Harborough Local Plan 2011-2031, Proposed Submission
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Harborough Local Plan 2011-2031, Proposed Submission
H1 clause 2 MH
Representation ID: 7340
Respondent: Castlerow Property Investments Ltd
Agent: Freeths LLP
Legally compliant? Not specified
Duty to co-operate? Not specified
Site allocations are based on an inaccurate assessment in the Sustainability Appraisal and the housing trajectory is based on sites which are fundamentally flawed or which have been delayed. Additional sites are required which are deliverable in the short term, land at Clack Hill (A/MH/HSG/50) is such a site. See full text.
The following statement is to be taken as representation to the Harborough Local Plan Proposed Submission consultation. The statement is prepared by Mark Pickrell of Freeths LLP who are Planning Agents acting on behalf of Castlerow Property Investments Ltd.
Land at Clack Hill (A/MH/HSG/50) has potential to provide up to 75 dwellings at a sustainable site adjacent to Market Harborough. The site has been promoted through the Local Plan process and has been subject of a recent application for outline permission with all matters reserved except for access (ref. 17/00532/OUT). The site is located to the south-east of Market Harborough and is proposed to be access from Kettering Road. The site is bounded to the north by the A6, by existing
residential development to the west and Kettering Road to the south and east.
The site at Clack Hill is in a sustainable location, abutting the current settlement boundary of Market Harborough. The Inspector on an appeal at the adjacent site (ref. 10/00179/OUT) identified that in light of the LPAs housing land supply position and the sustainability of the site, the principle of residential development at this location was accepted. The fact that the adjacent site was considered to be sustainable should be afforded considerable weight. It is also noted that planning permission was granted for residential development at Overstone House on 28th November 2014 (ref. 14/00623) for 48 dwellings, to the south west of the site. These sites occupy similar countryside locations to the application site but have been considered to be well related to the existing settlement.
Consequently, in the context of the adjacent built form and the fact that the site is physically bound by main roads separating it from the adjacent countryside, the development of the application site will result in a logical extension to the town whilst retaining defensible boundaries.
The site was identified in the LPA's Strategic Housing Land Availability Assessment 2015 (SHLAA) as developable for residential development with a timeframe for development of 11 - 15 years or 16+ years. The SHLAA identifies an estimated capacity for 75 dwellings. The SHLAA does not identify the site as being deliverable in the short term due to access issues and a lack of firm developer interest. Furthermore, the Sustainability Appraisal (SA) (September 2017) states that
access is unlikely without 'major investment' and is scored accordingly.
The statement of the SHLAA and SA is contrary to documents submitted as part of application ref. 17/00532/OUT. The submission documents, including a Transport Assessment, show that safe access can be achieved through the provision of a right hand turn lane, changes to signage, moving the speed limit and lane marking. No major structural alterations to the highway are required to provide the access. The proposed changes were considered to be acceptable to Leicestershire County Council who raised no objections to the application. This shows that access to the site is feasible and the site should be considered as such.
It is noted that land at Overstone Park (A/MH/HSG/35) is assessed as having access potential which is satisfactory. This is despite the current application (ref. 15/02006/OUT) which proposes significant highway works to facilitate the development, including a new roundabout on Kettering Road. Considering the scale of highway alterations required to provide access to the Overstone Park site,
it would be reasonable to expect that the SA were to have assessed the site as requiring major highway investment.
The disparity in the assessment of these sites shows that the land at Clack Hill has not been assessed appropriately and should be reconsidered as an allocated site.
With regards to deliverability, the landowners have a track record in delivering housing and have recently submitted an application seeking outline permission for residential development of the site. The applicants were responsible for the development of David Hobbs Rise which is located adjacent to the Clack Hill site and are also developers in their own right. The submission of the application
shows that the site is being actively promoted for development and is deliverable in the short term.
On the contrary, a number of other allocated sites that the LPA has considered to be deliverable in the next 6-10 years have potential major access, flooding and ownership issues which will need to be overcome before they can be developed. Other sites that have been included within the Council's housing trajectory as providing new housing development to meet the Council's housing requirements in the next 5 years have been delayed, affecting the expected timescales for delivery.
The delivery anticipated in the housing trajectory is disputed and additional sites that can be delivered within the next 5 years are required to ensure necessary delivery of housing in the short.
The land at Clack Hill is being actively promoted and is able to deliver much needed housing in the short term. Based on the above, it is considered that the proposed Local Plan is unsound as it based on inaccurate information within the Sustainability Appraisal. In light of recent submission documents, it is clear that access can be achieved to the Clack Hill site without major highway investment. This is contrary to the assessment set out in the SA. It is also noted that access to land at Overstone Park has been scored favourably, despite current proposals which include major highway alterations to provide a new roundabout on Kettering Road.
Furthermore, sites which have been predicted to deliver housing in the next 5 years have been delayed and the delivery expected in the housing trajectory is disputed. Additional sites which are deliverable in the next 5 years are required. Recent submissions for land at Clack Hill have shown that it is a sustainable site that is well located, abutting the settlement boundary of a designated as a 'sub-regional centre. The proposed development demonstrated that an attractive and well-designed
layout can be achieved at the site. This was supported by the LPA who recommended that the application be approved. The site is being actively promoted and is a site which would be able to deliver housing within the next 5 years.
Taking the above points into account it is requested that the site be reconsidered as an allocation for residential development due to its proven merits as being sustainable and deliverable.