Harborough Local Plan 2011-2031, Proposed Submission

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Object

Harborough Local Plan 2011-2031, Proposed Submission

SP2: Assisting other local authorities to meet their unmet housing need.

Representation ID: 7435

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Duty to Co-operate Statement does not explicitly confirm that all neighbouring authorities (outside Leicester & Leicestershire HMA)will be meeting their own OAHN in full.
It is considered that the Council has co-operated on an on-going basis with neighbouring authorities especially those authorities within the Leicester & Leicestershire HMA. Therefore there has been legal compliance with the requirements of the Duty to Co-operate but satisfactory outcomes from that process, in particular meeting unmet needs in the HMA, are not yet concluded which is an unsound basis on which to prepare a Local Plan. The Leicester & Leicestershire HMA authorities approach of deferring into the future via Local Plan Reviews the solution to identified unmet housing needs should not be condoned.
There is only limited reference to Strategic Growth Plan.
HBF may wish to comment on any Statement of Common Ground.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

IMR clause 2

Representation ID: 7437

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Concerned that IMR1 contains no firm commitment to a review or a timescale for review. Suggested modifications will ensure consistency with the North West Leicestershire Local Plan which also dealt with the same issue of unmet needs in the Leicester & Leicestershire HMA and was modified accordingly in its recently concluded Examination.
The final version of the MoU to be signed in January 2018 before the submission of the Harborough Local Plan for examination should set out unmet housing needs from Leicester/Oadby & Wigston together with the proposed re-distribution of these unmet needs across the remainder of the HMA.
Early review is not the optimum policy mechanism by which to resolve unmet housing need. A greater contingency is needed along with release of reserve sites.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

5.1.4 to 5.1.7 Explanation

Representation ID: 7439

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

An adjustment of +25 dwellings per annum is in itself modest and unlikely to achieve Objective 2 of the Local Plan.

The figure of 11,140 dwellings (557 dwellings per annum) is set out in the supporting text of Policy H1 as the District's housing requirement. This housing requirement excludes any contribution to meeting declared quantified unmet housing needs from elsewhere in the Leicester & Leicestershire HMA.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

SS1 clause 2a. enable housing development during 2011-2031 comprising:

Representation ID: 7440

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Council state that this housing provision will cater for unmet needs from elsewhere in HMA, slower than expected delivery, non-implementation of existing consents, economic change, and flexibility and choice in the housing market. This is somewhat confusing. The housing need that the Council is proposing to meet should be clearly stated. Furthermore the derivation of that housing need should be based on evidence which is transparent and easily understood. It is recommended that the Council provides further clarification by undertaking additional work on its OAHN and housing requirement before the Harborough Local Plan is submitted for examination. Implications of the Government's proposed standard methodology should be considered.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

SS1 clause 1. manage planned growth to 2031 in accordance with the following settlement hierarchy:

Representation ID: 7441

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There is concern that some settlements have been incorrectly placed within this tiered hierarchy for example Broughton Astley is designated above Fleckney. It is recommended that the Council re-examines such flaws before submission of the Local Plan for examination.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

H1 Opening sentence

Representation ID: 7443

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It is important that the Council's proposed housing distribution recognises the difficulties facing rural communities in particular housing supply and affordability issues. The NPPG emphasises that all settlements can play a role in delivering sustainable development so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided. The proposed distribution of housing should meet the housing needs of both urban and rural communities.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

v. about 790 dwellings on non-allocated sites or sites to be allocated in neighbourhood plans

Representation ID: 7444

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

There is concern over the reliance on non-allocated and / or Neighbourhood Plan allocations to meet a significant proportion of the District's residual HLS. This provides no guarantee that the Local Plan itself will deliver the District's housing needs. It is suggested that further allocations in lower rural tiers of the settlement hierarchy are needed.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

Appendix G Housing trajectory

Representation ID: 7446

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

It is also essential that the Council's assumptions on lead-in times, lapse rates and delivery rates for sites are realistic. These assumptions should be supported by parties responsible for delivery of housing and sense checked by the Council using historical empirical data and local knowledge.
The Council should also consider the allocation of developable reserve sites
together with an appropriate release mechanism as recommended by the
LPEG Report.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

5.1.8 to 5.1.11 Explanation

Representation ID: 7448

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The proposed overall HLS is 12,800 dwellings against a housing requirement
of 11,140. Therefore there is contingency of circa 11% in the proposed HLS to
cater for unmet needs from elsewhere in HMA, slower than expected delivery,
non-implementation of existing consents, economic change, and flexibility and
choice in the housing market. This level of contingency is below the DCLG
presentation slide from the HBF Planning Conference September 2015 (see
attached) which illustrates a 10 - 20% non-implementation gap together with 15
- 20% lapse rate.

Full text:

See attached document.

Object

Harborough Local Plan 2011-2031, Proposed Submission

5.1.8 to 5.1.11 Explanation

Representation ID: 7456

Received: 03/11/2017

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Re: 5 year housing land supply.
The Council's calculation is based on OAHN figure of 532 dwellings per annum rather than the housing requirement of 557 dwellings per annum which is incorrect.

It is clear that further site allocations are needed to demonstrate a 5 YHLS on adoption to maximize housing supply the widest possible range of sites, by size and market location are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products.

Full text:

See attached document.

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