Regulation 19 - Proposed Draft Local Plan Submission

As above.

This policy is generally supported, however, some flexibility should be included to allow development “wherever possible” to minimise carbon emissions during construction. It is anticipated that this could be agreed as part of a Construction Environment Management Plan (CEMP).
In addition, it is noted that the policy makes reference to the Home Quality Mark requirement, this is imminently to be replaced by the BREEAM Residential scheme, to ensure the policy can be complied with, reference to the Home Quality Mark requirement should therefore be deleted from the policy. This notwithstanding, the BREEAM Residential scheme will go beyond Building Regulations requirements and would therefore need to be robustly tested through the Council’s viability assessment supporting the plan and fully evidenced.
Lastly, a caveat should also be included in the emerging policy to state that the submission of a site-specific viability assessment may be accepted where viability is identified as a barrier to delivery.

As above.

Policy DS04 seeks to protect the rural character, landscape and heritage assets within the district, and Point 3 relates to the Green Wedge around Leicester, Scraptoft and Bushby.
As set out in our client’s representations to the Regulation 18 Local Plan, it is noted that the emerging Local Plan presents an opportunity to review the boundaries of the Green Wedge within the district, which comprises of two areas: the Leicester/ Scraptoft/ Bushby Green Wedge and the Thurnby/ Leicester/ Oadby Green Wedge on the north western edge of Harborough, adjoining Leicester City.
Since the Local Plan will incorporate unmet housing needs arising from Leicester City, it is entirely appropriate that the spatial strategy seeks to provide for this growth in sustainable locations, particularly in the ‘Adjoining Leicester Urban Area’ settlements such as Scraptoft, as set out earlier in these representations. These settlements are functionally related to Leicester and are served by good transport links, making them the most sustainable locations for growth in the district. These are also the settlements that are bound in part by Green Wedge designations.
Should the Green Wedge be retained in full, then the Local Plan should recognise that there may be opportunities for development within the Green Wedge to still achieve the overall purpose of the Green Wedge. This could be via facilitating recreational opportunities (as set out in Paragraph 4.48), alongside meeting development needs. This would be the subject of suitable high-quality design and placemaking which could be integrated into development. It is considered that these are matters that can be addressed through the planning application process and should be considered on a site-by-site basis.
In the context of the Scraptoft North SDA, part of the southwestern edge of the allocated site is within the Green Wedge. The current application locates the proposed primary school and associated fields in this part of the site, considered to be the most appropriate location given its proximity to the existing community and access to future residents on site. The proposed school integrates high quality design, open space and recreational space to ensure the development of this area is sensitive. The siting of the school in this location also accords with emerging policy DS05, ensuring new facilities are well related to the population they serve (part 4a). This demonstrates how development can respond effectively to the Green Wedge designation, should the boundary be unaltered through the emerging Local Plan.
This notwithstanding, to ensure that the plan is able to meet housing needs in the most sustainable locations (and in accordance with the development strategy at Policy DS01), it is considered that there should be some flexibility around the Green Wedge to allow development to come forward where it would comprise of sensitive and high-quality design.
As a minimum, Point 3 of Policy DS04 should be revised, to recognise that some development in the Green Wedge may be acceptable, to meet the district’s development needs, and subject to specific criteria (such as high-quality design and the provision of open space). This amendment would be in accordance with Harborough’s Green Wedge Assessment (December 2024), which states the following (on page 24):
“Land to the west of Hamilton Lane and three of four parcels west of Scraptoft Rise are allocated as part of the Scraptoft North Strategic Development Area (Local Plan 2011-2031 Policy SC1). The policy wording highlights that the area bounded by New Romney Crescent, Hamilton Lane and Scraptoft Lane should be retained as Green Wedge to prevent the merging of Leicester and Scraptoft, and to provide recreational resource for new and existing residents of the locality. The outline planning application (Ref: 19/00700/OUT) proposes this area as Public Open Space, including sports pitches. Existing and proposed land uses are compatible with Green Wedge policy.”
Furthermore, paragraph 4.4 of the Local Plan acknowledges that the visual connection between settlements and the surrounding countryside is a defining feature of the district landscape. However, this should not sterilise development opportunities within or near to the Green Wedge, particularly if high quality design can be achieved and appropriate landscaping can be incorporated to mitigate the impact of development.
The proposed updates set out above will ensure the Policy acknowledges that visual connections can be managed and mitigated through appropriate design, that can be controlled via conditions attached to future planning permissions.

As above.

In relation to part 2a of the emerging policy, further clarification is sought in respect of what a ‘significantly greater’ quantity of housing/employment land agreed through an updated Statement of Common Ground, would comprise, and therefore at what threshold a full or partial update of the plan would be triggered.

As above.

It is recommended that sub-section (c) of Paragraph 5 in Policy DM10 is updated to state:
‘Development proposals that are likely to result in a significant adverse effect, either alone or in combination with other proposals, on internationally designated sites, will not be permitted unless a Habitats Regulation Assessment has concluded that the proposal will not adversely affect the integrity of the qualifying features of the site’.
The above amendments would ensure that Policy DM10 appropriately considers both habitats and species.

As above.

The proposed natural and semi-natural greenspace requirement of 8.5ha per 1,000 population appears high and is significantly in excess of the Fields in Trust minimum natural and semi-natural greenspace requirement of 1.8ha per 1,000 population. The Council’s evidence base documents indicate provision varies across the district, with provision in some areas at 1.95ha.
The Policy should therefore be updated, to include more modest minimum requirements, and the total requirements to be reviewed and assessed on an individual site basis. This would ensure that site specific constraints are considered, and the matters associated with meeting Biodiversity Net Gain requirements are considered, all of which would be derived from a site-specific design response.
Furthermore, much of the value in increasing the greenspaces across the district revolves around the quality of the provision, rather than the quantity. It would therefore be more beneficial to consider each site on an individual basis, allowing connections between networks to be made, rather than creating isolated pockets of Green and Blue Infrastructure, which could result from the currently proposed blanket approach to provisions.
In line with the above, it is recommended that the emerging Local Plan recognises how the Draft Leicestershire, Leicester and Rutland Local Nature Recovery Strategy (2025) presents key related evidence to Policy DM05 (as well as Policy DM10, as currently identified in Appendix 2).
Similar to the above, it is acknowledged that the Playing Pitch Strategy presents a mixed picture in the provision for pitch and outdoor sports within the district (given an aging population, coupled with population growth anticipated to increase by c.12% to 2031). Again, this element of the policy should be updated to reflect the need to consider sites on an individual basis, reflecting local analysis relevant to each proposed development, and taking into consideration the most up to date needs evidence at the time of a planning application coming forward.

As above.

As set out in our client’s representations to the Regulation 18 Local Plan, the potential benefits of self and custom build development are recognised, however the policy needs to be amended to reflect local need, referencing the Council’s Self and Custom Build (SBCB) Register, and how design considerations will need to guide outcomes to ensure SBCB housing is complimentary to existing and proposed adjacent developments.

As above.

Policy HN04 requires specialist housing for older people to be provided as an integral part of all residential developments over 100 dwellings; caveated by the wording that recognises the need for the site to offer a suitable location for the provision of this type of accommodation.
This caveat is welcomed, given only the most appropriate locations should be providing this type of accommodation within the district, acknowledging the need for accessibility to services and facilities. This notwithstanding, the Policy does not clarify what comprises ‘supported and specialist forms of accommodation’, and it is recommended that the Policy is revised to make clear what this entails.

Remove reference to the M4(2)/ M4(3)A/ M4(3)B standards.

As set out in our client’s representations to the Regulation 18 Local Plan, setting M4(2)/ M4(3)A/ M4(3)B standards as a requirement for new homes in the district is not considered to be an appropriate approach to development since it would not take into consideration site characteristics or location, which may not be most suitable for those with access or mobility issues.
As set out in Paragraph 63 of the NPPF (2023), housing needs for people with disabilities should be reflected in planning policy, this should be assessed as part of the plan making process for the emerging plan and then an appropriate policy could be incorporated. However, a blanket policy for all sites is not considered to be a sustainable approach and could lead to homes in the wrong places for people with disabilities.

Re-allocation of Scraptoft North SDA.

Paragraph 2.12 notes that income inequality persists across the district which results in a requirement to attract and retain higher skilled employees to service new and growing industries. This economic success will only be achieved if there is adequate, new and high-quality housing growth, in attractive and accessible locations (including with access to public transport). As set out in respect of the vision, the plan should ensure that economic growth is complemented by housing growth to ensure that the objectives of the plan can be met. Scraptoft North SDA represents a sustainable and accessible opportunity to provide housing growth in the district to serve and support economic and employment growth aspirations over the plan period.

As set out in our client’s representations to the Regulation 18 Local Plan, setting M4(2)/ M4(3)A/ M4(3)B standards as a requirement for new homes in the district is not considered to be an appropriate approach to development since it would not take into consideration site characteristics or location, which may not be most suitable for those with access or mobility issues.

As set out in Paragraph 63 of the NPPF (2023), housing needs for people with disabilities should be reflected in planning policy, this should be assessed as part of the plan making process for the emerging plan and then an appropriate policy could be incorporated. However, a blanket policy for all sites is not considered to be a sustainable approach and could lead to homes in the wrong places for people with disabilities.

As set out in our client’s representations to the Regulation 18 Local Plan, setting M4(2)/ M4(3)A/ M4(3)B standards as a requirement for new homes in the district is not considered to be an appropriate approach to development since it would not take into consideration site characteristics or location, which may not be most suitable for those with access or mobility issues.

As set out in Paragraph 63 of the NPPF (2023), housing needs for people with disabilities should be reflected in planning policy, this should be assessed as part of the plan making process for the emerging plan and then an appropriate policy could be incorporated. However, a blanket policy for all sites is not considered to be a sustainable approach and could lead to homes in the wrong places for people with disabilities.