Harborough Local Plan 2011-2031, Proposed Submission

Object

Representation ID: 7417

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst Gladman raise no major issues with the approach the HEDNA has taken re: demographic and economic elements of housing needs assessment, given the severity of the affordability issue within the district and the Government's focus on tackling affordability through recent consultation on assessing housing needs, it is considered that a 15% uplift to address Market Signals is not sufficient.
Given affordability evidence and recent Inspectors'
decisions on Market Signals, Gladman consider that an uplift of 20% would be a more appropriate to address market signals. It is considered that the full OAN for Harborough,taking account of the Magna Park Sensitivity Study should be 581dpa.

Object

Representation ID: 7418

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman object to 40% affordable housing requirement on all relevant housing sites. The Council's latest evidence on viability (Local Plan Viability - Residential Options Viability Interim Report) sets out that the viability of sites varies between 30% and 40% affordable housing provision and there are likely to be trade-offs between infrastructure and affordable housing provision on a number of sites. It is concerning that Council has chosen to set the affordable housing requirement of 40% as this may render some schemes unviable thereby necessitating lengthy/detailed viability discussions on a site by site basis to ensure that housing requirement is met.

Object

Representation ID: 7419

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman object to the prescriptive approach to tenure split set out in Policy H2. This is based on the HEDNA report and is a snapshot in time. Requirements may change dependent upon the location and timing of an application and flexibility needs to be applied to the requirements set out in Policy H2 to ensure that the tenure mix on a particular site is reflective of the needs of the local population at the time of the application.

Support

Representation ID: 7420

Received: 16/11/2017

Respondent: Gladman Developments

Gladman support Policy H4 as it seeks to encourage the development of specialist accommodation for older people including both extra care and sheltered accommodation. However, there needs to be flexibility exercised in the implementation of the Policy as there may be circumstances where it is inappropriate to provide such accommodation on all sites over 100 units including a lack of need for such accommodation in the location of the application.

Object

Representation ID: 7421

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H5 sets out that new housing development should meet nationally described space standards. The Written Ministerial Statement of 25th March 2015 confirms that the optional new national technical standards should only be required through Local Plans if they address a clearly evidenced need and where the impact on viability has been considered. It is therefore important that the Council has undertaken a local assessment which evidences the need for adoption of the
Nationally Described Space Standards rather than relying on circumstantial evidence. The Council do not seem to have undertaken such an assessment.

Object

Representation ID: 7422

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H5 requires new housing to be designed to meet higher water efficiency standards of 110 liters per person per day. The Written Ministerial Statement of 25th March 2015 confirms that the optional new national technical standards should only be required through Local Plans if
they address a clearly evidenced need and where the impact on viability has been considered. The Housing Standards Review also set out that reduced water consumption rates should only be applied in water stressed areas. Given that only the eastern part of district suffers from water stress then the blanket approach is not justified.

Object

Representation ID: 7423

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H5 requires 4% of dwellings proposed on sites of 100 dwellings or more to meet the accessible and adaptable standards in Building Regulations, Part M, Category 2. If the Council wish to introduce the higher accessibility standards then
they need to undertake a local assessment which evidences the need for such standards. The Council do not seem to have undertaken such an assessment.

Object

Representation ID: 7424

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the concept of Self Build/Custom Build Housing is supported, Gladman have concerns regarding Policy H5 as the inclusion of plots on large scale sites does not add to the supply of houses overall (it merely changes the housing mix from one product to another). It is also difficult to assess how it will be implemented given issues around working hours, site access, health and safety etc. that are associated with large scale development sites. The percentage of provision on sites should be determined on detailed need evidence which the Council has not produced. Provision of these plots should be subject to viability testing.

Object

Representation ID: 7425

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HC1 does not reflect the guidance contained in the Framework. Paragraphs 132 to 134 of the Framework relate specifically to designated heritage assets and highlight that the more important the asset the greater the weight that should be attached to it. The policies in the Local Plan therefore need to make such a distinction so as to ensure they are consistent with the Framework. Policy should distinguish between the two tests included in the Framework for designated heritage assets to ensure it is sound. Policy should also reflect NPPF para. 135 re: non-designated heritage assets to ensure soundness.

Object

Representation ID: 7427

Received: 16/11/2017

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Gladman object to Policy IMR1 as the review policy as written contains no firm commitments on the timing and completion of the Local Plan review. The Policy refers to commencing a review within 12 months of the need for a review being established but there is no specific timeframe for completion of the review. This means that the Council has no specific imperative to do anything but start the review process which may, under the current policy, never be completed. It is therefore suggested that the review mechanism contained in Policy IMR1 is far more robust and set within a definitive timescale.