Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13640

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The justification for reducing the housing requirement after 2036 is flawed as it does not take account of unmet needs that are evidenced to exist beyond 2036. The increased Standard Method figure for the District illustrates an increased requirement for development in the district within the HMA context where the housing needs have not significantly changed overall.
The housing requirement is not justified, is not positively prepared and not consistent with national policy. It is unclear how the housing requirement relates to the
most up to date relevant standard method figure for the District and then how this has been uplifted to take account of best information available on unmet needs.
It is also failing the Duty to Cooperate. There is no evidence of engagement with other authorities dealing with the post 2036 situation with housing distribution or the changes brought in as a result of the 2024 NPPF. The Council needs to show that there has been constructive engagement on the housing requirement figure for the District up to 2041 not just to 2036.
The plan period is not justified because it: includes 4 yrs which precede the relevant LHN figure, only takes account of over not under delivery, and it doesn't provide a full 15 year time horizon.

Object

Representation ID: 13641

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The proposed contingency buffer should be increased from 12% to at least 15% and ideally 20% to allow for flexibility.

Given the likelihood that the unmet need in Leicester will further increase throughout the plan period, it is important to consider the role of additional sites.
Omission site Land at Witham Villa, Broughton Road (21/8220) is proposed for allocation.

Object

Representation ID: 13643

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Consideration should be given to setting out in the policy the other factors that will be taken into account when deviating from the latest mix evidence e.g. viability, market conditions, design and character of the area and other site-specific circumstances.
Accessibility Standards are set out in the nationally set Building Regulations. It is not, necessary for planning policy to cover these matters as any requirement will be superseded by changes to Building Regulations. The Government proposal to mandate the M4(2) requirement as a minimum for all new homes would be implemented through the Building Regulations. Introducing local standards ahead of this would be challenging.

Object

Representation ID: 13644

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

The threshold of 40 dwellings and 10% sought on site are not justified by the evidence because: registrations do not automatically reflect the need or demand for plots, of the effect on the delivery and phasing of a site, the LP Viability Appraisal has not specifically assessed the impact of unsold plots on deliverability and viability, Pockets of land within medium / large sites over 40dw are not an appropriate nor desirable means of meeting this need, approach is unlikely to meet the aspirations of someone looking to construct their own home.

Object

Representation ID: 13645

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy approach is supported as a pragmatic approach to consider the potential need for additional sites in the plan period outside the allocations and provides the Council with a policy framework within which to assess speculative applications.
However, its unclear why it doesn't also include scenarios where a 5 year Housing Supply is not available and when the Council is failing the Housing Delivery Test.

Object

Representation ID: 13646

Received: 02/05/2025

Respondent: Vistry Group

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy DM09 is not justified or effective because: it is not clear what the threshold is for compliance and 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.