Regulation 19 - Proposed Draft Local Plan Submission

The time horizon of the Local Plan should be extended to an end date to 2042. The housing requirement in the later stages of the Plan should be increased to meet 80% of the District's LHN. Additional sites should be allocated to meet this need. Land is identified in the SHELAA which can meet this deficit in the Market Towns. Site 24/10242 Harborough Road, Market Harborough (Land at Airfield Farm) should be identified as a housing allocation for 250 homes.

The Regulation 19 Local Plan covers the period 2020-2041. Para 22 of the National Planning Policy Framework 2024 (NPPF) states that “Strategic Policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure.

On the basis of the Local Development Scheme February 2025 (LDS), the new Local Plan is scheduled for adoption between October and December 2026. This programme is extremely ambitious with submission of the Plan anticipated in September/October 2025. Given the progression and adoption of Local Plans nationally, it would seem prudent to allow for some slippage in the Local Plan preparation timetable and therefore a slight extension to the time horizon of the Local Plan to ensure the strategic policies will be framed within a full 15 year time horizon. We propose an extension to the horizon of the Local Plan- taking the end date to 2042.

Policy DS01 identifies the housing requirement for Harborough District as 13,172; made up of 667 homes per annum in the first 16 years of the plan period and 534 homes in the last 5 years of the plan period. The Plan is progressing under the transitional arrangements described in Annex 1 of the NPPF 2024 as it has reached Regulation 19 stage before 12 March 2025. The critical issue is whether the housing requirement meets at least 80% of local housing need as it is required to do under the transitional arrangements.

Under the latest standard method, Harborough’s Local Housing Need (LHN) is 723 dwellings per annum. Over the Plan period 2020-2041 (21 years) the requirement would be 15,183 homes- 80% of which is 12,147 homes. Whilst the Plan does make provision for in excess of 80% of the LHN in the first 16 years of the Plan period, it fails to do so in the last 5 years of the period (a shortfall of 45 dwellings per annum). Therefore, whilst the first period of the Plan meets the minimum 80% requirement to proceed under the transitional arrangements (and examination under the pervious version of the Framework) the latter stages do not. A more robust approach would be to plan for a minimum of 80% LHN for the entirety of the Plan period. This would result in an additional 225 dwellings. Furthermore, if the Plan period is extended to 2042 as described above, the total additional requirement is 804 dwellings.

Land is identified in the SHELAA Assessment Update 2024 which can meet this deficit in the Market Towns. Site 24/10242 Harborough Road, Market Harborough (Land at Airfield Farm) is identified as being developable for 113 houses in period 6 to 10 of the Local Plan. This is in consideration of 6ha of land. The residual land (reference 24/12205) is considered able to provide 28,314 sqm of economic floorspace deliverable in period 6 to 10 of the Local Plan. With regard to availability and deliverability, the site is in a single ownership and would be available within 5 years.

Land at Airfield Farm is allocated within the 2019 Local Plan under Policy MH4 to provide approximately 13.1 ha of employment land for E(g) B2 and non-strategic B8 uses. As it is now a commitment, the site is not allocated for employment uses in the Regulation 19 Plan. Outline planning consent was granted for demolition of the farm buildings on site and construction of what is now known as Wellington Business Park in October 2023 (under application reference 21/00545/OUT). The site area is 13.49 ha and was envisioned to contain up to 35,001 sq.m Class E(g)(iii)/B2/B8 industrial floorspace, up to 5,994 sq.m Class E(g)(i) office floorspace and 250 sq.m of retail Class E(a/b).

As advised during the Call for Sites process, our Client (AFD Commercial Development Ltd) considers that the uses allocated for the Site under Policy MH4 and approved under application ref: 21/00545/OUT are unviable and ultimately undeliverable. The Council have been urged to examine potential alternative options for the site.

Despite the Council’s desire to maintain the employment allocation in its current form, the landowner cannot bring the site forward as the planning permission achieved is not viable. An alternative use for the site needs to be found in the context of the Local Plan review. Our preference is for the site to be allocated for Class E(d) leisure and residential uses.

Our current design work shows that the site has potential to accommodate 250 homes as a mixed-use development of housing (circa 250 homes) and Class E (sport/recreation/fitness) uses. The access and drainage can remain as approved under application ref: 21/00545/OUT and are sufficient infrastructure to serve a mixed use option. The site would still fulfil a role in providing jobs for the local economy and it is estimated to contribute 75-100 FTE jobs.

As demonstrated through the Outline Planning Application process, there are no technical constraints to development and the strategic access road is in place to enable an early phase to be delivered quickly. The site is located on the outskirts of Market Harborough which provides a wide range of services and facilities. The site has good public transport accessibility. It is served by bus routes 44, X3 and X7 and bus services connect the site to Market Harborough railway station providing further connectivity.

Whilst there is no prospect of the site being bought forward for the allocated use, the benefit in bringing the site forward for Class E(sport/recreation/fitness) and Class C3 residential units can be summarised as:
• Creation of new jobs during the construction phases with c250 homes delivered in the first 5 years of the Plan period
• Significant inward investment and delivery of 75-100 FTE jobs associated with a new leisure facility
• Meeting the need for a new health and fitness facility in the District
• A mixed use Class E(d)/C3 use would complement the proposed allocations MH2 East of Market Harborough Road (850 Homes) and MH3 Land South of Gallowfield Road(600 homes).
• The role and importance of Market Harborough would be enhanced with a new local facility and broadening of the leisure economy. Diversification of the economy with leisure use can help reduce over reliance on specific sectors (particularly logistics) and help widen the base of businesses in the town.

The envisioned 8.8 ha of industrial supply from Wellington Business Park at Market Harborough should be excluded from the employment land supply calculations.

Land at Airfield Farm is allocated within the 2019 Local Plan under Policy MH4 to provide approximately 13.1 ha of employment land for E(g) B2 and non-strategic B8 uses. Outline planning consent was granted for demolition of the farm buildings on site and construction of what is now known as Wellington Business Park in October 2023 (under application reference 21/00545/OUT). The site area is 13.49 ha and was envisioned to contain up to 35,001 sq.m Class E(g)(iii)/B2/B8 industrial floorspace, up to 5,994 sq.m Class E(g)(i) office floorspace and 250 sq.m of retail Class E(a/b).

As advised during the Call for Sites process, our Client (AFD Ltd) considers that the uses allocated for the Site under Policy MH4 and approved under application ref: 21/00545/OUT are unviable and ultimately undeliverable. The Council have been urged to examine potential alternative options for the site.

As noted in a recent decision of the Planning Inspectorate (ref: S62A/2023/0031- North of Thaxted Road, Safron Walden) the Inspector considered an allocated employment site where the owner had confirmed they would not release the site for employment related development. In this case, the fact that there was no reasonable prospect of an application coming forward for the use allocated in the plan had a considerable bearing on the decision. The willingness of a landowner to bring forward an allocated site or planning permission cannot be ignored in the Plan making process.

Wellington Business Park (Allocation MH4) has been included within the employment land commitments. The ‘Harborough Local Housing & Employment Land Evidence’ (January 2025’ notes that “The current supply pipeline for industrial development at Market Harborough is reliant on the delivery of Wellington Business Park, at Airfield Farm. This makes up 8.8 ha of 11.3 ha industrial supply at Market Harborough based on the current monitoring data; meaning that the site, which is suitable and well located, is of central importance to maintaining a supply of industrial land.”

In the evidence base document entitled ‘Harborough Local Housing & Employment Land Evidence Appendix A: Review of Existing Employment Areas & Extant Allocations’ (January 2025), the undeveloped allocations are assessed. The recommendation in respect to Wellington Business Park is that the site is expected to play an important role in enabling employment growth in Market Harborough and the site should remain allocated.

Prop-search were formally instructed to market the site in February 2021 and have continued to comprehensively market the site during the last four-year period through a combination of onsite V boards, direct email and web based methods. Whilst there has been some occupational demand for smaller units there has been no developer interest in purchasing the site as a whole given it is unviable. The principal reasons for this is a combination of the infrastructure costs, combined with a reduction in rents, an increase in building costs along with increased interest rates.

Despite the Council’s desire to maintain the employment allocation in its current form, the landowner cannot bring the site forward as the planning permission achieved is not viable. An alternative use for the site needs to be found in the context of the Local Plan review. Our preference is for the site to be allocated for Class E(d) leisure and residential uses. In any case, the Local Plan and its evidence base now need to take a realistic position in respect to the delivery of Wellington Business Park and it should be excluded from the employment land supply calculations.

Land at Airfield Farm should be allocated as mixed-use development of housing (circa 250 homes) and Class E (sport/recreation/fitness) uses.

Land at Airfield Farm is allocated within the 2019 Local Plan under Policy MH4 to provide approximately 13.1 ha of employment land for E(g) B2 and non-strategic B8 uses. Outline planning consent was granted for demolition of the farm buildings on site and construction of what is now known as Wellington Business Park in October 2023 (under application reference 21/00545/OUT). As advised during the Call for Sites process, our Client (AFD Ltd) considers that the uses allocated for the Site under Policy MH4 and approved under application ref: 21/00545/OUT are unviable and ultimately undeliverable. The Council have been urged to examine potential alternative options for the site.

The ‘Harborough Retail Town Centres Study’ February 2025, indicates that there are 11 registered health and fitness facilities in the District. As noted at Para 6.32 “Experian’s local expenditure data indicates the Harborough study area generates £19.66 million on subscriptions to sports/social clubs and leisure class fees, which is projected to increase to £25.7 million in 2041. Facilities in Harbough District would attract about £9.3 million, based on the 47.3% market share, which equates to about £21,000 per fitness station. Expenditure growth between 2024 to 2041, based on a constant market share of 47.3%, generates an additional £2.9 million, which could support 138 additional fitness station (based on one fitness station per £21,000). Based on this approach there could be scope for at least two additional medium sized health and fitness facility in the District.”

Furthermore, “Demand for additional facilities within Harborough should arise from future population growth. Population within the study area is projected to increase to 145,917 by 2041, an additional 16,284 people. Based on the regional average of 7.1 fitness stations per 1,000 people, this population growth could support about 116 fitness stations, 47.3% of which could be provided in the District based on the current market share. Based on this approach there could be scope for at least one additional medium sized health and fitness facility in the District.”

Our current design work shows that the site has potential to accommodate a mixed-use development of housing (circa 250 homes) and Class E (sport/recreation/fitness) uses. The access and drainage can remain as approved under application ref: 21/00545/OUT and are sufficient infrastructure to serve a mixed use option. The site would still fulfil a role in providing jobs for the local economy and it is estimated to contribute 75-100 FTE jobs.

Whilst there is no prospect of the site being bought forward for the allocated use, the benefit in bringing the site forward for Class E(sport/recreation/fitness) and Class C3 residential units can be summarised as:
• Creation of new jobs during the construction phases with c250 homes delivered in the first 5 years of the Plan period
• Significant inward investment and delivery of 75-100 FTE jobs associated with a new leisure facility
• Meeting the need for a new health and fitness facility in the District
• A mixed use Class E(d)/C3 use would complement the proposed allocations MH2 East of Market Harborough Road (850 Homes) and MH3 Land South of Gallowfield Road(600 homes).
• The role and importance of Market Harborough would be enhanced with a new local facility and broadening of the leisure economy. Diversification of the economy with leisure use can help reduce over reliance on specific sectors (particularly logistics) and help widen the base of businesses in the town.

The decision to focus new residential allocations on Leicester Urban Area and Market Harborough is very much supported and reflects the relative sustainability advantages (particularly in terms of public transport) of these locations.