Harborough Local Plan 2011-2031, Proposed Submission

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Object

Harborough Local Plan 2011-2031, Proposed Submission

c. Key Centres: Lutterworth, Broughton Astley

Representation ID: 7351

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy SS1 identifies a clear settlement hierarchy and states that development should be directed towards appropriate locations in accordance with this hierarchy; however, the second part of the policy fails to allocate development according to the hierarchy. Sustainable locations such as Broughton Astley should be considered for development.
Part 6 of Policy SS1 states that the Local Plan seeks to maintain and improve the character and environment of the market towns of Lutterworth and develop Broughton Astley but the plan will not deliver this without further land allocated for housing development at Broughton Astley.

Full text:

At Broughton Astley, DDL have built 24 new homes off Dunton Road (reference: 13/00688/FUL). DDL wish to promote the land to the north east and south east of the built site for further development. There is ability to access additional development land through the built site and there is additional access potential
further east off Dunton Road. A site location plan is attached.

Paragraph 157 of the NPPF requires Local Plans to allocate sites to promote development, bringing forward new land where necessary, and provide detail on form, scale access and quantum where appropriate.

The Local Plan as drafted does not allocate sites sufficiently in locations such as Broughton Astley.

Broughton Astley is identified within the third tier (part 1, limb 'c' of Policy SS1) of the settlement hierarchy under 'Key Centre' alongside Lutterworth. Part 2 of Policy SS1 identifies a Strategic Development Area (SDA) proposed for 1,500 dwellings on land east of Lutterworth. However, no housing growth is identified for Broughton Astley under part 2 of the policy, despite the settlement's position under the third tier of the settlement hierarchy. We consider that Broughton Astley is strategically placed near key transport networks as well as planned growth areas for the District. Broughton Astley represents a sustainable village with good access to local amenities and services and the settlement is ideally placed to deliver additional
housing growth for the District in accordance with the village's role as a Key Centre.

The Broughton Astley Neighbourhood Plan allocates 528 dwellings for the village. This is an increase above the 400 homes that were sought by the Core Strategy (2006 - 2028) adopted 14 November 2011. Broughton Astley Parish Council felt that the village had an insufficient level of facilities and services given its size, particularly in comparison to Lutterworth. Therefore, it was decided to allocate additional housing growth within the Neighbourhood Plan to ensure that both existing facilities and services were maintained but also to facilitate provision for new amenities including a supermarket, leisure centre, medical centre and recreational facilities. Permission has now been granted for all the allocated sites in the Neighbourhood Plan, including the reserve allocation, which is the site off Dunton Road developed by DDL.

The Neighbourhood Plan states that it will be actively managed throughout its 15-year period. This includes a commitment to undertake thorough five-year reviews of the Plan in 2018 and 2023. We consider that the preparation of the Harborough Local Plan 2011-2031 would further reiterate the need for a thorough review.
It is therefore considered that the Local Plan should allocate further development for Broughton Astley. Without the allocation of further numbers within Broughton Astley, the growth strategy for the District is not directed to the most sustainable locations as identified under the settlement hierarchy in accordance with
Policy SS1.

Policy SS1 identifies a clear settlement hierarchy and states that development should be directed towards appropriate locations in accordance with this hierarchy; however, the second part of the policy fails to allocate development according to the hierarchy. Sustainable locations such as Broughton Astley should be considered for development.

Part 6 of Policy SS1 states that the Local Plan seeks to maintain and improve the character and environment of the market towns of Lutterworth and develop Broughton Astley but the plan will not deliver this without further land allocated for housing development at Broughton Astley.

Selected Rural Villages:
We welcome the allocation of housing for Selected Rural Villages and consider that Dunton Bassett and Gilmorton represent a sustainable village with good access to local amenities and services. These settlements ideally placed to deliver some level of housing growth for the District to meet local housing need for rural communities and support village amenities and services.

Support

Harborough Local Plan 2011-2031, Proposed Submission

e. Selected Rural Villages

Representation ID: 7352

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Representation Summary:

We welcome the allocation of housing for Selected Rural Villages and consider that Dunton Bassett and Gilmorton represent a sustainable village with good access to local amenities and services. These settlements ideally placed to deliver some level of housing growth for the District to meet local housing need for rural communities and support village amenities and services.

Full text:

At Broughton Astley, DDL have built 24 new homes off Dunton Road (reference: 13/00688/FUL). DDL wish to promote the land to the north east and south east of the built site for further development. There is ability to access additional development land through the built site and there is additional access potential
further east off Dunton Road. A site location plan is attached.

Paragraph 157 of the NPPF requires Local Plans to allocate sites to promote development, bringing forward new land where necessary, and provide detail on form, scale access and quantum where appropriate.

The Local Plan as drafted does not allocate sites sufficiently in locations such as Broughton Astley.

Broughton Astley is identified within the third tier (part 1, limb 'c' of Policy SS1) of the settlement hierarchy under 'Key Centre' alongside Lutterworth. Part 2 of Policy SS1 identifies a Strategic Development Area (SDA) proposed for 1,500 dwellings on land east of Lutterworth. However, no housing growth is identified for Broughton Astley under part 2 of the policy, despite the settlement's position under the third tier of the settlement hierarchy. We consider that Broughton Astley is strategically placed near key transport networks as well as planned growth areas for the District. Broughton Astley represents a sustainable village with good access to local amenities and services and the settlement is ideally placed to deliver additional
housing growth for the District in accordance with the village's role as a Key Centre.

The Broughton Astley Neighbourhood Plan allocates 528 dwellings for the village. This is an increase above the 400 homes that were sought by the Core Strategy (2006 - 2028) adopted 14 November 2011. Broughton Astley Parish Council felt that the village had an insufficient level of facilities and services given its size, particularly in comparison to Lutterworth. Therefore, it was decided to allocate additional housing growth within the Neighbourhood Plan to ensure that both existing facilities and services were maintained but also to facilitate provision for new amenities including a supermarket, leisure centre, medical centre and recreational facilities. Permission has now been granted for all the allocated sites in the Neighbourhood Plan, including the reserve allocation, which is the site off Dunton Road developed by DDL.

The Neighbourhood Plan states that it will be actively managed throughout its 15-year period. This includes a commitment to undertake thorough five-year reviews of the Plan in 2018 and 2023. We consider that the preparation of the Harborough Local Plan 2011-2031 would further reiterate the need for a thorough review.
It is therefore considered that the Local Plan should allocate further development for Broughton Astley. Without the allocation of further numbers within Broughton Astley, the growth strategy for the District is not directed to the most sustainable locations as identified under the settlement hierarchy in accordance with
Policy SS1.

Policy SS1 identifies a clear settlement hierarchy and states that development should be directed towards appropriate locations in accordance with this hierarchy; however, the second part of the policy fails to allocate development according to the hierarchy. Sustainable locations such as Broughton Astley should be considered for development.

Part 6 of Policy SS1 states that the Local Plan seeks to maintain and improve the character and environment of the market towns of Lutterworth and develop Broughton Astley but the plan will not deliver this without further land allocated for housing development at Broughton Astley.

Selected Rural Villages:
We welcome the allocation of housing for Selected Rural Villages and consider that Dunton Bassett and Gilmorton represent a sustainable village with good access to local amenities and services. These settlements ideally placed to deliver some level of housing growth for the District to meet local housing need for rural communities and support village amenities and services.

Support

Harborough Local Plan 2011-2031, Proposed Submission

GD1 clause 1.

Representation ID: 7354

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Representation Summary:

GD1: A positive approach to development within the District is welcomed. It is also welcomed that applications will be approved without delay where possible.

Full text:

GD1: Achieving Sustainable Development
A positive approach to development within the District is welcomed. It is also welcomed that applications will be approved without delay where possible.
Support: No changes required

GD2: Settlement Development
The principle of development on sites within or adjoining the existing or committed built up area is welcomed. Notwithstanding this, further consideration to the implementation of this policy may be required. It would be useful to have an indicative level of development for growth or for an acceptable level of
provision within a settlement. It is also suggested that provision for development which facilitates the delivery of services or facilities is considered acceptable within or adjacent to the settlement boundary.

Redevelopment of previously developed land is welcomed; however, consideration of the viability implications of PDL should be considered depending on the site specifics.
Support: Change proposed as above

Support

Harborough Local Plan 2011-2031, Proposed Submission

GD2 clause 1

Representation ID: 7355

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Representation Summary:

The principle of development on sites within or adjoining the existing or committed built up area is welcomed. Notwithstanding this, further consideration to the implementation of this policy may be required. It would be useful to have an indicative level of development for growth or for an acceptable level of
provision within a settlement. It is also suggested that provision for development which facilitates the delivery of services or facilities is considered acceptable within or adjacent to the settlement boundary.

Full text:

GD1: Achieving Sustainable Development
A positive approach to development within the District is welcomed. It is also welcomed that applications will be approved without delay where possible.
Support: No changes required

GD2: Settlement Development
The principle of development on sites within or adjoining the existing or committed built up area is welcomed. Notwithstanding this, further consideration to the implementation of this policy may be required. It would be useful to have an indicative level of development for growth or for an acceptable level of
provision within a settlement. It is also suggested that provision for development which facilitates the delivery of services or facilities is considered acceptable within or adjacent to the settlement boundary.

Redevelopment of previously developed land is welcomed; however, consideration of the viability implications of PDL should be considered depending on the site specifics.
Support: Change proposed as above

Support

Harborough Local Plan 2011-2031, Proposed Submission

GD2 clause 2

Representation ID: 7356

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Representation Summary:

Redevelopment of previously developed land is welcomed; however, consideration of the viability implications of PDL should be considered depending on the site specifics.

Full text:

GD1: Achieving Sustainable Development
A positive approach to development within the District is welcomed. It is also welcomed that applications will be approved without delay where possible.
Support: No changes required

GD2: Settlement Development
The principle of development on sites within or adjoining the existing or committed built up area is welcomed. Notwithstanding this, further consideration to the implementation of this policy may be required. It would be useful to have an indicative level of development for growth or for an acceptable level of
provision within a settlement. It is also suggested that provision for development which facilitates the delivery of services or facilities is considered acceptable within or adjacent to the settlement boundary.

Redevelopment of previously developed land is welcomed; however, consideration of the viability implications of PDL should be considered depending on the site specifics.
Support: Change proposed as above

Object

Harborough Local Plan 2011-2031, Proposed Submission

H1 Opening sentence

Representation ID: 7357

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The provision of a contingency is welcomed. However, it is suggested that a contingency of just 15% will fail to meet the targets of Policy H1. It will not meet the FOAN for the market area as well as the other objectives of the contingency including providing for potential unmet need, lack of delivery from housing allocations and permitted sites and changing economic circumstances.

The sites at Broughton Astley, Gilmorton and Dunton Bassett represent achievable, suitable and deliverable sites to support the necessary housing growth for the District. The sites would contribute towards the Council's housing requirements, expected further unmet need from Leicester City/Oadby and Wigston Borough and 5 year housing supply.

Full text:

See attached full reps.
H1: A 15% contingency in the supply of housing land has been added to the housing requirement. This contingency needs to accommodate any provision for the unmet housing need of other authorities within the HMA. The supporting text under paragraph 5.1.10 states that the contingency is not only to provide for the potential need of unmet housing arising from other LPAs, roles also include allowances for a slower than expected delivery of the housing allocations, failure of permitted sites to deliver, changing economic circumstances and to provide flexibility and choice in the local housing market.

Although it is currently out for consultation and can therefore hold limited weight, the long awaited 'Planning for the right homes in the right places: consultation proposals identify both Leicester City and Oadby and Wigston Borough Councils as having a potential uplift on their local assessment of housing need. This could result on additional pressure for districts such as Harborough to provide for the wider area.

The provision of a contingency is welcomed. However, it is suggested that a contingency of just 15% will fail to meet the targets of Policy H1 insofar as it will not meet the FOAN for the market area as well as the other objectives of the contingency including providing for potential unmet need, lack of delivery from
housing allocations and permitted sites and changing economic circumstances.

In view of the Council's current five-year housing land supply position, it is
considered that additional deliverable sites for residential development will need to be brought forward through site allocations in the Local Plan.

There are no known constraints to the proposed residential development of the sites at Broughton Astley, Gilmorton and Dunton Bassett (see attached location maps). Safe access to the sites can be achieved and the sites are located close to a range of local amenities and services. It is considered that landscape enhancements will help mitigate any potential landscape and visual impact from the proposed development of the sites. Illustrative masterplan/layout plans can be provided for each site in due course to provide details of proposed layout and design to show how residential development of the sites can be delivered.

In view of the above, the sites at Broughton Astley, Gilmorton and Dunton Bassett represent achievable, suitable and deliverable site to support the necessary housing growth for the District. The proposed development will contribute towards the Council's housing requirements and expected further unmet need from Leicester City and Oadby and Wigston Borough. Residential development of the sites can be
delivered and achieved within the forthcoming five-year period, which will contribute significantly towards the Council's five-year supply and help towards addressing their current shortfall.

Object

Harborough Local Plan 2011-2031, Proposed Submission

H2 clause 1

Representation ID: 7359

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is no justification for the Council to apply the higher figure of 40% affordable housing provision as a blanket figure across the whole District when their latest evidence base suggests otherwise. It is suggested that affordable housing provision reflects the Council's evidence base in terms of viability across different areas of the District; flexibility within the policy should allow for provision of Starter Homes.

Full text:

The allowance of off-site affordable housing is welcomed where it is not possible to provide an on-site contribution.

There is a clear need for affordable housing within the District; however, it is important that the affordable housing requirement does not restrict development within the District. Part 5 of the policy is welcomed as there will be instances where the high level of affordable housing provision is not feasible given the market
values or site-specific concerns.

The latest evidence base for affordable housing is contained within the Local Plan Viability Interim Report - Residential Options Viability, prepared by Aspinall Verdi and published April 2016. This report demonstrates that viability varies between 30% to 40%. We consider that there is no justification for the Council to apply the higher figure of 40% affordable housing provision as a blanket figure across the whole District when their latest evidence base suggests otherwise.

Policy CS3 of the adopted Core Strategy recognised the need for different areas of the District to provide lower affordable housing requirements. This helped enable developers to provide high quality developments whilst compensating for lower market values within these areas. It is recommended that a similar aspect of this policy is incorporated into Policy H2. Policy H2 needs to consider the level of
affordable housing requirements to ensure that an effective viability of the Local Plan can be undertaken as required by the NPPF.

We consider Policy H2 should consider the Government's emerging proposals for a new definition of affordable homes when the NPPF is update. A proposed affordable housing tenure mix of 75% affordable/social rent and 25% low cost home ownership is too prescriptive and could prevent the delivery of homes.

We consider that DDL's land interests at Broughton Astley, Gilmorton and Dunton Bassett are suitable to provide an element of affordable housing provision in order to help meet the District's affordable housing need.

Object

Harborough Local Plan 2011-2031, Proposed Submission

H2 clause 2

Representation ID: 7360

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We consider Policy H2 should consider the Government's emerging proposals for a new definition of affordable homes when the NPPF is update. A proposed affordable housing tenure mix of 75% affordable/social rent and 25% low cost home ownership is too prescriptive and could prevent the delivery of homes. Flexibility within the policy should allow for provision of Starter Homes.

Full text:

The allowance of off-site affordable housing is welcomed where it is not possible to provide an on-site contribution.

There is a clear need for affordable housing within the District; however, it is important that the affordable housing requirement does not restrict development within the District. Part 5 of the policy is welcomed as there will be instances where the high level of affordable housing provision is not feasible given the market
values or site-specific concerns.

The latest evidence base for affordable housing is contained within the Local Plan Viability Interim Report - Residential Options Viability, prepared by Aspinall Verdi and published April 2016. This report demonstrates that viability varies between 30% to 40%. We consider that there is no justification for the Council to apply the higher figure of 40% affordable housing provision as a blanket figure across the whole District when their latest evidence base suggests otherwise.

Policy CS3 of the adopted Core Strategy recognised the need for different areas of the District to provide lower affordable housing requirements. This helped enable developers to provide high quality developments whilst compensating for lower market values within these areas. It is recommended that a similar aspect of this policy is incorporated into Policy H2. Policy H2 needs to consider the level of
affordable housing requirements to ensure that an effective viability of the Local Plan can be undertaken as required by the NPPF.

We consider Policy H2 should consider the Government's emerging proposals for a new definition of affordable homes when the NPPF is update. A proposed affordable housing tenure mix of 75% affordable/social rent and 25% low cost home ownership is too prescriptive and could prevent the delivery of homes.

We consider that DDL's land interests at Broughton Astley, Gilmorton and Dunton Bassett are suitable to provide an element of affordable housing provision in order to help meet the District's affordable housing need.

Object

Harborough Local Plan 2011-2031, Proposed Submission

H5 clause 2

Representation ID: 7361

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is important to remember that development cannot only provide for existing demand, it can also address the aspirations of an area. For example, young
families could be attracted to an area through the provision of family accommodation whereas the elderly would have different housing requirements.

It is recommended that Policy H5 is amended to include variations to the policy where evidence is provided to support any deviation. The required housing mix density for housing developments in different locations across the District needs to reflect the market in these locations and the local housing need.

Full text:

H5: Housing Density, Mix and Standards
The provision of high quality housing, suitable to the needs and aspirations of an area is strongly supported. Notwithstanding this, the practicalities of housing provision needs to be carefully considered to ensure that unnecessary delays in housing delivery are not experienced. It is important to remember that development
cannot only provide for existing demand, it can also address the aspirations of an area. For example, young families could be attracted to an area through the provision of family accommodation whereas the elderly would have different housing requirements.

It is recommended that Policy H5 is amended to include variations to the policy where evidence is provided to support any deviation. The required housing mix density for housing developments in different locations across the District needs to reflect the market in these locations and the local housing need.

It is not necessary to require adherence to Building Regulations within a development plan policy and therefore this reference should be omitted.

We consider that DDL's land interests at Broughton Astley, Gilmorton and Dunton Bassett are suitable to provide a mix of housing size, types and tenure in order to help meet the District's mix of market and affordable housing need.

Object: Suggested amendment proposed to accommodate appropriate housing mix on sites and to omit reference to Building Regulations

Object

Harborough Local Plan 2011-2031, Proposed Submission

H5 1c

Representation ID: 7362

Received: 17/11/2017

Respondent: Davidsons Developments Limited

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is not necessary to require adherence to Building Regulations within a development plan policy and therefore this reference should be omitted.

Full text:

H5: Housing Density, Mix and Standards
The provision of high quality housing, suitable to the needs and aspirations of an area is strongly supported. Notwithstanding this, the practicalities of housing provision needs to be carefully considered to ensure that unnecessary delays in housing delivery are not experienced. It is important to remember that development
cannot only provide for existing demand, it can also address the aspirations of an area. For example, young families could be attracted to an area through the provision of family accommodation whereas the elderly would have different housing requirements.

It is recommended that Policy H5 is amended to include variations to the policy where evidence is provided to support any deviation. The required housing mix density for housing developments in different locations across the District needs to reflect the market in these locations and the local housing need.

It is not necessary to require adherence to Building Regulations within a development plan policy and therefore this reference should be omitted.

We consider that DDL's land interests at Broughton Astley, Gilmorton and Dunton Bassett are suitable to provide a mix of housing size, types and tenure in order to help meet the District's mix of market and affordable housing need.

Object: Suggested amendment proposed to accommodate appropriate housing mix on sites and to omit reference to Building Regulations

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