Harborough Local Plan 2011-2031, Proposed Submission

Policy SC1 Scraptoft North Strategic Development Area.
This representation is submitted by Parker Strategic Land Limited who are the promoters of the Scraptoft North SDA. Parker Strategic Land have agreements in place over the whole SDA area and are able to bring the site forward for development quickly to meet the objectives of the Plan. We have worked closely with the existing owners, Scraptoft Golf Club and Leicester City Council, to assess the potential of the site and to ensure that the land can be developed. Plans are in place to relocate the golf club to a new site within the district and within the ownership of Parkers of Leicester Limited, the parent company of Parker Strategic Land, a decision supported by the membership of the golf club.

We are supportive of Policy SC1 and consider the site is a highly sustainable location for new housing growth being located on the edge of the existing urban area, close to local facilities such as the secondary school and district-scale shops at Hamilton District Centre, and can be served easily by extending the existing infrastructure and highways network into the site and by extending bus services, which already provide links to the city centre and to major employment locations nearby.
The site has few major constraints and we consider can be developed as an attractive new neighbourhood. The development can also bring benefits for the village of Scraptoft by reducing and calming through-traffic, as well as providing high quality new and accessible facilities such as public parklands, a new primary school and local centre with shops, potentially a doctor's surgery, community hall and other community facilities.

Our representations relate to the detailed elements of the policy and these are considered below. We also make representations on the proposed new replacement golf course at Houghton on the Hill, and we are making separate representations on the de-designation of the Scraptoft Local Nature Reserve. In summary, our general concern is that the policy is overly-prescriptive and need not be to meet its objectives. The detailed prescription is not necessarily supported or justified by evidence at this stage. We have also recommended that a further element be added to paragraph 3 of the Policy to cover the requirement for a 'Delivery and Phasing Programme' that would obviate the need for (unsubstantiated) specific thresholds within the policy itself.

Community facilities 3.e. a two-form entry primary school to be provided soon after completion of 300 dwellings.

This policy element has a specific requirement for provision of the full two-form entry school 'soon after completion of 300 dwellings'. We are not aware however, of any evidence to support or justify this specific figure.

We are aware that there is limited capacity within existing primary schools locally and that provision of the new primary school will be required early within the development programme, to ensure sufficient spaces are available to meet the needs of new residents. However, we consider that the timing/programme of the school should be subject to a specific assessment to determine the timing of its provision.
We suggest that this is subject to testing through the proposed 'Delivery and Phasing Programme' (see below). This would determine with some certainty and verified by the education authority, that the timing is appropriate and achievable. It may also consider the potential phasing of the school (for instance phased opening) to meet the additional requirements generated specifically by the development of the SDA.
We also outline issues with the timing and location of the school under 3.r. below. The requirement to deliver the school to this programme may limit the location within the site.

3.g. a neighbourhood centre as a social and retail hub for the new community to be provided before completion of 500 dwellings, to include some or all of the following:
i. a supermarket or shops to meet local convenience needs;
ii. a public house/café;
iii. a doctor's surgery;
iv. a community hall; and
v. other community facilities or upgrade of existing facilities.

Our concern with this element of the policy is again, that provision is required before the completion of 500 dwellings, but that this figure is not supported by evidence and therefore not justified.
We recognise the importance of delivery of the new local facilities to establish patterns of local shopping and to meet local needs for facilities. The location has local facilities nearby and there are local convenience shops within the village and the Hamilton District Centre is 1.3km away and easily walkable.

However, this figure is specific and would mean delivery of the entire local centre before half (that is 42%) of the proposed development is completed. The facilities within the local centre would either need to operate at sub-optimal levels of viability initially or draw from a much wider catchment. It may also be the case that the timing of the provision affects the likely quality of operator, as higher quality operators might find the potential less attractive until the development is progressed further. Depending on viability, facilities may need to be subsidised to enable them to open (which then affects the overall viability of the development). There is also a risk, for instance, with any new health provision that facilities would not be supported by the health authority/NHS England, at this stage, and so may not be capable of provision to this programme.

We consider it better to identify the need for and composition of the local centre as the policy does, but that its timing be determined through the master plan process (through the proposed Delivery and Phasing Programme), which can also test the viability issues and consider the requirements for provision of the various elements that make up the local centre.

3h. a multifunctional green infrastructure network, including: iii. a new cemetery in accordance with Policy GI3.

We do not object to the principle of a new cemetery being located within the SDA area as such, and the Green Wedge Policy GD7 provides for this use within paragraph 2 (as 'burial grounds') and therefore the cemetery could be located within the retained Green Wedge area within the SDA subject to specific assessments of the site suitability. However, the Policy does not appear to be evidenced or justified by any comparative assessment of the suitability of specific alternative locations or sites.
The main basis of the Policy appears to be the Harborough Cemetery and Burial Strategy (2016) which identifies a surplus of capacity within Scraptoft (paragraph 6.52.5 and Table 7). It therefore appears that provision is proposed within the SDA to meet wider needs. Indeed, the strategy at paragraph 12.2.1 identifies the need 'towards the north of the district around Thurnby and Bushby and Houghton on the Hill', not Scraptoft, so new sites at those settlements may better meet the need than Scraptoft.

The Scraptoft SDA is located at the northern edge of the district, and while the SDA is one focus for growth, Scraptoft itself remains a small settlement, with the highest concentration of the district's population being within the larger established settlements of Market Harborough, Lutterworth, Broughton Astley, and the larger villages of Kibworth, Fleckney, Great Glen, Thurnby and Bushby. On the basis that the larger population centres are likely to generate the largest proportion of demand, we would have thought that options closer to those settlements would be better able to meet the requirements than this more peripheral location.

We therefore consider that the Policy is not justified and should be supported by a comprehensive consideration of the specific alternative options first.

Highways and Transportation
l. a minimum 20 minute frequency bus service from the site into Leicester city centre.
The location is already well-served by public transport and extending the current services into the site can be achieved relatively easily and discussions are already underway with operators. We consider this requirement is too onerous and should refer to 'peak hours' only.

We therefore suggest the following change:
* Suggested Revised l. a minimum 20-minute frequency bus service during peak
hours from the site into Leicester city centre (change in bold).

Environment r. retention of the area bounded by New Romney Crescent, Hamilton Lane and Scraptoft Lane as Green Wedge to prevent the merging of Leicester and Scraptoft, and to provide recreational resource for new and existing residents of the locality.

Our concern here is that this policy to apply the Green Wedge to this area would restrict its potential use, which may in turn not lead to the best master planned proposals for the whole SDA. In particular, we consider that the area defined as Green Wedge and within the SDA (shaded pink) should be considered as a potential location for the proposed new primary school, as the land is otherwise unconstrained, would be well-located to serve the proposed and existing population and offers an opportunity, which we are keen to explore, of providing a larger community facility that can include community facilities such as meeting places, sports hall and sports pitches for use of the wider community. The Green Wedge policy would preclude the development of the built element of the school.

The Green Wedge has buildings within it currently, including the golf club house and its ancillary buildings, and has the farm buildings within this part of the Green Wedge, so is not without built development of a similar scale already. A two-form entry school would be around 2 hectares and the built floor space (assuming some community use too) might be around 4,450 sq. m, so less than 6% of the proposed retained Green Wedge area. The pitches and outdoor space would be compatible with the Green Wedge (and are allowed for by the Green Wedge Policy GD7), and to be attractive and useful would need ancillary car parking and changing facility/clubhouse, so the additional floor space to accommodate the school (over and above the farm buildings and buildings required for the pitches) would be a small increase, and we do not consider this at all compromises the objective of maintaining the separation of Scraptoft from Leicester.

We would also contend that locating the school within the Green Wedge accords with Policy GD7 Green Wedges in that school playing fields are specifically referenced in paragraph 2 and that development is relatively small scale and the use of the Green Wedge meets other objectives such as the provision of community facilities and additional access to open space areas, which are not accessed currently or wouldn't be unless these new facilities are provided, so there are clear public benefits of locating the school within the area. It is also important to recognise the issues of timing and programming of the school provision and the availability of land within the SDA. The Policy at 3.e. requires the school to be provided 'soon after the completion of 300 dwellings'. The provision of the new replacement golf course is likely to require a build programme of 3 years from start to completion, until the course is fully playable. This means that the current golf course area would not be accessed for around 3 years and development of the SDA would start elsewhere outside of the golf course area, which is land generally in the south of the SDA area. Our outline trajectory assumes (conservatively) that by 3 years some 220 new dwellings will be completed, but by this time it is likely that the school construction will need to have started to enable the school to be available in time. This would mean it must be developed on land in the south of the SDA. We feel there are also advantages to the school relating well to the existing village and catchment of Scraptoft. It is likely the school will draw from existing residents too and a more central location and one well-related to the village (which does not have a primary school) better serves the existing population.

Our aim therefore, is to retain the potential to locate the school within the(existing /retained) Green Wedge area and to allow the proposed master plan to assess and evaluate options, which can include for issues such as the availability of alternative sites, timings, scale and nature of the school (including community uses) and such like, but not to rule out this option at this stage.

If it is considered incompatible with the Green Wedge policy as it stands, then we recommend the area east of New Romney Crescent within the SDA is omitted from the Green Wedge but that provision is made within the Policy itself, with paragraph r. revised as follows:

* Suggested Revised r. retention of the area bounded by New Romney Crescent, Hamilton Lane and Scraptoft Lane as predominantly open space uses to prevent the merging of Leicester and Scraptoft, and to provide recreational and other community facilities (including the primary school), for new and existing residents of the locality (changes in bold).

4. Land to the east of Houghton on the Hill, as shown on the Policies Map, is allocated for a replacement golf course

Our comments relate to the area defined on Inset Map 55 (Houghton on the Hill). The boundary shown for the proposed golf course (shaded green with a red boundary) is incorrect and not the area now being promoted for the golf course. The Policies Map should be updated to correspond to the area being planned for the golf course. For clarity, we have attached two plans of the proposed boundary. Plan ST 15452-SO1 shows the proposed site boundary on a 1:10,000 scale Ordnance survey base, the second draws the proposed site boundary on the Inset Map 55 (Houghton on the Hill) to show the changes.

Suggested new sub-heading
'Delivery and Phasing Programme'

To address the issues of when certain facilities should be provided such as the school and local centre, we recommend that an additional clause be added to the policy entitled 'Delivery and Phasing Programme' after paragraph 3, and following the Environment subheading. This would require a Delivery and Phasing Programme to be prepared and for the programme to determine and specify the timing (dates) and thresholds (housing completions) for the provision of key facilities and pieces of infrastructure, as well as setting out the proposed housing trajectory and phasing arrangements.

This would explain the requirements for the 'delivery and phasing arrangements' mentioned in paragraph 2 of the Policy, and would also provide comfort and certainty in approving the master plan (through the Supplementary Planning Document and/or planning application) that the proposed delivery requirements and potential has been fully assessed and is acceptable to the authority. This would provide the assessment to justify the timings and thresholds and obviate the need to set these out in the Policy at this stage. A suggested wording for this addition is below;

Suggested new sub-paragraph:

Delivery and Phasing Programme
A delivery and phasing programme will be provided to accompany the master plan and shall specify:
i. An overall phasing and sequencing plan for development of the site;
ii. The housing trajectory showing the programmed delivery of new homes by year for the whole development period;
iii. The anticipated timing and threshold in dwelling numbers for provision of the following:
a. Local Centre, including provision of each proposed element of the centre;
b. Primary School;
c. Other community facilities;
d. Major areas of new parkland and recreational facilities; and
e. Key highways infrastructure and public transport services.