Harborough Local Plan 2011-2031, Proposed Submission

Policy SS1 identifies The Kibworths as a Rural Centre, which given the level of facilities and services within the settlement is considered appropriate. The supporting text notes that of the Rural Centres "The Kibworths and Great Glen are the largest with significant village centres offering a range of shops and services" and "The Kibworths benefit from a secondary school."

Part 7 of the policy seeks to "enable Fleckney, Great Glen, and The Kibworths and, to a lesser extent, Billesdon, Houghton on the Hill, Husbands Bosworth, and Ullesthorpe to operate as Rural Centres providing housing, business, retail, leisure, and community facilities."

DWH supports these elements of policy SS1. However DWH does not support the fact that no additional housing is proposed above existing completions and commitments in Kibworth, as set out in relation to Policy H1.

This policy effectively provides a framework for considering potential windfall sites. By specifying that appropriate development is acceptable adjacent to the existing or committed built up areas of Rural Centres, the Plan should be regarded as being positively prepared and flexible.

However, because of the requirement for the policy to not significantly exceed the housing targets set out at Policy H1 of the Local Plan, DWH does not support the policy. Further comment is provided in relation to Policy H1 itself.

The Local Plan proposes two Areas of Separation where it considers the potential for settlement coalescence is greatest (paragraph 4.3.6). Outside of these two areas, the prevention of coalescence is given protection by part e) of Policy GD2.

Part 2 of the policy seeks to prevent development in the Areas of Separation "where it would not compromise, either alone or in conjunction with other existing or proposed development, the effectiveness of the Area of Separation in protecting the identity and distinctiveness of these settlements." The wording of Part 2 of the policy is broadly supported as it is more flexible and less restrictive that saved Policy EV/3 of the 2001 Local Plan.

The supporting text at paragraph 4.11.3 states that Areas of Separation may be added by future neighbourhood plans. It is acknowledged by DWH that their land interest at Smeeton Road is designated as an Area of Separation in The Kibworths Neighbourhood Plan, although this policy is not yet part of the development plan.

The proposed Neighbourhood Plan Area of Separation has not undergone the same rigorous assessment process as that undertaken by HDC. It should be noted that in the Council's own evidence (Rural Centres Landscape Sensitivity Assessment), the potential for coalescence at Smeeton Road is considered to be of medium impact (as opposed to high or medium-high) for the majority of the site (land parcel 11). After taking into account coalescence and other visual impact criteria, the RCLSA concludes that the site "has a Medium capacity to accommodate development. Residential development is considered most suitable for this location and can be seen as a natural extension to the existing built edge of Kibworth Beauchamp to the north."

Policy H1 states that in addition to existing completions and commitments, a minimum of 4,600 new homes will be provided up to 2031. In the Rural Centres only a further 110 dwellings are proposed, the majority of these in Houghton on the Hill.

DWH notes that scenarios of extremely high levels of housing development or no housing development in Kibworth were tested during the latter stages of the Local Plan assessment process (final spatial alternatives). Whilst there has been a high level of completions and commitments in Kibworth over the plan period so far, it is considered that Policy H1 could be more flexible in enabling additional development in Kibworth to come forward to meet local housing need, i.e. to contribute towards a housing land supply shortfall, to take account of lapse rates on committed developments in the Rural Centres or committed sites in the Rural Centres that prove to be undeliverable or undevelopable.

It is considered that in these circumstances, a modest amount of additional development should be permitted in Kibworth. David Wilson Homes site at Smeeton Road (site reference A/KB/HSG/15) could deliver in the region of 150-170 dwellings. The site is assessed in the Council's SHLAA where it was considered to be suitable, available and achievable for residential development and deliverable in accordance with the NPPF definition (i.e. in 0-5 years). The Sustainability Appraisal which forms part of this consultation considers that the only factor where mitigation is likely to be required (as opposed to may) or where there is an unavoidable impact is access to a railway station, which is comparable across the majority of sites in the Rural Centres.

The Sustainability Appraisal identifies the low levels of development at Great Glen, Ullesthorpe, (under SDA options) and Kibworth (Options B and D) as a key issue (p.130), concluding that this "could lead to less positive effects on health, wellbeing, housing and economy (than relying on completions and commitments alone)." In relation to this issue, the SA considers that:

"...an increase in growth at Great Glen and Kibworth would not be expected to have significant negative effects upon the built and natural environment. However, it would generate positive effects in these settlements, whilst mitigating negative effects at more sensitive locations (For example South Kilworth).

Under options 3 (Scraptoft North) and 6 (Lutterworth East), it ought to be possible to increase housing delivery in Kibworth (given its role as a Rural Centre) without significantly affecting the built or natural environment. This would help to generate more positive effects on well-being, housing and economy should the preferred approach be option 3 or 6 (which involve no/low growth at Kibworth and Great Glen)."

The SA also confirms that there is current highways assessment taking place that will impact on the amount of development which can take place along the A6 including the Kibworths (p.255). As a result, it may be possible to accommodate additional housing development in Kibworth which reflects its status as one of the larger Rural Centres. A more flexibly worded policy in relation to future housing development in Kibworth is recommended.

Marrons Planning has concerns that the housing trajectory at Appendix G would not ensure a 5 year housing land supply on adoption and consider that in order to significantly boost the supply of housing, this should be addressed by the Local Plan prior to submission to the Secretary of State.

Part 2 of the policy seeks a tenure split of about 75% social rented and about 25% low cost home ownership products or a variation of the two, to be justified by reference to the latest assessment of affordable housing need. 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. However, the principle of broadening the scope of intermediate housing to incorporate "low cost home ownership products" is supported as it includes a broader range of products.

A flexible approach to the type of affordable housing that could be provided could ensure that the Council's percentage policy requirement is met in scenarios where there might otherwise be a viability issue and would help increase the choice of products available to those in housing need. This would accord with the HEDNA, which states that "in applying [tenure mix requirements] to individual development sites regard should be had to the nature of the development site and character of the area, and to up-to-date evidence of need as well as the existing mix and turnover of properties at the local level" (paragraph 12.49).

Policy H4 seeks the delivery of specialist housing, such as sheltered and extra care accommodation as an integral part of all residential developments of over 100 dwellings, at a rate of 10%, where the site offers a suitable location for the provision of specialist housing; and provision of specialist housing would not impact upon deliverability/viability.

Firstly, the relationship between this policy requirement and the proposed requirement for 4% Part M Category 2 in Policy H5 is unclear. If taken as separate requirements, and in combination with the proposed affordable housing requirements, this could have an impact upon the viability of residential schemes.

The HEDNA concludes that councils should also give consideration to the potential to identify sites in accessible locations for specialist housing. The supporting text states that no such sites were submitted via the SHLAA, however it is not clear if consultation with any extra care providers has taken place as part of the Local Plan preparation.

The February 2017 Housing White Paper highlights the issues faced by an ageing population in terms of housing and confirms it is committed to exploring this issue further with a wide range of stakeholders, including housebuilders (paragraph 4.43). The White Paper goes on to confirm that the government is committed to funding and developing supporting housing, including sheltered, step down and extra care housing. Any further government guidance on this issue should be taken into account during the Local Plan preparation process as it may impact upon the proposed requirements at part 1 b) of the Policy H4.

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 flexibility where there are viability or practical considerations.

On schemes of 100 dwellings or more, Part 3 of the policy proposes the provision of 4% of dwellings as Part M, Category 2. This is an optional requirement of the Building Regulations, and it is considered that the evidence in the HEDNA 2017 used to underpin this requirement (paragraphs 9.24 and 9.25) may not be fully justified in terms of the requirements for Harborough District. The HEDNA only makes broad assumptions nationally and regionally about need, and the report highlights the doubts about the validity of even the regional figures.

It is also unclear how the proposed Part M Category 2 requirement relates to general housing need and the specialist housing which is proposed by Policy H4.

Part 4 of the policy proposes that housing development of 250 dwellings or more should provide land for self-build and custom build dwellings to help meet identified local demand. The policy is considered to be vague in terms of its specific requirements. Furthermore, whilst the Council has confirmed it has had 57 individual registrations for self build, the HEDNA concludes that such registrations should be treated with some caution (paragraph 9.56) and that an 'interest' in self-build does not take into account market factors (9.58). HEDNA concludes that most new delivery of self-build is expected to come forward on small windfall sites, and whilst there is the potential to encourage developers of larger schemes to designate custom build plots, "it is likely to be difficult to demonstrate concrete evidence of demand at a local level, albeit those local authorities are required to maintain registers of those with an interest in doing so" (paragraph 9.58)

Whilst the Planning Practice Guidance confirms that landowners can be encouraged to consider self-build, it is considered that on the basis of the HEDNA conclusions and the lack of clarity with the policy wording, part 4 of Policy H5 is not justified.

The proposed allocation of the site is supported, as too are requirements a to h iii) of the Policy. However, for the reasons detailed in respect of Policy H1 (refer to representations to Policy H1), David Wilson Homes object to the identification of a maximum number of 90 dwellings.
It understood that the site capacity for the proposed allocation has been reduced as a result of advice received from the Highways Authority. There is however no evidence to support this position.
A planning application is currently being prepared for the development of the site for 144 dwellings. The Transport Assessment which has been prepared to support the application confirms that the site access is suitable and that the local highway network can accommodate the proposed development without the need for mitigation.
Any concerns of the Highways Authority have been fully addressed. The proposed development of Burnmill Farm is not impacted by capacity issues of Burnmill Road and therefore it is no longer appropriate for proposed Policy H1, and associated Policy MH3 to limit the number of dwellings that can be delivered on the site. It is therefore considered that Policy H1 and MH3 should be amended to reflect a site capacity of up to 144 dwellings.