Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
Policy DS01 Development Strategy: Delivering Homes
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.
Policy DS01 should be modified to incorporate Leicester’s Unmet Need to the end of the plan period, rather than until 2036.
The plan should be supported by evidence of on-going and constructive engagement of the Leicester and Leicestershire authorities beyond the 2022 Statement of Common Ground.
An updated Statement of Common Ground is ideally needed 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. In the absence of this an agreement should be reached that the current SoCG provides a sufficient basis to meet the housing needs across the Housing Market Area based on the latest relevant evidence of local housing needs.
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.
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
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.
Draft Policy SA01 needs to be modified to include additional sites which have been previously
appraised positively to assist with the identified shortfall and the need for a greater buffer in
identified supply.
It is imperative for the Local Plan to provide provision for additional sites to come forward within sustainable locations to ensure that housing requirement is met and the Local Plan is positively prepared and effective. The proposed plan does not have sufficient flexibility or
contingency built into the supply which is reliant on large strategic sites.
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN02 Housing Need: Mix of New Homes
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.
Policy HN02 should include reference to the factors that will be taken into account by the decision-maker in establishing whether it is appropriate to deviate from the housing mix identified in the latest evidence. This will ensure the policy is effective.
Policy HN02 should also be modified to be in line with national policy and not set out policy requirements which go beyond the current building regulations.
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN05 Housing Need: Self and Custom Build Housing
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.
Policy HN05 should be deleted or modified. The policy is not justified by the evidence and are unlikely to effective at providing land that meets the aspirations of those looking to custom or self build.
If retained, the threshold and level of provision should be reviewed and justified against the evidence base and the timescale for marketing should be reduced to avoid problems with the delivery of sites.
The policy should be properly tested as part of a Whole Plan Viability Assessment.
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy AP01: Development in Settlements
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.
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/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM09: Sustainable Construction and Climate Resilience
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.
Policy DM09 requires further explanation to be justified and effective.
See attachment/s.
