Harborough Local Plan 2011-2031, Proposed Submission
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Harborough Local Plan 2011-2031, Proposed Submission
c. Key Centres: Lutterworth, Broughton Astley
Representation ID: 7562
Respondent: Manor Oak Homes
Agent: Armstrong Rigg Planning
Legally compliant? Yes
Duty to co-operate? Yes
Manor Oak Homes recommend that the Council introduce criteria to distinguish Key Centres as any settlement with over 5ha of dedicated employment land and a secondary school. The Kibworths has both of these facilities and should therefore be classified as a Key Centre.
Manor Oak Homes consider that Policy SS1 is unsound as it fails to accurately consider reasonable alternatives based on proportionate evidence (NPPF Paragraph 182) to justify the inclusion of the Kibworths as a Rural Centre as opposed to a Key Centre.
The inclusion of the Kibworths as a Rural Centre is based on information contained in the Settlement Profiles 2015. These Settlement Profiles provide a detailed background on each settlement in the district, before making a recommendation on where the settlement sits in the settlement hierarchy. The evidence contained in the Settlement Profiles is considered to be proportionate to the task at hand, but the consideration of this evidence is flawed with regards to the criteria it sets for distinguishing between a Rural Centre and a Key Centre. This flawed assessment incorrectly identifies the Kibworths as a Rural Centre when it is clear that it is comparable in size, function and number of facilities (retail, services and employment) to the Key Centres.
Manor Oak Homes would expect any assessment of a settlement hierarchy to be based on clear criteria and to involve a comparative assessment of each settlement against other settlements in the district in order to identify the most sustainable locations for development. The assessments contained in the Settlement Profiles are flawed in this regard, as while it is clear from Appendix F of the draft Local Plan that clear criteria are used in the assessment of Selected Rural Villages (which are required to have at least two of six key services - i.e. a food shop, GP surgery, library, post office, primary school and pub - and a minimum of 100 households) and Rural Centres (which are expected to have at least four of the six key services and a minimum of 400 households), no such criteria are provided for Key Centres. Instead, Appendix F simply states that Key Centres have "a range of retail, service and employment and a significant residential area", without defining what is meant by "a range of" or how many households constitutes a "significant residential area".
In the absence of any criteria for judging Key Centres, the choice to classify the Kibworths as a Rural Centre was not based on a detailed consideration of evidence, but rather the decision was made simply because it had previously been identified as a Rural Centre in the Core Strategy 2011. The Settlement Profile for the Kibworths concludes that "As a single settlement the Kibworths have the services to support their continued designation as a Rural Centre and a good range of further services, facilities and shops along with some employment opportunities." This statement makes it clear that the only assessment undertaken regarding the Kibworths position in the settlement hierarchy was whether it still met the criteria for a Rural Centre. The Settlement Profile recognises that the Kibworths has a good range of further services and facilities, but at no point does it consider whether due to recent/committed development it should be reclassified as a Key Centre.
As is demonstrated below, the failure of the Council to set any criteria for judging Key Centres and therefore to consider whether the Kibworths should be reclassified as a Key Centre, has led it to be incorrectly identified as a Rural Centre alongside settlements that are far smaller and have a much smaller range of retail, service and employment provision. This decision is significant as it results in the Council failing to recognise the sustainability of the Kibworths as a location for further growth as is discussed further at Enclosure 2.
Size of Settlement
A comparison of the population and number of homes in the Kibworths and that of the other Rural Centres and Key Centres (see table below), shows that it is much more akin in size to the Key Centres than the Rural Centres. Its population and number of dwellings is more than double the average size of Rural Centres, and when recent growth in housing numbers/commitments are factored in, its size is comparable to that of the Key Centres. Furthermore, in terms of the definition provided for Rural Centres as having more than 400 households, the Kibworths have almost seven times the level of housing required to be a Rural Centre and with committed levels of growth it will soon be eight times higher.
The large size of the Kibworths in comparison with the other Rural Centres is recognised in Section 17 of the draft Local Plan which describes the Kibworths as "the largest Rural Centre" that has "seen significant housing development since 2011, primarily as a result of the build-out of a large allocation dating from the 2001 Local Plan". There have been over 400 dwellings completed since 2011 and there are planning commitments for nearly 450 further homes." Despite this recognition, however, at no point do the Council consider the reasonable alternative that the Kibworths should be classified as a Key Centre.
The table below demonstrates that with recent levels of growth, the number of dwellings in the Kibworths is now over 2,500 and will soon be over 3,000 which is comparable to that of Broughton Astley which is a Key Centre. The average number of dwellings in the Rural Centres was just 1,128 in 2011 and in this context, the Kibworths is clearly more similar in size to the Key Centres. Manor Oak Homes therefore recommend that the Council introduce criteria to distinguish Key Centres as any settlement with over 2,500 dwellings in addition to criteria regarding retail, service and employment provision detailed in the submission.
Retail, Service and Employment Provision
In addition to the size of the settlement, The Kibworths are an important destination for retail, services and employment. The Kibworths have a thriving high street, a full range of facilities and services, and employment provision that is due to increase significantly with Manor Oak Homes' approved development on Land to the south and west Of Priory Business Park, Wistow Road (Ref: 16/00286/OUT).
In the recent appeal decision (Ref: 15/01153/OUT / APP/F2415/W/16/3152485) dated 7th December 2016 on our client's site to the south-east of Warwick Road, the inspector confirms the sustainability of the Kibworths as a location for growth. The inspector states that: the Kibworths is served by an extensive range of services and facilities, including two schools (one primary and one secondary), newsagents, supermarket, doctors surgery, health centre, pharmacy, community library, post office, two churches, restaurants, pubs, a range of other shops and a number of halls and other accommodation for use by community groups; and also recognises that the recently granted planning permission for new retail and employment facilities on land to the south and west of Priory Business Park will add to the sustainability of the settlement.
As outlined above, Appendix F of the emerging Local Plan defines Rural Centres as having at least 4 of 6 key services, while the definition of Key Centres simply states that they have a "range of retail, service and employment". In the absence of set criteria for Key Centres, it is therefore necessary to compare the average level of service provision in each settlement type to ascertain whether the Kibworths should be classified as a Rural Centre or a Key Centre (see table in submission document).
The information contained in the table above is taken from the Settlement Profiles 2015 except for the data on the food stores and employment land for the Kibworths which has been updated in light of the recent consent at land south and west of Priory Business Park (Ref: 16/00286/OUT).
The table demonstrates that the Kibworths has all 6 of the key facilities required to be a Rural Centre and in addition has significant areas of employment land (both existing and consented) and a secondary school which is something found in no other Rural Centre. In comparison with the Key Centres, the Kibworths has a similar level of retail, service and employment provision, whereas the majority of the Rural Centres have far fewer facilities. Of the Rural Centres, only Fleckney and Great Glen have all 6 key facilities, but neither has a secondary school and Great Glen also has limited employment land. All the other Rural Centres only have 4 or 5 of the key facilities and none have a secondary school or dedicated employment land.
With regards to the above, it is clear that the Kibworths is comparable to the Key Centres of Lutterworth and Broughton Astley in terms of its range of retail, service and employment provision. The key distinction between the Key Centres and the Rural Centres is the provision of a secondary school and significant areas of employment land. These presence of these two facilities impacts significantly on the suitability of the settlements in sustainability terms to help meet the development needs of the district. Manor Oak Homes therefore recommend that the Council introduce criteria to distinguish Key Centres as any settlement with over 5ha of dedicated employment land and a secondary school. The Kibworths has both of these facilities and should therefore be classified as a Key Centre.