Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13742

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

- Assuming adoption in Dec. 2026, the plan period needs extending to achieve a minimum 15 year period.
- 2020 start date is inappropriate and should be 2025. Most of the evidence published after 2020.
- Council should commit to early review to meet increased housing requirement under new standard method.
- Vision should have regard to catering for Leicester City’s unmet need and effective delivery.
- Vision should state specifically the Plan's housing
requirement to outline clearly the aims of delivery across the plan period.
- Over relaince on large strategic sites. Needs greater emphasis on provision of smaller, more deliverable sites to complement larger schemes.
- Link between jobs and homes needs further consideration.

Object

Representation ID: 13744

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

We question why the Council have decided to ‘water down’ the previous objectives drafted and consider the updated objectives do not accord with NPPF Paragraph 15.
We consider the revised objectives proposed as part of the Regulation 19 consultation are not reflective of the broad range of spatial planning issues currently present within the District. The objectives proposed at Regulation 18 stage were more appropriate and covered a broader range of topics than the revised objectives. On this basis we consider the Council should review the proposed objectives and ensure the accord with the aims of NPPF Paragraph 15.

Object

Representation ID: 13745

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

To meet the District's needs, the housing requirements should be reviewed to ensure a suitable level of housing is provided. 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 housing distribution needs to ensure that the housing that is being delivered is distributed suitably where there has been a need for housing identified (i.e. sustainable small villages such as Swinford). Currently, the Plan focuses only on the Leicester Urban Area/market towns.

Object

Representation ID: 13747

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

Concerns regarding the soundness of Policy HN01. Harborough District Council request 40% affordable housing to be provided within residential developments. Although the Policy positively allows for flexibility such as offsite provision or financial contribution, or accepting of a viability assessment for lower provision, we do not consider a requirement for 40% affordable housing to be viable. 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: 13749

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

Site Selection Methodology: It is not considered sound that sites in small villages have been excluded as they form a large proportion of the settlements in Harborough.

The 2024 SHELAA assessed our client's site 'Land to the south of Shawell Road, Swinford' as able to deliver in 6-10 years. A more accurate assessment of the site in needed to show the site to be developable within the first 5 years of plan period. It will be able to meet the identified need for 8 dwellings in Swinford and go some way in meeting the recognised capacity of Swinford. However, the Local Plan does not look to make any allocations in small villages, which we consider unsound.

Object

Representation ID: 13757

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

- Housing delivery on the site (as set out in the trajectory) is overly optimistic both in terms of commencement and build out rate. This is supported by the Lichfield 'Start to Finish Report 3'.
- The site is a cross-boundary site. Time needs to be provided for within the Housing Trajectory to account for delays which may be incurred in working with two local authorities.
- Regarding affordable housing, the Viability Report found that the site is only marginally viable when a 40% requirement is applied.
- Contamination on site could create further delays.

Object

Representation ID: 13763

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

The Housing Trajectory provides a series of commencement years for the different sites, despite the allocation requiring a singular masterplan needing to be in place for all the sites. 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 allocation area. The commencement of delivery of the allocation should commence from 2032/33 to allow for agreement in how development is brought forward. Given the lack of consideration re: financial contributions or onsite infrastructure, the site should be put back in the Housing Trajectory to allow for greater certainty and details to be provided, to ensure that the site is viable.

Object

Representation ID: 13764

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

The trajectory is overly optimistic in terms of when the site will start delivering dwellings and build out rate (Lichfield's Start to Finish Report). This should be reflected in the Housing Trajectory.
Marginal viability when providing 40% affordable housing on site and existing cumulative traffic issues, further support the need for the delivery of housing to be delayed in the trajectory 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.

Object

Representation ID: 13765

Received: 01/05/2025

Respondent: Castlethorpe Homes

Agent: Boyer

Legally compliant? No

Sound? No

Duty to co-operate? No

Housing Trajectory: If the our concerns re: timescales and delivery rate were reflected in the trajectory, there would see a total of 2,320 dwellings being provided in the plan period, 1,130 dwellings less than currently anticipated. Therefore the Council should provide further allocations in order to ensure that the housing needs of Harborough are met within the short term. The land south of Shawell Road, Swinford is a suitable site for allocation (50 dwellings) to meet some short term needs.