Harborough Local Plan 2011-2031, Proposed Submission

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Harborough Local Plan 2011-2031, Proposed Submission

2.1 Local Plan vision

Representation ID: 6823

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The HCA fully supports the process Harborough District Council has undertaken. The HCA will continue to work positively with Harborough District Council and Partners to support housing delivery within the District and wider Housing Market Area, using the range of investment and other possible interventions that are available to the Agency. The HCA wishes to make representations to the Submission Draft Local Plan, specifically in regard to the surplus landholding at Stretton Hall Farm which extends to 96.6ha. The site is adjacent to the border of Oadby and Wigston Borough Council and the Leicester Principle Urban Area (PUA).

Full text:

The Homes and Communities Agency (HCA) fully supports the Local Plan preparation process that Harborough District Council has undertaken, and recognises the collaboration and co-operation that has taken place with a range of Partners and stakeholders. The HCA will continue to work positively with Harborough District Council and Partners to support housing delivery within the District and wider Housing Market Area, using the range of investment and other possible interventions that are available to the Agency.
The HCA wishes to make representations to the Submission Draft Local Plan, specifically in regard to the surplus landholding at Stretton Hall Farm which extends to 96.6ha. The site is adjacent to the border of Oadby and Wigston Borough Council and the Leicester Principle Urban Area (PUA). It is currently in agricultural use. To the north west is the residential edge of Oadby and to the south east is Leicester Grammar School. The Site wraps around a residential development built in the 1990s on the site of the former hospital at Stretton Hall.
These representations are being made in the context of emerging housing requirements at the Housing Market area level, and national government objectives to make the best use of public sector land to support the delivery of housing. The representations are seeking to secure the status of the Stretton Hall land as a potential Reserve Site, should the need arise as part of the plan making process.
The HCA has not formally promoted the site in the earlier consultation stages of this plan however, discussions with Council Officers were undertaken in the early plan preparation stages. More recently the HCA has recently met with senior officials and identified to Harborough District Council that the site is available, suitable and achievable. There are no constraints to development of the site that cannot be adequately mitigated and the site provides the opportunity to help achieve a Sustainable Urban Extension of around 1900 dwellings, that is well located to Leicester and Oadby.
As surplus public sector land, the HCA is looking at opportunities for bringing forward land at Stretton Hall for high quality residential /residential-led development at the earliest opportunity. This important site can help contribute to the delivery of more homes within the country and help to meet national government commitments to enable more people to own a home of their own and to access housing more generally, particularly affordable homes. To this end, the site's development potential of circa 1900 dwellings has been assessed in terms of its capacity to support residential development, having regard to known physical, environmental and policy constraints. It also represents a significant opportunity to provide a range of local facilities and services as part of the proposals for the site.

Support

Harborough Local Plan 2011-2031, Proposed Submission

SS1 clause 1. manage planned growth to 2031 in accordance with the following settlement hierarchy:

Representation ID: 6824

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

In principle, the HCA supports development near to the edge of Leicester, but notes the historic emphasis for development to the east of Leicester and considers that this should be rebalanced with development to the South East, namely the Stretton Hall Farm site. This would prevent over-development to the east, spread the benefits of new development outwards, provide flexibility for housing supply, avoiding a significant amount of development coming forward in one area at the same time. HCA contends that such a rebalancing of development would support the position that the settlement strategy has been positively prepared and justified.

Full text:

The proposed settlement strategy places great emphasis on settlements near to the edge of Leicester, in particular Scraptoft, Thurnby and Bushby. In principle, the HCA supports development near to the edge of Leicester, but notes the historic emphasis for development to the east of Leicester and considers that this should now be rebalanced with development to the South East, namely the Stretton Hall Farm site. This would prevent over development to the east, spread the benefits of new development outwards and provide flexibility for housing supply, avoiding a significant amount of development coming forward in one area at the same time. The HCA contends that such a rebalancing of development would support the position that the settlement strategy has been positively prepared and justified.
The proposed Housing Trajectory is based largely upon the two Strategic Development Areas (SDAs) identified within the plan, and large sites with planning permission. The HCA is also aware that work is underway between the Leicestershire Local Authorities to consider the distribution of unmet housing needs arising from Leicester, over and above the proposed 15% buffer.
In particular, Leicester City Council's Emerging Local Plan Options document identifies a shortfall of circa 15,000 dwellings up to 2031. The accompanying Strategic Housing Land Availability Assessment (SHLAA) finds a potential capacity within Leicester City Council administrative boundary for circa 7,100 dwellings, leaving land for circa 7,900 dwellings to be found. It is important to note that the SHLAA states that there is no guarantee of those identified potential housing sites delivering the estimated housing yields, meaning that there may well be a need for other Local Planning Authorities to find sites for more than the 7,900 anticipated shortfall up to 2031.
In the Leicester and Leicestershire Authorities Joint Statement of Co-operation Relating to OAN January 2017 (Memorandum of Understanding), the OAN for each individual district in the Housing Market Area (HMA) is considered to be secondary to that of the HMA as a whole.
The nine local authorities and the LLEP have jointly agreed to produce a Strategic Growth Plan, a non-statutory strategic plan looking forward to around 2050. The Strategic Growth Plan is anticipated to be complete at the end of 2017/early 2018 and has not, therefore, informed this Submission Draft. However, it can be assumed that there will be a significant unmet housing need to be accommodated in the other local authorities in the HMA. As the need arises from Leicester City Council it seems sensible that need should be accommodated as close to Leicester as practicable. In this way, Stretton Hall is ideally located to assist with meeting this need.
Table.1 OAN as defined in HEDNA (January 2017) and Theoretical Capacity based on assumptions as set out in notes below (Source - Leicester and Leicestershire Authorities Joint Statement of Co-operation Relating to OAN January 2017 (Memorandum of Understanding)).
OAN*1 (2011-2031) OAN*1 (2011-2036) Theoretical Total
Capacity*2
Harborough DC 10,640 12,850 30,578*3
Leicester City Council 33,840 41,700 26,230*3
Oadby and Wigston 2,960 3,875 2,799*3
*1 The OAN as set out in the agreed HEDNA
*2 This figure is based on information on completions, commitments, windfalls and SHLAAs
*3 The final figure will be determined by each authority through the Local Plan process.
The 2017 Leicester and Leicestershire Housing Needs and Economic Development Needs Assessment (HEDNA) figures, as set out in the table above, clearly shows that both Leicester City Council and Oadby and Wigston Borough Council cannot accommodate their housing need within their own boundaries.
The Leicestershire HMA authorities reached agreement in summer 2016 on appropriate trigger mechanisms that would be inserted into all Local Plans coming forward before the Strategic Growth Plan. The HCA supports draft Policy IMR1 which sets out the proposed approach to monitoring and reviewing the Local Plan.
However, the HCA suggests that the inclusion of the Stretton Hall Farm site as a Reserve Site, if additional land is needed, would assist the Council in demonstrating that the plan would be effective and best able to respond to changing circumstances. It also reflects the role of the HCA in delivering Government objectives of making the best use of surplus public sector land to deliver housing, and to invest in driving up housing supply.

Support

Harborough Local Plan 2011-2031, Proposed Submission

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

Representation ID: 6826

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The inclusion of Stretton Hall Farm as a Reserve Site would help HDC accommodate unmet need from neighbouring authorities, as well as contribute to its own rolling 5 year housing land supply, and would be in compliance with the guidance contained within the NPPF and would add substantial weight to the soundness argument.

Full text:

The HCA welcomes Harborough Districts commitment to helping other Local Authorities meet their unmet housing needs in the HMA and acknowledgement that the District cannot be viewed in isolation from adjoining areas. The scale of Leicester City Council's unmet housing need will be established during the progress of its Local Plan, which is expected to be adopted in 2018.

The current DCLG "Planning for the right homes in the right places: consultation proposals" include a draft standardised method of calculating OAN. Under that formulae, the OAN for Leicester City Council and Harborough District Council would increase by circa 396 and 10 dwellings per year respectively.
Paragraph 5.1.10 states that the Submission Draft Local Plan "...includes a 15% contingency in the supply of housing land in order to allow for possible future circumstances affecting the supply of housing in the District, including a potential need to help meet demonstrable unmet housing need arising from other local authorities within the Leicester and Leicestershire Housing Market Area".
The work carried out by the HEDNA and Leicester City Council's SHLAA could suggest that some of the unmet housing need from Leicester City Council could be required to be accommodated within Harborough District Council's administrative area. As such, further consideration should be given as to the level of buffer (15%) being applied, in order to assist in maintaining a rolling five year housing land supply or accommodate a fair proportion of the unmet housing need from neighbouring authorities.
The Local Plans Expert Group (LPEG) (established by the Communities Secretary and the Minister of Housing and Planning), with a remit to consider how local plan making can be
made more efficient and effective, recommend:

"that the NPPF makes clear that local plans should be required not only to
demonstrate a five-year land supply but also focus on ensuring a more effective
supply of developable land for the medium to long term (over the whole plan
period), plus make provision for, and provide a mechanism for the release of,
developable Reserve Sites equivalent to 20% of their housing requirement, as far
as is consistent with the policies set out in the NPPF. Reserve Sites represent land
that can be brought forward to respond to changes in circumstances."
The inclusion of Stretton Hall Farm as a Reserve Site would therefore be in compliance with the guidance contained within the NPPF and would add substantial weight to the soundness argument.

Support

Harborough Local Plan 2011-2031, Proposed Submission

SP5: Providing transport and other infrastructure to support new development.

Representation ID: 6827

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The HCA supports SP5 in principle and confirms that the development of the Stretton Hall Farm site would contribute to plans to improve the connectivity of SE Leicestershire through Section 106 contributions, to improve walking, cycling and bus connections, and potentially contribute to the improvement of the strategic highway network, in particular the important A6 corridor, and support the aims of the Midlands Connect initiative, which in turn would support the Governments objectives for the West Midlands Engine.

Full text:

The HCA supports SP5 in principle and confirms that the development of the Stretton Hall Farm site would contribute to plans to improve the connectivity of SE Leicestershire through Section 106 contributions, to improve walking, cycling and bus connections, and potentially contribute to the improvement of the strategic highway network, in particular the important A6 corridor, and support the aims of the Midlands Connect initiative, which in turn would support the Governments objectives for the West Midlands Engine.

Support

Harborough Local Plan 2011-2031, Proposed Submission

Objective 1. Housing

Representation ID: 6828

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The Stretton Hall Farm site can provide for a range of housing needs, including affordable homes, self-build plots, specialised care homes and a range of housing types and sizes. Its development would improve local sustainability and provide a range of community facilities and benefits, green infrastructure and improvements to the highway network.

Full text:

The HCA supports Objective 2 in principle and has many programmes, tools and funding streams available to support Harborough District Council in the delivery of a range of house types, tenures and sizes to meet local needs in the District, including the Affordable Homes Programme, Single Land Programme, and HCA Recoverable Investment.
Such investment programmes and tools will also allow the HCA to bring development at Stretton Hall forward quickly, and ensure an appropriate mix of housing types and tenures are available. The HCA has significant experience in enabling early delivery and the Stretton Hall Farm site can begin to contribute to the Districts housing supply in the early to mid-stages of the Plan.
There are no constraints on the site that cannot be mitigated. There are no statutory designated biodiversity sites within 1.5km of the site boundary. The existing farm buildings are not of any historic value. The site is within Flood Zone 1. At a local level the Leicester PUA Landscape Character Assessment and Landscape Capacity Study, September 2009 outlines the site as one of three study areas within the Leicester Fringes Local Landscape Character Area and considers the site to have a medium to high capacity to accommodate development.
Consideration has been given to the development potential of the Site based on a capacity assessment of the development impact on the local road network and also a review of design standards for access. The southern section of the Site benefits from good access to sustainable transport, with a bus stop provided to the north of Chestnut Drive. The junctions within proximity of the Site are all well within operational capacity and would remain so up to circa 900 dwellings. Widening of Chestnut Drive from 5.5m to 6.75m could enable a greater number of dwellings to be served.
Provision of an additional arm to the Glen Gorse roundabout could, in conjunction with the existing Chestnut Drive access, accommodate circa 1,900 dwellings.
The Stretton Hall Farm site can provide for a range of housing needs, including affordable homes, self-build plots, specialised care homes and a range of housing types and sizes. Its development would improve local sustainability and provide a range of community facilities and benefits, green infrastructure and improvements to the highway network.

Support

Harborough Local Plan 2011-2031, Proposed Submission

H1 Opening sentence

Representation ID: 6829

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The reduction of the 20% buffer to 5% from 2018/19 onwards is noted, but needs to be considered in the context of the Council's shortly anticipated 5 year housing land supply update and the cross boundary housing needs. It is proposed that draft Policy H1 be amended to include the wording as set out in the main representation, which is drawn from the Inspectors comments on the recent Scarborough Borough Council Local Plan.

Full text:

The latest update on the 5 year housing land supply for Harborough District Council is that dated 12 July 2017 and covers the period from 01 April 2017 to 31 March 2022. It notes that the HEDNA recommends a total housing requirement of 10,640 between 2011 and 2031, or 532 dwellings per annum. The latest update from Harborough District Council (dated July 2017) states that the Council has applied a 20% buffer. This buffer, in addition to the shortfall to be added to the annual requirement over the next 5 years equates to a requirement for the next 5 year period of 815 dwellings. As assessed against the five year supply of deliverable dwellings, this equates to a 4.45 year supply of land. The reduction of the 20% buffer to 5% from 2018/19 onwards is noted, but needs to be considered in the context of the Council's shortly anticipated 5 year housing land supply update and the cross boundary housing needs. It is proposed that draft Policy H1 be amended to include the wording as set out below, which is drawn from the Inspectors comments on the recent Scarborough Borough Council Local Plan:
"Notwithstanding the position as set out in the HEDNA January 2017, there is a need to continually monitor delivery and the supply of housing sites to ensure a minimum rolling five year supply throughout the Plan period. Should the local planning authority be unable to demonstrate a deliverable five year supply at any point, Policy HC1 provides the mechanism for the delivery of sites not allocated within the Plan, that are well related to the neighbouring administrations that are unable to meet their OAN, are of an appropriate scale to deliver sustainable development and that meet the requirements of other relevant local and national policies, including the Presumption in Favour of Sustainable Development (Policy SD1).
In such cases, proposals will not be required to accord with polices GD3, GD4 or H3 within this plan but will have to demonstrate that they will be deliverable in the short to medium term and contribute to any identified shortfall in the five year supply of housing sites. Any development granted permission under the auspices of making up shortfalls in the five year supply will not be renewed automatically if the permission expires."
Paragraph 47 of the NPPF states that to boost significantly the supply of housing, Local Planning Authorities should "...ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area." The HCA is aware that an increase in flexibility regarding the supply of housing sites that can come forward during the plan period, may assist in meeting this national policy requirement.

Support

Harborough Local Plan 2011-2031, Proposed Submission

IN1 clause 1

Representation ID: 6831

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The HCA welcomes and supports the position that major development can be permitted where there is, or will be when needed, sufficient infrastructure capacity to support and meet all the requirements arising from it. Future development on land Stretton Hall Farm benefits from the presence of existing infrastructure, including direct access to the Strategic Highway Network.

Full text:

The HCA welcomes and supports the position that major development can be permitted where there is, or will be when needed, sufficient infrastructure capacity to support and meet all the requirements arising from it. Future development on land Stretton Hall Farm benefits from the presence of existing infrastructure, including direct access to the Strategic Highway Network.

Support

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: 6832

Received: 16/11/2017

Respondent: Homes England

Agent: Amec Foster Wheeler

Representation Summary:

The HCA respectfully request that the Stretton Hall Farm site is included as a Reserve Site, to be developed in the event that the District cannot demonstrate a 5 year Housing Land Supply and/or in response to emerging unmet housing needs within the HMA. The Stretton Hall site should also be included as a Strategic Site within the anticipated early review.

Full text:

The HCA respectfully request that the Stretton Hall Farm site is included as a Reserve Site, to be developed in the event that the District cannot demonstrate a 5 year Housing Land Supply and/or in response to emerging unmet housing needs within the HMA. The Stretton Hall site should also be included as a Strategic Site within the anticipated early review.
The HCA further request that it be invited to the appropriate Hearing Sessions, as a significant land holder and housing delivery partner for Harborough District Council.
The HCA look forward to working in partnership with Harborough District Council and the adjoining administrations to strengthen the District's position on Housing Land Supply and enable the development of Stretton Hall Farm to contribute to the vision of enabling residents to benefit from increased access to suitable housing.

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