Regulation 19 - Proposed Draft Local Plan Submission

Objection is made to the non-inclusion/deletion of the Scraptoft North Strategic Development Area (SNSDA) from the Reg 19 Local Plan.
This site is currently allocated for housing development in the existing Harborough Local Plan (2011-2031) (Policy SC1). The site was also previously allocated in the Regulation 18 Local Plan (January 2024).
The plan should be changed to retain the SNSDA site as a housing development site allocation and remove the proposed open space designation of the site from DM05. The local nature reserve designation for the site should similarly be removed (please note this does not appear have any policy reference number).

Response (as landowner) from Leicester City Council ‘Development Team’
Policy DS01 Development Strategy : Delivering Homes/ Policy SA01 Site Allocations
Objection is made to the non-inclusion/deletion of the Scraptoft North Strategic Development Area (SNSDA) from the Reg 19 Local Plan.
This site is currently allocated for housing development in the existing Harborough Local Plan (2011-2031) (Policy SC1). The site was also previously allocated in the Regulation 18 Local Plan (January 2024).
The site is subject to a live outline planning application for development of up to 1,200 dwellings and ancillary facilities and infrastructure (Ref 19/0700700/OUT).
The city council has an interest as landowner of part of the site and in this capacity has the following comments concerning the soundness of the plan:

1) There is no meaningful justification provided in the Reg 19 plan for formally deallocating this site.

2) The SNSDA was considered an appropriate area for residential development in the current Local Plan and Reg 18 Local Plan given its sustainable location adjacent to existing built development on the boundary of the city. Any development would thus be able to benefit from the existing infrastructure within the City.

3) Some 1,200 dwellings would be provided to support the housing provisions made in the Reg 19 Plan, helping to meet both Harborough’s needs and unmet need from the City.

4) It is understood that the plan period will be less than the required 15 years at the point of adoption which is inconsistent with national planning policy, rendering the plan unsound. Furthermore the housing provision made in the plan does not include unmet need provision from Leicester City after 2036. Consequently the plan does not provide for the necessary levels of housing growth over the full plan period. The deletion of the SNSDA site makes no sense in this context.

The SNSDA is located directly adjacent to the existing developed area of the City and remains a more logical and sustainable extension of the urban area than both neighbouring proposed sites S1- Scraptoft East land between Scraptoft and Bushby (950 new homes) and S2- Land east of Beeby Road (175 new homes). Both of these proposed Reg 19 designations encourage development which would be disconnected from the existing urban area and would result in disconnected infrastructure and less sustainable travel movements.

5) Following the allocation of the SNSDA in the existing local plan considerable sums have been expended working up a comprehensive planning application for the site which is currently undetermined. The Planning Authority has indicated there are concerns over viability in the scheme submitted. There has been little opportunity to explore this further and consider options to improve viability for example through review of section 106 contributions and the opportunity to draw in external funding. For example, Homes England has been active in contributing towards significant infrastructure costs in strategic development sites in the area e.g. Ashton Green (Leicester City) and Broadnook sites (Charnwood Borough). Furthermore if other nearby sites such as S1 and S2 come forward with the SNSDA then an element of the education and infrastructure costs could possibly be shared thus reducing cost pressures on the SNSDA which will assist in the viability of the site. The SNSDA site can be delivered in phases across the whole development plan period to 2041.

6) It is noted that a new proposed allocation for Open Space, Sport and Recreation is being made in the Reg 19 plan within the SNSDA area. This does not reflect the current land use of the City Council’s land holding (as it’s private land with no public access and no formal sports or recreation use, other than the small portion used as a golf practice ground) and is not only anomalous in the context of the points made above, but it prejudices future development potential and does not represent positive planning in respect of the NPPF plan making requirements.

In conclusion, objection is made to the unjustified deletion of the SNSDA site for the reasons given above and the reinstatement of this allocation is proposed.
We request to attend the Examination in support of the above concerns of soundness.

See attachment for full representation letter.

See attachment for full representation letter.

To address this issue of potential soundness we would expect inclusion and identification of an appropriate buffer to address any unmet need arising within the HMA instead of only planning for the standard method housing figure for Harborough for the latter years of the Plan period.
We note that the housing supply shows there will be supply higher than the housing requirement. We note the trajectory at the end of the document, but request a
reference / link to the trajectory and confirmation in this section of how the supply and projected delivery relates to the annual requirement up to and beyond 2036 and how
any buffer would relate to the stepped requirement. If the supply identified from 2036/37 onwards is sufficient to contribute (apportioned as per the SoCG) towards the unmet need above (as well as meet PPG expectations in terms of an appropriate buffer) then this should address the potential soundness concern identified above.

See attachment for full representation letter.

We would like to see a dedicated strategic trigger policy earlier in the plan outlining detailed circumstances as to when a partial or full review of the plan will be triggered.
We feel having this section as part of the monitoring framework policy is not sound, effective or justified.

See attachment for full representation letter.

See attachment for full representation letter.

See attachment for full representation letter.

To avoid this we suggest that criteria 2a, of Policy DS02 is restricted to 1000sqm of offices.
a) 5 hectares on site allocations, (identified in Policy SA01) in the Leicester Urban Area at the Land South of Gartree Road Strategic Development Area, where no more than 1000sqm of offices should be permitted

See attachment for full representation letter.

Changes sought to criteria 7(f) to ref Leicester and to criteria 9(b) and 9(c) to refer to cumulative and cross boundary impacts incl radial routes into the city and orbital routes eg A563 Outer Ring.
9(c) City Council will seek contributions to improve walking / cycling routes to connect to city centre and other sources of employment, services and education.
9(e) seek a 10 (rather than stated 15 min) bus service and connections to Leicester’s orbital routes eg to General Hospital, Fosse Park / Meridian and railway st.

See attachment for full representation letter.

See attachment for full representation letter.