Harborough Local Plan 2011-2031, Proposed Submission

Support Lutterworth as a Key Centre suitable for growth
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The Council's spatial strategy for distribution of growth is supported. Harborough District Council has arrived at the most appropriate strategy, in accordance with national policy, to deliver the development requirements of the area. The spatial strategy closely aligns with the objectives of higher level strategic plans such as the Strategic Growth Plan and the Strategic Economic Plan.

Leicester & Leicestershire's emerging Strategic Growth Plan (SGP) recognises the M1 as a major corridor and one of the plan's objectives is to maximise the potential of transportation corridors to deliver sustainable development and enable the creation of an integrated public transport network. Furthermore, the spatial options include identifying development through growth corridors and employment led growth. Harborough Local Plan's settlement hierarchy recognises Lutterworth as a Key Centre with capacity to expand and facilities to support growth. The town's location is unique within the district, being close to the M1 and A5 corridors and close to existing and planned employment growth. Therefore, development in this area would accord with the emerging SGP.

In this context, the strategy supports the development of further appropriate and developable land around Lutterworth. Therefore, as explained in representations submitted to this Local Plan elsewhere, Land South of Lutterworth Road fits in with the overall spatial strategy

Policy GD2 is supported. By specifying that appropriate development is acceptable adjacent to the existing or committed built up areas of Key Centres, such as Lutterworth, it ensures that the Plan is positively prepared and provides flexibility as the Plan can respond to changing needs. Other local authorities have similar policies to this in recently adopted local plans.
This policy is in effect to provide a framework for considering potential windfall sites, adding flexibility and ensuring District meets its housing target. Therefore, where there are sites that are known now that meet the criteria in the policy these should be allocated. For instance, Land South of Lutterworth Road, Lutterworth meets the criteria in the policy:
* As a scheme for approximately 90 units, it is of a scale that reflects the size of Lutterworth which has range of services;
* It is physically and visually connected to the town, and this can be further enhanced through improved cycling and walking connectivity;
* It respects the form and character of the area as it is physically contained, surrounded by existing or committed development on three sides;
* Natural boundaries can be retained and enhanced; and
* The site does not diminish in anyway the separation with neighbouring settlements given its strong boundaries

Whilst the Settlement Hierarchy is supported as the most appropriate strategy to deliver growth and rightly identifies Lutterworth as a Key Centre able to deliver growth, an objection is lodged in so far as the policy does not allocate sufficient land to ensure a 5 year housing land supply on adoption. Furthermore, the policy does not boost significantly the supply of housing in accordance with the NPPF.

Trajectory

Based on the Housing Trajectory as shown in Appendix G of the Local Plan, the Council would not have a 5 year housing land supply on adoption. From a base date of 2017, and using the 'Sedgefield' approach, supply would be 4.93 years with a 5% buffer or 4.31 years with a 20% buffer. A base date of 2018 would result in 5.31 years with a 5% buffer or 4.65 years with 20%. Projecting a further year forward to an adoption in 2019 would result in 5.73 years with a 5% buffer and 5.01 years with a 20% buffer. As it stands, due to the Council's record of persistent under delivery against the District's OAN of 557dpa since 2011, it is considered that a 20% buffer is necessary.

Given the above, it is considered both appropriate and necessary for Harborough to allocate further sites that can deliver completions within the first five years. Not only will this ensure choice and competition in the market for land, in accordance with the NPPF, it will also support the Local Plan strategy and existing supply identified in H1. It will also further ensure that the Council can clearly demonstrate the realistic prospect of a 5 year housing supply on adoption of the Plan.

Land South of Lutterworth Road, Lutterworth

Land South of Lutterworth Road, Lutterworth is a site that could help address these issues. The Council's existing evidence base is supportive of development at this site, and further technical work undertaken addresses any remaining potential concerns. The SEELA 2017 identified the site as suitable, available and achievable, however further employment land allocations are not necessary beyond those already identified in the Local Plan. It is in this context that the Plan should consider the relative merits of the site for residential development. HLM consider the site to be suitable, the land is available now and a viable scheme can be delivered. The Illustrative Masterplan submitted with these representations demonstrates how a scheme of up to 90 dwellings could successfully be achieved.

Landscape

The Council's Landscape Character Assessment and Capacity Study for Lutterworth, suggests the landscape capacity for change is medium high for this particular site. Overall, the Council's assessment identified the parcel as one of the most suitable sites in Lutterworth.

The Landscape Assessment concluded that the separation of development from Lutterworth and proximity to M1 meant that commercial or industrial development could be appropriate. It is considered that residential development would be more suitable, given its proximity to residential development to the west, and the highway arrangements that mean the principal access is from the south. The Landscape and Visual Review submitted with these representations demonstrates how the site could be developed, recognising key features, amenity and landscape character.

In addition, the site would be surrounded by existing and committed development on 3 sides, to the north, east and west, and would not draw out the urban form of Lutterworth any further southwards.

Highways

The SEELA 2017 states that the Highway Authority suggests access off Swinford Road to the south of the site is most appropriate and this is the proposed access that HLM is intending to use to secure development. Reference is made in the SEELA to safety concerns as Swinford Road is currently 60mph and pedestrian and cycle access is poor. This year, HLM have undertaken technical work in liaison with the Highway Authority (HA) and Highways England (HE). The HA consider access arrangements to be acceptable in principle. And the HA and HE consider improvements to existing links to the town centre for pedestrians and cyclists acceptable in principle. Furthermore, significant improvements are programmed to the Frank Whittle Roundabout, including for non vehicular users as part of the delivery of the East of Lutterworth SDA. The highways access drawing and technical note on pedestrian crossings options for Lutterworth Road illustrate the progress made to date and how HDC's concerns can be satisfactorily addressed.

Accessibility and Other Mitigation

Land South of Lutterworth Road is in a sustainable location; it has good connectivity to the town centre and key facilities and will be in relative close proximity to the East of Lutterworth SDA. This is demonstrably shown in the submitted 'Site and Its Context' and 'General Connectivity' Plans.

Other mitigation measures, such as those necessary for noise, pollution and ecology can be addressed, and necessary conditions could be imposed to secure these at the planning application stage.

Delivery

HLM is actively preparing a planning application, which will be submitted in the near future. As outlined above, the site's physical constraints and offsite infrastructure requirement can be addressed satisfactorily and quickly. Overall the site is realistically viable and deliverable. Therefore, it is possible that the site in its entirety could contribute towards the Council's 5 year land supply.

Conclusion

Overall, the strategy and policies in the Local Plan and the Council's evidence base should lead to the support for an allocation of Land South of Lutterworth Road. The housing requirement is specified as a minimum figure, the site is within a sustainable location, where further settlement development is acceptable in principle and is suitable, available now and can be delivered in full within 5 years. An allocation will support the delivery of the plan, boost short term supply and allow time for SDAs to be realised.

Finally, it is understood that the Council will be updating the SHLAA prior to the submission of the Local Plan. Land South of Lutterworth Road should be considered in this process, having regard to evidence submitted with these representations and points raised above.

It is welcomed that the affordable housing requirement set out in Policy H2 includes provision for different level of affordable housing or tenure split where there are demonstrable viability considerations. The Council will be aware that whether a development is viable or not can change over time due to a multitude of factors. Therefore, whilst paragraph 5.3.9 of the supporting text cites the recent evidence, "Local Plan Viability Assessment, 2017" as justification, the Council should amend the text to recognise that this evidence is a snapshot in time.

In addition, it is recommended that the Council simply make reference to the latest assessment of affordable housing need rather than specifying the tenure split in the policy.

It is unclear what criterion k in respect of "making provision for specific groups in the community such as the elderly or those with disabilities" means in practice. There appears to be no reference or further detail in the explanation to the policy. It is neither clear what 'make provision' entails for a development proposal or what the Council considers 'specific groups' other than those listed.

Paragraph 154 of the Framework requires that 'only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan'.

HLM therefore object to the policy on the grounds that it is not consistent with the Framework in that it is not clear what is meant by the above criterion.