Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 12852
Received: 01/05/2025
Respondent: Parker Strategic Land Ltd
Agent: Miss Jessica Herritty
We have provided a review of the scoring set out in the SA, and it is noted that there is some uncertainty in relation to the effects of development, however it has reinforced the opportunity that Scraptoft North presents for a sustainable and accessible development, providing significant positive effects in respect of several of the SA objectives. Accordingly, we strongly urge the Council to reconsider the continued allocation of the Scraptoft North SDA.
Appendix F of the Sustainability Appraisal presents a map showing the location of the sites considered for allocation in the New Local Plan. The sites comprising the Scraptoft North SDA are referred to as 3 parcels:
• 24/12222 Land west of Beeby Road (Scraptoft Golf Club), and land east and west of Hamilton Lane – Housing
• 24/10117 Land west of Beeby Road (Scraptoft Golf Club), and land east and west of Hamilton Lane – Mixed use
Appendix E of the Sustainability Appraisal contains a table which explains the Council’s reasons for selecting or rejecting site options. It confirms that the site at Scraptoft North site has not been taken forward as a proposed allocation as “the site is not developable within the Local Plan period”.
This notwithstanding, the site remains available, suitable for development and is the subject of an ongoing planning application, supported by a substantial evidence base, it is therefore considered to be capable of delivering during the plan period. Furthermore, it is located in a sustainable location within the Leicester Urban Area, as such, retaining the allocation of this site in the emerging plan would achieve the key objectives set out by the emerging plan.
Paragraph 2.41 of the Sustainability Appraisal sets out the methodology for how each site has been scored / appraised against the Sustainability Appraisal (SA) objectives in the SA framework (see Chapter 3), with symbols being attributed to each option to indicate their likely effects on each SA objective as shown in the table / image below. Where a potential positive or negative effect is uncertain, a question mark was added to the relevant symbol (e.g. +? or -?) and the symbol was colour coded in line with the potential positive, negligible or negative effect (e.g. shades of green, blue, purple, yellow, pink, etc.). A key to symbols and colour coding is shown below.
[Image to be provided separately]
Having regard to table 6.1 in the Main Report, the sites comprising Scraptoft North are scored as follows:
[Image to be provided separately]
SA Objective 6: Safeguard and improve community health, safety and wellbeing
The purpose of the objective is to score sites highly that are within walking distance of existing health services and facilities (good access to healthcare), while being in close proximity to open spaces and footpaths and cycle routes (more active lifestyles).
Part of the site has been considered as likely to have significant positive effects (++) as it lies within 720m of the referenced ‘assets’, whilst the remainder of the site is scored as having a minor positive effect (+).
SA Objective 9: Provide affordable, sustainable, good-quality housing for all
All of the residential site options are expected to have positive effects on this objective, due to the nature of the proposed development. It is expected that sites of a larger size may be able to offer a wider mix of housing, including affordable housing, as well as making a greater contribution towards local housing needs.
The site has been considered as likely to have a significant positive effect (++).
SA Objective 10: Support the sustainable growth of the economy and provide good employment opportunities
The site has been considered as likely to have a minor positive effect (+) as the site is within walking distance (600m) of either: public transport links or one or more Key and General employment area and / or major employment site.
However, the site should be considered as likely to have a significant positive effect (++) given the proximity of the site to Leicester city centre, which provides access to a significant number of jobs, and as set out by these representations, will be in close proximity to the largest proposed employment allocation in the district.
SA Objective 13: Promote sustainable transport and active travel use
This SA objective considers the proximity of development sites to sustainable transport links, which in turn affects the extent to which people are able to make use of non-car based modes of transport to access services, facilities and job opportunities.
The site has been considered as likely to have a minor positive effect (+) as the site is more than 1.8km from a railway station but within 450m of a bus stop.
However, the site should be considered as likely to have a significant positive effect (++) as the planning application has demonstrated the capacity for improved bus infrastructure on site, whilst the proposed development (as per the current planning application) would also include other uses (including retail), reducing the need to travel by car for day to day needs.
Conclusion
Although as noted in the scoring above, there is some uncertainty in relation to the effects of development, it has reinforced the opportunity that Scraptoft North presents for a sustainable and accessible development, providing significant positive effects in respect of several of the SA objectives.
Accordingly, we strongly urge the Council to reconsider the continued allocation of the Scraptoft North SDA.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13010
Received: 02/05/2025
Respondent: Mulberry Land
Agent: Miss Jessica Herritty
The Bushby site has been found to be as sustainable, if not more sustainable, than most proposed residential allocations. It is also clear that the site scores more highly than several of those identified for allocation by the emerging plan.
Land at Bushby is developable given that it is promoted by a house building business, the land is not restricted in any way, and is not subject to any policy designations nor constraints that cannot be mitigated during the technical work required to support a planning application.
We strongly urge the Council to reconsider this site for allocation.
Please refer to the uploaded documents Land off Uppingham Road, Bushby – Reps to the Evidence Base SA and Land off Uppingham Road, Bushby – Site Opportunity and Promotion Statement submitted in response to the proposed plan objectives and policies DS03, SA01 and DM05.
Appendix F of the Sustainability Appraisal presents a map showing the location of the sites considered for allocation in the New Local Plan. The site being promoted by our clients for up to 850 new homes to the south of Uppingham Road in Bushby was given the reference 21/8150.
Appendix E of the Sustainability Appraisal contains a table which explains the Council’s reasons for selecting or rejecting site options. It confirms that the Bushby site has not been taken forward as a proposed allocation “Given its encroachment into open countryside to the south and east (towards Houghton on the Hill), the site is not considered an appropriate location for residential development when compared with other locations and deliverable sites of a similar scale within the Scraptoft, Thurnby and Bushby area. The site was put forward for mixed use development. As the site is not considered appropriate for residential development, it is unavailable for consideration for employment use.” We would point out that any employment to be considered at this location, would only be included as a supportive use such as small scale convenience opportunities in support of a residential development.
The above notwithstanding, the Landscape Constraints and Opportunities Plan and Concept Masterplan supporting these representations demonstrate how the site could come forward (see Appendix 2) incorporating landscaping and green space to the south, west and east of the site. This would essentially contain the development of the site, which would form a natural extension of the sustainable settlement of Bushby.
The site has been promoted for a mixture of uses, including employment and residential uses, to discount this site on the basis that it would be “unavailable” for employment use is incorrect.
Furthermore, the feedback provided by planning officers at the pre-application stage suggests that officers accept the site is capable of delivering sustainable development and does not appear to have any significant technical constraints to development (subject to further technical assessment).
Paragraph 6.49 notes that mitigation would be required should this site (and others) be considered for allocation through the plan given the “high level of greenfield development, historic assets and Local Wildlife Sites in Harborough district”.
Considering the potential impact of greenfield development, it is reiterated that Bushby is a sustainable location for development, located within the Leicester Urban Area, which is the area of focus to meet the needs of Harborough district and the unmet needs of Leicester City, in accordance with the emerging development strategy. Although development of the site would inevitably result in the loss of some greenfield land, this should be considered against the importance of delivering much needed housing, in sustainable and accessible locations, whilst development would incorporate high quality design, public open space and integrate PROW’s to ensure access is still retained to the countryside beyond the site (see Appendix 2).
Having regard to heritage assets, the Grade II Listed “Milestone” is located beyond the northern boundary of the site off Uppingham Road. There are several listed buildings within Bushby, although these are around 1km to the west of the site. This notwithstanding, during pre-application discussions officers acknowledged that there is little evidence of heritage assets on the site and limited within the vicinity of the site. Officers have recommended a heritage assessment is undertaken to assess any impact on the setting of the Bushby Conservation Area to support a planning application, which is considered to be a standard approach for development on sites such as this.
Paragraph 6.6 of the SA (Chapters) notes that the site could have “significant negative effects as they contain all or part of a LWS, and some are also within 250m of national biodiversity designations”. The Bushby Spinney Local Wildlife Site is located centrally on site whilst the Scraptoft Local Nature Reserve, is approximately 2km to the north west of the site. The site lies within the SSSI Impact Risk Zone associated with several designations to the south-east, the closest of which is approximately 10km from the site. This notwithstanding, during pre-application discussions Officers acknowledged the presence of Bushby Spinney in the southern part of the site, but considered that there would be opportunities to enhance biodiversity on site.
Chapter 7 of the SA presents the appraisals of the proposed site allocations in draft Policy SA01. The scores for a number of the proposed allocations against the SA objectives are set out within the table below (see uploaded document). The Bushby site (land off Uppingham Road) was assessed within the Sustainability Appraisal and is included within the table below.
The Bushby site generally scores at a similar level to the sites chosen to be allocated for development in the New Local Plan and against several objectives, scores more highly.
SA Objective 6: Safeguard and improve community health, safety and wellbeing
The purpose of the objective is to score sites highly that are within walking distance of existing health services and facilities (good access to healthcare), while being in close proximity to open spaces and footpaths and cycle routes (more active lifestyles).
The site has been considered as likely to have significant positive effects (++) as it lies within 720m of all of the referenced assets. This includes a healthcare facility (Bushby Branch Surgery), an area of open space (off Davenports Hill), and footpaths along the A47.
The site’s location, accessibility and connectivity into existing connections will promote health and wellbeing, allowing for access to the surrounding spaces and encouraging sustainable transport methods such as walking and cycling, which in turn will promote good health. There are significant opportunities to reduce levels of crime through careful and considered design initiatives, creating a safe and inviting residential environment. By comparison, sites identified for allocation have scored less favourably, achieving only minor positive effects.
SA Objective 9: Provide affordable, sustainable, good-quality housing for all
All of the residential site options are expected to have positive effects on this objective, due to the nature of the proposed development. It is expected that sites of a larger size may be able to offer a wider mix of housing, including affordable housing, as well as making a greater contribution towards local housing needs.
The site has been considered as likely to have a significant positive effect (++) as it could accommodate over 500 dwellings (up to 850 dwellings). This is a significant opportunity to deliver a wide range of housing, including the delivery of much needed affordable housing, potential for housing for older people, and housing for self-custom build opportunities. The promoter, Mulberry Land, operates an in-house house-building business which delivers housing of the highest quality. Therefore, the quality of housing stock will be improved. This means that not only is the site available, but it is deliverable and achievable in the shorter term given that the promoter specialises in delivery of housing.
Against SA9, sites much smaller than land at Bushby have been scored with a ++, such as land off Frolesworth Road for 475 homes, land west of Warwick Road for 475 homes, and land south of Gallow Field for 600 homes, which are significantly smaller. We question the logic used here, scoring these sites the same as that off Uppingham Road, and we strongly urge the Council to reconsider land at Bushby as a significant opportunity capable of delivering significant positive effects against this Objective, particularly when considering the smaller scale of the sites identified for allocation.
SA Objective 10: Support the sustainable growth of the economy and provide good employment opportunities
The site has been considered as likely to have a minor positive effect (+) as the site is within walking distance (600m) of either: public transport links or one or more Key and General employment area and / or major employment site.
However again this is something we strongly disagree with. The site should be considered as likely to have a significant positive effect (++) as public transport is available directly from the site into Leicester city centre, which provides access to a significant number of jobs. Given the proposed scale of the development at Bushby, there is also the opportunity to route a bus service into and through the site (through dialogue with operators) to enable improved access to employment opportunities.
The site at Bushby presents employment opportunities in support of the local economy given the potential for delivery of a local centre to include convenience shops and services on the site. Alongside this, the promoter has been engaging with a high-end leisure provider, which will provide significant employment opportunities for local people, whilst also diversifying the economy. Such employers offer a wide range of jobs at varying levels.
As an example, it is unclear how and why draft allocation S2 Land at Beeby Road for 175 dwellings is scored more favourably than land at Bushby, particularly given its separation and distance from key services, plus difficult issues surrounding sustainable transport and decent highway linkages.
Accessibility in a north-south direction around the eastern edge of Leicester is problematic from a highways perspective, given that the key routes into Leicester City run from east to west, such as the A47 Uppingham Road. This, couples with the A6 further to the south, is the only route running into the City from the east, capable of handling higher levels of traffic associated with growth. Our concern remains that some allocations presented in the draft plan will simply not be deliverable due to highways constraints.
SA Objective 13: Promote sustainable transport and active travel use
This SA objective considers the proximity of development sites to sustainable transport links, which in turn affects the extent to which people are able to make use of non-car-based modes of transport to access services, facilities and job opportunities.
The site has been considered as likely to have a minor positive effect (+) as the site is more than 1.8km from a railway station but within 450m of a bus stop.
However, the site should be considered as likely to have a significant positive effect (++) as public transport is available directly from the site to Leicester city centre, providing access to Leicester City Railway Station, which in turn provides access to the rest of the UK including direct services to Lincoln, Sheffield, London St. Pancras International, Nottingham, Birmingham New Street and Cambridge.
As previously set out, through engagement with operators, there is an opportunity to route a bus service through the proposed development, thus delivering and promoting the use of an improved sustainable mode of transport. Walking and cycling routes will be enhanced and created throughout the proposed site, not only internally, but delivering connections via routes into Bushby, Thurnby and east to Houghton on the Hill.
Given the proposed scale of the site, reliance on private vehicles will be reduced for future residents, as the services delivered on site will ensure journeys are localised and within shorter distances.
Conclusion
It is abundantly clear that the Bushby site has been found to be as sustainable, if not more sustainable, than most of the sites proposed for allocation for residential development in the New Local Plan. It is also clear that the site scores more highly than several of those identified for allocation by the emerging plan.
As set out above, the key reasons for the site being omitted from the emerging Local Plan pertain to the perceived impact development would have on the landscape, heritage assets, Local Wildlife Site and that it would be unavailable for employment development.
This notwithstanding, Officers confirmed through our pre-application discussions that there are not considered to be any significant constraints to development that could not be addressed through technical assessment and appropriate mitigation supporting a planning application. This has also been confirmed through the initial evidence base work undertaken and submitted with these representations.
Land at Bushby is absolutely developable, including for employment generating uses, given that it is promoted by a house building business who specialise in delivering high quality developments, who have also been liaising with potential providers interested in the site. The land is not restricted in any way and is not subject to any policy designations nor constraints that cannot be mitigated during the technical work required to support a planning application.
We maintain that there is continued strong evidence from the market for housing at this location, and we support a successfully developed residentially led community at Bushby, to introduce small-scale retail and leisure centre uses.
Accordingly, we strongly urge the Council to reconsider this site for allocation.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13382
Received: 06/05/2025
Respondent: Mrs Mariola Hudson
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13383
Received: 06/05/2025
Respondent: Mrs Mariola Hudson
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13387
Received: 06/05/2025
Respondent: Mrs Mariola Hudson
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Who will be in a position to purchase these houses? I suspect that most of the houses will not be owned and occupied by private individuals and therefore I object.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13606
Received: 01/05/2025
Respondent: E Taylor Consulting Ltd
Agent: Marrons
The SA process did not test the refined options against a higher or lower housing requirement. There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could at least potentially provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
The overall quantity of growth has not been adequately tested through the SA process and therefore the housing requirement lacks justification.
See attachment.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13631
Received: 01/05/2025
Respondent: NS Consultancy Limited
Agent: Marrons
The SA process did not test the refined options against a higher or lower housing requirement. There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could at least potentially provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
The overall quantity of growth has not been adequately tested through the SA process and therefore the housing requirement lacks justification.
See attachment/s.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13633
Received: 04/05/2025
Respondent: Besh Limited
Agent: Marrons
We disagree that only meeting the District's own LHN is a reasonable option. There is a compelling case to test a higher housing requirement because of: recent housing delivery trends, the wider issue of an HMA-wide shortfall over the plan period beyond 2036. Given these considerations, we suggest that the overall quantity of growth is subject to further testing through the SA process.
See attachment.
Support
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13635
Received: 04/05/2025
Respondent: David Wilson Homes East Midlands
Agent: Marrons
There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends mentioned above, but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed
given that alternative scales of growth were not tested beyond the initial spatial options.
Given these considerations, we would suggest that the overall quantity of growth subject to further testing through the SA process.
See attached representations document.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13642
Received: 02/05/2025
Respondent: Vistry Group
Agent: Pegasus Group
The reasons for rejecting or selecting different options are not clearly set out in the SA report.
The reason for selecting or rejecting certain site options relies on the fact that council has decided the level of development that should be accommodated in certain settlements. However without a clear description of the process that led to the identification of levels of development in certain settlements, the site selection process is flawed and is not justified.
See attachment/s.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13693
Received: 06/05/2025
Respondent: Trustees of the Crane Estate and Mrs Jean Williams
Agent: Twenty5
In account of the scores afforded to the Land South of Dunton Road (24/12209) in relation to BNG, soil, historic environment, flood risk and landscape, the Crane Estate do not support the findings of the Sustainability Appraisal and recommend that the following amendments are made in order for the Sustainability Appraisal to be considered sound and justified, as per paragraph 36 of the NPPF:
• The Site should score minor negative effect in relation to SA Objective 3 on the basis that the wider Leicestershire area is rural in nature and therefore to ensure that the
District Council meet their development requirements, it will be necessary to develop agricultural land
• The Site should score negligible effect in relation to SA Objective 12 given the Site is located in Flood Zone 1 and proposes a suitable drainage strategy to mitigate any
surface water flooding onsite.
• The Site should score minor negative effect likely in relation to SA Objective 14 on the basis that the proposals will retain strong landscaping buffers along the Site boundaries and also propose large portions of open space and green corridors onsite.
See attachment.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13711
Received: 06/05/2025
Respondent: Bloor Homes
Agent: Stantec UK Ltd
In account of the above scores afforded to S2 (Land at Beeby Road, Scraptoft) in relation to soil, flood risk and landscape, Bloor Homes do not support the findings of the Sustainability Appraisal and recommend that the following amendments are made in order for the Sustainability Appraisal to be considered sound and justified, as per paragraph 36 of the NPPF:
• S2 should score minor negative effect in relation to SA Objective 3 on the basis that the wider Leicestershire area is rural in nature and therefore to ensure that the District
Council meet their development requirements, it will be necessary to develop agricultural land
• S2 should score negligible effect in relation to SA Objective 12 given S2 is located in Flood Zone 1 and proposes a suitable drainage strategy to mitigate any surface water flooding onsite. It is further noted that pre-application discussions have not raised any significant concerns in relation to S2 proposals and flood risk
• S2 should score negligible effect likely in relation to SA Objective 14 on the basis that the proposals will retain strong landscaping buffers along the Site boundaries and also propose open space and green corridors onsite.
See attachment/s.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13733
Received: 02/05/2025
Respondent: Richborough
Agent: Boyer Planning Ltd
The Council have opted to pursue a combination of the low (A) and medium (B) growth option as HDC are only providing for Leicester City’s unmet need for the first 16 years of the plan. We consider this is not justified in accordance with the NPPF’s test of soundness and is not a scenario which was previously assessed as part of the SA and therefore is not an appropriate strategy.
We consider given the increase in housing requirement as a result of the new standard method (December 2024) and to accord with the transitional arrangements the high growth scenario needs to be pursued.
Overall, although it is welcomed that HDC have considered a more proportional approach to housing distribution we consider this could go further in order to support growth at all scales of the settlement hierarchy. We also consider an appropriate buffer and higher growth scenario need to be implemented in order to ensure the soundness of the Plan.
See attachment.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13739
Received: 01/05/2025
Respondent: Catesby Estates
Agent: Marrons
The SA process considered three housing growth options. Only meeting the District’s own LHN is not a “reasonable alternative,” as this would not meet Leicester’s unmet housing need and not be consistent with national policy or DtC.
Recent housing delivery trends are close to the 'high growth' scenario. There is a clear/compelling case to test a higher housing requirement not only because of recent housing delivery trends but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could at least potentially provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
The SA process should consider higher growth scenarios across the refined distribution options.
See attachment for representations for Catesby Estates in respect of the site at 'Land east of Welford Road, Husbands Bosworth' (HB1).
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13740
Received: 04/05/2025
Respondent: NS Consultancy Limited
Agent: Marrons
The overall level of growth had already been fixed in line with Option B and the SA process did not test the refined options against a higher or lower housing requirement.
There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends mentioned above, but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could at least potentially provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
Accordingly, we do not consider that the overall quantity of growth has been adequately tested through the SA process and therefore the housing requirement lacks justification.
See attachment/s
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13768
Received: 01/05/2025
Respondent: Castlethorpe Homes
Agent: Boyer
We consider, the stages which define the SA to be robust in nature and ensure that the fundamental areas in relation to the plan making process have been considered. However, there is a heavy reliance placed on large strategic sites which could struggle to deliver the required housing numbers across the plan period as anticipated. It would be a more sound and positive approach to plan making if smaller sites in lower tiers of the settlement hierarchy were identified in the local plan process. This would assist in the delivery of growth across the District and avoid potential speculative applications being submitted to meet the shortfall in growth.
See attachment for full representations including those relating to the promotion of the site 'Land South of Shawell Road, Swinford'.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13770
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Disagree that only meeting the Districts own LHN is a reasonable alternative for SA, as not consistent with national policy or the legal Duty to Cooperate. We encourage the SA process and the wider evidence base to consider an aspirational scenario.
No clear reasoning for why the 'High' growth option was not taken forward.
There is a clear and compelling case to test a higher housing requirement, which should be explored through the SA.
See attachment/s
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13790
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Overall, although it is welcomed that HDC have considered a more proportional approach to housing distribution we consider this could go further in order to support growth at all scales of the settlement hierarchy. We also consider an appropriate buffer and higher growth scenario need to be implemented in order to ensure the soundness of the Plan.
Also we consider that our client's site at west of Leicester Road, Fleckney scores the same if not better than F1 in relation to the SA objectives but has not been put forward as a proposed allocation. We consider it should be reassessed taking into account the location context and
planning permission for recent solar scheme.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13795
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Disagree that only meeting the Districts own LHN is a reasonable alternative for SA, as not consistent with national policy or the legal Duty to Cooperate.
We encourage the SA process and the wider evidence base to consider an aspirational scenario.
No clear reasoning for why the 'High' growth option was not taken forward.
There is a clear and compelling case to test a higher housing requirement, which should be explored through the SA.
See attachment/s
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13800
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Option B (HDC’s LHN plus 123 dpa to address Leicester’s unmet housing need) was selected as the preferred option. We disagree that only meeting the District’s own LHN is a “reasonable alternative,” as this would be tantamount to the HDC turning its back on Leicester’s unmet housing need, which would not be consistent with national policy or the legal Duty to Cooperate.
There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends mentioned above, but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed given that alternative scales of growth were not tested beyond the initial spatial options.
Given these considerations, the overall quantity of growth has not been fully explored through the SA process
See attachment for full representation document.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13891
Received: 04/05/2025
Respondent: Davidsons Developments Limited
Agent: Marrons
Disagree that only meeting the Districts own LHN is a reasonable alternative for SA, as not consistent with national policy or the legal Duty to Cooperate. We encourage the SA process and the wider evidence base to consider an aspirational scenario.
No clear reasoning for why the 'High' growth option was not taken forward.
There is a clear and compelling case to test a higher housing requirement, which should be subject to further testing through the SA process.
See attachment/s.
Support
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13903
Received: 02/05/2025
Respondent: Ashfield Land
Agent: Pegasus Group
The Sustainability Appraisal (SA) (February 2025, Doc S-NLP4) published alongside the Reg 19 Proposed Submission Version Local Plan refers to the options and reasonable alternatives considered for employment land development in Harborough at Chapter 4.
NPPF paragraph 33 identifies that local plans should be informed throughout their preparation by an SA which meets the relevant legal requirements, and which should
demonstrate how the Plan has addressed relevant economic, social, and environmental objectives. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Proposed Submission Draft Local Plan, where the SA outputs should have informed the Council’s Vision, Objectives, Spatial Strategy and policies.
The SA has utilised a Framework to evaluate how the different reasonable alternatives for growth and the policies of the emerging Plan perform against the 14 SA objectives, identified in Chapter 3 of the SA. These are:
1 – Minimise greenhouse gas emissions and develop a managed response to the effects of climate change
2 – Protect, enhance and manage biodiversity and geodiversity
3 – Support efficient use of resources, including soils
4 - To conserve and enhance the historic environment including the setting of heritage features
5 – Protect and improve air quality
6 – Safeguard and improve health, safety and wellbeing
7 – Achieve social inclusion and equality for all
8 – Provide access to services, facilities and education
9 – Provide affordable, sustainable, good-quality housing for all
10 – Support the sustainable growth of the economy and provide employment opportunities
11 – Reduce waste generation and increase levels of reuse and recycling
12 – Manage and reduce flood risk from all sources and protect the quality and quantity of water resources
13 – Promote sustainable transport use and active travel
14 – To conserve and enhance the character and distinctiveness of the landscape
Within the SA, three options were considered in terms of the amount of employment growth that the Plan would provide for. These are identified as ‘low’, ‘medium’ and ‘high’ levels of growth but no quantums or size parameters are included in the SA.
The SA concludes that the ‘low’ level of growth would not be appropriate, and goes on to discuss the medium and high level options, but again there is no discussion on the quantums of development that are being assessed.
There are also three spatial options considered in the SA for the location of employment development. None of those options include new locations that would meet locational requirements and aspirations. Particularly for B8 uses, where the Council’s own evidence base sets out the locational requirements, and identifies optimum locations, for such development, including rail freight locations that would have access to other facilities particularly now the Hinckley NRFI has been refused.
The SA is not considered to have fulfilled its legal requirements to justify the Local Plan strategy. In neither referring to the quantums of development being considered at each ‘growth level’ for employment land, nor including for all reasonable alternatives in terms of the location of that growth, it is failing its legal requirements and the Local Plan itself cannot be considered to have proposed a sustainable strategy.
The SA has appraised the Ashfield Land’s interests south of Gibbet Lane, as well as the proposed allocations of land for strategic B8 employment development at Magna Park.
Ashfield Land’s land interests perform better than the proposed allocation of land of 15.8 hectares south of George House, Coventry Road with reference to Objective SA6 regarding safeguarding and improving health, safety and wellbeing, and comparatively for all other objectives.
Further, it is considered that the assessment of the land south of Gibbet Lane in respect of SA Objectives 12 and 14 should be reconsidered. Consultant work is being undertaken on flood risk and drainage to ensure the development will not increase the risk of flooding elsewhere, and detailed advice has been provided on landscape such that the development can be adequately assimilated into the landscape with no long-term significant adverse effects. As such the impact for both SA Objectives 12 and 14 should be neutral and minor
adverse or neutral respectively. Similarly, with a requirement to deliver 10% BNG, Objective SA2 should be considered neutral, or even minor positive. The proposed development will have no impact on any heritage assets and therefore the impact should be neutral.
Other matters have been considered based on site knowledge and any ambiguity such as the use of ‘question marks’ has been addressed.
Taking those matters into account it will actually perform better than the two proposed strategic B8 allocations, Table 1 provides a visual comparison.
In order to fulfil the relevant legal requirements, the SA must be reviewed and updated, or the Plan cannot be found sound. In addition, all SA Objectives and site reviews should not result in ambiguity over potential effects but take into account site specifics for each and provide a view on the potential impact on the relevant objective.
See attachment
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 13927
Received: 02/05/2025
Respondent: Catesby Estates
Agent: Nexus Planning
Policy SA03 does not comprise an appropriate strategy. As set out at Table 1 of our representations, with further consideration of our Site, it is demonstrated that the SA scoring (which informs Policy SA03) does not fully realise the sustainable merits of development on the Site (east of Market Harborough). Overall, it cannot be concluded Policy SA03 is justified but in any event, additional allocations are required having regard to our representations made in response to Policy DS01.
See attachments (representation and appendices).
Omission site: Land at Lodge Farm, Dingley,
Market Harborough adjacent to the eastern edge of Market Harborough (SHELAA ref: 21/8233).
Support
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 14017
Received: 06/05/2025
Respondent: Bloor Homes East Midlands
Agent: Stantec
As part of the supporting evidence base for the Draft Local Plan, a Sustainability Appraisal (February 2025) has been prepared by LUC on behalf of Harborough District Council.
The Sustainability Appraisal lists a series of objectives which include:
1) Minimise greenhouse gas emissions and develop a managed response to the effects of climate change
2) Protect, enhance and manage biodiversity and geodiversity
3) To support efficient use of resources, including soil
4) To conserve and enhance the historic environment including the setting of heritage features
5) Protect and improve air quality
6) Safeguard and improve health, safety and wellbeing
7) Achieve social inclusion and equality for all
8) To provide access to services, facilities and education
9) Provide affordable, sustainable, good-quality housing for all
10) Support the sustainable growth of the economy and provide employment opportunities
11) Reduce waste generation and increase levels of reuse and recycling
12) To manage and reduce flood risk from all sources and to protect the quality and quantity of water resources
13) Promote sustainable transport use and active travel
14) To conserve and enhance the character and distinctiveness of the landscape
The Site scores the following in relation to the above objectives:
1. Negligible effect likely
2. Minor negative effective likely / likely effect uncertain
3. Significant negative effect / negligible effect likely / likely effect uncertain
4. Minor negative effective likely / likely effect uncertain
5. Negligible effect likely
6. Minor positive effect
7. Negligible effect likely
8. Minor positive effect likely / negligible effect likely / likely effect uncertain
9. Minor positive effect likely
10. Minor positive effect likely
11. Negligible effect likely
12. Significant negative effect likely / negligible effect likely
13. Minor positive effect likely
14. Significant negative effect likely / likely effect uncertain
In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA). For these documents it is also necessary to conduct an environmental assessment in accordance with the requirements of the Strategic Environmental Assessment (SEA) Directive (European Directive 2001/42/EC), as transposed into law in England by the SEA Regulations and which remains in force despite the UK exiting the European Union in January 2020.
Turning to the assessment of the Site, it is positive to see that the Site mostly consists of positive, negligible or uncertain likely effects.
However, turning to the significant negative effects associated with SA Objective 3 (soil), given the rural nature of Harborough District, the majority of site options are expected to have significant negative effects on this SA objective as they consist of greenfield and agricultural
land. It is therefore essential that sites are reviewed on an individual basis rather than in comparison with other sites to assess the level of effect. Further to this, it is also not possible to avoid building on agricultural land if the required levels of housing are to be met, as discussed
throughout these representations. Bloor Homes therefore do not support the Site’s awarding in this regard and consider that the score should be changed to minor negative effect likely.
With regards to SA Objective 12, the entirety of the Site is located within Flood Zone 1 (as per the EA’s updated flood maps for planning). In terms of surface water flooding, there are nominal areas of this present onsite. This has been considered in the design of the Site with drainage
basins proposed along the northern end of the Site. It is considered that there are no technical concerns which cannot be overcome through appropriate mitigation. In this regard, it is considered that the scoring of significant negative effect likely should be amended to negligible
effect.
In terms of the landscape, the existing landscape and hedgerows will be retained onsite wherever possible to inform new public open space and green corridors. Strong buffer boundaries are proposed onsite and additional landscaping will be introduced. The north and western edges of the Site will comprise primarily of open space and tree planting. This is considered to be of particular benefit in in regard to landscape character. The existing
development to the south forms an abrupt modern boundary with the open countryside. Development of the Site in line with the concept masterplan would create a softer and more visually appropriate boundary with the countryside to the north and west. Therefore, Bloor
Homes consider that the score for the Site should be changed from significant negative effect likely to minor negative effect likely.
In account of the above scores afforded to the Site in relation to soil, flood risk and landscape, Bloor Homes do not support the findings of the Sustainability Appraisal and recommend that the following amendments are made in order for the Sustainability Appraisal to be considered
sound and justified, as per paragraph 36 of the NPPF:
• The Site should score minor negative effect in relation to SA Objective 3 on the basis that the wider Leicestershire area is rural in nature and therefore to ensure that the
District Council meet their development requirements, it will be necessary to develop agricultural land
• The Site should score negligible effect in relation to SA Objective 12 given the Site is located in Flood Zone 1 and proposes a suitable drainage strategy to mitigate any surface water flooding onsite.
• The Site should score minor negative effect likely in relation to SA Objective 14 on the basis that the proposals will retain strong landscaping buffers along the Site boundaries
and also propose large portions of open space and green corridors onsite whilst improving on the existing situation.
See attachment for representations.
This submission relates to Land at Stretton Road, Great Glen and is prepared by Stantec on behalf of Bloor Homes.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 14197
Received: 04/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Marrons
The Sustainability Appraisal (“SA”) process considered three options in relation to the overall level of housing growth. Option B (HDC’s LHN plus 123 dpa to address Leicester’s unmet housing need) was selected as the preferred option. We disagree that only meeting the District’s own LHN is a “reasonable alternative,” as this would be tantamount to the HDC turning its back on
Leicester’s unmet housing need, which would not be consistent with national policy or the legal
Duty to Cooperate.
Regarding the "high" growth option, a figure of 936 dpa has been tested, which is higher than the long-term average of 637 dpa since 2011 (the base year of the adopted local plan). However, relying on historical housing delivery trends to test future housing requirements may not fully address the ongoing challenges related to housing affordability and supply. The NPPF emphasises the need to “boost significantly” the supply of housing, reinforcing the importance of a forward-looking, evidence-based approach. We believe that reasonable alternatives for housing growth should not be benchmarked against past delivery rates but should instead focus on strategies to enhance housing supply, support economic growth, and address affordability concerns. We encourage the SA process and the wider evidence base to consider such an
aspirational growth scenario.
Recent housing delivery trends in Harborough show an average of 891 dpa from 2021/22 to 2023/24, which is close to the "high growth" scenario. This suggests that the District can practically sustain this rate of homebuilding. However, the SA does not clearly explain why the "high growth" option was rejected, though the Development Strategy Paper provides some reasoning, indicating that the “high” growth option would have the most negative impacts across all six spatial options. Table 4.1 of the Regulation 19 SA suggests that the differences between
the "high" and "medium" growth options are not significant for most SA objectives. There is no clear reasoning for why the “high” growth option was not taken forward.
In addition, neither of the six initial spatial distribution scenarios were taken forward in their totality. Refined distributional options were subsequently tested. By that time, however, the overall level of growth had already been fixed in line with Option B and the SA process did not test
the refined options against a higher or lower housing requirement. To support the HLP’s housing requirement, we consider that the refined spatial options for growth should be tested alongside the “high” growth option.
There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends mentioned above, but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed
given that alternative scales of growth were not tested beyond the initial spatial options.
Given these considerations, the overall quantity of growth has not been fully explored through the SA process.
See attachment/s.
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 14198
Received: 02/05/2025
Respondent: Colecar Strategic Land
Agent: Pegasus Group
The Local Plan Sustainability Appraisal assesses 3no. refined spatial options based on a refined medium growth that includes a 15% buffer but this does not apply to homes already built. The Sustainability Appraisal does not assess low or high growth scenarios of the refined
spatial options and so this should be undertaken to ensure the Sustainability Appraisal assesses all reasonable options appropriately.
Sustainability Appraisal
Chapter 5 of Sustainability Appraisal (SA) explains how the Council has considered six broad distribution options in November 2023 which led to 3 further refined options for the level and distribution of housing. The reasons for rejecting or selecting different options are not clearly
set out in the SA report.
The SA report refers to certain Council meetings, but case law determines that such reasons should be clearly set out within the SA document and there should not be a ‘paper chase’ to other documents, especially if they are not part of the Local Plan evidence published on the
Local Plan consultation website.
The reason for selecting or rejecting certain site and growth options relies on the fact that the Council has decided the level of development that should be accommodated in certain settlements .However, without a clear description of the process that led to the identification of levels of development in certain settlements, the growth and site selection process is
flawed and is not justified.
To positively plan for this, more homes will need to be distributed across the sustainable settlements particularly Large Villages and Kibworth.
As outlined above, the affordability in Harborough District and the ward of Kibworth is above the regional median affordability ratio. The amount of housing delivery in Kibworth has been limited since the allocations at Wistow Road and east of Warwick Road/Fleckney Road were
built out in 2020/21 and 2022/23, respectively. The Neighbourhood Plan has also only allocated 4no. sites with 20no. dwellings permitted on 2 of the sites so far and another 5no. dwellings allocated on the other 2no. sites. This has exacerbated the affordability within Kibworth.
In addition, demographically, there has been significant growth in the number of people aged 0 - 15 and 16- 64 in Kibworth. In order to retain people within these age groups and maintain sustainable demographic growth, appropriate housing supply must be provided for these
younger people. It is therefore considered that further housing should be directed towards Kibworth, and particularly smaller sites should be allocated such as our client’s site, which can deliver housing in the short term and would help to promote the development of a good
mix of sites within Kibworth.
Large Villages such as Kibworth will be a critical part of the development strategy alongside development in other sustainable locations in the District. New development in the Large Villages will complement the existing commitments identified through the adopted Local Plan.
The Large Village settlements are highly sustainable locations for growth, already benefiting from a range of services and facilities as identified in the Settlement Hierarchy Assessment. The scale of these settlements means that new homes can be within walking distance of
these services and facilities also benefitting from existing infrastructure. In turn new homes help to sustain services such as bus services, contributing to the continued sustainability of the settlement.
It will be important not to rely solely on large strategic sites and therefore development in the proposed Large Villages and other sustainable locations will be essential in combination with any strategic proposals.
The Council’s Settlement Profile (February 2025) identifies the settlement has a good range of services, facilities and shops including its one supermarket alongside Key and General Employment Areas. Kibworth is also served by a number of regular bus services including X3 and X7 to Market Harborough and Leicester, therefore residents can easily gain access to these services when required. In particular, our client’s site, Land North of Wentworth Close, Kibworth, is approximately 800m from the town centre and nearest bus stops served by the above- mentioned bus services.
The site is capable of delivering up to 65 dwellings. It is a logical and sustainable extension to the settlement limits and existing built- up area being bounded by built development to the north and southwest and other development to the south of the site.
See attachment
Object
Proposed Submission Draft Local Plan Sustainability Appraisal
Representation ID: 14199
Received: 02/05/2025
Respondent: William Davis Homes
Agent: WSP UK Ltd
DRAFT POLICY HN05 – HOUSING NEED: SELF AND CUSTOM BUILD HOUSING
William Davis Homes recognise that there is a local demand for self- and custom-build housing
plots, however it is not appropriate to assume 10% of all dwellings on residential sites of 40 dwellings or more should accommodate this.
Table 7.12 of the Local Housing and Employment Land Evidence Report (ref. EMP-NLP 2) identifies that in the most recent period (2023/24) there were 16 individuals on the register, however this data does not extend to the specific requirements of these individuals, such as
location. Although there is local interest, this does not necessarily translate to an interest in providing suitable plots across all large residential sites within the HDC. The evidence base therefore fails to provide adequate justification for this requirement and going above and beyond the currently adopted position (per Policy H5) of “the provision of land… as part of an appropriate
mix of dwellings”. As such, the choice of 10% (compared to an alternative proportion of sites) appears arbitrary; alternative levels of provision have not been tested within the Sustainability Appraisal to determine that this is the most appropriate.
While the policy states that a lower level of provision may be permitted where there is clear evidence of lower demand, there is limited provision in the policy for the point at which this will be considered adequate, stating this would only be the case if evidence is provided that a thorough marketing exercise has been undertaken over a period of at least 18 months. This would likely
result in vacant plots and require a new planning permission following this period. Unless the draft policy recognised that a reduced (e.g. 3-month) period was more appropriate, the requirements would limit the ability for sites to deliver their full development guideline, thus making the plan ineffective (per paragraph 36 of the NPPF) in reducing its ability to deliver the local housing need.
Therefore, a review mechanism should be built into the policy with explicit timescales of when plots identified to be delivered as self- and custom-build housing plots may be returned to the delivery of market housing.
Furthermore, the delivery of self- and custom-build housing plots is overly complex and unlikely to be feasible in a practical or logistical sense in the delivery of wider residential sites. As a result, there are likely to be health and safety implications through the co-delivery of the wider site with these self- and custom-build plots, which has not been reflected in the Sustainability Appraisal. The
Sustainability Appraisal (Table 7.6) has assumed positive effects for objectives 6, 7 and 9, however this is assuming (per the Health Impact Assessment, ref. PRE-NLP 4) that these levels are carried out across all sites, which is unlikely. Instead, there would be vast significant negative effects as a result of these plots not coming forward.
In recognition of the appropriacy of particular locations for the delivery of self- and custom-build housing plots, in their attractiveness to individuals on the local register and suitability of sites for allowing plots to come forward separately without negatively impacting delivery, the current position of adopted Policy H5 should be continued. This will ensure there is sufficient flexibility that correlates with the unpredictability of this specific market, rather than seeking these plots to deliver the objectively assessed local housing need of HDC, in addition to the draft expectations for affordable and specialist housing.
HN01 – HOUSING NEED: AFFORDABLE HOUSING
While William Davis Homes recognise the value in delivering affordable housing, the proposed continuation of the adopted requirement for 40% of homes on new developments to be affordable is inflexible and has not been adequately informed by the draft Plan’s evidence base.
The Local Housing and Employment Land Evidence Report (ref. EMP-NLP 2) assesses local housing needs and demographics by sub-areas within the District, recognising the spatial variation, including between rural and urban areas. Table 5.3 (Lower Quartile Prices and Market Rents) is broken down by sub-area, highlighting those rural areas, Kibworth and the Leicester Fringe are the least affordable. Table 5.5 (Estimated Household income Required to Buy and Privately Rent by sub-area) further demonstrates that Rural Areas, Kibworth, Great Glen and the Leicester Fringe area experience the largest income gap. This analysis is culminated in Tables 5.7 and 5.10, noting that the greatest need for social/affordable rented housing and affordable home ownership are within the rural areas.
However, this has not been translated into the draft policy requirements, as a blanket requirement of 40% affordable housing has been given across the District, despite the evidence base looking at a finer scale; the conclusions have been overgeneralised. Rather, the draft policy should focus the requirement to deliver affordable housing in rural areas, and the Leicester Fringe, in recognition of the proportion of the plan’s housing requirement in contributing towards the unmet housing needs of Leicester City. A lower proportion, in recognition of the findings of the evidence base, should apply to areas such as Lutterworth which are already more affordable, with a boost in housing delivery supporting this further. Therefore at present, the draft policy cannot be considered justified per the requirements for soundness in paragraph 36 of the NPPF.
Although the position of draft Policy HN01 is a continuation of the existing local plan position (adopted policy H2), this has not been effective. The East of Lutterworth Strategic Development Area has a pending application (ref. 24/01135/S106) to vary the Section 106 Agreement to remove the requirement to achieve a minimum of 40% affordable housing on each sub-phase, to a minimum of 10% and a maximum of 40%, in recognition that this will ensure the development can continue to be viable. Particularly given the location of this development within Lutterworth, this demonstrates that a blanket 40% affordable housing requirement is not feasible, and there should be a level of variation within draft Policy HN01 to reflect the sub-areas, and local market conditions.
WDH have instructed Brookbanks to undertaken a review of the Aspinall Verdi HDC Local Plan Viability Report (ref. INF NLP 2, January 2025), with a particular focus on the implications of development viability, which is provided within Appendix A of these representations.
The report identifies several fundamental input parameters that cannot be considered sufficiently robust to support a blanket 40% affordable housing provision across the high and medium value zones within the District. Furthermore, the report identifies that schemes in Lutterworth and Market Harborough did not meet the Benchmark Land Value when modelling 40% affordable housing provisions. A blanket 40% requirement for affordable housing is therefore not consistent with the Planning Practice Guidance on Viability2 which requires policy requirements to be informed by a proportionate assessment of viability, and the policy requirement should be reduced.
By not introducing flexibility to the local affordable housing requirement, the plan may be unable to be effective in delivering the objectively assessed housing needs of HDC, per the requirements of paragraph 36 of the NPPF.
In amending the wording of draft Policy HN01, Sustainability Appraisal objectives 6 (health and wellbeing), 7 (social inclusion) and 9 (housing) can continue to be met, in a way that is more appropriate with the spatial context of specific developments
See attachment