Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
Our Local Plan Vision
Representation ID: 13647
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
The proposed vision is supported in principle, although it could be made more spatially specific by making reference to the key strategic developments being delivered through the plan period including the new strategic sites at the Land south of Gartree Rd and east of
Oadby, Market Harborough and the existing Lutterworth East Strategic Development Area.
Although the Lutterworth East SDA is an existing commitment it will be a key area of growth and change through this plan period which should be recognised in the vision.
Vision should be modified to reference the key Strategic Development Areas and provide a vision for them, since they will collectively comprise the key areas of change
within the District during the proposed plan period and beyond.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
4.2
Representation ID: 13648
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Key Diagram (Figure 2) gives no indication that there
is a Strategic Development Area delivering 2,750 homes as part of a mixed use development to the east of Lutterworth. The Key Diagram should include reference to the Lutterworth East SDA, as this consented scheme will be providing a significant portion of the District’s housing supply, as set out in Appendix 5.
Whilst it is a commitment following allocation in the current adopted Local Plan, it is also a key component of the Development Strategy for District over the plan period.
Key Diagram should be amended to incorporate reference to the Lutterworth East SDA to provide certainty and transparency about the delivery of this site and ensure the plan is positively prepared and effective.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS01 Development Strategy: Delivering Homes
Representation ID: 13649
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? No
The housing requirement must incorporate a proportion of Leicester’s unmet need through the entirety of the plan period until 2041. It is clear that unmet need should continue to be incorporated into the housing requirement for the Borough post 2036 given the unmet need in Leicester is likely to remain or increase through the District’s plan period.
The Council can avoid further unnecessary delays during the Examination process by extending the plan period now to 2042.
It is our opinion that the Lutterworth East SDA, as an existing commitment for 2,750 homes, is a key component of the growth in Harborough District and should be referenced throughout the Local Plan. The approach, of limiting development in a Tier Two Market Town, should be reconsidered.
Not sound: not positively prepared, not justified, not effective, not consistent with National Policy.
Policy DS01 should be modified so that the housing requirement incorporates Leicester’s Unmet Need until the end of the plan period, rather than until 2036.
The plan should be supported by an updated Statement of Common Ground between the Leicester and Leicestershire authorities which apportions the unmet need from Leicester beyond 2036 taking account of the authorities progressing under the transitional arrangements such as Harborough District Council. Or an interim position should be agreed between the authorities to demonstrate that the existing agreed SoCG housing figures meet the needs of the Housing Market Area based on the pre-2024 NPPF change to the standard method, including the unmet need from Leicester and if so agree to carry these figures forward beyond 2036 until further work is complete to confirm the scale of unmet need.
The plan period should be rebased to 2024 or potentially 2025 given the intention to submit the plan later this year. The plan period should also be extended by at least a year.
Policy DS01 should make clear reference to the role of the consented Lutterworth East SDA in contributing to the housing requirement within the plan period in part 2 in relation to commitments.
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS02 Development Strategy: Creating Jobs and Diversifying the Economy
Representation ID: 13650
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
The approach, intension to co-locate employment and residential uses, set out is supported in principle.
The Lutterworth East SDA, identified in the adopted Local Plan, is consented to provide over 20 hectares of employment uses, including B2 and B8 to be delivered in the first Phase of the SDA. This commitment to contribute to the quantity of employment land available should be
referred to within this policy, particularly given the sustainable location of these employment uses adjacent to the ‘Golden Triangle’ road network.
The strategically important committed employment development within the Lutterworth East SDA should be referred to in the Local Plan, it should be noted within Policy DS02 in part 2 in relation to commitments.
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS05 Development Strategy: Supporting Strategic Infrastructure
Representation ID: 13651
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
The inclusion of reference to the Lutterworth East SDA and the spine road to be delivered in the Infrastructure Delivery Plan is supported and highlights the importance of this site to the future growth of the District and the need therefore to include a policy on the site and reference to it in other key policies.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
Representation ID: 13652
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The reason for selecting or rejecting certain site options relies on the fact that council has decided the level of development that should be accommodated in certain
settlements, However without a clear description of the process that led to the identification of levels of development in certain settlements, the site selection process is flawed and is not justified.
Figure 5, like the Key Diagram, should incorporate Lutterworth East as a strategic commitment.
Policy SA01 should carry forward the policy for Lutterworth East SDA in the adopted Local Plan.
To meet the national policy requirement to consider the longer term vision for the District, it would be appropriate for the Council to identify directions for growth beyond
the Lutterworth East Strategic Development Area to indicate the longer term potential for development beyond the existing permission towards the end of the plan period and beyond.
Omission site Land north of Gilmorton Road, Lutterworth (Ref. 24/10318) is proposed for allocation.
The site selection process set out in the Sustainability Appraisal is unclear and requires further explanation.
The Lutterworth East SDA should be acknowledged within the Site Allocations policy and Figure 5 as a key aspect of the development strategy and a policy framework provided for future applications.
Land North of Gilmorton Road should be incorporated into the Site Allocations, given its relationship with the Lutterworth East SDA and its potential to provide additional housing and employment. It has the potential to come forward on its own as a logical extension to the
existing Lutterworth East SDA which would sit comfortably alongside a wider extension using Leicestershire County Council Land. This land could alternatively be considered for identification as a Direction for Growth as part of a longer term vision for additional growth in this sustainable location.
See attachment.
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN01 Housing Need: Affordable Homes
Representation ID: 13653
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
The principle of this policy is acceptable.
It is noted that an application to Vary the Section 106 of the Lutterworth East SDA was approved by the Council in December 2024, confirming that the SDA may provide affordable housing at a minimum of 10% and a maximum of 40%. Given this potential reduction in affordable housing provision within the SDA, it is considered that the site at Gilmorton Road could assist with providing additional affordable housing in line with the proposed policy phrasing.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy AP01: Development in Settlements
Representation ID: 13654
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is unclear however why the policy doesn’t also include scenarios where a five year supply of deliverable sites is not available as well as when the Council is failing the Housing Delivery Test.
Policy AP01 should be modified to include a scenario where the Council is unable to demonstrate a five year supply under criteria (f) or as an additional criteria (g).
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM09: Sustainable Construction and Climate Resilience
Representation ID: 13655
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy DM09: is not justified or effective.
The Policy states that it relates to all development and states that all development must, amongst other things “minimise carbon emissions during construction”. It is not clear what the threshold is for compliance with this policy. It does not comply with NPPF para 16 as it is not evident how a decision maker should react to development proposals. The lack of clarity about compliance with this policy means that is uncertain whether it has been robustly tested through viability.
Policy DM09 requires further explanation to be justified and effective.
See attachment.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.7
Representation ID: 13664
Received: 02/05/2025
Respondent: Storey Property Developments Limited
Agent: Pegasus Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Appendix 1 - The removal of Policy L1 (East of Lutterworth Strategic Development Area) is not supported, particularly given the minimal references throughout the Plan to the role of the Lutterworth East SDA in supporting the provision of housing and employment uses within the plan period.
The Lutterworth East SDA should be referred to in Part 1 of the Local Plan, particularly policies DS01, DS02, and SA01 as set out throughout this representation document.
See attachment.
