Harborough Local Plan 2011-2031, Proposed Submission

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Harborough Local Plan 2011-2031, Proposed Submission

SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas.

Representation ID: 6721

Received: 10/11/2017

Respondent: Leicester City Council

Representation Summary:

Priorities SP1 and SP2 welcomed. One of the key housing issues refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Support

Harborough Local Plan 2011-2031, Proposed Submission

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

Representation ID: 6746

Received: 10/11/2017

Respondent: Leicester City Council

Representation Summary:

Priorities SP1 and SP2 welcomed. One of the key housing issues refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

H1 Opening sentence

Representation ID: 6747

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Appreciate on going work on an Memorandum of Understanding and the inclusion of a contingency of housing land of 15% over and above the plans housing requirement. We would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE1 clause 1

Representation ID: 6749

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Policy proposes that an additional 58.8ha will be allocated. HEDNA forecasts a need between the range of 44 and 51 ha for Harborough (2011-2031).
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. An additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

Key issue 8: Transport

Representation ID: 6750

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

Objective 10. Transport

Representation ID: 6752

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Propose adding wording 'and therefore will help to encourage active and healthy lifestyle choices'.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

SS1 clause 3

Representation ID: 6753

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Object

Harborough Local Plan 2011-2031, Proposed Submission

GD8 clause 1

Representation ID: 6754

Received: 10/11/2017

Respondent: Leicester City Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Support

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2e.

Representation ID: 6755

Received: 10/11/2017

Respondent: Leicester City Council

Representation Summary:

The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

Support

Harborough Local Plan 2011-2031, Proposed Submission

Funding Infrastructure (above para 11.1.4)

Representation ID: 6760

Received: 10/11/2017

Respondent: Leicester City Council

Representation Summary:

Para. 11.1.10 noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA. Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Full text:

Harborough District Local Plan 2011 - 2031. Proposed Submission
Below are Leicester City Council's comments to the 'Proposed Submission' Harborough District Local Plan.

Strategic Priorities SP1 and SP2.
We welcome, in particular, Strategic Priorities SP1 and SP2 (para 1.5.3) which refer to meeting the housing and employment needs of the housing and economic market areas, and to assist other authorities to meet their unmet housing need. Furthermore we also support 'Key Issue 2: Meeting housing needs (para 2.2).'
One of the key housing issues in this section refers to 'making an appropriate contribution to meeting the established and justified unmet housing needs of other authorities within the Leicester and Leicestershire housing market area'
As you are aware, and have noted at paragraph 5.1.6, Leicester City formally declared an unmet housing need arising in the administrative area of the city in a letter to each local authority in the housing market area in early 2017. The scale of unmet need in the City will become clearer as Leicester's local plan progresses, however it is likely to be significant.

Policy H01
It is appreciated that work is ongoing across the HMA on a memorandum of understanding which will identify how HMA wide unmet need will be accommodated. We note the inclusion, in policy H01, of a contingency of housing land of 15% over and above the plans housing requirement. There are a number of circumstances set out in the supporting text at 5.1.10 as to why the contingency is required 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)'.
Whilst we welcome the Harborough Local Plan specifically referring to unmet need in Leicester, and the inclusion of a contingency in housing land which may help assist in meeting unmet need arising elsewhere in the HMA, we would wish the plan to go further to meeting Leicester City's unmet needs now, for example, by setting aside a specific amount of housing land to help meet our unmet need, in advance of full agreement on HMA wide housing distribution.

Employment - Policy BE1
Policy BE1 'Business and Employment', proposes that an additional 58.8ha will be allocated. The HEDNA forecasts a need between the range of 44 and 51 ha for Harborough between 2011 and 2031.
However, Table B11 confirms that of that forecast HEDNA need, 16.5ha has already been built. Therefore, only between 27.5ha and 34.5ha is required to be allocated. In fact an additional 58.5 ha has been allocated which is between 24 and 31 ha over provision. On top of this over provision, Paragraph 6.1.13 also allows an unspecified additional amount of employment in neighbourhood plans.
Therefore the City Council seeks further justification for the over provision of employment land in Policy BE1.

Transport
Key Issue 8: Transport - propose inclusion of wording referring to Leicester - 'addressing road infrastructure constraints affecting the Leicester urban fringe and within Leicester itself...'
Page 18 - Objective 10 - propose wording 'and therefore will help to encourage active and healthy lifestyle choices.'
Sustainable settlements:
Page 21, Section 3 - Propose the inclusion 'good accessibility to key destinations ' within this sentence.
Page 47 - Good design in development
Suggest the inclusion within this section that 'any adverse impacts identified on the highway network will be subject to appropriate mitigation.'
Page 81 - BE2 Strategic Distribution - part E.
The Council supports wording that additional development would be permitted where it would not lead to severe traffic congestion....whether within Harborough District or outside.
Page 148 - Funding Infrastructure - para. 11.1.10
It is noted that the City is acknowledged where highway mitigation measures are required as a result of growth in Harborough District. We will continue to work positively with Harborough District Council and Leicestershire County Council in delivering Harborough's Local Plan.
The evidence produced as part of the South East Leicester Transport Study (draft, phase 2, version 6, 16-9-17) looks at the cumulative effects on travel of a number of potential housing locations in the South East sector of the Leicester PUA.
Whilst the report has not been finalised, where it is demonstrated that there is an adverse impact to the city's highway and transport network from new developments, for example from the proposed Scraptoft development, we will be looking for a range of measures to enhance and improve the efficiency and operation of the highway network that will address the problems of congestion, the public transport service and current journey times, particularly along the constrained A47 corridor.
We will be seeking opportunities to mitigate these impacts. For example, traffic calming measures to deter rat running, road safety measures to alleviate any accident 'hotspot' areas, improvements to urban traffic control systems and equipment, the implementation of new (SMART) technology to enable more efficient and responsive movement of traffic around the city, bus infrastructure improvements and walking and cycling improvements.
A list of possible transport infrastructure that may be required for Leicester city, in the context of the Scraptoft North SDA was sent Peter Brett Associates (8th May, 2017) as part of their work in developing Harborough District Council's Infrastructure Delivery Plan for the Local Plan.

Chapter 11 (Infrastructure)
There is no consideration given to the funding of a new bus service, or extension of an existing route, to new developments where no service exists. For example, Section 106 contributions from the Hamilton Trustees in Leicester were used over a number of years to fund the establishment of the bus service from Leicester to Hamilton which is now a successful commercial route. Therefore there is opportunity to explore this as part of the infrastructure required for any new developments.

IN2 Sustainable transport
Page 153 - Para. 11.3.7. This should refer to the Scraptoft SDA
Page 168 - Policy SC1 Scraptoft North SDA
Highways and Transportation:
- suggest the inclusion that SMART improvements - the application of modern technologies and management strategies to improve the performance of the highway and transport system.
- Page 170 - Para 13.2.7 - suggest the inclusion of walking, cycling and bus service routes to Leicester city centre.
- It is noted in the Jacobs report produced for Harborough District Council's Local Plan, 'Preliminary Traffic Impact Assessment' (version 1, November, 2016) that much of the traffic generated by the Scraptoft North SDA distributes to the road network in Leicester. A Transport Assessment produced as part of the planning process will need to be based on strategic modelling as well as local modelling scenarios.
- Education:
The Council welcomes the inclusion in the policy of the requirement for a two form entry primary school and the need for appropriate contributions towards secondary education provision as determined by the local education authorities. As the masterplanning of the SDA progresses, it is important that there is effective dialogue between the City Council, Harborough District Council and the County Council in achieving effective outcomes.

Lutterworth SDA
Page 195 / 201 (para 15.2.21) - the Transport Assessment produced for Lutterworth SDA will need to consider if there are any strategic impacts, particularly to Leicester.

Appendix A
Highways
The highway road links and junctions that are currently of concern and may need further assessment are:
* A47 Uppingham Road corridor;
* A563 Outer Ring Road ;
* Spencefield Lane junctions with the A47 Uppingham Road, Goodwood Road and Evington Lane (routes towards the north and south of the city); and
* Ambassdor Road / Wicklow Road / Green Lane Road.
In addition, the following would also need to be considered:
* Traffic calming measures to deter rat running if appropriate.
* Road safety measures to alleviate any accident 'hotspot' areas.
* Contributions towards improvements of urban traffic control systems and equipment, and the implementation of new technology to enable more efficient and responsive movement of traffic around the city.

Public Transport
Contributions towards public transport infrastructure improvements are likely to be expected to support existing services and any new/extended services . Targeted bus services may be required to run to / from the city centre or serve any other relevant destinations, for example, Hamilton, Thurmaston, Barkby Thorpe, and Beeby.
The Council has a strategy for removing 'bus pinch points' on the key bus routes in the city in order to facilitate better bus journey times and bus journey reliability, therefore making buses more attractive as a mode of transport. Relevant bus pinch points for further assessment are:
* St. George's Way roundabout (outbound from Humberstone Gate - frequent delays spread throughout the day Monday -Friday 7.30am -6pm);
* A47 Uppingham Road (outbound and inbound delays at The Portwey / Coleman Road - frequent delays spread throughout the day Monday - Friday 7.30am - 6pm);
* Green Lane Road / Coleman Road (queues eastbound along Green Lane Road frequent delays in the peak periods 7.30am - 9.30am and 4pm - 6pm Monday to Friday);
* Forest Road - inbound queues to Humberstone Road (frequent delays in the peak period 7.30am to 9.30am and 4pm - 6pm Monday - Friday); and
* Humberstone Village, Main Street - (queues at school start and finish times) (7.30am - 9.30am and 4pm - 6pm Monday to Friday).
In addition other infrastructure required to improve bus journey times, frequency, reliability and the attractiveness services along the preferred route are expected to include, where appropriate:
* bus priority measures,
* bus gates,
* bus links,
* real time information and
* bus shelters for bus stops serving the city.

Sustainable Transport
- Opportunities for links towards the development and the existing cycle network at Hamilton which would connect to the proposed North East of Leicester sustainable urban extension. Mitigation at junctions should include facilities for cycling and walking.
- Walking and cycling links from the development to local / district key centre(s) and services (including leisure, retail, education and health care) to Hamilton, Netherhall Road and Uppingham Road.

Air Quality
Leicester has a declared an Air Quality Management Area which includes parts of the A47 (E) corridor. Road traffic is the main source of pollution. Our adopted Air Quality Action Plan (2015-26) supports measures that reduce emissions and congestion that will ensure we will meet the EU targets for nitrogen dioxide by 2020. This would need to include:
* Provision of monitoring equipment or enhancements to urban traffic control measures to mitigate development impacts.
* Opportunities to encourage the use of low emission vehicles (including public transport).

Longer term Scraptoft development
If further development, (beyond the 1,200 dwellings) comes forward at Scraptoft, additional assessment and mitigation of the highway and transport network would be required. This would include the identification of major highway infrastructure required to help deliver significant growth, and to reduce any adverse impacts on the highway network, making the city an attractive place to live, work and for leisure opportunities. Further assessment of work would be likely to include:
* A proposed A46 Express Way, linking from M1 J20 to the A46 (eastern side of the city) to help unblock transport hotspots and in Leicester city and improve connectivity from the east of the city to the strategic transport network. A proportionate investment would be sought;
* The Eastern District Distributor Road (EDDR). Currently land is safeguarded for the completion of the Outer Ring Road to the south east of Leicester. The delivery of such a scheme could mitigate the impact of the Scraptoft development. A proportionate investment should seek;
* Further localised highway improvements; and
* Further opportunities to improve a public transport.

Green Infrastructure Networks
This section is generally accepted and some of the previous comments have been addressed which is welcomed and adds to the clarity of the section .A definition of Green Infrastructure would be useful at the beginning of the section and also to briefly refer to other benefits associated with Green Infrastructure to link it to relevant policy areas within the Plan e.g. Biodiversity, flooding, Air Quality/Climate Change, Sports/Recreation

Policy G15 - Biodiversity and Geodiversity
The SSSI sites and areas of Local Green Space are included in the Appendix I and J but there is no reference to Local Wildlife Sites which although non-statutory are still a material consideration in planning.
The following needs to be addressed:
 -There is no reference to how net loss/gain will be measured/monitored
 -Will there be a map/plan to show the designated areas ?- the location of sites needs to be shown .

De-Declaration of the Scraptoft Local Nature Reserve:
The ecological value of areas of the site should be recognised which may include designation as a Local Wildlife Site where criteria for designation are met .
If the de-declaration is submitted to Natural England, alternative areas for designation as a Local Nature Reserve and/or further enhancements to an existing LNR nearby would be required and this is referred to in the public consultation report. Taking a strategic approach to Green Infrastructure/Biodiversity and the establishment of the green networks would be beneficial in trying to avoid this situation of designation/de-declaration in the future, but in any case it is recommended that potential mitigation areas are identified within the Local Plan .

Open Space and Sports Provision
The Council notes that a Playing Pitch Strategy has not been produced to evidence sports provision .

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