Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13847

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

We welcome the Statement of Common Ground. . We have often cited the work of the County as an exemplar of how the Duty to Cooperate and the issues of unmet need should be being addressed.

The HBF is concerned by the slightly dated nature of the Statement of Common Ground mentioned in the Local Plan and we would request that it is updated and kept up to date as the Plan progresses through consultation to examination and to adoption.

Object

Representation ID: 13848

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Although, HBF recognise the changing national policy context against which the Plan has been prepared, but we are still concerned that Plan is not providing for enough homes in Harborough over the whole Plan period. We believe the Council should pause the Plan and prepare a new Reg 19 that reflects the new standard method figures in full. In light of the housing crisis, we would continue to suggest an even higher housing requirement figure would be justified.

Object

Representation ID: 13849

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

To ensure that the Plan covers the full 15 years on adoption, this requires the Plan to be adopted in 2026 and the Council’s (Feb 2025) LDS shows adoption in October- December 2026. The HBF considers that this is unlikely, and the Plan period should be extended until at least 2042. We note that the supporting evidence would need to reflect the full period.

The HBF also question the base date of the Plan. By not using the most up to date data as required by the PPG the result is the housing requirement is incorrect and artificially suppressed

Object

Representation ID: 13850

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The HBF would request that the vision for Harborough is more explicit about its ambitions to meet the housing needs of Harborough in full, whilst also making a contribution to meeting the unmet needs of Leicester.

In relation to the first Objective Delivering Homes: Deliver the housing needed, HBF agrees that the Plan should provide housing that addresses the specific needs of different communities and age groups, including the provision of affordable, accessible and specialist housing

Object

Representation ID: 13852

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Under the new NPPF the standard method calculation the Harborough is 723 per annum. This Plan is providing 534 homes per annum to meet the needs of Harborough. This is only 74% of the new standard method as such calls into question if the Plan should be proceeding under the transitional arrangements when it is not delivering 80% or more of the new standard method calculation

concerned about the Council’s reliance on windfall in place of allocating housing sites.

monitoring of housing delivery-suggest separate Leic need

Plan should also recognise that there may be clusters of villages that provide a range of services

Allocating housing sites in rural areas can provide opportunities for small sites helpful for SME builders.

Object

Representation ID: 13853

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The HBF have some concerns about the DM10 (set out elsewhere is our Reg 19 response) which is referenced in this policy. There would need to be some consequential changes to this policy to address our concerns.

Object

Representation ID: 13854

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

As the HBF believe the housing requirement for Harborough should be higher, and more allocations are needed, this is likely to require a review of the countryside protection policies and designations- such as green wedges, if additional sites are to be brought forward for housing

Object

Representation ID: 13855

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

HBF are concerned about the deliverability of the Plan in light of the County Council previously proposed approach to seeking contributions in Charnwood EIP. For the Harborough Plan to be sound it will be important for the Council to be able to demonstrate they will not be impacted by this same issue in a way that makes the Plan undeliverable and/or unviable.

The HBF have significant concerns about the viability study, which are set out in response to the Viability Report itself (see para 61-69 of our response). These concerns make the need for flexibility around policy requirements more likely as the evidence already shows some sites are unviable, and the HBF suggest several other costs impacting on viability have not been fully considered.
There is likely to need to be a change to this policy, reflecting the change we are requesting to Policy HN01.

Object

Representation ID: 13856

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy includes an opportunity for viability arguments to be made on a cases by case basis which HBF support. We would question the use of the term’ exceptional circumstances’ within the policy as the Aspinall Verdi whole plan viability appraisal already shows that some sites are not viable. The report concludes that blanket rate of 40% affordable housing across the District.” HBF questions the justification of this approach.

The HBF also strongly recommends that the plan allocates more sites than required to meet the housing requirement as a buffer.

The HBF would also recommend that windfall allowances are not included in the supply and instead form part of the flexibility in supply. However, the HBF recommends that if the Council intends to include an allowance for windfall that they have an appropriate evidence

Object

Representation ID: 13857

Received: 05/05/2025

Respondent: Home Builders Federation

Legally compliant? No

Sound? No

Duty to co-operate? No

Along with other issues we have flagged elsewhere (see our comments on the While Plan Viability Appraisal) this may be challenging from a deliverability or viability perspective especially as HBF evidence suggest that delivery M4(3)B is around 10 times as expensive as delivering M4(3)A. Further flexibility in this, and other policies may be needed to address our concerns, especially now that delivering 10% BNG in mandatory nationally.