Regulation 19 - Proposed Draft Local Plan Submission

The Local Plan should be aligned with the adopted Scraptoft Neighbourhood Plan with development principles guided by those in the Neighbourhood Plan.

The Made Scraptoft Neighbourhood Plan which runs from 2015 – 2028 should have formed a consideration for the preparation of the Local Plan. The HDC Green Wedge Review (2024), the HDC Landscape Sensitivity Assessment (LSA) (2024) and the Scraptoft Neighbourhood Plan all recognise the importance of the high lying land and seeks to direct development to the lower lying land which is more visually sheltered and screened from longer distance views. The Neighbourhood Plan seeks to protect an Area of Separation which is significantly smaller than that proposed within the Regulation 19 Local Plan or the current Policies Map (April 2019). The proposed Scraptoft Allocation (S1) allocates development on the entirety of the Area of Separation and therefore it is disingenuous to state that ‘neighbourhood planning has been wholeheartedly embraced in the Harborough District’.

We welcome the recognition of the strong connection between Leicester City and Harborough District Council and the constraints to growth within Leicester. We therefore support housing growth on the edge of Leicester City.

Extend the Plan period by 1 year.
Extend the 80% level across the entirety of the plan period.
Increase the housing levels in the Thurnby, Bushby and Scraptoft area to reflect past under delivery and facilitate future growth for the extended plan period.

Paragraph 22 of the National Planning Policy Framework 2024 (NPPF) states that “Strategic Policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure” [our emphasis]. While this is currently the case based on the anticipated timeline within the Local Development Scheme (2025), we consider the timeframe to be extremely ambition and as such there is no room for delays in the process. It would be prudent of Harborough District Council to extend the plan period by one year to ensure there is sufficient time and allow for unexpected delays.

We also consider that in order to provide a fully robust approach to housing delivery, the housing requirements should remain at 80% (as a minimum) for the entirety of the plan period rather than just the first 16 years. This would equate to a requirement for a further 225 dwellings to be allocated to create a reliable buffer.

If both the plan period was extended, and the Plan provided for 80% of the Local Housing Need (LHN) for the entirety of the plan period, an additional 804 dwellings would be required. This under provision means that the Plan fails to fully address the housing requirement for the district within the plan period. Furthermore, it leaves very little scope should developments not come forward as expected (which was the case in the previous plan).

The development strategy throughout the Local Plan seeks to direct development towards the most sustainable locations, with the edge of Leicester being the main area for growth. While it is appreciated that the annualised housing numbers recognise some of the previous under provision, it is important to note that one of the strategic locations of growth in the 2019 Local Plan was Scraptoft North. This allocation has failed to come forward and is no longer retained as a housing allocation, resulting in the loss of some 1,200 dwellings that were due to be developed in the coming years. The proposed allocation of the 1,125 dwellings in Scraptoft merely replaces the provision previously allocated for this area of the district and therefore does not provide for further growth in this highly sustainable location. The level of development within the Thurnby, Bushby and Scraptoft area should be amended to reflect the previous growth levels and include new projected growth for this area to ensure that sufficient homes are provided in the most sustainable locations. Further development within the Scraptoft valley could provide important road links to alleviate congestion as well as bringing forward much needed facilities such as a GP surgery and sporting facilities without putting pressure on the core purposes of the Green Wedge and therefore allowing greater and more meaningful access to the countryside.

We strongly support the collaborative arrangements between Leicester City Council and Harborough District Council. It is vital that HDC help meet some of the housing needs of the city. The proximity of the Thurnby, Bushby and Scraptoft urban area and functional relationship between these areas and the city are well established. The rising house prices within these areas are the result of increasing pressure on housing requirements. It is therefore vital that HDC continues to support the growth of the City and supports its aims and objectives. While this may not be so relevant for the towns of Harborough and Loughborough, Thurnby, Bushby and Scraptoft have a clear physical connection to the city and are best placed to provide this much needed housing.

Decouple Leicester Urban Area into a standalone tier.

We strongly support the settlement hierarchy. We do however consider that there should be a differentiation between land adjoining Leicester City and that adjoining Oadby and Wigston.

Leicester is the 9th biggest city in the Country whereas Oadby and Wigston are towns. This is an important differentiation and should be supported within the development hierarchy. Leicester City is the main area for employment, shopping and higher order services and facilities. Therefore the principle urban area for Leicester should be above that of Oadby and Wigston in the development hierarchy with the housing numbers reflecting this important differentiation. The inclusion of the Oadby and Wigston development area within the first tier of the settlement hierarchy is disingenuous and hides the fact that 1200 homes are being developed adjoining Oadby and Wigston, while 1,125 homes (which is a reduction from the 1,200 homes previously proposed by Scraptoft North) are being developed in the Leicester Urban Area. These allocations have been conjoined throughout the Local Plan; however it is our opinion that for the purposes of transparency and fair representation, they should be decoupled to provide a clearer picture of what is actually being proposed.

The extent of the Green Wedge designation should be revised and sub areas C & D removed from the Green Wedge designation.

We strongly object to the Leicester / Scraptoft / Bushby Green Wedge. Please see the full assessment undertaken by Alastair Macquire CMLI which is based on the evidence provided.

Mr Macquire concludes that while it is clear that the western extent of the Leicester / Scrapatoft / Bushby Green Wedge (sub areas A & B) contributes strongly to the separation of Scraptoft from the wider urban area to the south and west, sub areas C & D are located further along the valley and set lower down in the landscape and therefore do not contribute to the separation of the settlements. Sub areas C & D make little or no contribution (weak at most) to preventing the coalescence of the settlements.

The Green Wedge fails to acknowledge the prevailing development patterns and identify growth of the urban area. In its current form, the Green Wedge seeks to curtail any further growth into the valley, however this would be contrary to the findings of the 2024 HDC Landscape Sensitivity Assessment (LSA) which forms part of the evidence base of the Local Plan. Based on the Guidance within the LSA, development along the lower valley sides, extending to the east of the city would not be at odds with the prevailing character and it is considered that sub-areas C & D would not guide development in the right areas. Reconfiguring the Green Wedge to cover the more elevated landscape, leaving the lower slopes available to assist in the delivery of housing would ensure that development on the more visible open ridge is avoided. It would also create opportunities for a high quality network of green and blue infrastructure, as well as public open space and habitat creation along Thurnby Brook.

The allocation of S1 fails to follow any defined boundaries which would be at odds with the methodology set out within the Review at paragraph 2.9. Furthermore, the Green Wedge fails to recognise the importance of Covert Lane from a recreational perspective. This sensitivity is highlighted within the LSA.
The public’s ability to access the wider countryside setting would not be compromised if sub-areas C & D were excluded from the Green Wedge.

It is therefore concluded that there is clear justification for sub-areas A & B however it is considered that sub areas C & D make weaker contribution to the objectives of the Green Wedge.

We strongly support the allocation of 125 dwellings on this site. The scheme is currently being prepared for a planning application and pre-application advice has been undertaken with Development Control Officers. Initial survey and technical assessments have confirmed that this site is capable and suitable for development of at least 125 dwellings as planned. There are no constraints to development and therefore subject to obtaining a deliverable planning permission within the next 12-18 months (outline and reserved matters), the site should be able to start delivering homes in the early years of the Plan and therefore it forms a vital part of the development strategy.

While we do not object to this allocation, it is important to note that at no point has the site been assessed for the 950 dwellings. The original SHLAA submission suggested that 698 dwellings was a suitable level of housing for the site. In order to ensure that the principles of the Green Wedge in this location are fully considered, the level of development proposed for this site is considered too high and needs further evidence to demonstrate it is achievable. While maximising the level of development is considered important, this site sits in an elevated part of the district and as such, development should be pulled away from the top of the ridge to ensure that the principles of the Green Wedge can be retained, in full, in this location. The allocation of this level of housing at S1 could mean that the site was incapable of meeting Objective e. of Policy SA04 ‘Maintaining the part of a Green Wedge identified on the Policies Map in accordance with Policy DS04’.

- Detail the level of customisation required.
- Incorporate SCB housing within Policy AP03 to allow for smaller sites
- Reduce the time period for keeping plots on the market prior to allowing them to change to market housing to 6 months.

We very much support the provision of self and custom build housing and understand that Harborough District Council is struggling to meet the level of demand for self and custom build homes. Notwithstanding this the practical implications of Policy HN05 need to be carefully considered. Research suggests that self builders are often looking for larger plots within a countryside setting rather than plots on housing estates. Policy HN05 as currently worded is unlikely to meet the demands of those on the SCB list. The requirement to keep the plots on the market for at least 18 months is likely to significantly slow the delivery of larger housing sites. It is recommended that policy HN05 is rewritten to allow larger sites to incorporated SCB plots where there is an identified need for them to do so. It is however also vital that smaller schemes for SCB plots are supported through planning policy and as such the focus should be on the delivery of SCB plots on land that adjoins the settlement boundary in small scale developments. This has proven particularly successful in other authorities where such a policy has been implemented.

If permission for SCB plots is granted on larger sites as per the current policy, these plots should be offset against the affordable housing requirements for the entire site as SCB houses offer an affordable alternative to home ownership.

Details of the level of customisation required to meet this policy should also be included. A low threshold should be set in this regard given relatively minor amendments to house plans could allow potential residents to customising their homes to meet their specific needs such as: accommodating certain disabilities, allowing for multi-generational living, home working, etc.. This will fulfil the reasons for SCB housing and meet the current gaps in the market while ensuring that the economies of scale from larger developers are passed to those wishing to customise their own homes while also achieving a comprehensive masterplan for the development.

- Combine policy with DS01.
- Remove limb 4.a.

We consider this policy to be best combined with DS01. We also consider that limb 4.a should be removed from this policy. The aims of the Green Wedge should not be to limit development but rather increase access to the countryside and as such development should not be outrightly excluded in the Green Wedge if the proposed development would not impact on the functions of the Green Wedge.