Regulation 19 - Proposed Draft Local Plan Submission

We object to the proposed housing requirement post 2036 and think it should reflect the revised housing requirement in the current standard method.

We do not object to the proposed housing requirement between 2020 to 2036 (657 dwellings per annum) as this is as agreed in the Leicester and Leicestershire Statement of Common Ground. 657 dwellings per annum (dpa) equates to more than 80% of the new local housing need figure of 723 dpa (NPPF paragraph 234a) and although this figure incorporates 123dpa of Leicester’s unmet need, we do not have any objections to the Local Plan being examined under the previous version of the NPPF (as directed by NPPF paragraph 235). However, post 2035, Policy DS01 proposes a housing requirement of 534dpa. This is calculated using the previous version of the standard method and equates to 74% of the current local housing need of 723dpa. We question whether the proposed housing requirement post 2035 is the most appropriate option, given the fact that the new standard method figure is over 25% higher and that it doesn’t factor in any of Leicester’s (and potentially Oadby and Wigston’s) unmet need.

Policy DS02(2) states that the employment land requirement for the plan period (2020-41), excluding strategic warehousing, is some 60ha.
Harborough DC is not required to accommodate any of Leicester City’s unmet employment need (see the Leicester & Leicestershire Authorities Statement of Common Ground relating to Housing and Employment Land Needs (June 2022)). After completions and commitments have been taken into account, there is a residual requirement for at least 16.4ha of employment land. The plan includes site allocations for some 27.8ha as described in Policy DS02. NWL welcomes the Local Plan’s commitment to meet the district’s employment land requirements in full, including through the allocation of specific sites.

• Identifying reserve site/s. The Harborough Strategic B8 Study identifies additional sites as potential allocations.
• Including a policy by which applications for strategic warehousing on unidentified sites will be assessed
• Committing to an early partial review of the Plan

The Leicester and Leicestershire authorities have a strong track record of joint working on the matter of strategic warehousing. A number of previous studies have been prepared on this subject, dating back to 2013.

The Leicester & Leicestershire Authorities have a Statement of Common Ground relating to strategic warehousing and logistics need (September 2021). This statement, which is based on the findings of the Warehousing and Logistics in Leicester and Leicestershire: managing growth and change study (2021), affirms the authorities’ commitment to cooperate on strategic cross boundary matters including agreeing the distribution of large warehousing need (paragraph 3.12) and their intention that the need for 2,570,000 sqm of large warehousing and logistics floorspace (2020 – 2041) will be met in Leicester and Leicestershire (paragraph 3.13).

More recently the authorities have jointly commissioned a new study to:
• Provide an up to date assessment of the requirement for additional strategic warehousing
• Advise on how the requirement could be apportioned to locations within Leicester and Leicestershire to inform Local Plans

Work on this study is in progress and its findings are not yet finalised.

To enable HDC to meet its own Local Plan timetable, it commissioned its own study entitled Harborough Strategic B8 Needs Sensitivity Analysis, 2024. This study forms part of the evidence base for the Local Plan.

The study recognises that its recommendations are interim pending the completion of the joint study. Taking into account completions and commitments and (subsequently) the refusal of the Hinckley SFRI proposal, it advises there is a residual need for 537ha (2024-41) in Leicester and Leicestershire and recommends that HDC contributes between 100-140ha to this.
Policy DS02(7) provides for some 340,000sqm of strategic-scale warehousing at two locations at Magna Park. Policy SA01 allocates these two sites with a combined area of 138ha.

MP1 - Land south of George House, Coventry Road - 15.8ha
MP2 – Land at Mere Lane, Magna Park - 122 ha

In site area terms, these allocations are towards the upper end of the recommended range.

The floorspace figure however is below what might be expected from this quantum of land. Using the plot ratio which Iceni apply (0.35), 138ha could in theory deliver in the order of 483,000sqm. This suggests that these ha figures could mask some overall under provision.

Further, the study recommends “that it is appropriate for Harborough to plan for between 100-140ha on an interim basis, pending the completion of the current updated L&L Strategic B8 Need & Apportionment evidence and agreement of the apportionment of this through an SOCG between the Leicester and Leicestershire authorities” (paragraph 6.30, emphasis added).

There is some prospect that the joint study may reach a different conclusion from the HDC interim work. This could mean an apportionment which is higher (or lower) than that revealed by the HDC work.

A higher apportionment is a ‘known’ risk and one which NWL considers the submission Local Plan should anticipate and make provision for. This could be by:
• Identifying reserve site/s in the event HDC’s apportionment increases. The Harborough Strategic B8 Study identifies a number of sites as potential allocations.
• Including a policy by which applications for strategic warehousing on unidentified sites will be assessed
• Committing to an early review of this aspect of the Plan. We have submitted separate, specific comments on Policy IM01 (Monitoring and review of the Local Plan).

As it stands, and without further amendment, NWL considers this aspect of the plan pre-empts and prejudices effective joint working on this cross-boundary strategic matter. It fails to meet the tests of soundness with respect to EFFECTIVENESS

Resolve the following issues:
• ‘significantly greater’ is a subjective term which fails to provide sufficient clarity.
• The trigger for revisions to the submission plan should be the publication of the Apportionment Study. There is considerable uncertainty concerning the timing of a potential SoCG and indeed whether it will be progressed at all. Without an agreed SoCG there would be a policy vacuum which would be disadvantageous for all of the authorities, local communities and the industry

Whilst NWL welcomes the commitment to an early review of the plan’s approach to strategic distribution in section 2c of this policy, we do not think that the policy wording is sufficiently robust.

Part 2c of this policy describes the circumstances when a review of the plan’s approach to strategic distribution will be triggered. NWL does not consider that 2c provides sufficient certainty that this issue will be dealt with rather than deferred (NPPF paragraph 36c) for the following reasons:
• ‘significantly greater’ is a subjective term which doesn’t provide clarity about the circumstances when a partial review will be triggered.
• The tigger for revisions to the submission plan (though Main Modifications as appropriate) should be the publication of the Apportionment Study. The Apportionment Study will be part of the evidence base for the submitted plan in due course and it will no doubt be tested through the Examination process. Conversely at this point there is considerable uncertainty in terms of the timing of a potential Statement of Common Ground and indeed whether it will be progressed at all. In the event that a SoCG is not agreed, this would leave a policy vacuum which would be disadvantageous for all of the authorities, local communities and the industry.

As it stands, and without further amendment, NWL considers this aspect of the plan pre-empts and prejudices effective joint working on this cross-boundary strategic matter. It fails to meet the tests of soundness with respect to EFFECTIVENESS