Regulation 19 - Proposed Draft Local Plan Submission

Support

Representation ID: 14149

Received: 27/03/2025

Respondent: Leicestershire County Council

Comments from LCC as a landowner:
The thrust of the overall policy is supported. In particular, the policy recognises the challenges that viability presents in the delivery of affordable housing at a rate of 40% and provision is therefore made for viability to be taken into account to ensure deliverability which is welcomed.

Object

Representation ID: 14150

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority (LTA) comments:
Dealing with clusters of sites; assessing transport impacts of allocation sites; and seeking to promote access to sites by active/ sustainable travel are helpful.
However, LTA considers the Plan fails to meet the NPPF tests of soundness re:
• Effectiveness:
- Fails to provide a coherent policy basis to ensure that transport interventions necessary to enable the Plan’s site allocations delivery are deliverable over its time period, especially in respect of interventions necessary to deal with cumulative and cross-boundary transport matters (deferred to development management process).
- Elements of the spatial strategy are dependent on strategic scale improvements to the SRN, but the LTA has no confidence that such will be brought forward and delivered within the Plan’s time period; and
- Lacks any coherent, (likely) lawful policy approach to seeking to secure developer contributions towards transport measures that will be required to address cumulative and/or cross-boundary transport impacts, particularly on the A6 corridor.
• Consistency with national policy: No coherent policy basis for enabling the coordinated delivery of transport interventions to achieve sustainable development in reality.

Object

Representation ID: 14151

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority (LTA) comments:
In principle the concept of a more geographically focused approach to growth – as opposed to the scattering of relatively smaller scale sites across a wide geographic area – is supported by the LTA. However, the specific site allocation proposals set out in the Plan give rise to issues as set in the LTA’s comments regarding:
- Supporting the delivery of the Leicester and Leicestershire Strategic Growth Plan to 2050;
- Position with regard to the development of transport evidence;
- Position with regard to the Plan’s underlying transport strategy;
-Proposed allocation of further Strategic B8 Warehousing; and
- Delivery of sustainable development in accordance with the National Planning Policy Framework (NPPF).

Object

Representation ID: 14152

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority (LTA) comments:
The Plan pays only cursory reference to the Strategic Growth Plan; not a golden thread that runs through it. Nothing in the policy framework would give a basis for the Local Planning Authority, the County Council as the LTA (or wider service provider) or any other relevant body to ensure/to require that developers bring forward the growth proposed on the edge of Oadby in such a way as to positively enable the Priority Growth Corridor's wider, longer-term development, or to safeguard against growth being delivered in a way as to fetter or frustrate the PGC’s wider delivery from a transport perspective.

Object

Representation ID: 14153

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority comments:
No separate transport testing (transport modelling) of the Plan’s proposed spatial strategy has been undertaken. In general terms, it has been tested though wider work looking at the transport impacts of growth across the south of Leicestershire.
However, the south Leicestershire JTE work is not at a stage where any package of strategic transport measures is confirmed. The LTA is not yet able to reach a definitive view on the extent to which the current Plan may or may not fetter/frustrate any package’s delivery.
While the Council published the Harborough Strategic Transport Impact Assessment, the LTA had no input to the brief for work and assessment's contents remain of concern to the LTA.

Object

Representation ID: 14154

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority comments -
The Plan lacks any coherent approach to seeking to address the issue of its transport impacts overall. For example:
- Weak in consideration of transport measures to address the cumulative transport issues, particularly on the A6 corridor;
- Weak in terms of the delivery of transport measures without the District (i.e. to addressing cross-boundary impacts of the growth on the edge of Oadby); and
- Policies that reference or relate to transport are fairly generic.
Where significant cumulative impacts arise from planned growth, the appropriate delivery mechanism is a Community Infrasturcuture Levy. This should be developed with a Local Plan if it is to receive the support of the County Council.

Object

Representation ID: 14156

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority comments: Proposed allocation of further Strategic B8 Warehousing.
The evidence (JTE) clearly demonstrates that a strategic scale improvement is required at least at the Gibbet Hill junction in order for further strategic scale logistics growth to be delivered in the Magna Park area; the scale of scheme required is beyond that which a developer(s) could be expected to deliver and/or reasonably be required to do so in respect of the CIL tests.
The absence of any confirmed approach to the delivery of the SRN improvements necessary to deliver further logistics growth in the Magna Park area poses a significant risk to the Plan’s effective delivery.

Object

Representation ID: 14158

Received: 27/03/2025

Respondent: Leicestershire County Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

LCC Local Transport Authority comments: (Delivery of sustainable development in accordance with NPPF).

Whilst there are some welcome policy aspects regarding the provision of active/sustainable travel, including some that reference cycling, walking and passenger transport, the absence of an overall coherent policy approach to dealing with the Plan’s transport impacts appears to run a significant risk that this will likewise result in the delivery of piecemeal, uncoordinated active and sustainable transport measures that are not sufficiently attractive to encourage and enable modal shift away from the car.
It is questionable therefore whether the Plan is consistent with the NPPF regarding the delivery of sustainable development.