Harborough Local Plan 2011-2031, Proposed Submission
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Harborough Local Plan 2011-2031, Proposed Submission
d. Rural Centres
Representation ID: 6256
Received: 02/11/2017
Respondent: The Cooperative Estates
The Co-op supports the recognition of Houghton on the Hill as a Rural Centre in the Settlement Hierarchy under Policy SS1 (1d).
The Co-op supports the recognition of Houghton on the Hill as a Rural Centre in the Settlement Hierarchy under Policy SS1 (1d).
Support
Harborough Local Plan 2011-2031, Proposed Submission
SS1 clause 2a. enable housing development during 2011-2031 comprising:
Representation ID: 6257
Received: 02/11/2017
Respondent: The Cooperative Estates
The Co-op supports the Council's aim of delivering a minimum of 12,800 dwellings over the Plan period.
The Co-op supports the Council's aim of delivering a minimum of 12,800 dwellings over the Plan period.
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: 6261
Received: 02/11/2017
Respondent: The Cooperative Estates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
- The Local Plan should allocate 790 dwellings rather than relying on Neighbourhood Plans to deliver these allocations.
it is considered that the Policy is too reliant on allocations (to deliver a total of 790 dwellings) via Neighbourhood Plans. There is no certainty that Neighbourhood Plans will be forthcoming to ensure all 790 dwellings will be delivered over the Plan period and a risk that such provision is, in effect, a secondary windfall allowance. It such an eventuality, the Policy cannot be sound or positively prepared.
An alternative approach would be to allocate additional housing sites within the Local Plan to deliver the additional 790 dwellings. Any additional allocations which are subsequently identified via Neighbourhood Plans would be commensurate with the overriding objective of delivering a minimum of 12,800 dwellings and boost the overall supply of housing, as required by the NPPF.
Suitable sites have already been assessed via the SHLAA process, therefore the evidence base for making such allocation is already in place.
Object
Harborough Local Plan 2011-2031, Proposed Submission
SS1 clause 7
Representation ID: 6262
Received: 02/11/2017
Respondent: The Cooperative Estates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Co-op objects to the unhelpful distinction made between Fleckney/Great Glen/The Kibworths and other Rural Centres, as implied in the expression "...and to a lesser extent...". These settlements share the same status within the Settlement Hierarchy. Although some may be physically smaller than others, they all offer the provision of facilities and services sufficient to warrant recognition as Rural Centres, rather than Selected Rural Villages or Key Centres.
The Co-op objects to the unhelpful distinction made between Fleckney/Great Glen/The Kibworths and other Rural Centres, as implied in the expression "...and to a lesser extent...". These settlements share the same status within the Settlement Hierarchy. Although some may be physically smaller than others, they all offer the provision of facilities and services sufficient to warrant recognition as Rural Centres, rather than Selected Rural Villages or Key Centres.
Object
Harborough Local Plan 2011-2031, Proposed Submission
GD2 clause 1a
Representation ID: 6264
Received: 02/11/2017
Respondent: The Cooperative Estates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy GD2 is ambiguous and should be deleted.
Moreover, the Council has not adduced the evidence to explain why the more conventional Limits to Development (as utilised in the Saved Core Strategy and Local Plan) are not appropriate in the new Local Plan.
Policy GD2 contains a number of ambiguities which are unlikely to assist the interpretation of policy in a Development Management context. For instance, it is unclear at what point additional housing would be deemed to have "significantly exceeded" the target for delivery of new homes within a particular settlement. The supporting text refers to 10% or more growth as being excessive as a "rule of thumb", however this is considered to be arbitrary, wildly imprecise, unsupported by any detailed, technical evidence or endorsed in national policy and guidance. Moreover, restricting growth to 10%, whatever the local circumstances, is at odds with the overriding objective of delivering a minimum of 12,800 new dwellings over the Plan period.
Object
Harborough Local Plan 2011-2031, Proposed Submission
H1 clause 5c - Houghton on the Hill
Representation ID: 6269
Received: 02/11/2017
Respondent: The Cooperative Estates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy H1 should identify suitable allocations within each settlement, sufficient to deliver the minimum housing requirement identified in the Local Plan. This would not prevent subsequent Neighhourhood Plans making additional allocations, which are in general conformity with the Local Plan.
Additionally, land at Stretton Lane in Houghton on the Hill should be allocated for up to 36 dwellings. The suitability and deliverability of this site is supported by the Local Plan evidence base.
Policy H1(5c) states that land will be provision to deliver a minimum of 65 dwellings within Houghton on the Hill (in addition to commitments, presumably from the date of adoption). In accordance with representations made by the Co-op in reference to Policy SS1, it is contended that the Local Plan should identify these sites via specific allocations. The benefits of such an approach are explicitly acknowledged at para. 5.1.15. of the Submission Local Plan, which prompts the question as to why the Plan takes a selective approach to allocations.
The justification for the distribution of housing is also ambiguous. Para. 5.1.17 states that the minimum quantum of development apportioned to each settlement is a product of the SHLAA process, relative populations, accessibility and physical constraints. However, the Local Plan should be more specific as to the actual circumstances relevant to each settlement which has determined the distribution of growth rather than vague reference to the elements of the evidence base.
In that regard, the SHLAA (May 2016 Update) concludes that land in which the Co-op has an interest at Stretton Lane, Houghton on the Hill (ref: A/AA/HSG/04) is suitable, available and achievable. Overall, it is assessed as being deliverable (36 dwellings) within 5 years (as defined in the NPPF).
The only other site in Houghton also assessed as being deliverable within five years is Land off Winckley Close (A/HH/HSG/01) for which the Council has recently granted outline planning permission (ref: 17/00212/OUT) for 48 dwellings.
It is also constructive to consider the Houghton on the Hill Landscape Character Assessment and Landscape Character Study (April 2016) within the Local Plan evidence base. The Co-op land at Stretton Lane was identified as having a medium landscape capacity, equivalent to the Winckley Close site which benefits from outline planning permission. Mitigation landscaping introduced at Stretton Lane will further support development on this site to help meet the identified minimum need for 65 dwellings in Houghton on the Hill. For these reasons, it is contended that the Local Plan should identify housing allocations in the Rural Centres, including the land at Stretton Lane in Houghton on the Hill.