Harborough Local Plan 2011-2031, Proposed Submission

The Consortium strongly supports the Council's spatial strategy for distribution of growth. It is clear that 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, strategic development in this area would accord with the emerging SGP.

In addition, the Strategic Economic Plan (SEP) identifies South West Leicestershire as a priority growth area to deliver the economic goals for the sub region. The M1 and A5 are essential economic corridors for the sub region and important nationally. There is already substantial business investment and evidence identifies further job growth here in the future. Thus, in order to support their strategy the Local Enterprise Partnership is focussing investment in infrastructure in this area. Hence, through the spatial strategy of the Harborough Local Plan, strategic development of Lutterworth and the surrounding environs, including Magna Park, is essential to the delivery of this priority growth area in the SEP.

Alternate spatial strategies that the Council have considered, such as focussing strategic growth around Rural Centres such as the Kibworths, would not deliver the aims and objectives of either the emerging Strategic Growth Plan or the Strategic Economic Plan of focussing growth around the greatest opportunities for increased economic development linked to key transport corridors and infrastructure investment. Such dispersal of strategic growth to more remote settlements would also not help to achieve a sustainable pattern of development as required by the Framework.

Alternate spatial strategies would not therefore achieve sustainable development by failing to ensure that sufficient land of the right type is in the right place to support growth.

How L1 fits with the overall spatial strategy

East of Lutterworth fits with the Local Plan's overall spatial strategy, and is the most appropriate location for large scale growth to meet housing and employment needs in the town and the District. Lutterworth benefits from range of services and facilities, which make it suitable for significant development as a Key Centre. It is also located close to significant employment opportunities both within the town itself and nearby Magna Park.

The allocation of East of Lutterworth facilitates the growth of the town in a sustainable way without harming the separate identity of neighbouring settlements. It also provides for a range of benefits and can mitigate potential impacts.

The Consortium has produced a Vision Statement, submitted with these representations which sets out in detail the site characteristics, context, the alignment of the East of Lutterworth SDA with the Local Plan, the benefits of the scheme and a concept masterplan.

The key points from this are summarised below:

Benefits

The delivery of the land to the East of Lutterworth offers many significant benefits, much of which is described in the Policy L1 and the supporting text. In accordance with the plan East of Lutterworth will provide approximately 2750 market and affordable homes and 23 hectares of employment land. In addition range of community facilities are proposed to service the development and the wider area, including primary schools, neighbourhood centre, parks and open spaces and enhanced green infrastructure.

The allocation will also facilitate the provision of a spine road to both serve the development and divert traffic from Lutterworth town centre, which suffers from pollution and congestion and is consequently zoned as an Air Quality Management Area. This will assist substantially in the Council's statutory obligations to undertake measures to reduce harmful particulates. The reduction in traffic will improve the shopping environment in the town centre and provide opportunities to strengthen the retail economy.

Further, significant investment in highway and transport infrastructure will compliment other investment programmes within this corridor.

Mitigating Impacts

Currently, East of Lutterworth is predominantly agricultural fields; however the site does contain some key assets. These include Misterton Marshes, a Site of Special Scientific Interest, which will be protected and enhanced in accordance with national and local planning policies. The Consortium has undertaken technical ecological work in consultation with Natural England and the Environment Agency to agree an appropriate strategy to protect the SSSI, and the first iteration of the Feasibility Study in relation to this is on the Council's Evidence Base webpage. Submitted with these representations is the latest iteration of the Feasibility Study (October 2016), along with correspondence from Natural England confirming that the mitigation scheme is feasible, subject to securing appropriate conditions or obligations at the detailed planning application stage. Elsewhere, the proposed green infrastructure network will be developed to include enhancements to other significant features such as the River Swift and Thornborough Spinney.

Other potential impacts include traffic and transport, which will be mitigated by a network of vehicular and non vehicular routes, and connections to Lutterworth town centre provided to ensure suitable and sustainable access. To this end, the Consortium have engaged extensively with the Local Highways Authority and Highways England in respect of both access and necessary offsite highway works, taking account of predicted traffic forecasts and junction capacity assessments, which can be found in the Draft Strategic Transport Assessment for East Lutterworth (STA) on the Council's evidence base webpage. Consequently a strategy of required highway works and broad timings has already been agreed. The STA Executive Summary and associated appendices submitted with these representations provides the latest update in this respect.

Infrastructure Requirements & Costs

Given the scale of the development, there are significant infrastructure requirements. Policy L1 sets out the key infrastructure required for development with specific triggers. The Consortium supports the identified infrastructure requirements and the Council's estimated costs for their delivery.

The costs for infrastructure provision for the site will principally be met through secured and future capital receipts yielded from the development of the allocation. Other sources of funding will be sought where appropriate and necessary including the Housing Infrastructure Fund, or other sources which may assist with cash flow and/or pump prime the development. However, the Consortium does not consider the other sources of funding essential to deliver the Strategic Development Area.

Addressing key physical constraints

Key physical constraints principally relate to creating access to the site, offsite highways works, and an additional access across the M1 in a later phase of development at the northern end of the allocation.

The first principal accesses will be created at the southern end of the SDA from the A4304, which will enable the development of the employment land to the south and the initial phase of residential development to the north. In addition to this, offsite highway works will address highway capacity at key junctions including the J20 of the M1 and the Frank Whittle roundabout.

From the southern access, the spine road will be phased before linking via a new bridge over the M1 to the A426 to the north of Lutterworth town centre in a later phase of the plan period. It is appropriate that as well as the allocation to the east of the M1, the Council have additional safeguarded land in this area to allow for flexibility in the siting and design of the motorway bridge and access to the A426 to the west. The Consortium will support the Council in the use of its Compulsory Purchase Powers to ensure the certainty of delivery of this link and the proper planning of the area.

Realistically viable and deliverable

The Consortium considers East of Lutterworth to be viable and deliverable. The Consortium is willing to bring forward the land in their control for development and consider that the allocation as proposed will generate a meaningful return. More specifically, Leicestershire County Council has formally resolved to promote this land for development as detailed in the minutes of the Cabinet Meeting held on 9th May 2016 attached to this representation.
The Council's housing trajectory at Appendix G of the Local Plan is considered a reasonable assumption of the delivery for the East of Lutterworth SDA. The Consortium can confirm that early work has started on the preparation of an outline planning application for the entire site. An indicative timetable for this process is attached to this representation. The timetable takes a cautious approach and allows extensive time for the preparation of a collaborative masterplan, environmental impact assessment, determination of the application and agreement of funding obligations.

On this basis, first completions starting in 2022/23 can be expected, with outlets and completions rising through the plan period as parcels of land are opened up for development. The Consortium is committed to seeking opportunities and working with partners to bring forward infrastructure, particularly the spine road, as early as possible in order to accelerate delivery of homes and jobs. Given experience elsewhere and demand within the housing and employment market area, the trajectory is considered achievable.

Employment Land (e)
The Consortium is supportive of the allocation of 13 ha of non-strategic storage and distribution uses on land to the south of the A4304 as part of the Strategic Development Area. It is appropriate to identify land for additional B8 employment uses in the South West Leicestershire growth area, and in specific locations attractive to the market for logistics and storage. Locating employment land close to new areas of residential land will provide new opportunities for people to live and work in close proximity, and represents sustainable economic growth. Furthermore, this part of the SDA could deliver significant value to help fund necessary offsite infrastructure at an early stage in the development of the allocation.
However, objection is raised at the imposition of a maximum floor space area of 9,000sq.m. It is suggested a more flexible approach should be taken that responds positively to economic demand and opportunities in accordance with national policy (see bullet point 3 of paragraph 21 of the Framework).

Air Quality (y)

The delivery of the spine road for East of Lutterworth SDA will facilitate a reduction in traffic passing through Lutterworth town centre and consequent concentrations of air pollution. However, the Consortium has concerns as to the specific wording 'no moderate or worse adverse impact' in respect of impacts of the Lutterworth AQMA. This phraseology is not consistent with national policy which is concerned with preventing 'unacceptable levels' of air pollution (see bullet point 5 of paragraph 109 of the Framework).

Triggers (various)

Whilst the Consortium considers that the triggers for delivery of infrastructure as specified in the policy should be capable of being met, it is felt that they are not necessary in the policy itself.

National policy states that in bringing forward land, Local Plans should provide detail on form, scale access and quantum (see bullet point 5 of paragraph 157 of the Framework), but it does not require infrastructure trigger points to be specified. Furthermore, national policy states that the Local Plan should only include policies that provide a clear indication of how a decision maker should react (paragraph 154).

The crystallisation of trigger points for key infrastructure would normally be developed and agreed during the master planning and planning application processes, where phasing, need, viability and other considerations can be considered in much greater detail. In the absence of this work being undertaken, the suggested trigger points may well need to change. Whilst the wording of each trigger is caveated to allow flexibility in their interpretation, their inclusion is not necessary and may create uncertainty for decision makers in how to respond to planning applications in due course.

The provisions within Policy GD9 are supported to ensure mineral resources are not unnecessarily sterilised. It is suggested that the explanation should also emphasise the importance of viability as well as the practicality of prior extraction. For instance, the Consortium, have reviewed the mineral resources of the East of Lutterworth SDA. Evidence provided with these representations confirms that it would not be practicable to exploit the mineral resource in this area due to economic and environmental constraints. This includes the prohibitive measures required to protect the SSSI and the watercourses in the area.

The Consortium support the Council's approach to the provision of new housing being specified as a minimum figure and identifying a housing supply over and above the District's own needs to address unforeseen circumstances and unmet needs elsewhere. The Settlement Hierarchy is the most appropriate strategy to deliver growth co-locating strategic housing and economic development in those areas with the greatest propensity to give access to services and facilities by sustainable modes of transport, aligned with the investment strategies of the sub-regional economic bodies.

The provision of affordable housing is supported. However, 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 also suggested that the policy provide additional flexibility for large scale developments that would be delivered over numerous phases, in order to allow a reasonable degree of flexibility within each phase.

The aims of the policy overall are supported. However, whilst the Council's plan wide viability deems the policy generally viable, this can change over time and therefore the requirements as specified should also allow for variation where there are viability or practical considerations.

The evidence in respect of the provision of 4% of dwellings as Part M, Category 2, is not substantive enough to warrant this requirement. The HEDNA 2017 (para. 9.24 and 9.25) only makes broad assumptions nationally and regionally about need, and the report highlights the limitations of the evidence. It is also unclear how this figure relates to general housing need and specialist housing required in policy H4.