutterworth East SDA in Policy RT1 is supported, as is the additional provision within Lutterworth town centre which will complement the development of the new local centre and maintain a balance across the expanded community.

20. Policy L1- East of Lutterworth SDA is strongly supported. Being situated in the M1 corridor within one of the priority areas for economic growth in the Strategic Economic Plan it is clear that Lutterworth should be the focus of major strategic development within the District. The East of Lutterworth SDA is seen to meet best the criteria set out in Key Issues section of the plan and compliments the further development of Magna Park. Further, it is confirmed that the site, which is recognised as the most sustainable location for major development within the district, is available, being owned by a consortium of willing landowners, deliverable and capable of supporting a viable development.

21. Policy L2 - Land south of Lutterworth Road/Coventry Road. Outline planning consent has been granted and accordingly it should be regarded as an existing commitment for the purposes of the Local Plan.

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.

These representations have been prepared on behalf of our client Barwood Homes Ltd in respect of its interest in Bowden Sawmill, north of Leicester Lane, Great Bowden. See attached document

The extent of our client's land interest is shown on the attached Site Location Plan.

SS1: Object
Great Bowden currently has Selected Rural Village status in the Harborough District Core Strategy (2011). This means that some level of development will be is likely to be directed to the village on a scale that reflects the size and character of the settlement. Selected Rural Villages have been identified on the basis of the presence of at least two of six relevant services (food shop, GP surgery, library, post office, primary school and pub).

Great Bowden currently has four of these Key Services; these are a Primary School (Great Bowden Academy Church of England Primary School, Gunnsbrook Close); two Pubs (The Shoulder of Mutton, The Green; The Red Lion Inn, Main Street); and Food Stores/Post Office (Bowden Stores, The Green - Fresh produce and Off License; Welton's, The Green - Post Office, Newsstand, Deli Counter and Tea Room (ATM located here too)).

The Settlement Profile for Great Bowden confirms that with 4 out of the 6 key services, it has the level of services to become upgraded from a Selected Rural Village to a Rural Centre. Barwood Homes considers that the spatial strategy for the district should be amended so that Great Bowden is upgraded from a Selected Rural Village to a Rural Centre.

GD2: Support and Object
Barwood Homes objects to the wording of Policy GD2 Part 1 (a) as it only seeks to support housing where 'it does not cumulatively with other proposals, significantly exceed the target for the delivery of new homes in Rural Centres and Selected Rural Villages specified in Policy H1: Provision of New Housing.' Whilst this approach is not generally objected to, the wording of Policy GD2 Part 1(a) provides difficulty in determining applications for 'development within or contiguous with the existing or committed built up area of...Rural Centres and Selected Rural Villages' where the Rural Centres and Selected Rural Villages in question do not have an identified target set out in Policy H1.
Policy H1 makes reference to and provides a specific housing target for all Selected Rural Villages apart from Great Bowden. Although it is understood that this approach was adopted due to the scale of previous development permitted in the village, the Plan fails to make any reference to why this decision was taken. Furthermore, Policy H1 only makes reference to the Rural Centres of Billesdon, Fleckney, Great Glen and Houghton on the Hill as having housing targets. The wording adopted under Policy GD2 Part 1(a) would therefore prohibit 'development within or contiguous with the existing or committed built up area of' Great Bowden, Husbands Bosworth, The Kibworths and Ullesthorpe.

However, Barwood Homes supports the approach to separate reference to 'previously developed land which is not of high environmental value' within GD2(Part 2), thus meaning that such development is not subject to criteria (a-d) of GD2 Part 1. This approach would allow the development of appropriate previously developed land to come forward within all settlements. However, it is considered that this approach needs to be made clearer within the policy, as it is important and in accordance with national policy that LPAs 'encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value.' This is established within the Core Planning Principles at para 17 of the NPPF.

H1 Provision of New Housing

As set out above, it is considered that Great Bowden should be identified as a Rural Centre and an appropriate housing target assigned accordingly.

In any event, the relationship between Policy H1 and Policy GD2 needs to be addressed in accordance with the comments made above.

In so far as Policy H1 relates to the Policies Map and Inset Plans, Barwood Homes considers that there is no justification for omitting Bowden Sawmill from the limits to development for Great Bowden. As is evident from Figure 2 below, the site is intensively developed brownfield land that directly adjoins the settlement; the Harborough Local Plan limits to development should therefore be revised to include the site.

Finally, in reviewing the role of Great Bowden in the settlement hierarchy, the LPA should also have regard to the comments in the proceeding section below.

Consider that there will be a shortfall in the number of dwellings built over the plan period and the plan will not therefore be sound.

Policy H1 identified land for a minimum of 4660 houses during the plan period to 2031.

The policy states that at Fleckney, for example, a minimum of 295 dwellings will be required for which the only allocation is for land at Arnesby Road where 130 dwellings has been identified.

Refer to attached document.

Refer to attached document.

On behalf of my client, Richborough Estates, I write to submit representations to the consultation on the Harborough District Local Plan: Submission Version. These representations relate to land Richborough is currently promoting for residential development at Kimcote Road, Gilmorton. The site was subject to a recent outline planning application for up to 43 houses (ref 17/00885/OUT), which now has a resolution to grant planning consent following the meeting of Planning Committee on 3 October 2017.
We support the strategic priorities identified in the Local Plan, and in particular the objective of meeting housing needs for both Harborough District and the wider Leicester and Leicestershire Housing Market Area (HMA). However, the local planning authority must ensure that the strategy taken to meeting these priorities takes full account of the most recent evidence of housing need for the HMA, and in particular the fact that both Leicester City and Oadby and Wigston District Councils have confirmed that they will not be able to meet their full needs within their own administrative areas.
If the Harborough Local Plan is to be adopted in advance of the extent of unmet need being confirmed, or its distribution between the remaining authorities in the HMA being agreed, a firm policy commitment must be made to undertake a prompt review of the Local Plan to address these matters at the earliest possible opportunity. In the meantime, and in anticipation of the role Harborough is expected to play in meeting unmet need in the HMA, it would be prudent for the overall level of development and range of identified sites to be increased. Such an approach will ensure that the Local Plan is sound at the time of examination, and capable of providing the certainty and plan-led approach which is required.
The distribution of development set out in Policy SS1 The Spatial Strategy, and in particular the identification of Selected Rural Villages (SRVs) to accommodate appropriate levels of growth, is supported. However, consideration should be given to the allocation in the Local Plan of sites across all tiers of the settlement hierarchy for which growth is planned. For SRVs where options for growth are limited, and/or Neighbourhood Plans which allocate housing sites are not being taken forward, the allocation of sites in the Local Plan will ensure the delivery of sufficient levels of development across the full range of the settlement hierarchy. This will reduce the risk of certain settlements and tiers of the hierarchy not making their required contribution to meeting Harborough's housing requirements, and ensure that the plan is both effective and positively prepared. The failure to make such allocations could risk the plan not being found sound.
We broadly support the distribution of development as defined in Policy H1 Provision of New Housing, and the proposed levels of development in the SRVs being expressed as minima. We also support the identification of Gilmorton as a SRV, which correctly reflects the range of services and facilities available in the village and confirms its sustainability and suitability as a location for growth.
The deliverability of Richborough Estates' site at Kimcote Road is demonstrated by the Planning Committee's resolution to grant planning consent on 3 October 2017, subject to completion of a Section 106 agreement which is now close to being finalised. It is anticipated that the site will be marketed before the end of 2017, to enable to swift submission of reserved matters and commencement of delivery on this sustainable site in 2018.
I trust these representations are of assistance and will be taken into consideration. If you have any queries or require any further information then please do not hesitate to contact me.

On behalf of my client, Richborough Estates, I write to submit representations to the consultation on the Harborough District Local Plan: Submission Version. These representations relate to land Richborough is currently promoting for residential development at Kimcote Road, Gilmorton. The site was subject to a recent outline planning application for up to 43 houses (ref 17/00885/OUT), which now has a resolution to grant planning consent following the meeting of Planning Committee on 3 October 2017.
We support the strategic priorities identified in the Local Plan, and in particular the objective of meeting housing needs for both Harborough District and the wider Leicester and Leicestershire Housing Market Area (HMA). However, the local planning authority must ensure that the strategy taken to meeting these priorities takes full account of the most recent evidence of housing need for the HMA, and in particular the fact that both Leicester City and Oadby and Wigston District Councils have confirmed that they will not be able to meet their full needs within their own administrative areas.
If the Harborough Local Plan is to be adopted in advance of the extent of unmet need being confirmed, or its distribution between the remaining authorities in the HMA being agreed, a firm policy commitment must be made to undertake a prompt review of the Local Plan to address these matters at the earliest possible opportunity. In the meantime, and in anticipation of the role Harborough is expected to play in meeting unmet need in the HMA, it would be prudent for the overall level of development and range of identified sites to be increased. Such an approach will ensure that the Local Plan is sound at the time of examination, and capable of providing the certainty and plan-led approach which is required.
The distribution of development set out in Policy SS1 The Spatial Strategy, and in particular the identification of Selected Rural Villages (SRVs) to accommodate appropriate levels of growth, is supported. However, consideration should be given to the allocation in the Local Plan of sites across all tiers of the settlement hierarchy for which growth is planned. For SRVs where options for growth are limited, and/or Neighbourhood Plans which allocate housing sites are not being taken forward, the allocation of sites in the Local Plan will ensure the delivery of sufficient levels of development across the full range of the settlement hierarchy. This will reduce the risk of certain settlements and tiers of the hierarchy not making their required contribution to meeting Harborough's housing requirements, and ensure that the plan is both effective and positively prepared. The failure to make such allocations could risk the plan not being found sound.
We broadly support the distribution of development as defined in Policy H1 Provision of New Housing, and the proposed levels of development in the SRVs being expressed as minima. We also support the identification of Gilmorton as a SRV, which correctly reflects the range of services and facilities available in the village and confirms its sustainability and suitability as a location for growth.
The deliverability of Richborough Estates' site at Kimcote Road is demonstrated by the Planning Committee's resolution to grant planning consent on 3 October 2017, subject to completion of a Section 106 agreement which is now close to being finalised. It is anticipated that the site will be marketed before the end of 2017, to enable to swift submission of reserved matters and commencement of delivery on this sustainable site in 2018.
I trust these representations are of assistance and will be taken into consideration. If you have any queries or require any further information then please do not hesitate to contact me.

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.

See attached.

The representation concerns land off Burnmill Road (land rear of Top Yard Farm), Great Bowden. The site boundary is attached.

The site is contained within unit 3 in the Area of Separation Review 2017. The
review found that unit three forms part of a primary contribution to the Area of
Separation. However it is considered that the west of unit 3 is different to the east,
and notably the representation site is self-contained and screened by mature trees,
thick vegetation and existing residential development. We submit that the site should be removed from the Area of Separation.

Given the sustainable location, the site would make an appropriate residential allocation. The entire site is in single ownership and is immediately deliverable, and could be brought forward in the next 5 years.

See attached documents.

Land to the Rear of The Ridgeway (see attached map) is well suited to a residential allocation and development could occur within a 1-5 year time frame. The April 2017 Area of Separation Review confirms that coalescence will not be compromised given the position and context of the site and the site could potentially accommodate circa 45 dwellings at a standard density of 30 units per hectare.

We support the removal of the land from the Area of Separation, and suggest given the site's location and my client's control of number 54 The Ridgeway, the site would make an appropriate residential allocation to fill the unallocated numbers within the district.

The entire site is in single ownership and is immediately deliverable, and this is recognised by the 2016 SHLAA which identifies the land could be brought forward in the next 5 years.

See attached documents.

The representation concerns land off Main Street, Great Bowden. The site boundary is shown in attachment.

This site should be removed from the Area of Separation, as the Area of Separation Review found that the westerly section of the representation site presented only a secondary benefit to the Area of Separation. It is considered that all of the representation site should only provide limited benefit due to the screening of the site.

Given the sustainable location, the site would make an appropriate residential allocation. The entire site is in single ownership and is immediately deliverable, and
could be brought forward in the next 5 years. The landowners believe that a high
quality development, based on the concept of a Village Green would be in-keeping
with the characteristics of Great Bowden and would be complementary to its unique
character and style. Any such scheme would be widely consulted on with local
stakeholders, and would be designed in accordance with the Neighbourhood Plan.

The representation site is well suited to a residential allocation and whilst the SHLAA (May 2016) states development could occur within a 6-10 year time frame, the site is available now.

Comments provided in the Area of Separation Review 2017 confirm that part of the site provides only a secondary benefit to the Area of Separation. It is considered that all of the representation site should only provide limited benefit due to the screening of the site.

Our client would be prepared to offer some of the site for use as a village green to replace those historic greens within the village which have been lost. We believe that the site could become the new "Middle Green" in Great Bowden.

The site is suitable for a small residential allocation of up to 15 dwellings and the representation site will not contribute to the coalescence between Market Harborough and Great Bowden, because the site is self-contained and screened.

We suggest that the site should be removed from the defined Area of Separation, and allocated for a Village Green-style small residential development of up to 15 dwellings.

The landowners of Whetstone Pastures, duly object to the failure of the Council to recognise the potential to:

* Identify land within Whetstone Pastures as a future logistics park; and more over
* Recognise the ability of land within Whetstone Pastures to deliver a new Garden Village as part of a large strategic allocation extending over the administrative boundaries of both Blaby and Harborough.

2 On this basis objections are duly made insofar as SS1 - The Spatial Strategy is not 'sound' insofar as it is not:

* Positively Prepared as it fails to meet objectively assessed development needs and infrastructure requirements, including, where they arise, potentially making an appropriate contribution towards meeting unmet requirements from neighbouring authorities;
* Justified in that the plan is not based on the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
* Effective in that the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy as the plan does not enable the delivery of sustainable development in accordance with the policies in the NPPF.

3 With regard to SS1 it is submitted the following strategic priorities of the Local Plan (pp. 9) are not fully met:

* SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas;
* SP2: Assisting other local authorities to meet their unmet housing need; and
* SP3: Meeting regional and national demand for strategic distribution (logistics) development.

4 This is predicated on the basis that:

* Policy H1 - fails to make provision for sufficient new housing for the Plan period;
* Policy BE1 - fails to make provision for sufficient new business development for the Plan period; and
* Policy BE2 - fails to identify land at Whetstone Pastures as a potential logistics park.

5 Policies H1, BE1 and BE2 are effectively drafted on the basis of Harborough meeting its own objectively assessed needs. Accordingly, the draft Plan fails to recognise the wider needs of its neighbours as established in January 2017 when the Leicester and Leicestershire Authorities (including Harborough and Blaby) and LLEP jointly published its HEDNA which identifies the future quantity of housing and employment land needed in Leicester and Leicestershire up to 2031 and 2036.

6 The HEDNA has identified an Objectively Assessed Need for 117,900 dwellings between 2011 and 2036 across Leicester and Leicestershire. The need for larger more strategic warehousing and distribution units across Leicestershire is set out in the Leicester and Leicestershire Strategic Distribution Study 2015 (updated in 2017).

7 Leicester City Council has indicated that there will be unmet housing need within the City. A letter from Leicester City Council to all the other local planning authorities in the HMA dated 13th February 2017 stated that;

"the scale of the need [OAN] set out in the HEDNA is of such magnitude that it is concluded that there will be an unmet need arising in the city'. An additional letter sent on the same day to the Planning Inspector for the examination of the North West Leicestershire Local Plan set out 'our formal declaration of unmet housing need arising in the city."

8 In addition to setting out the future housing and employment requirement the document recognises that there is a need for all authorities within the Leicester and Leicestershire Housing Market Area to work collaboratively to account for the distribution of any identified unmet need.

9 On the basis of the foregoing local authorities have a statutory Duty to Cooperate over such matters and to identify how any such needs would be met. A Memorandum of Understanding (MoU) is currently being prepared by the 9 local authorities within the HMA (including Harborough). This document will identify how any unmet housing needs will be accommodated and will be signed by each authority as a binding agreement.

10 Given that the unmet needs of Leicester City Council should be addressed within the period of the Harborough emerging Local Plan the landowners are very concerned that there is no flexibility within the Plan to demonstrate how Harborough will accommodate unmet need through policies H1, BE1 and BE2 to meet this need.

Harborough DC - New Local Plan Options

11 The Council will be aware of representations made to Harborough DC - New Local Plan Options document (2015) by Nathaniel Lichfield & Partners (NLP) on behalf of Prologis UK Limited (Prologis). The representations principally related to proposals for a new logistics park on land between junctions 20 and 21 of the M1.

12 In broad terms the landholding related to an area in excess of 185 ha to the east and west of the proposed new M1 junction 20a (Whetstone Pastures Estate). The land is located to the south east of Cosby and west of Willoughby Waterleys. The Estate straddles the administrative boundaries of both Harborough and Blaby.

13 At the time of the submission the landowners and Prologis were promoting:
A new motorway Junction 20a on the M1 to relieve congestion at Junction 21 and to help remove an obstacle to further economic development;
* A new motorway service area to replace the existing Leicester Forest East motorway service area allowing for the managed motorway programme to be introduced; and
* A new 370,000 sq m logistics park on approximately 80 ha next to the proposed Junction 20a that would deliver over 6,000 high quality jobs in a wide range of roles.

14 Representations were duly made and recorded as follows:

* New Local Plan Options (September 2015), (rep. ID 2680 / 4242); and
* 'Sustainability Appraisal - Second Interim Report Appraising Options for Strategic Distribution Growth (February 2016) (rep ID 5327 / 5326 and 5245).

15 The representations were endorsed by the landowners in a follow up written submission lodged by Strutt & Parker on the 28th June 2016.

A New Garden Village

16 Since these submissions Blaby District Council, with the support of Leicestershire County Council and the Leicester and Leicestershire Local Enterprise Partnership (LLEP), made a submission in response to the Department for Communities and Local Government (DCLG) and Home and Communities Agency's (HCA) invitation for Garden Village proposals in July 2016.

17 The proposed Garden Village would be focused around a new M1 junction at 20a. The total site area would extend to approximately 400 hectares and would include the 185 hectares previously identified for the logistics park. Whilst the majority of the site falls within the administrative boundary of Blaby some 15% of the southern part of the landholding lies in Harborough. Please see attached map for more detail.

18 Whilst the bid was not successful the HCA in their individual letter of response went on to encourage the continued pursuit of the Garden Village idea:

"The HCA is responsible for delivering the Garden Villages Programme for the DCLG and we recognise the potential of your proposal. We would like to have a conversation with you around how we can best support you in progressing your Garden Village ambitions. There is scope for us to offer support from our planning Team ATLAS, from delivery specialists in our teams and in HCA's Land Team. We hope to open another round of Garden Village Funding in 2017/2018 and offer guidance in preparing applications."

19 Blaby District Council are continuing to work with the landowners to deliver a shared vision for the Garden Village proposals.

20 The proposals are at an early stage. However, the Local Authority and landowners have a shared goal to develop the ideas into fully-fledged proposals over the next 12-24 months. In broad terms it is envisaged that the Garden Village would offer a unique opportunity to deliver truly sustainable strategic growth; comprising of a new community, large scale employment opportunities and considerable benefits for the surrounding highways network. Specifically the plans would ensure:

* The delivery of a new M1 Junction (J20a):
* Approximately 280,000 sqm employment and logistics park; and
* In excess of 3,500 homes.

It is envisaged that this sustainable new community would deliver facilities including schools, healthcare and sports, and green and blue infrastructure, new local shops and other community facilities, all set within an attractive landscaped network of streets and parks. All this on a site located approximately 5km from the major commercial hub of Leicester City Centre.

Policy H1 - Provision of New Housing sets out the proposed distribution by settlement for a minimum residual housing land supply of 4,660 dwellings in the plan period. Policy H1 includes two Strategic Development Areas (SDA) allocations, three site allocations in Market Harborough for 1,140 dwellings (Policies MH1 - 3) and one site allocation in Fleckney for 130 dwellings (Policy F1).

This policy outlines that Harborough District Council is able to meet all of its housing requirement within the District, evidenced by the Strategic Housing Land Availability Assessment (SHLAA), 2016. The Plan, as at paragraph 5.1.5., notes that should any local authorities within the Leicester and Leicestershire HMA be unable to meet their full housing needs, because of either a lack of physical capacity or significant harm to the principles and policies of the NPPF, there will be a need to consider whether those needs can be met elsewhere within the HMA.

Given current uncertainty over the extent of any unmet need within the Leicester and Leicestershire HMA, this is not a sound basis upon which the Plan can reasonably progress. Any such unmet need must be considered fully at this stage in order to ensure compliance with the tests of soundness, and any relevant provisions of the NPPF. The Plan cannot be considered positively prepared, effective or consistent with national policy. If the Council continues with this approach, it will not have demonstrated the Duty to Co-operate.