Harborough Local Plan 2011-2031, Proposed Submission

APPENDIX
HARBOROUGH LOCAL PLAN 2011 TO 2031 PROPOSED SUBMISSION
LEICESTERSHIRE COUNTY COUNCIL RESPONSE

Transport

1. Leicestershire County Council, in its role as Local Highway Authority (LHA), has been working closely with Harborough District Council as part of the Local Plan making process. As such, the LHA is content that the draft submission document is appropriately evidenced and also appropriately deals with transportation considerations at this stage in the planning process.

2. Subject to Harborough District Council's continued commitment to the policies and delivery approaches set out within the document, the LHA supports the submission of the Local Plan and looks forward to working with Harborough District Council in its delivery.

Education

3. Policies F1, MH2 and MH3 include no reference to securing suitable contributions for educational facilities. It may be that the intention is that these are covered by Policy IN1 - Infrastructure Provision, however whilst this policy refers to the Leicestershire Planning Obligations Policy (LPOP), it only does so in terms of waste, it does not refer to education.

4. Policies L1 and SC1 refer to delivery of Primary Schools 'soon after 300 dwellings'. The County Council would normally, and has with Harborough District Council, requested that the intended provision be available for opening in the September prior to the occupation of 300 dwellings.

Ecology

5. It is acknowledged that the de-declaration of the Scraptoft Local Nature Reserve is also currently being consulted on, and that its de-declaration would enable land to come forward for development as part of the Scraptoft North Strategic Development Area (SDA). The County ecologist has and continues to be actively involved, working through an approach which ensures the retention and management of areas of ecological value whilst enabling the release of some land for future development. This may involve the designation of a Local Wildlife Site.

Waste Management

6. The Local Plan needs to recognise that Waste Management considers proposed developments on a case-by-case basis and, when it is identified that a proposed development will have a detrimental effect on the local civic amenity infrastructure, appropriate projects to increase the capacity to offset the impact have to be initiated. Contributions to fund these projects are requested in accordance with Leicestershire's Planning Obligations Policy and the Community Infrastructure Legislation Regulations.

Economic Growth

7. The County Council supports the new employment land allocated in association with the Lutterworth SDA and recognises a similar approach is not necessarily appropriate with the Scraptoft North SDA with opportunities to access existing B use employment sites and proximity and ease of access to the City for employment.

8. The proposed portfolio of B use employment land in the Local Plan, which will provide the opportunity to deliver a range of jobs and economic prosperity in the District and wider area, is supported.

9. The County Council supports the approach taken to strategic storage and distribution (strategic B8 use) at Magna Park in the Local Plan, which has been informed by recent evidence commissioned by Harborough District Council. In particular, it supports additional strategic distribution proposals at Magna Park needing to meet the six criteria set out within the second part of Policy BE2, which sets a limit of 700,000 square metres for non-rail-served strategic B8 use in the Plan period.

10. The emphasis on the vitality and viability of the town centres is supported, and the regeneration emphasis on Lutterworth town centre although it is considered there is scope to strengthen this further, beyond the focus on vacant units absorbing identified need in Lutterworth town centre.

Strategic Assets

11. Comments from Strategic Assets are made in relation to the County Council's role as landowner. Its main interests in Harborough District are:

* land at Misterton County Farms Estate which forms part of the East of Lutterworth SDA (for which a separate detailed collaborative response will be submitted on behalf of the landowner consortium), and;
* potential smaller scale sites within Market Harborough, Lutterworth and rural settlements throughout the District.

12. Query whether the settlement hierarchy requires further consideration, to enable settlements which are better serviced than others in the same tier of the hierarchy to be more clearly distinguished and potentially receive more development.

13. In general terms the distribution of housing across the settlement hierarchy is supported; however, considers that there needs to be more clarity regarding the future housing needs of key settlements and seeks more flexibility for future housing numbers for smaller settlements.

14. The allocation of the East of Lutterworth SDA as a preferred strategic housing allocation is, in particular, strongly supported. The Objectively Assessed Need (OAN) supported by the Housing and Economic Development Needs Assessment (HEDNA) should therefore inform and provide strategic guidance to the development of later SPDs and Neighbourhood Plans. In considering the distribution of housing in the lower tiers of the hierarchy the Plan needs to demonstrate that those key centres and rural centres with neighbourhood plans will deliver housing numbers based on the current OAN rather than those contained within existing plans which were based on an earlier, much lower, OAN. Without this clarity the methodology could be open to criticism.

15. The integration of the social element of housing for older people and specific groups should be incorporated within the quantum and mix of affordable housing in order to mitigate any negative effect on site viability.

16. The County Council requests that planning consents at Airfield Business Park, Market Harborough (BE1.1a (ii)) and the land south of Lutterworth / Coventry Road, Lutterworth (BE1.1b (ii)) should be shown as existing commitments. Further, the consented site at Gaulby Road, Billesdon (a former highways depot), should also be shown as a commitment.

17. Whilst recognising the desire to concentrate strategic distribution at Magna Park, the proposal in Policy BE2.2 to allocate sites capable of delivering units of at least 9,000 sqm is seen as logical, as is the desire to stimulate economic growth by delivering sites that meet regional and sub-regional demand.

18. Policy BE3 on existing employment areas is supported; BE3.1 being seen as of particular relevance in ensuring that development meets the needs/demands of the wider sub-regional market in addition to local businesses in order to attract inward investment.


19. The allocation of both convenience and comparison retail floor space within the Lutterworth East SDA in Policy RT1 is supported, as is the additional provision within Lutterworth town centre which will complement the development of the new local centre and maintain a balance across the expanded community.

20. Policy L1- East of Lutterworth SDA is strongly supported. Being situated in the M1 corridor within one of the priority areas for economic growth in the Strategic Economic Plan it is clear that Lutterworth should be the focus of major strategic development within the District. The East of Lutterworth SDA is seen to meet best the criteria set out in Key Issues section of the plan and compliments the further development of Magna Park. Further, it is confirmed that the site, which is recognised as the most sustainable location for major development within the district, is available, being owned by a consortium of willing landowners, deliverable and capable of supporting a viable development.

21. Policy L2 - Land south of Lutterworth Road/Coventry Road. Outline planning consent has been granted and accordingly it should be regarded as an existing commitment for the purposes of the Local Plan.