Regulation 19 - Proposed Draft Local Plan Submission

See above comments. Steindale requests an additional employment allocation at Land West of Rockingham Road (SHELAA Update 2024 (HSG-NLP 6) site reference 24/10398) and a more balanced spatial distribution of employment growth.

1. Policy DS02
1.1. At the Regulation 18 stage, Steindale’s representations set out the requirement for the Local Plan to be innovative and proactive in its strategy for encouraging sustainable economic growth, to ensure that the NPPF’s expectations for economic growth and productivity could be met. The growth projections for the District illustrate a significant upward trend in the elderly population, meaning it is important to attract younger people to the District. The supporting text to Policy DS01 (paragraph 4.3) recognises the need to accommodate the growing population through the provision of a sufficient number of new homes and other needs including new jobs. The provision of local jobs that are accessible will assist in supporting a balanced population and sustainable growth, as well as continue to ensure that a range of employment opportunities are provided for an economically active population.

The reasoning for higher employment growth
1.2. The draft Local Plan has not been innovative or pragmatic in its approach to ensuring the District’s existing and future economic needs are planned for. The Development Strategy Paper (PRE-NLP 5, February 2025) confirms that a medium growth employment strategy has been taken forward, rather than high growth. This option has been selected despite the Sustainability Appraisal (S-NLP 4, February 2025) demonstrating that the negative effects associated with both options would be equal and the high growth option performing the best in terms of providing the greatest variety of employment opportunities.
1.3. Steindale continues to encourage the Council to take an ambitious approach towards the strengthening of the local economy, in a manner that drives prosperity, supports existing and new businesses, allows for the provision of supporting infrastructure and ensures the delivery of local jobs in sustainable locations. Additionally, the enclosed Economic Need Analysis (Appendix 1) explains that the creation of new businesses in Harborough is lagging behind the national trends in job growth. A support of strong economic growth is needed to ensure this does not turn into a downward trend in job creation in the long-term. Higher growth and the diversity that comes with it will also allow for more ‘higher skilled’ jobs to be created – which is recognised in the Council’s Economic Development Strategy 2024-2031 as being important to address income inequality that persists in the District.

Comments on spatial distribution of employment growth
1.4. Steindale’s previous representations also strongly recommended the spatial diversification of new employment land– directing new employment growth towards sustainable and accessible locations, and seeking to align new employment provision with areas of significant housing growth. Market Harborough meets both these criteria, being a highly sustainable location that has a good concentration of existing jobs and is allocated to deliver 1,350 new homes through the new Local Plan.
1.5. The supporting evidence for the draft Local Plan also recognises this. Paragraph 8.4 of the Local Housing and Employment Land Evidence (EMP-NLP 2, February 2025) identifies Market Harborough as one of the District’s main economic centres with a good concentration of jobs. Paragraph 8.21 states that there is currently a broad balance between jobs and homes in Market Harborough.
1.6. However, this is not borne out in the employment strategy that is set out in the draft Local Plan (in Policy DS02). Only one strategic employment allocation is made in Market Harborough at Compass Point Business Park (MH6), which itself is an allocation carried over from the adopted Local Plan (raising questions about timing and deliverability). The only other employment allocation is 0.6ha of land at Leicester Road (MH5) – a site on which, it should be noted, the Council refused an application in May 2023 for B2, B8 and E(g) uses due to issues of access and transport impacts.
1.7. Given the role of Market Harborough as an economic centre, it is also relevant to consider the employment strategy from a District-wide perspective. At paragraph 4.9, the draft Local Plan claims, “Our strategy identifies a pattern of development that seeks to support our economy, provide a balance between homes and jobs in the district.” The vast majority of new residential allocations / commitments are located in the east and north of the District as set out in Policy DS01 and illustrated by Figure 2. This is further exaggerated by the concentration of new homes adjoining east of the Leicester Urban Area (2,450 homes) and 1,350 homes in Market Harborough.
1.8. Conversely, the draft Local Plan seeks to concentrate new employment provision in the east of the District, at Magna Park. Although the Development Strategy Paper (PRE-NLP 5, February 2025) states that employment growth options 2 (focussing new employment in the main economic centres and sustainable settlements) and 3 (aligning employment land growth with new housing growth) from the Regulation 18 consultation. This though does not seem to be reflected in the allocations that have been identified.
1.9. Of the 60ha of employment allocation land identified, around 70% is located in the west of the District at Magna Park. This concentration is perhaps best exemplified by Figure 2 in the draft Local Plan, which highlights Magna Park as part of the development strategy but does not highlight any other employment sites in the District. The importance of Magna Park as an employment site, and its location within the logistics ‘Golden Triangle’, is recognised but there is a risk that the draft Local Plan is placing an over-reliance on Magna Park without proper consideration of alternatives. The enclosed Economic Need Analysis (Appendix 1) provides further evidence of the need for balanced and sustainable growth across the District to ensure that the increasing demand for strategic employment land can be met.
1.10. As well as allowing for a positively prepared and effective Local Plan to be prepared, this amend in strategy would allow the Local Plan to be sufficiently flexible to respond to changing circumstances in specific sectoral requirements should these arise, given there is the possibility of one or even two distinct economic cycles during the plan period. Economic growth is driven by increasing employment and productivity rates, which is why building sufficient resilience into the Local Plan is important.
1.11. The draft Local Plan may be vulnerable to challenge on effectiveness and flexibility, especially if allocated sites underperform – with the risk being greater given the current concentration of strategic employment at Magna Park.
1.12. Providing a better balance of employment land in the east of the District will help to diversify the employment offer and better meet the needs for jobs arising in the wider District in a sustainable manner. Providing additional employment land in Market Harborough would be a logical approach due to its sustainability, location for future growth and its function as an economic centre that serves the surrounding area. Market Harborough also has a good relationship with Leicester City, which is important because the District forms part of the wider Leicester and Leicestershire housing market and functional economic area, and also because the draft Local Plan seeks to accommodate a portion of Leicester City’s unmet industrial need to 2036.
1.13. The matter of ensuring a sustainable employment strategy is followed must be emphasised. The Sustainability Appraisal (S-NLP 4) highlights the negative climate change impacts associated with the expansion of Magna Park, as a result of the additional vehicular traffic. The draft Local Plan needs to carefully consider the alternative options available which would allow jobs to be created closer to where new residents will be, improving the ability to travel by sustainable modes of travel.

Steindale’s recommended solution
1.14. There are employment sites available that have been identified through the SHELAA as being available and that are located in or adjoining Market Harborough. Steindale submitted one such site through the 2024 Call for Sites process, which is located at Rockingham Road, Market Harborough and is promoted for employment development. The site lies directly adjacent to the settlement boundary of Market Harborough (confirmed as being a highly sustainable settlement), and its surrounding area is a well-established hub for employment, logistics and light industrial uses. The adopted Local Plan identifies the area east of the site as a Key Employment Area (Policy BE3), and the area to the south as a General Employment Area (Policy BE3). The site therefore represents a logical expansion of Market Harborough’s existing employment provision, with quick and easy access to the strategic highway network and sustainable connections via rail
and bus for local workers to access the site.
1.15. The site is suitable, available and achievable for sustainable development. It has direct highway frontage with Rockingham Road (the A4304) with no constraints to achieving a safe and suitable access. The site is actively promoted by Steindale Properties Limited, which has an option on the site that can be exercised at the appropriate time. The site is therefore available for development with no legal or ownership constraints. As delivery of the site is not dependent on the provision of any strategic infrastructure, the site would be developable early in the Local Plan period.
1.16. The SHELAA Update 2024 (HSG-NLP 6) agrees, identifying the site (under reference 24/10398 as shown in Appendix 2) as being deliverable and developable (for employment uses), albeit suggesting the site can deliver 25,200sqm within 6-10 years. Steindale is actively working on promoting the delivery of the site, and contends that it can actually be delivered within 0-5 years. It should also be noted that the site has not been subject to detailed capacity testing yet, and so the floorspace quoted in the SHELAA is based on the Council’s own estimate based on an average density of 4,000sqm/ha. The SHELAA Site Companion Guide (HSG-NLP 4) reviews the site in more detail and confirms the site is available, achievable and potentially suitable, concluding ‘The site would provide an attractive location for employment uses’. Despite this assessment of suitability, there appears to be a lack of consideration within the draft Local Plan for alternative employment allocations such as this site – and the important role that can be played in boosting the supply of economic land, and associated jobs growth, in the District.
1.17. The only constraint flagged by the SHELAA is the potential impact of Flood Zone 3 on how the site could be developed. Steindale is taking an active and pragmatic role in the promotion of this site, and has thus been engaged in ongoing discussions with the Environment Agency regarding development on the site, with recent dialogue indicating positive movement on flood risk mitigation.
1.18. It is noted that the SHELAA does not raise any other constraints as potentially restricting development. Notwithstanding, the site is clearly a logical extension of existing development. It would continue the existing linear development that has taken place to the east of Rockingham Road, and would be of a suitable scale that would not cause coalescence with Great Bowden. It is noted that noted that Great Bowden Neighbourhood Plan has an Area of Separation policy which stops at the site boundary – providing extra protection to land between the site and Great Bowden.
1.19. Work is also being progressed on other relevant technical matters as required to clarify the developable area of the site and its capacity, as well as any mitigation measures that may be required. This includes undertaking landscape appraisal, biodiversity and arboricultural surveys, and undertaking a detailed review of the site access strategy to confirm that a safe and policy-compliant access strategy can be demonstrated.
1.20. Steindale Properties Limited will continue with this work, and is confident in the deliverability of the site. Steindale is willing to continue engaging with the Council to provide any information necessary (as appropriate at this promotion stage) to further demonstrate the deliverability of the site.
1.21. The whole site, part of which falls within the neighbouring North Northamptonshire Council – Kettering area, is suitable and capable of delivering strategic scale employment, which would support the needs for strategic housing growth that have been identified. There is clearly a need for strategic scale employment as discussed in the accompanying Economic Need Analysis (Appendix 1), and this site would allow new jobs to be created on a sustainable site close to where existing and new residents will be living.
1.22. However, it is also feasible to deliver non-strategic industrial and distribution uses (within the part of the site which falls solely within Harborough District Council) to contribute towards a diversification of employment uses in the District. The location of the site on a key gateway into Market Harborough is also suitable to deliver supporting uses, such as drive-thru units and electric vehicle charging forecourt. Steindale is also currently investigating the feasibility of delivering a Data Centre on this site. This flexibility in the type and amount of uses that can be delivered make the site suitable for allocation to fill the ‘gaps’ in the employment market which cannot be met by the current employment allocations made by the draft Local Plan.
1.23. It should be noted that the northern part of the site is located in the Kettering area of North Northamptonshire. Representations will be made to the emerging Local Plan for North Northamptonshire at the appropriate time, for employment uses at the site. However, given the site is more closely related to the built area of Market Harborough, it is logical to refer primarily to emerging policies in the Harborough Local Plan and its supporting evidence base when assessing the deliverability of this site and its suitability for employment uses.

Summary – Proposed Amendment
1.24. Accordingly, Steindale requests an additional employment allocation at Land West of Rockingham Road (SHELAA Update 2024 (HSG-NLP 6) site reference 24/10398) and a more balanced spatial distribution of employment growth.

See above comments. Steindale recommends revised wording to clarify the meaning of ‘coalescence’ and avoid over-restriction, and suggest removing the duplicated AoS policy tests in AP03 and AP04.

2. Policy DS04 – Areas of Separation
2.1. The approach taken to Areas of Separation in the Draft Local Plan is not sound. In the Regulation 18 consultation, the Council recognised that the Areas of Separation were a longstanding designation that needed review to ensure they remain fit for purpose and consistent with national policy. A review has been undertaken (LAN-NLP 1, November 2024) but this is not thorough or robust as it has not assessed, fundamentally, whether any of the existing or proposed Areas of Separation are required – and if they are, whether the boundaries of those Areas of Separation (AoS) are necessary.
2.2. Instead, an approach has been taken of excluding the potential site allocations from the assessment areas, with the assessment commenting on the impact on settlement gaps if the allocations were to be taken forward. Or in the case of OA1, the assessment at the request of the Council, seeks to “suggest a boundary for an AoS that would represent the minimum area required to retain clear separation” between the relevant settlements.
2.3. This approach suggests there is flexibility in the extent of the current AoS, and that there is scope for development to take place within the AoS without impacting on the overarching goal of maintaining a sense of separation between settlements. This though is not reflected in the relevant policies as presented in the Draft Local Plan.
2.4. Criterion 2 of draft Policy DS04 sets out the policy requirement for new development within AoS to “avoid coalescence and preserve the existing visual and physical separation”. This does not reflect the evidence set out in LAN-NLP 1. Taking the Great Bowden and Market Harborough AoS as an example, it is clear in the findings of LAN-NLP 1 that the key area of sensitivity is the southern edge of Great Bowden, around Great Bowden Road / Station Road. The area east of Great Bowden is recognised as being a significant separation gap, and although the A4304 is established as the boundary, there is no reason given for why the River Welland could not perform the same function.
2.5. While Policy DS04 as drafted does not restrict outright development in an AoS, that is how the policy will be applied in practice unless the policy is very clearly drafted. Steindale strongly recommends that the wording of the policy is reviewed to ensure its application is not overly restrictive. In addition to ensuring both the policy and the boundaries of the AoS is in line with the evidence as discussed above, a clear definition of ‘coalescence’ and how a development’s impact on coalescence will be assessed. This will provide clarity to those making applications, and ensure that a consistent approach is taken by decision makers.
2.6. Draft Policies AP03 and AP04 both also contain a criterion (the same criterion) relating to development in AoS:
“Within Areas of Separation, development will only be permitted where this does not compromise, either alone or in conjunction with other existing or permitted development, the effectiveness of the Area of Separation in protecting the identity and distinctiveness of these settlements and supports the strategic objectives in Policy DS04.”
2.7. This duplication is considered to be unnecessary – a reference in each policy only needs to be made to Policy DS04 rather than setting out a further policy requirement controlling development in AoS.
 
Summary – Proposed Amendment
2.8. Accordingly, Steindale recommends revised wording to clarify the meaning of ‘coalescence’ and avoid over-restriction, and suggest removing the duplicated AoS policy tests in AP03 and AP04.