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: 13600
Received: 04/05/2025
Respondent: Richborough
Agent: Planning Prospects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The housing requirement in the policy is understated and does not reflect need; the Plan will fail to meet the minimum requirement. It deliberately seeks to avoid meeting this need. It invites an immediate review of the Local Plan if adopted. It would result in an inability to demonstrate the required supply of housing on adoption, immediately making its policies out of date. Housing growth directed to Lutterworth is inadequate, inflexible, and the Plan seeks the continuation of a previous failed delivery strategy. Changes are required to identify significantly more deliverable and developable housing sites, including in Lutterworth specifically.
Policy DS01 should be fundamentally recast. The Regulation 19 document fails to address in any tangible way how the HLP will deliver the homes needed in Harborough and its neighbouring authorities during the HLP period. As a result, it fails to meet the tests of soundness set out in the Framework. A step-change in approach including in terms of the requirement (which should be elevated so that it reflects need) and distribution (which should direct materially more growth towards Lutterworth) is required to avoid the new homes that are needed in Harborough and its neighbouring authorities not being provided over the emerging HLP period.
See attached Representations Statement.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS02 Development Strategy: Creating Jobs and Diversifying the Economy
Representation ID: 13601
Received: 04/05/2025
Respondent: Richborough
Agent: Planning Prospects Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The development of non-strategic employment land in Harborough has been slow. Continued reliance on land previously identified which cannot be relied on to deliver is inappropriate; more land is needed. The approach taken to identify and apportion the requirement for strategic employment land is problematic and understates the need in Harborough. The deliverable supply of non-strategic employment land, and the identified supply of strategic employment land, are both just less than half of the actual requirement. Consideration of further sites is required to meet the demand for local and strategic employment and help the Council achieve its policy aims.
Policy DS02 should be fundamentally recast. The Regulation 19 document fails to address how the HLP will deliver the employment land needed to meet both the local and strategic requirements during the Plan period; the shortfall in the former is over 31ha, and in the latter 138ha. As a result, it fails to meet the tests of soundness set out in the Framework. A step-change in approach including in terms of the requirement (which should be elevated so that it reflects this higher need) and distribution (to be more market responsive and flexible rather than focusing on a limited number of allocations and sites which are unlikely to deliver) is required to avoid the employment land needed in Harborough and its market area not being provided over the emerging Plan period.
See attached Representations Statement.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS04 Development Strategy: Preserving and Enhancing our Heritage and Rural Character
Representation ID: 13602
Received: 04/05/2025
Respondent: Richborough
Agent: Planning Prospects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The approach to heritage is inconsistent with national policy. The spatial expression of the Bitteswell, Lutterworth and Magna Park Area of Separation is expansive and includes the Site (west of Lutterworth). Evidence submitted here shows that carefully planned development within this Area of Separation can be achieved without compromising the relevant policy objectives around identity, distinctiveness and separation. A redrawing of the Area of Separation to allow an allocation for development of the type sought elsewhere in these representations can successfully be made whilst still maintaining the integrity of that designation.
Part 1b of the policy should be redrafted to reflect the approach in national policy. The spatial expression of the Area of Separation identified at part 2b of the policy should be amended to allow the allocation of land within the Site (west of Lutterworth) for development.
See attached Representations Statement.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy IM01: Monitoring and review of the Local Plan
Representation ID: 13603
Received: 04/05/2025
Respondent: Richborough
Agent: Planning Prospects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
These representations show the Plan should be paused so development requirements can be properly assessed and additional sites allocated to meet it. Otherwise, the Plan will need immediate review and its policies will not adequately meet requirements. Draft Policy IM01 allows for the prospect of review, but without absolute triggers, rather governed by criteria relying on the Council’s judgement (adopting SoCG, identifying “satisfactory” evidence, conducting a review). This is inadequate, unacceptable and unreliable, particularly in the context of the current Plan where the Council’s approach has explicitly been to avoid fully identifying and meeting development requirements.
The correct approach here is to halt the Plan process and undertake an exercise that seeks properly and fully to identify development requirements and allocate land sufficiently to meet them. If that is not done, then an early review policy needs to be in place that ensures a review will be progressed, rather than leaving it to the discretion of an Authority that has decided to rush through an approach to avoid meeting those requirements. That early review policy should:
- Acknowledge that the current Plan is interim;
- Commit to the production of a comprehensive new Local Plan commencing immediately upon adoption of the current Plan;
- Commit to a programme for the prompt submission for examination of the comprehensive new Local Plan;
- Require that the comprehensive new Local Plan meets the minimum development requirements for Harborough in accordance with the NPPF;
- Require the publication of annual monitoring reports on development delivery by no later than 1 April each monitoring year to provide clear evidence of progress and implementation of sites allocated;
- Require the updating of the evidence base to inform this process;
- Require that the comprehensive new Local Plan be prepared to cover a minimum period of 15 years from the date of adoption, informed by an up-to-date evidence base, and prepared in line with Government policy and statutory requirements;
- Acknowledge the implications of out of datedness if the requirements of the early review policy is not met.
See attached Representations Statement.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
Representation ID: 13604
Received: 04/05/2025
Respondent: Richborough
Agent: Planning Prospects Ltd
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
(Omission site: West of Lutterworth)
These representations demonstrate the housing requirement in the Plan is understated and does not reflect need; the Plan will fail to meet the minimum requirement. They show the deliverable supply of non-strategic employment land, and identified supply of strategic land, are both less than half the actual requirement. There is a failure to plan and make sufficient provision for development needs, making the Plan unsound. More development land is needed. The Site (west of Lutterworth) should be regarded as acceptable to accommodate employment and residential development whilst maintaining an appropriate Area of Separation and allocated accordingly.
Residential and employment requirements in Harborough are inadequately accounted for in draft Policies DS01 and DS02, and by some margin. As a result, the allocation provision made in Chapter 5 (principally draft Policy SA01) is manifestly inadequate. More land needs to be identified and allocated.
The nature of the shortfall here is extensive and fundamental. It is considered that the Plan should be paused whilst a full assessment is made of the extent of the additional development requirements and the opportunities that exist to accommodate them.
It has been demonstrated that the Site (west of Lutterworth) should be regarded as acceptable to accommodate employment and residential development. It should be allocated, and included within Policy SA01. It is suited to both employment and residential uses, or a mixture. In employment terms it is capable of accommodating strategic and non-strategic provision. The scale of the Site is also such that with careful planning and distribution of development within it very considerable opportunities will remain to preserve areas for landscaping such that an appropriate and well-functioning Area of Separation can be maintained here.
See attached Representations Statement.
