Harborough Local Plan 2011-2031, Proposed Submission

Bloor Homes do not object to the principle of the allocation of the Scraptoft SDA. However, they do have serious concerns in relation to its deliverability within the plan period that are not addressed in either the Submission Plan or the supporting evidence base. As a consequence the proposed allocation and the Submission Plan that relies on its delivery to ensure that the identified housing needs for the District are met in accordance with the NPPF is currently unsound. They also object to the allocation of this SDA at the exclusion of any other appropriate sites in this highly sustainable location at the Leicester PUA and the over reliance on the SDAs in general in terms of meeting the District's identified housing needs (as also set out in the objections to Policies SS1 and H1).

Notably the delivery of the Scraptoft SDA requires the prior relocation of the golf course within the site. That will inevitably affect the timescale for the SDA's delivery, as the new course will need to be constructed and opened before the club can relocate and release the site for development. However, there is no evidence of a new site being identified, how will it be funded, or when it will be delivered.

It is, therefore, apparent that the Local Plan Housing Trajectory incorporates entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDA. That indicates that the Council anticipate the first completions being delivered in the period 2021/22, i.e. within 41/2 years.

Bloor Homes' objection in relation to Policy H1 clearly demonstrates why that will not be achieved, and that a more realistic assumption of delivery from 2025/26 should be assumed. Even then there is a significant risk that the resolution of the site specific landownership issues highlighted above will further delay delivery. Thereafter a robust view on the rate of delivery also needs to be taken. The assumed rate of delivery (rising to around 175dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Clearly the recalibration of the housing trajectory will have a significant impact on the housing land supply position in the District and its ability to meet the identified housing need. That will need to be addressed through the allocation of additional development sites before the Local Plan can be found sound.


Soundness
For the reasons set out above, Bloor Homes object to Policy SC1, which is considered unsound on the basis that it:
- is not justified in that it is has not fully acknowledged the practical constraints to development within the SDA;
- is not effective in that the SDA will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Proposed Change
To remedy the flaws in the soundness of the plan:
- The housing trajectory should reflect a realistic timescale for the delivery of the Scraptoft SDA;
- The Local Plan should then identify sufficient deliverable and developable supply of housing land to meet the identified housing need in sustainable locations in the District, notably at the PUA; and
- That should include the allocation of the land off Uppingham Road, Bushby.

Bloor Homes do not object to the principle of the allocation of the Lutterworth East SDA. However, they do have serious concerns in relation to its deliverability within the plan period that are not addressed in either the Submission Plan or the supporting evidence base. As a consequence the proposed allocation and the Submission Plan that relies on its delivery to ensure that the identified housing needs for the District are met in accordance with the NPPF is currently unsound.

Most notably, the site promoters have requested that the District Council exercise their compulsory purchase powers in order to deliver the highway crossing over the M1 and associated link road required to serve the development and ensure that there is not an unacceptable severe impact on the local and strategic highway network. However, as yet the Council has not confirmed their commitment in that regard. In any event, this is an extremely lengthy process and there is clearly no certainty in relation to the final outcome. Moreover, the evidence base demonstrates that the viability of the scheme relies on the delivery of further development beyond the plan period.

The evidence base also refers to major environmental issues, including ecological and heritage constraints, which will need to be appropriately addressed through the allocation and application processes. It is also clear that the development will have significant highway impacts and there is no evidence at this stage that they can actually be appropriately addressed (refer to PBA report paras 19.2.3 and 22.3.5).

Moreover, it is apparent that the Local Plan Housing Trajectory incorporates entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDA. That indicates that the Council anticipate the first completions being delivered in the period 2022/23, i.e. within 51/2 years.

Bloor Homes' objection in relation to Policy H1 clearly demonstrates why that will not be achieved, and that a more realistic assumption of delivery from 2025/26 should be assumed. Even then there is a significant risk that the resolution of the site specific environmental constraints, infrastructure provision and landownership issues highlighted above will further delay delivery. Thereafter a robust view on the rate of delivery also needs to be taken. The assumed rate of delivery (rising to around 240dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Clearly the recalibration of the housing trajectory will have a significant impact on the housing land supply position in the District and its ability to meet the identified housing need. That will need to be addressed through the allocation of additional development sites before the Local Plan can be found sound.

Soundness
For the reasons set out above, Bloor Homes object to Policy L1, which is considered unsound on the basis that it:
- is not justified in that it is has not fully acknowledged the practical constraints to development within the SDA;
- is not effective in that the SDA will not deliver the scale of development the Submission Plan currently assumes, and the identified needs will not therefore, be met; and
- is inconsistent with national policy in that it does not fully reflect the Government's priorities and policies in terms of enabling sustainable development and boosting the supply of housing to meet identified needs.

Proposed Change
To remedy the flaws in the soundness of the plan:
- The housing trajectory should reflect a realistic timescale for the delivery of the Lutterworth SDA.
- The Local Plan Plan should then identify sufficient deliverable and developable supply of housing land to meet the identified housing need in sustainable locations in the District, notably at the PUA.
- That should include the allocation of the land off Uppingham Road, Bushby.

Objectively Assessed Need & Housing Requirements
A central tenet of the NPPF is the provision of sufficient housing to meet the needs of present and future generations and, in doing so, to widen the choice of housing (paragraphs 7 and 9). To achieve that it requires (paragraph 14) "local planning authorities should positively seek opportunities to meet the development needs of their area", that "Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change", and set out a "clear strategy for allocating sufficient land" (paragraph 17). Delivery is underpinned by paragraph 47, which seeks to significantly boost the supply of housing requiring local planning authorities to "use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area".

In terms of the required evidence base, the NPPF requires (para. 159) local planning authorities to prepare a Strategic Market Housing Assessment (SHMA) to assess their full housing needs, and that the SHMA should identify the scale and mix of housing and the range of tenure that the local population is likely to need over the plan period. That should meet household and population projections, address the needs for all types of housing and cater for housing demand in the area. The housing requirement set out in Policies SS1 and H1 is derived from the Housing and Economic Development Needs Assessment (HEDNA) published in January 2017. That concluded that the Objectively Assessed Need (OAN) for Harborough District for the period 2011-2031 is 532dpa and for the period 2011-2036 is 514 dpa.

However, the HEDNA does not take account of the proposed major extension to Magna Park within the M6, M69 and M1 triangle (700,000m2 of B8 floor space) in the period to 2031. The Council's Magna Park Employment Growth Sensitivity Study 2017 concludes that in order to align this employment growth and housing provision, the housing requirement should be increased by 25dpa above the HEDNA OAN figures. That should be appropriately reflected in the housing requirements established in Policies SS1 and H1.

It is inevitable that there will be a delay to at least some of the identified development sites in the Submission Plan coming forward and/or the rate of their delivery will not be high as currently anticipated. That inevitability should be addressed at the outset rather than monitored and managed. The proposal to incorporate an uplift of 20% above the OAN into the housing requirement in Policies SS1 and H1 is therefore, supported. That approach reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the HMA's housing needs as required the NPPF (para 150-151). However, the uplift must be applied to the true OAN (i.e. the HEDNA OAN plus the recommended uplift to reflect the growth of Magna Park) and across the extended plan period to 2036.

Moreover, the housing requirement uplift should not be used as both a contingency guarding against a shortfall in delivery in the District and a potential contribution to unmet needs arising elsewhere in the Housing Market Area (HMA). Unmet needs arising in the wider HMA must be directly addressed as set out below, and should form an specific part of the overall housing requirement with a shortfall contingency uplift applied to the total requirement.

Unmet Need & the Duty to Cooperate
The Duty to Cooperate (DTC), introduced by the Localism Act 2011, requires the Council to engage "constructively, actively and on an on-going basis to maximise the effectiveness of Local and Marine Plan preparation in the context of strategic cross boundary matters" (NPPG). The NPPF requires (para 181) that authorities "demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts". The demonstration of effective cooperation in reality means a positive outcome to these strategic planning discussions, even if agreement is not secured on all issues. Compliance with the duty to cooperate is central to ensure that a Council delivers sustainable development (NPPF paras 150-151) and meets its full objectively assessed needs for market and affordable housing in the HMA (NPPF para 47), including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council has not prepared a Local Plan that is compliant with the DTC in terms of the housing requirement proposed in Policies SS1 and H1. It is apparent that the Council have sought to engage with the other Local Authorities in the HMA (the "HMA Authorities") during the preparation of the Plan. However, it is also clear that there has not yet been a positive outcome to that engagement that will ensure that (market and affordable) housing needs in the HMA, identified in an up to date objective assessment, will be properly identified and then effectively provided for.

The Duty to Cooperate Paper sets out the Council's engagement with the HMA Authorities and others, including in the preparation of various studies most notably the HMA wide HEDNA. It highlights the intention is to agree a new "final" Memorandum of Understanding (MOU) between the HMA Authorities by January 2018 and for it to inform the preparation of the emerging Strategic Growth Plan that will guide growth across the HMA. In the meantime, the Submission Plan suggests that the 20% uplift in the housing requirement will provide for a potential unmet need arising elsewhere in the HMA in the future.

However, as set out above, that uplift provides an appropriate mitigation strategy within the Local Plan for unforeseen circumstances in relation to the housing land supply required to meet the District's own needs. It cannot be considered to provide for unmet housing needs arising elsewhere in the District under the DTC.

Moreover, it is very clear that there is already an unmet need arising in Leicester City that needs to be positively addressed now. Shortly after the publication of the HEDNA, Leicester City Council wrote to North West Leicestershire District Council in the context of the examination of its Local Plan, formally declaring an unmet need arising in the City. The reasons given refer to substantial increase in the OAN for the City over the same period compared to the 2014 SHMA (now over a third of the total OAN for the HMA arises within the city), and that the densely urbanised nature of the city, flood constraints and tightly drawn boundaries, limits the amount of land available for development. The letter eschews precisely defining the scale of unmet need, but the Appendix to it highlights that there is already a shortfall of 2,917 dwellings of completions compared to need in the period from 2011, and if completions were to remain relatively consistent, then there would be a shortfall of nearly 11,840 dwellings against the HEDNA OAN by 2031. It later highlights that even if all of the total capacity in the draft SHLAA is developed out in that period, then there would still be a shortfall of 8,834 dwellings against the HEDNA OAN by 2031 (although that is clearly seen as a minimum figure). Oadby & Wigston Borough Council also indicated a potential unmet need arising in the period post 2031.

This is clearly a critical matter that all of the Planning Authorities in the HMA need to address as part of their obligations under the DTC through the preparation of their Local Plan Reviews. It is not appropriate to seek to defer this issue to a review of this Local Plan, particularly because the "Final" MoU is apparently imminent and the currently proposed housing requirement would, therefore, be effectively out of date before the Local Plan is even adopted. Nor is it necessary to wait for the preparation of the Strategic Growth Plan, as that is a non-statutory plan that will consider options for guiding growth in the HMA over the period 2031 to 2050. The identified unmet need in Leicester is arising now (as highlighted by the City Council's letter referred to above) and needs to be addressed now in this Local Plan, otherwise it is fundamentally unsound. A failure to do so will only continue the great uncertainty going forward as to how much development should take place and where, and ultimately lead to a situation where housing needs in the City continue to be ignored.

Land Supply & Housing Trajectory
To accord with the NPPF, the Local Plan must facilitate a continual supply of both market and affordable housing from a "portfolio" of deliverable development sites based on a robust spatial development strategy, with sufficient flexibility to make sure that the identified full OAN for the District and the unmet need arising in Leicester needs are met even if key developments do not proceed as currently anticipated. That will ensure a rolling 5 year housing land supply is maintained, that the overall housing requirements are met within the plan period (NPPF para. 47) and that everyone actually has the opportunity of a decent home.

However, the Submission Plan fails to allocate sufficient housing sites to meet even the identified housing requirement, let alone what the stated requirement should be in light of the matters highlighted above. Notably Policy H1 does not allocate specific sites at the Rural Centres or Selected Rural Villages, instead seemingly relying on Policy GD2 to facilitate delivery of the required development on unallocated sites (the housing trajectory indicates circa 800 dwellings plus over 200 dwellings on windfall sites). However, that approach does not reflects the positive plan led approach to ensuring the delivery of sustainable development to actually meet the identified housing needs as required the NPPF (para 150-151). There is no certainty that there are deliverable or developable sites available in those locations (as required by NPPF para. 47). Policy GD2 should only be used to complement Policy H1 in this regard, and not used as an alternative to the allocation of appropriate sites.

Moreover, as highlighted in Bloor Homes' objection to Policy SS1 there is an over reliance in the Local Plan on a small number of development locations (the SDAs) to provide the majority of the required housing, which creates a significant risk that the identified housing need will not be met in the plan period if one or both of those sites fails to come forward as anticipated. That concern is only exacerbated when the specific issues in relation to the deliverability of both proposed SDAs, as set out in the objections to Policies CS1 and L1, are considered.

Notwithstanding that, entirely unrealistic assumptions in terms of both the timing and rate of delivery at the SDAs have been embedded in the Local Plan Housing Trajectory (Appendix G). That indicates that the Council anticipate that the Lutterworth SDA will deliver its first completions in the period 2022/23, i.e. 51/2 years away from this date. Annual completions are then expected to significantly increase to circa 240 dpa. The first completions at the Scraptoft SDA are expected even earlier in the period 2021/22, i.e. only 41/2 years away from now. Annual completions then expected to increase to circa 180 dpa. On that basis, the Housing Trajectory indicates that the SDAs are expected to deliver a total of 2,702 dwellings in the period to 2031.

In order to achieve that, this Plan will first need to be submitted, examined and, if found sound, adopted. The District Council's Local Development Scheme currently anticipates that the Plan will be adopted by October 2018, but that programme is extremely ambitious given the progress made thus far, and the complexities of the key development proposals on which the Local Plan relies in order to meet identified development needs. Adoption during 2019 does, however, appear feasible subject to the issues highlighted in these representations being appropriately resolved.

Outline planning applications will then need to be prepared, submitted and approved. The very detailed allocation policies in the Submission Plan clearly highlight the scale and complexity of that process for each of the SDAs. Notably, the Policies SC1 and L1 require the prior preparation and agreement of comprehensive Masterplans that have been considered via an independent design review. That is perfectly understandable, but will take time to do given the range of issues that need to be addressed (as highlighted by the allocation policies). Furthermore, given the scale and nature of the sites, the planning applications submissions will need to be accompanied by robust Environmental Statements and Transport Assessments. The outline application preparation process should, therefore, be expected to take 1 to 2 years. The determination of those applications, including the signing of the associated Section 106 Agreements to secure the infrastructure required to support the development, should also be excepted to take 1 to 2 years.

Following the grant of outline planning permission, the sale (if promoted by the landowner) / purchase (if promoted by the developer) of the land needs to be finalised in light of a detailed cost & revenue planning exercise (which is even more complicated if multiple landowners are involved). Reserved Matters submissions will then need to be prepared, submitted and approved, conditions discharged and other (highway and drainage) consents secured to deliver the site. That process will take at least 2 years.

The developers resources (labour, equipment and materials) will then need to be mobilised before the development can begin. That commonly takes around 6 months. Site preparation and enabling works (e.g. infrastructure provision) then takes place prior to the construction of the actual homes and their delivery to the market. The first completions are then usually provided 6 months following the start on site. However, on strategic sites where major upfront infrastructure and site preparation is required, it is often 9-12 months form start on site to first legal completions.

This view of the likely timescales for delivery of the SDAs is supported by the various nationwide studies of the delivery of housing on strategic sites that have been published in recent years. Moreover, the folly of the District Council's delivery assumptions is clearly evidenced by the experiences of other Local Authorities in the HMA that have similarly sought to rely on the delivery of strategic urban extensions (SUEs) in excess of 1000 dwellings in their post NPPF Development Plan Documents in order to meet identified housing needs and are now needing to manage a shortfall in the housing land supply in their area.

Charnwood
The Charnwood Borough Core Strategy was adopted in November 2015 after the Inspector concluded that the delivery assumptions in relation to the 3 strategic urban extensions were optimistic but realistic. The Housing Trajectory indicated that the West Loughborough and North East Leicester sites were expected to deliver completions from 2016/17 and the North of Birstall site was expected to deliver completions from 2017/18. However, none of those sites have come forward as expected. The current position is as follows:

- An outline planning application for the development of the West Loughborough site was submitted in September 2014, and the Borough Council resolved to grant permission a year later in September 2015. However, a Section 106 Agreement has not yet been finalised and so planning permission has not yet been granted over 3 years following the submission of the planning application.
- An outline planning application for the development of the North East Leicester site was submitted in December 2013, and the Borough Council resolved to grant permission a little under a year later in November 2014. However, planning permission was not actually granted until August 2016. Now, over a year later, there is still no sign of the site's development.
- An outline planning application for the development of the North Birstall site was submitted in August 2016, but there is no clear indication when it will be determined.

Clearly the Core Strategy's housing trajectory was entirely unrealistic and now, only 2 years following its adoption, the Borough Council have indicated that there is a shortfall in their 5 year housing land supply.

Blaby
The Blaby District Core Strategy was adopted in February 2013, and relies on the delivery of the Lubbesthorpe SUE to meet the vast majority of the identified housing needs. The Housing Trajectory indicated that the SUE was expected to deliver housing completions from 2014/15. That was considered sound by the Inspector on the basis that the District Council has resolved to grant outline planning permission for the development of the site in September 2012 (following submission of the application 19 months earlier in February 2011).

Planning permission was not, however, actually granted until 16 months later in January 2014. Various Reserved Matters and condition discharge approvals have followed and development has now began, but only 2 completions were recorded by 2016/17. That was over 2 years later than the Core Strategy Trajectory had assumed and the anticipated rate of delivery is now much lower. Consequently, the District Council are now in the process of preparing a Delivery DPD that seeks to allocate additional sites close to the PUA to remedy the growing shortfall in the housing land supply.

Hinckley & Bosworth
The Hinckley and Bosworth Core Strategy was adopted in December 2009 and allocated 2 strategic urban extensions in Earl Shilton and Barwell. The housing trajectory anticipated first completions on both sites in 2012/13. That was followed by the Earl Shilton and Barwell Area Action Plan in September 2014 that sought to facilitate the delivery of the SUEs.

An outline planning application for the delivery of the Barwell SUE was subsequently submitted in February 2015 and the Borough Council resolved to grant permission in June 2016. However, 2 years 9 months later planning permission has still not actually been granted.

A planning application for the development of the Earl Shilton SUE has not yet been submitted.

As a consequence of the ongoing delays in the delivery of these sites, the Borough Council allocated the Hinckley West strategic urban extension in its Site Allocations DPD. That was adopted in July 2016. By that time, the Borough Council had resolved (in June 2016) to approve an outline planning application that had been submitted in over 17 months earlier in February 2015. The submission of the outline application had been quickly followed (in May 2015) by a full application for the development of the first 2 phases and the Borough Council resolved to approve that in August 2016. However, the planning permissions have not yet been formally granted.

Leicester
The Ashton Green SUE was first allocated for development in the Leicester Local Plan adopted in 2006, and reallocated in the Core Strategy that was adopted in July 2014. That assumed that the first completions on the site would be delivered in 2017/18 on the basis that an outline planning permission was granted in January 2014 (following submission in June 2010 and resolution to approve in March 2011). It is understood that a developer partner has not yet been secured, and consequently there is no sign that the site will be delivered in the foreseeable future.

Harborough Housing Trajectory
Based on the conservative analysis of the required timescales to deliver the SDAs set out above, the Submission Plan should assume the first delivery of housing completions at the SDAs a minimum of 6 years post the likely adoption of the Local Plan in 2019; i.e. in the 2025/26 period. Even then there is a significant risk that the resolution of the site specific environmental constraints, infrastructure provision and landownership issues highlighted in the objections to Policies L1 and SC1 and will further delay delivery.

Thereafter a robust view on the rate of delivery needs to be taken. The assumed rate of delivery for the Lutterworth SDA in particular (rising to around 240dpa for a sustained period) is extremely ambitious, and no evidence has been presented that demonstrates that it is actually achievable in this location.

Notwithstanding that, the delay in delivery alone will mean that the Lutterworth SDA will only provide 518 dwellings in the period to 2031 and the Scraptoft SDA will only provide 634 dwellings, resulting in a total shortfall of 1,152 dwellings in the plan period.

Consequences
Consequently Bloor Homes are very concerned that the District Council are not seeking to meet the FOAN across the HMA in accordance with the NPPF or allocating sufficient land to meet the identified housing need. This must be remedied in the Submission Draft Local Plan as the consequences of not planning to meet the identified need would be dire.

The Housing Strategy for England "Laying the Foundations" states in paragraph 1 that a "thriving, active but stable housing market that offers choice, flexibility and affordable housing is critical to our economic and social wellbeing." It continues to highlight (paragraph 5) that "we have not built enough homes for more that a generation and the credit crunch has simply compounded this challenge", and (paragraph 8) that "without urgent action to build new homes, children will grow up without the same opportunities to live near their families, young people will struggle to get a place to call their own and older people will not have the choice and support they need." Furthermore, paragraph 9 states: "Housing is crucial for our social mobility, health and wellbeing - with quality and choice having an impact on social mobility and wellbeing from an early age, and our homes accounting for about half of all household wealth. Social housing should provide support for those who need it, when they need it, and should help vulnerable people to live independently. And opportunities for wealth must be open to all, with housing choices helping rather than hindering people's ability to build assets and find employment."

More recently the Housing White Paper presents startling facts and figures that highlight the acute socio-economic effects of a continued undersupply of housing in the country. Average house prices have rocketed compared to earnings, home ownership in the under 35s has significantly decreased and rental costs are continuing to escalate. The under supply of housing is also having a severe negative impact on the economy in terms of labour mobility, the construction industry, economic spend and increasing housing benefit costs.

A key element of addressing this negative cycle is a focus on "planning for the right homes in the right places" as espoused by the NPPF. The District Council must, therefore, increase the housing requirement established in Policies SS1 and H1 and propose additional development allocations accordingly to ensure that the identified housing needs are actually met.

Land to the North of Uppingham Road, Bushby

Bloor Homes are a house building company who have an interest in land off Uppingham Road, Bushby. Some of that land already benefits from a planning permission and reserved matters approval for the delivery of 275 dwellings, and development of the site will commence in 2018.

However, given the concerns raised in this objection and in that submitted in relation to Policy SS1, Bloor Homes are of the view that the PUA could and should accommodate further development in order to ensure the District's Housing Needs are met and to meet a proportion of the unmet housing need stemming from Leicester within the plan period. The PUA is positioned at the top of the proposed settlement hierarchy that underpins the Submission Plan, and further development at Thurnby and Bushby (over and above that already committed and the proposed allocation of the SDA) would entirely accord with Harborough's established development strategy and housing objectives.

In that context there is additional land available adjacent to the committed site that would be an entirely appropriate development allocation for accommodating an element of that further growth on the edge of the PUA.

The site assessments and masterplanning that has been undertaken to underpin an imminent outline planning application submission have confirmed that the site is suitable and deliverable in NPPF terms. The location benefits from having good access to Leicester via the A47, providing access to an extensive range of higher order services, facilities and employment opportunities. Some key services (such as convenience store, primary schools, post office and GP surgery) are also provided within Thurnby and Bushby (and new additional retail provision will be made as part of the committed site). It is, therefore, entirely appropriate to locate new development in this sustainable location.

Bloor Homes' aspiration for the development of the site is to deliver a high quality housing development that respects its relationship with the surrounding urban form and sensitive environmental and cultural features. In that light, the development proposals for the site have evolved through an iterative masterplanning exercise that has taken into account the requirements of the various technical and environmental assessments, and best urban and landscape design practice. Whilst the development of the site would inevitably result in the loss of agricultural fields on the edge of the settlement, the Masterplan seeks to ensure that the proposals respond to the surrounding landscape character by retaining and enhancing boundary hedgerows and trees within the site wherever possible, and by providing new public open space with additional tree hedgerow planting to ensure a soft transition between the built development and open countryside. Within that context the Masterplan demonstrates that the site has the capacity to deliver a further 125 dwellings.

Local Plan Review
Policy IMP1 sets out the circumstances where a review of the Local Plan would be undertaken. However, a review mechanism is an inappropriate and ineffective response to the fundamental matters of soundness set out above (and in the response to Policy SS1) that need to be directly addressed now before the Local Plan can be found sound. Moreover, such a "commitment" to a Review cannot be enforced if the Council decide, for whatever reason, not to honour the commitment in the policy (e.g. a failure to agree a new MOU that addresses unmet need arising elsewhere).

Whilst a similar review mechanism was endorsed by the North West Leicestershire Local Plan Inspector to address some similar issues, the trigger for the review there is the agreement of a MoU demonstrating a requirement to address an unmet need and that is apparently due in January 2018. A short delay in the submission of the Local Plan will allow the distribution of the development needs to be understood and then agreed ensuring that the unmet needs that are already arising in Leicester are appropriately provided for within the HMA, including Harborough District, in accordance with the requirements of the NPPF.