H1 Opening sentence

Manor Oak Homes are actively involved in the development
of the Kibworths and are committed to enabling the sustainable development of the parishes to help meet the local area's housing, employment, education and community infrastructure needs. It is in this context that Manor Oak Homes are making these representations as they seek to ensure that the Local Plan provides for the sustainable development needs of the area. As currently drafted they do not believe that the draft plan proposes the most appropriate strategy when considered against reasonable alternatives and based on proportionate evidence, nor is effective as it will not ensure the delivery of the required level of development over the plan period.
Manor Oak Homes welcome the Council's proposal to meet the District's full Objectively Assessed Housing Need (OAHN) of 10,640 dwellings (2011-2031), plus a small uplift to respond to the Magna Park Growth Sensitivity Study and an additional 15% contingency. While they are supportive however of a strategy that includes SDAs, they have concerns regarding the extent to which the Lutterworth and Scraptoft SDA's will deliver new housing during the plan period in accord with the Council's assumptions and consider that the decision not to give the
Kibworths a minimum housing target fails to recognise its sustainability and that allocating further land for housing offers the opportunity to resolve current infrastructure constraints i.e education. In this context, they have significant concerns regarding the effectiveness and therefore the soundness of the Proposed Submission Local Plan in delivering the proposed housing requirement (in accordance with NPPF Paragraph 182).
While Manor Oak Homes are disappointed that an SDA to the west of the Kibworths is not being proposed by the emerging plan, they accept that a number of parcels of land within it now have planning permission and represent commitments such that the remainder cannot provide the scale of additional development required of an SDA.
They are surprised though that given the relative sustainability of the land to the west of the Kibworths as demonstrated by its positive performance when the proposed SDA was assessed as part of the Sustainability Appraisal accompanying the Harborough Local Plan: Options Consultation Paper - September 2015, and the positive conclusions drawn regarding the sustainability of the Kibworths in determining a number of recent planning applications there, that the plan does not set a minimum housing requirement for the settlement. Manor Oak Homes do not therefore wish to object to the proposed allocation of land at Scraptoft and Lutterworth as SDA's but they are concerned by the overly optimistic assumptions being made by the emerging plan regarding their delivery and believe that there is a need to allocate additional land for housing. So far as new housing
should be directed where it can best respond to local needs and thereby promote sustainable patterns of development, they further believe the plan has erred in not setting a minimum housing requirement for the
Kibworths and that additional housing land should be allocated there.

Policy H1 states that in addition to the 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:
1. Scraptoft SDA - 1,200 dwellings in accordance with Policy SC1;
2. Market Harborough - a minimum of 1,140 dwellings on three allocations;
3. Lutterworth SDA - 1,500 dwellings in accordance with Policy L1;
4. Fleckney - a minimum of 295 dwellings, including one allocated site for 130 dwellings;
5. Rural Centres - a minimum of 10 dwellings in Billesdon, 35 in Great Glen and 65 in Houghton on the Hill; and 6. Selected Rural Villages - minimum targets set of between 10-50 dwellings for specific villages.

The level of development proposed meets the District's full Objectively Assessed Housing Need (OAHN) of 10,640 dwellings (2011-2031), plus a small uplift to respond to the Magna Park Growth Sensitivity Study and an additional 15% contingency in the supply of housing land 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.
Manor Oak Homes consider that this policy is unsound as it is not positively prepared, justified or effective.

Positively Prepared and Justified

As outlined at Enclosure 1, the Kibworths is by far the largest of the Rural Centres and should actually be considered to be a Key Centre due to its size and its role providing key retail, service and employment infrastructure. In this context, Manor Oak Homes consider that the decision not to give the Kibworths
a minimum housing target fails to recognise its sustainability and that allocating further land for housing offers the opportunity to resolve current infrastructure constraints i.e. education.

Policy H1 sets minimum housing targets for the majority of the settlements in the district, with the exception of Broughton Astley (which is set to deliver significant housing through its made neighbourhood plan), the Kibworths and several settlements that are considered too small to accommodate growth. The Kibworths is therefore the only settlement above the level of very small villages not to be set a minimum housing target. Section 17 of the draft plan explains the reason for this decision stating that: "Given the high number of commitments already in place, there is no minimum target set for the Kibworths in the Local Plan."

This decision leaves by far the largest of the Rural Centres, and one that actually performs as a Key Centre, as having fewer homes proposed to be allocated than the majority of the Selected Rural Villages. We question the sustainability of this approach and the justification behind this decision. The Local Plan states that there have been over 400 dwellings completed since 2011 in the Kibworths and there are planning commitments for nearly 450 further homes. This level of development is given as the reason for not planning for further sustainable growth, but further investigation shows that the Council has not based this decision on a thorough consideration of reasonable alternatives as required by NPPF Paragraph 182 for the Local Plan to be considered sound.

First and foremost, the Local Plan identifies the level of housing completions since 2011 in the Kibworths as significant in demonstrating that the Kibworths are already meeting their share of development. This is not the case, however, as this high level of delivery is primarily a result of the build out of Land off Wistow and Warwick Road that was allocated for development by Policy KB/1 of the Harborough District Local Plan adopted in April 2001. The delivery of these homes is therefore not a sign of the Kibworths meeting a proportion of current needs, but rather the much-delayed development of a site that was allocated to meet the needs of the district in the previous plan period that ended in 2006. Conversely, the delivery of 400 dwellings since 2011 is actually therefore a sign of past under delivery which the Kibworths is only just catching up with. Recent housing commitments that have come forward due to the Council's inability to demonstrate a five-year housing land supply are a further demonstration of this need to catch up with past under delivery.

Secondly, the Proposed Submission document identifies the level of committed development in the Kibworths as further justification for not allocating any additional land. This indicates a short-sighted decision-making process that fails to assess reasonable alternatives fully or fairly and therefore fails to assess the sustainability of the Kibworths as a location for growth. As outlined in the cover letter to these representations, the Kibworths was identified in the Harborough Local Plan: Options Consultation Paper (2015) as a potential option for a Strategic Development Area (SDA) of up to 1,200 dwellings. The Kibworth SDA option was then shortlisted as one of four preferred options for assessment, before a decision was made to allocate land at Lutterworth and Scraptoft North as the Council's proposed SDAs. In this respect, the approach that has been taken by the Council has been one of extremes - either the Kibworths are allocated with an SDA or they receive no additional development at all. There has been no assessment of the needs of the settlement, nor any recognition of how additional development at a smaller scale to the previously proposed SDA could still achieve many of the benefits of the SDA that are desperately needed, most notably a new primary school site (as detailed further at Enclosure 6).

Effectiveness

As outlined, the provision for housing set out at Policy H1 proposes to deliver a 15% contingency uplift on the OAHN in order to allow for possible future circumstances affecting the supply of housing in the district. We welcome and support this proposed strategy to deliver an uplift on the OAHN, but raise concern regarding one of the stated reasons for this contingency i.e. "a slower delivery than expected on housing allocations and/or the strategic development areas".
Manor Oak Homes consider that it is prudent to include a contingency to provide a buffer against unforeseen circumstances that cannot reasonably be predicted or planned for (e.g. economic factors and potential unmet need elsewhere in the HMA), but such a buffer should only be used when circumstances affecting housing need or delivery are genuinely unpredictable. As is explained at Enclosures 3 and 4, Manor Oak Homes consider that the two SDAs are likely to fail to deliver the predicted number of homes during the plan period resulting in a shortfall against the plan requirement of circa 1,050 homes. This shortfall would account for the majority of the 15% uplift and would leave very little flexibility in the housing supply to meet truly unpredictable circumstances. Policy H1 cannot therefore be considered to represent an effective policy in accordance with NPPF Paragraph 182 as it will not deliver the level of development proposed alongside an adequate buffer to account for unforeseen circumstances.

Omission Site 1 - Land West of Warwick Road

Land to the West of Warwick Road, Kibworth Beauchamp, as identified on Plan 2 below, should be allocated for up to 400 dwellings, together with a new 2 form primary school in response to acute capacity issues at the existing school and to provide additional housing in a sustainable location that can assist in making up for an anticipated shortfall in the Council's predicted delivery at Lutterworth
and Scraptoft North SDAs.

The allocation of Manor Oak Homes' Land to the West of Warwick Road, we consider, would assist in resolving some of the current problems relating to the soundness of the draft Local Plan. As explained in our representations contained at Enclosures 1-4, the Local Plan cannot in its current form be considered sound as it is unjustified in including the Kibworths as a Rural Centre and not a Key Centre
(see Enclosure 1) and on this basis it fails to plan positively for the needs of the Kibworths going forwards or to consider its potential to deliver sustainable housing growth over and above its current commitments (Enclosure 2). In addition, it makes overly optimistic assumptions regarding the delivery of the proposed SDAs at Lutterworth and Scraptoft North meaning that the plan will be ineffective in
ensuring the delivery of the proposed housing requirement (Enclosures 3 and 4).

Land West of Warwick Road offers an important opportunity to assist in ensuring that the Local Plan is sound and that the needs of the Kibworths will be met by resolving capacity issues at the existing primary school and providing additional housing in a sustainable location.

Primary School
As the Education Report prepared by EFM at Appendix 3 explains, the existing primary school in the Kibworths, Kibworth CE Primary School, has been expanded a number of times and is now a threeform entry school. It is one of the largest primary schools in Leicestershire, and the County Council considers that it is incapable of further expansion due to site constraints. This point is confirmed in the
committee reports for both Manor Oak Homes' application at Land to the South-East of Warwick Road (Ref: 15/01153/OUT) and David Wilson Homes' application at Land North of Fleckney Road, Kibworth Beauchamp (Ref: 16/00166/OUT):
* The December 2015 report for Land to the South-East of Warwick Road notes that the school had recently submitted a planning application for expansion to 630 places and that "This would take the school to the maximum size desirable, as set out in LCC's Pupil Place Planning Strategy "In the Right Place". It notes LCC's advice that "662 pupils are projected on the roll should this development proceed" which is a clear deficit even with the expansion plans; and
* The May 2017 report for Land North of Fleckney Road note that "Since September 2016, the school has increased its net capacity to 630 (90 per year group). This is the maximum size desirable, as set out in LCC's Pupil Place Planning Strategy" and "LCC Education have advised that 713 pupils are projected on the roll should this development proceed; a deficit of 83 pupil places after taking into account the 47 pupils generated by this development."

The S106 agreement for Manor Oak Homes' proposals at Land South-East of Warwick Road secures significant financial contributions towards education improvements at other schools and transport costs for transporting pupils to schools elsewhere. The resolution to grant planning permission for David
Wilson Homes' application is subject to a S106 agreement securing similar obligations. It is evident therefore that the inability of the existing primary school to be expanded represents a significant constraint to ensuring that existing committed developments in the Kibworths can be sustainably delivered.

Leicestershire County Council (LCC), as the authority with statutory responsibility for the provision and commissioning of school places, works with the school and Academy Trust to ensure the provision of sufficient school places in the locality. However, it is clear from the determination of the above applications that there are no plans to increase educational capacity in the Kibworths. The David Wilson
Homes' committee report states that "Instead pupils would be offered places at the next nearest schools with financial contributions from the developer used for the provision, improvement, remodelling or enhancement of education facilities at schools in the locality of the development." This is a far from ideal from a sustainability perspective and would lead to large numbers of primary aged children in the Kibworths travelling elsewhere to go to school, particularly when opportunities to resolve this matter exist.

As the EFM report notes, Land to the West of Warwick Road offers an important new opportunity to make a sustainable addition to primary education provision which is well placed to meet local needs, and will help address local concerns about the pressure on the existing school. The provision of this school site would ensure the sustainability of the existing approved developments in the Kibworths and
there is therefore considerable justification for allocating the proposed site for development to achieve this significant benefit to the local community. Furthermore, as noted in the EFM report, the expected pupil yield from an additional 400 dwellings, as now proposed by Manor Oak Homes, together with other committed developments, will be more than sufficient to sustain a new primary school.

As explained at Enclosure 1, the Kibworths is by far the largest of the Rural Centres and should be defined as a Key Centre, so far as it represents a sustainable location for growth due to its size and its role providing key retail, service and employment infrastructure. As outlined at Enclosure 2, Manor Oak Homes consider that the decision not to give the Kibworths a minimum housing target fails to recognise its sustainability as a settlement in addition to failing to consider how development there could assist in meeting the needs of the settlement going forward and resolving existing infrastructure constraints.

In the context of the above, we consider that the allocation of additional housing in the Kibworths represents a particularly appropriate and sustainable option for meeting the anticipated shortfall in the Council's predicted delivery at Lutterworth and Scraptoft North SDAs (as outlined at Enclosures 3 and 4). Furthermore, Manor Oak Homes consider that their Land West of Warwick Road is the most sustainable option available in the Kibworths to provide the significant level of additional housing needed so far as it is located adjacent to Manor Oak Homes' approved developments at Land to the South-East of Warwick Road and Land to the South and West of Priory Business Park and David Wilson Homes' site at Land North of Fleckney Road. The sustainability of land to the west of the Kibworths was recognised in the Council's Sustainability Appraisal of potential SDA options following their Options Consultation in September 2015 and was accepted by the appeal inspector in her consideration of our client's appeal relating to their land to the south-east of Warwick Road (Ref: APP/F2415/W/16/3152485). In the decision notice for this appeal, the inspector states that:
"Based on the evidence that is before me and observations gleaned from my site visits, it is clear that future occupiers of the proposed development would have access to everyday local facilities and services using means other than the private car" (Paragraph 20). "the appeal proposal would be in a location where services and facilities would be readily accessible by sustainable modes of travel" (Paragraph 23).

The Inspector's conclusion was based upon the following observations:
- The Kibworths, is served by an extensive range of services and facilities, including two schools (one primary and one secondary), newsagents, supermarket, doctors surgery, health centre, pharmacy, community library, post office, two churches, restaurants, pubs, a range of other shops and a number of halls and other accommodation for use by community groups;
* There is an acceptable and deliverable walking route between the site and these local facilities (n.b. land to the west of Warwick Road would also benefit from this route);
* The Kibworths is served by several bus services providing connections to Leicester, Market Harborough and other settlements. Furthermore, whilst there would be access to an existing bus service from a bus stop within the Kibworth Meadows development, a short walk from the appeal site, new bus stops are proposed on Warwick Road to directly serve the proposal. These would provide direct access to local facilities by public transport (n.b. these new bus stops will be located adjacent to the promoted site); and
* The recently granted planning permission for new retail and employment facilities on land to the south and west of Priory Business Park are within a short walking distance to the north of the appeal site (n.b. they are a similar distance from the promoted site).

This appeal decision clearly demonstrates the sustainability of the promoted site for development as it is located directly across Warwick Road from the appeal site and would also be accessed off Warwick Road. In the Statement of Common Ground agreed between the Council and the appellant ahead of the appeal, all of the above points were agreed upon and it is therefore clear that the Council considers the promoted site to be sustainably located.

Appropriateness for Residential Development

In addition to the clear sustainability of the site's location and the significant social benefits that would accrue from its allocation, it meets the required tests of delivery, as set out below and there should be no hesitation from the Council in releasing it for residential development:
Available:

The application site is within a single ownership and is wholly in the control of Manor Oak Homes. As such, no barrier exists to prevent a planning application on the site being submitted immediately and the proposed scheme being implemented immediately following achieving planning consent. Suitable: The site represents a suitable and unconstrained location for the proposed development, as follows:
* Landscape: The site is identified in Harborough District Council's Rural Centres Landscape Capacity Study (July 2014) as having a medium-high capacity to accommodate development and in general the west side of the Kibworths is least constrained in landscape terms. The Initial Landscape and Visual Appraisal prepared by Aspect Landscape Planning and contained at Appendix 3 (Ref: 6080.LBN.001), confirms that the surrounding landscape has the capacity to accommodate development and that the proposed development can be successfully integrated in this location.
-Heritage: The site is in an area of overall low to moderate potential for archaeological remains being present and is located some distance from any listed buildings and the Kibworths' two conservation areas. By virtue of distance, vegetation and intervening development, including modern housing estates, the site is effectively separated from any heritage designations and would have little to no impact from a heritage perspective. The site compares positively to other locations around the Kibworths in this respect and in particular land to the north and east of the settlement where there is a higher concentration of recorded archaeological sites, land is in close proximity to the Kibworth Harcourt Conservation Area and there are a number of listed buildings located near to potential development sites including the Grade II* listed Kibworth Post Mill, which is also a Scheduled Ancient Monument, Grade I listed Old House and Grade II* listed St Wilfred's Church and Grade II listed Kibworth Hall.
* Ecology: The Preliminary Ecological Review prepared by Aspect Ecology and contained at Appendix 4 (Ref: 1005105 BN02 EOD dv1), confirms that the site is not constrained by any statutory or non-statutory ecological designations and that the habitats present are dominated by intensively managed arable land, which is of negligible ecological value. There are some small areas of habitat value on site (e.g. hedges and ponds) which have been incorporated into the indicative proposals as part of substantial areas of open space that will enhance the value of the site for wildlife. *
-Arboriculture: The site is largely absent of any significant tree cover, but there are some examples of high quality trees along the sites boundaries and along field boundaries within the site. The Preliminary Arboricultural Appraisal prepared by Aspect Arboriculture and contained at Appendix 5 (Ref: ARB9733), confirms that a sympathetic design such as that shown on the submitted Masterplan Sketch at Appendix 1 would enable the integration of important trees and mitigation for low quality removals, such that development would enhance the arboricultural interest of the site. *
-Highways: The Highways Improvements / Capacity Note prepared by JPP Consulting and contained at Appendix 6, identifies a number highways improvements that would mitigate the impact of the development on the surrounding road network. In addition to these improvement works, the inclusion of a school on the proposed allocation would reduce the number of vehicles on the Kibworths' roads associated with people accessing the existing school and the proposed school would reduce the highway impact from developments with planning permissions already granted.
* Flood Risk: The site is in Flood Zone 1 (i.e. Low Risk).

Achievable:

As referred to above, a package of technical assessments have been prepared, which confirms that there are no significant constraints to the development of the site. Accordingly, upon the grant of the necessary consents, the provision of new housing is achievable with immediate effect.

A report last year from Lichfields (http://lichfields.uk/media/1728/start-to-finish.pdf) identifies that the average planning approval period for schemes of 100-499 dwellings is 2.4 years with an additional 1.6 years from approval to first delivery (i.e. 4 years total) and that following the grant of planning permission the average annual build out rate is 60 dwellings per year.

Manor Oak Homes are currently preparing detailed proposals for the site with a view to submitting an outline planning application by the planned adoption date of the Local Plan October 2018, if not before. Based on industry standards contained in the Lichfield's report, if an application were submitted in October 2018, building would start in October 2022 and the scheme would deliver 60 dwellings by October 2023 (i.e. within 5 years of the adoption of the Local Plan). The proposed allocation is therefore achievable with a realistic prospect that housing will be delivered on the site within five years (in accordance with NPPF Paragraph 47 Footnote 11) and is considered fully developable within the plan period as outlined in the table below. 18/19-App, 19/20-App, 20/21-App, 21/22-App, 22/23-30, 23/24-60, 24/25-60, 25/26-60, 26/27-60, 27/28-60, 28/29-60 29/30-10, 30/31-0 Total: 400

Viable:

Manor Oak Homes are an established promoter of development sites with a track record of delivering viable planning consents in the Kibworths; as is demonstrated by the sale of their Land at Wistow Road, Kibworth Harcourt to Mulberry Developments. Manor Oak Homes achieved outline planning permission on this site in 2015 and Mulberry Development subsequently received reserved matters consent in May 2017 and are currently discharging conditions ahead of commencing development in the very near future.

Manor Oak Homes has a unique understanding of the local property market and can confirm that the site represents an viable source of housing land capable of viable delivery in the short-term.

Omission Site 2 - Land at St Wilfrid's Close

Land at St Wilfrid's Close, Kibworth Beauchamp, as identified on Plan 3 below, should be allocated for up to 45 residential units in order to provide additional housing in a sustainable location that can assist in making up for an anticipated shortfall in the Council's predicted delivery at Lutterworth and Scraptoft North SDAs.

Background

At the Council's Planning Committee meeting on 7th November 2017, members unanimously resolved to grant full planning permission, subject to a S106 agreement, for the erection of 45 retirement living apartments with associated access, parking and outdoor amenity space (Ref: 17/00500/FUL) at Land at St Wilfrid's Close, Kibworth Beauchamp. The officer's report to committee provides a comprehensive assessment of the scheme and finds the site to be a sustainable location for residential development and the proposals to be in compliance with relevant national and local planning policies.

Soundness

The representations contained at Enclosures 1-4 raise a number of concerns regarding the soundness of the emerging Local Plan, which for the most part relate to the decision not to afford the Kibworths, one of the more sustainable settlements in the District, a minimum housing requirement and the overly.optimistic assumptions that underpin the anticipated delivery rates from the two proposed SDAs and which are likely to result in the plan being ineffective in delivering the overall housing requirement over the plan period. In this context, it is considered that additional land should be allocated in the Kibworths to ensure the rolling delivery of new housing in sustainable locations. Land at St Wilfrid's Close for residential development represents one such parcel of land that could make a positive contribution in this regard.

As explained at Enclosure 1, the Kibworths is by far the largest of the Rural Centres and should be defined as a Key Centre, so far as it represents a sustainable location for growth due to its size and its role providing key retail, service and employment infrastructure. As outlined at Enclosure 2, Manor Oak Homes consider that the decision not to give the Kibworths a minimum housing target fails to recognise its sustainability as a settlement in addition to failing to consider how development there could assist in meeting the needs of the settlement going forward and resolving existing infrastructure constraints.

In the context of the above, we consider that the allocation of additional housing in the Kibworths represents a particularly appropriate and sustainable option for meeting the anticipated shortfall in the Council's predicted delivery at Lutterworth and Scraptoft North SDAs (as outlined at Enclosures 3 and 4). Having received a resolution to grant planning permission Manor Oak Homes consider that their land at St Wilfrid's should be allocated for residential development to ensure its delivery.

Appropriateness for Residential Allocation

Land at St Wilfrid's comprises a rectangular paddock of low grade agricultural land with no existing structures totalling approximately 0.97ha. It is located within the settlement boundary and built up area of Kibworth Beauchamp near the centre of the village and has existing access from the end of St Wilfrid's Close that can easily be upgraded to serve a residential development. In addition, there is a second gated access to the southwest of the site leading to an adjacent footpath from which the village's facilities located along the high street are only circa 400m walk from the site. The site is also highly accessible by public transport with local bus services to Market Harborough, Leicester and surrounding areas a short walk away on either Church Road or High Street (both approximately 300-400m walk).

There are no statutory environmental designations on the site or in the immediate surrounding area and the nearest heritage designation is the Kibworth Beauchamp Conservation Area which is located to the east and south of the site and at its closest point is more than 80m east from the site. The recent resolution to grant planning permission on the site confirms that the site can accommodate 45 residential dwellings in a way that respects the constraints and opportunities that the site affords. In doing so, it recognises the suitability and available of the site to deliver new and viable housing in the short term.

Page 15 of the Proposed Submission Local Plan identifies 'Meeting Housing Needs' as a Key Issue for the Local Plan.

Paragraph 5.1.17 of the Proposed Submission Local Plan explains "The scale of new housing to be provided in individual settlements reflects the roles of different places in the settlement hierarchy (see Policy SS1 The spatial strategy). These roles partly reflect the population size of the settlements and their location in respect of other settlements but also relate to the range of activities and services present and, in relation to primary schools, their ability to expand to accommodate the needs generated by new development."

Policy H1 is silent in respect of growth at Broughton Astley, identified as a Key Centre at Policy SS1. There is no supporting evidence within the Sustainability Appraisal 2017 to suggest the Council has considered the potential for Broughton Astley to accommodate additional growth, notwithstanding the recently adopted Neighbourhood Plan..

It is acknowledged that the nine Leicestershire local authorities and the Local Enterprise Partnership (LEP) have worked together to prepare the Leicester and Leicestershire Housing and Economic Development Need Assessment (HENDA) 2017. However, it is apparent from review of the Duty to Cooperate Statement 2017 (page 9) that not all authorities have concluded whether they can plan to meet their own needs or whether they will require assistance from surrounding authorities. To date both Leicester City Council and Oadby and Wigston Borough Council have stated that they will not be able to meet their needs within their administrative boundaries.

Harborough Council's Duty to Cooperate Statement states at paragraph 4.11 that a final Memorandum of Understanding is only expected to be available in January 2018, at which point Harborough Council is expecting to submit its Local Plan for Examination, a point beyond which alterations should not be made to the Local Plan.

Paragraph 5.1.10 of the Proposed Submission Local Plan states that "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"; albeit that the Council explains at paragraph 6.17 of its Duty to Cooperate Statement that "the Local Plan should provide land for an uplift of 20% over OAN, bringing the total housing land provision to 12,800 dwellings. This would allow for a contingency to meet unforeseen circumstances and flexibility to make a contribution towards any unmet needs from other Councils that arise across the Housing Market Area (HMA)."

However, the Council's position as explained at paragraph 6.20 of the Duty to Cooperate Statement is "If in the future, an agreement is reached through the Duty to Cooperate, for Harborough to meet some of Leicester's or Oadby and Wigston's unmet needs, then this would further increase the housing requirement" and therefore it is our interpretation that this would reduce any contingency planning for Harborough's housing need, therefore its ability to respond to slower than expected delivery, non-implementation of existing consents, economic change, and flexibility and choice in the housing market.

It is unclear at this stage whether there will be unmet housing need within the Leicester and Leicestershire Housing Market Area and whether this would be further exacerbated as a result of the Harborough Local Plan progressing ahead of other Local Authorities within the Housing Market Area. This is an unsound basis on which to prepare a Local Plan and therefore the current version of the plan cannot be considered positively prepared, effective or consistent with national policy.

In addition the Government has published a consultation document setting its thoughts for a standardised approach for the calculation of objectively assessed housing need. It maybe that the Council will be required to update its evidence base in light of any new Government Guidance, albeit the consultation document does include allowance for transitional arrangements.

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.

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.

Land north-east of Kibworth Harcourt:

Savills and Andrew Granger & Co. have prepared these representations on behalf of Merton College and Leicester Diocesan Board of Finance in respect of their land interests to the north-east of the Kibworth Harcourt.

If the Harborough Local Plan 2011 - 2031 is to be found sound at examination, it must satisfactorily meet the four tests of soundness as set out in the NPPF. The Plan should be positively prepared, justified, effective, and consistent with national policy. In its current iteration and for the reasons set out in this correspondence, the Plan is considered unsound.

Our clients' land interest incorporates land to the north-east of Kibworth Harcourt. The site comprises a total site area of circa 182 hectares. An Illustrative Masterplan Framework demonstrating the extent of land ownership is enclosed.

The site is considered a suitable option for a possible reserve site. The site is capable of delivery for a strategic development area for circa 1,600 homes, employment uses, associated open space and a bypass, based on the Aspinall Verdi Residential Options Viability Interim Report (One) (April 2016).

The provision of a bypass at Kibworth has been a longstanding aim for the Council. Strategic mixed use development at Kibworth could be utilised to secure an appropriate level of developer funding towards the provision of a bypass at Kibworth. Our clients' land ownership is well placed to facilitate such a proposal.

Our clients' interests at Kibworth would contribute well to the achievement of sustainable development as per relevant guidance of the NPPF, including necessary economic, social, and environmental roles. Morevoer, the inclusion of strategic development area at Kibworth would be likely to increase significantly the robustness of the plan to providing more flexibility and a clear contingency to assist the Council in demonstrating an adequate housing land supply in the latter half of the plan period.