Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13719

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We object to the proposed plan period because it does not: meet the minimum 15 year period, allow for delays or align with the timeframe of some evidence documents. The plan start date of 2020 is inappropriate and should be amended to 2025, using the new standard method in full. And to reflect this the plan end date extended to 2046. As a minimum an additional year should be added, meaning the plan period would run to 2042.
HDC should also commit to an early review of the plan, to meet the increased housing requirement introduced under the new standard method.

Object

Representation ID: 13720

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Welcome recognition within vision to provide a range of housing, including affordable, and support local economy.
Vision should also: give regard to the need to cater for Leicester's unmet need and effective delivery, state specifically the housing requirement of the new Local Plan, and should accurately reflect the settlement heirarchy and support sustainable patterns of growth across the District.
Further emphasis of the important link between the delivery of housing and employment need, needs to be reflected in the vision.

Object

Representation ID: 13721

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The objectives have been watered down and do not accord with para 15 of the NPPF. The revised objectives proposed are not reflective of the broad range of spatial planning issues currently present within the District. We consider the objectives proposed at Regulation 18 stage were more appropriate and covered a broader range of topics.
the objectives are based on and framed by the Corporate Plan, which is not a spatial planning document.

Object

Representation ID: 13724

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The housing requirements should be reviewed. As currently planned for, HDC are at risk of either not meeting the required 80% of the new standard method as per the transitional arrangements, or are at risk of breaching the Statement of Common Ground and not providing the agreed housing on behalf of Leicester City, as it has not been made clear which the Council are prioritising.
The proportion of housing allocated to small villages and how this is distributed is unsound and should be reviewed.
Dunton Bassett's identification as a small village should not prevent sustainable growth. The plan is unsound as it does not seek to allocate housing to small villages where there is an identified need.

Object

Representation ID: 13725

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

We do not consider the requirement for 40% affordable housing to be viable, especially on sites of a scale to 20-45dw and sites of low greenfield value at all scales.
Land which is of lower greenfield value should be used first in development in order to protect higher value greenfield land. The affordable housing requirement requested by HDC should take this into consideration in requesting affordable housing on site.

Object

Representation ID: 13726

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The non assessment and exclusion of sites that are located within or extending from small villages, in the Site Selection process, is not a sound approach because small villages are a large proportion of settlements in Harborough.
It is important to provide allocations in small villages.

Object

Representation ID: 13727

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

The site provides a large proportion of the total housing allocations for the District. The complexities of the site, including its scale, cross-boundary location and viability create risks around; delivery timeframes, over reliance on the allocation, lower provision of affordable housing and its ability to provide an appropriate level of contributions to mitigate against impacts.
The commencement of delivery from this site should be amended to 9 years following adoption (i.e. 2035/36 if adoption in 2026) and the build out rate reduced to a more realistic level (Ref. Start to Finish Report 3, Lichfields).

Object

Representation ID: 13728

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Appendix 5 provides a series of commencement years for the different sites, despite the allocation requiring a singular masterplan . We consider that the Housing Trajectory should align with the proposed policy, to ensure that a carefully designed masterplan is brought forwards to provide direction for development across the whole allocation area.
Delivery should be pushed back to commence from 2032/33 to allow for agreement in how development is brought forwards and the consideration of contributions through the Section 106 agreement, or any additional onsite infrastructure that may be required due to the scale of the development.

Object

Representation ID: 13731

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Evidence (HDC Viability Assessment, The Start to Finish Report 3, Lichfield's) supports the need for the delivery of housing to be delayed in the Housing Trajectory to 2031/32, to allow for additional time for confirmation the proposed allocation is indeed viable, with the ability to provide the affordable housing, with the needed mitigation
works on the identified highways.
Delivery of first housing on the site should be pushed back to 2031/32 and the build out rate from year second year of delivery reduced to 68dw pa, resulting in a lower total delivery of 662dw in the plan period.

Object

Representation ID: 13732

Received: 02/05/2025

Respondent: Richborough

Agent: Boyer Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

An alternative Appendix 5 (Housing Trajectory) is provided to reflect suggested amendments to the delivery timeframes and build-out rates of sites allocated by policies SA02, SA03 and SA04. This would see 1,130dw delivered in the plan period, less than currently anticipated, resulting in HDC being unable to demonstrate a five year housing land supply upon adoption, in the first 5 years of the plan when assessed against the new standard method and when assessed against the transitional arrangements.
The Council should provide further allocations to rectify the shortfall, including Land West of Lutterworth Road, Dunton Bassett.