Regulation 19 - Proposed Draft Local Plan Submission

PNNH considers that Policy DS01 e) should be modified to allow for site specific allocations within the Small Villages and read as follows:
e) At least 350 homes on Site Allocations (Policy SA01) in Small Villages including:

Modifications to Policy SA01 are considered in our representations on that policy.

However, as proposed it is considered that the Plan has not been positively prepared, does not comply with national policy and the cumulative impacts of not planning for increased housing delivery within the Borough and also the increased unmet need from Leicester City means ultimately the delivery strategy is unsound and will ultimately fail.

If further sites were to be considered, then PNNH has a site that they are currently promoting and is available, developable and achievable, with an estimated capacity of 13 dwellings, which would include an element of policy compliant affordable housing.

The site (referred to as land off Manor Road) is described in detail within the introductory section of the attached document.

See attachment for full representations.

Policy DS01 is not legally compliant and is unsound, because it is not sufficiently justified, nor is it consistent with national policy. The succeeding paragraphs set out PNNH’s position on the matter.

As previously outlined above the Council have not met the tests of the transitional arrangements of the 2024 NPPF, in particular Paragraph 234a which requires a Plans draft housing requirement meets at least 80% of local housing need.

Housing Requirements:
Following publication of the Issues and Options (Regulation 18) consultation in January/February 2024, and subsequent change in Government, there has been a significant change in housing needs (based upon updates to the standard method set out in changes to national policy) and a ‘pro-growth agenda’ resulting on a revised NPPF (December 2024).

The 2024 NPPF introduced a new Standard Method (adopted December 2024) for calculating housing need and restored mandatory housing targets in order to deliver 370,000 homes per annum across England.

The result of the new Standard Method is that the housing need for Harborough is 723 dpa. This is greater than the proposed Local Plan stepped trajectory requirement to 2036 of 657 dpa, and 189 dpa greater that 2036-2041 requirement of 534 dpa.

Policy DS01 sets out a total housing requirement between 2020 and 2041 of 13,182 dwellings compared to the Standard Method requirement of 15,183 dwellings in the same period.

Therefore, whilst the overall housing requirement meets the requirements of Paragraph 234a the stepped trajectory does not meet the 80% requirement in the period 2036 to 2041 and therefore does not conform with transitional arrangements set out within Annex 1 of the 2024 NPPF and is therefore unsound. As published the annual requirement in the period 2036 and 2041 only meets approximately 74% of local housing need when calculated using the standard method.

Given that the emerging Local Plan does not meet the requirements of the transitional arrangements set out within Annex 1 of the 2024 NPPF, the emerging Plan should be examined under the 2024 NPPF, with the total housing requirement for the plan period being 15,183.

Leicester’s Unmet Need

PNNH has considered the effectiveness of the emerging Local Plan Update in addressing the unmet housing need of Leicester City Council.

Local Plan Paragraph 4.6 acknowledges that taking into account the district’s functional relationship with Leicester, that the Local Plan will accommodate part of Leicester city’s unmet need between 2020 and 2036; this being 123 dwellings per annum.

However, as acknowledged in the emerging Local Plan this figure was agreed as part of the Leicester & Leicestershire Authorities - Statement of Common Ground relating to Housing and Employment Land Needs which was published in June 2022 and based upon the Government’s standard method for calculating housing need at the time of preparation.

Since the publication of the Statement of Common Ground there have been significant changes in national planning policy which will impact on the future unmet need from Leicester City. The Examination of the Leicester Local Plan is still in progress and the quantum of unmet need may change because the deliverability of Leicester’s housing land.

Leicester City Council’s housing requirement over their current plan period is 1,280 dpa, and their emerging Local Plan, which is currently at examination, proposing 1,296 dpa. On the basis of the new Standard Method Leicester City’s housing requirement is currently 1,557 dpa.
3.5.14
Therefore in not taking into account any increase in unmet need for the Leicester City administrative area, then the Local Authority is at significant risk of not suitably addressing the unmet need of a neighbouring area throughout the remainder of the plan period.

The result being that the Plan as proposed is not positively prepared and is therefore unsound and also fails to meet the requirements of the NPPF and the Duty to Co-operate which expects effective joint working on cross-boundary strategic matters.
Paul Newman New Homes Land at Manor Road,

PNNH are generally supportive of the allocation of 350 homes in Small Villages within Policy DS01 and in particular the distribution of 29 dwellings to the settlement of Bitteswell.

However, PNNH are of the view that specific sites should be allocated through the emerging Local Plan to the identified Small Villages in order to provide a degree of flexibility and quick deliverability required to respond to any changing circumstances (in terms of housing need) within the plan area.

Allocating specific sites within Small Villages will ensure there are suitable and deliverable sites which can come forward over the plan period, particularly noting the emphasis the NPPF places upon the role of small and medium sized sites and the important contribution they can make to meeting the housing requirement of an area and can often be built out relatively quickly.

In this context Paragraph 70 of the 2023 NPPF states that:
Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.

Therefore, in order to ensure balanced delivery, flexibility and contingency within the overall supply of housing, additional site specific allocations for housing should be made within the Small Villages.

Many larger sites rely on the delivery of significant infrastructure prior to commencement, some of which may require public funding. PNNH has significant concerns regarding the delivery of larger sites in respect of viability, and therefore as set out above small to medium sized sites provide a degree of flexibility and quick deliverability to enable a response to any changing circumstances (in terms of housing need) within the plan area.

The Local Plan relies on the delivery of 1,200 dwellings over the plan period within the proposed South of Gartree Road Strategic Development Area, part of a larger allocation of c.4,000 dwellings including 850 within neighbouring Oadby and Wigston Borough.

In regard Strategic Developments in general their delivery as a whole is contingent upon complex infrastructure requirements including, but not limited to, highways and education provision and delivery of these infrastructure requirements on large sites can result in significant delays and also impact on viability, which results in delays in delivery.

It is noted that site specific Policy SA02 sets out the infrastructure and delivery requirements for the South of Gartree Road Strategic Development Area and these include employment land, community infrastructure, site(s) to meet the needs of travelling show people and cemetery provision, all based upon a heritage led masterplan requiring cross boundary co-operation.

Given the future relance in the delivery of the Strategic Development Area it would be practical to ensure sufficient contingency sites are available with the Borough to react to delays and complications which result in a drop in delivery and/or deliverable supply.

Therefore to provide a degree of flexibility and quick deliverability required to respond to any changing circumstances site specific allocations should be made within the Small Villages.

Whilst acknowledging that the emerging Plan makes provision for a total of 14,839 dwellings to meet a housing requirement of 13,182 dwellings it is considered that site specific allocations within Small Villages will provide greater certainty of delivery.

This includes sites such as PNNH’s interest at Manor Road, Bitteswell, which is available, developable and achievable, can respond to such change is circumstances and assist the District Council in maintain their housing trajectory.

PNNH considers that Policy SA01 should be modified to allow for site specific allocations within Small Villages in the Site Allocations Schedule.

In allocating sites , then PNNH has a site that they are currently promoting and is available, developable and achievable, with an estimated capacity of 13 dwellings, which would include an element of policy compliant affordable housing.

The site (referred to as land at Manor Road, Bitteswell is described in detail within the introductory section of this Statement. (see attachment).

The site was previously assessed through the Strategic Housing and Economic Lands Availability Assessment (SHELAA) in 2021 and is also included within the SHELAA Update 2024. The site (ref 21/8219) was considered potentially suitable, available and potentially achievable and therefore developable with the 6-10 year timeframe. A copy of the site’s proforma taken from the SHELAA is provided at Appendix 4 (see attachment).

The site is currently being promoted by PNNH, with various preliminary studies (Appendix 2 & 3 (see attachment)) being undertaken, and the site is considered to be achievable, developable and deliverable within 5 years. This updates the position from when the site was previously assessed within the 2021 SHELAA, and subsequently not reassessed within the 2024 SHELAA, despite being resubmitted by PNNH as a developer with an interest in the site.

As per Paragraph 70 of the 2023 NPPF, PNNH acknowledges the important contribution that sites of this size make towards meeting the housing requirements of an area. Therefore, they are seeking to promote it for residential development, and it is considered that the site is a suitable, available and achievable site which would contribute to meeting the housing requirement of the District.

It is therefore proposed that SA01: Site Allocations Schedule be modified to include Land at Manor Road, Bitteswell for 13 homes.

See attachment for full representations.

Policy SA01 is unsound, because it is not sufficiently justified, nor is it consistent with national policy. The succeeding paragraphs set out PNNH’s position on the matter.

Housing Allocations in Small Villages:
PNNH are generally supportive of the allocation of at least 350 homes in Small Villages within Policy DS01 and in particular the distribution of at least 29 dwellings to the settlement of Bitteswell.

However, PNNH are of the view that specific sites should be allocated within the Policy SA01: Site Allocation Schedule in regard to Small Villages in order to provide a degree of flexibility and quick deliverability required to respond to any changing circumstances (in terms of housing need) within the plan area.

Allocating specific sites within Small Villages will ensure there are suitable and deliverable sites which can come forward over the plan period, particularly noting the emphasis the NPPF places upon the role of small and medium sized sites and the important contribution they can make to meeting the housing requirement of an area and can often be built out relatively quickly.

In this context Paragraph 70 of the 2023 NPPF states that:
'Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.'

Therefore, in order to ensure balanced delivery, flexibility and contingency within the overall supply of housing, additional site specific allocations for housing should be made within the Small Villages.

Many larger sites rely on the delivery of significant infrastructure prior to commencement, some of which may require public funding. PNNH has significant concerns regarding the delivery of larger sites in respect of viability, and therefore as set out above small to medium sized sites provide a degree of flexibility and quick deliverability to enable a response to any changing circumstances (in terms of housing need) within the plan area.

The Local Plan relies on the delivery of 1,200 dwellings over the plan period within the proposed South of Gartree Road Strategic Development Area, part of a larger allocation of c.4,000 dwellings including 850 within neighbouring Oadby and Wigston Borough.

Given the future relance in the delivery of the Strategic Development Area it would be practical to ensure sufficient contingency sites are available with the Borough to react to delays and complications which result in a drop in delivery and/or deliverable supply.

Therefore to provide a degree of flexibility and quick deliverability required to respond to any changing circumstances site specific allocations should be made within the Small Villages.

Whilst acknowledging that the emerging Plan makes provision for a total of 14,839 dwellings to meet a housing requirement of 13,182 dwellings it is considered that site specific allocations within Small Villages will provide greater certainty of delivery.

This includes sites such as PNNH’s interest at Manor Road, Bitteswell, which is available, developable and achievable, can respond to such change is circumstances and assist the District Council in maintain their housing trajectory.