Full text:
Criterion 1 of the Policy which suggests that the housing requirement for Harborough District is 13,182 between 2020 and 2041. And that the annual housing requirement is 657 homes per year between 2020 and 2036, and 534 homes per year between 2036 and 2041. The overall housing requirement however should be increased or at least confirmed as a minimum figure to ensure it fully aligns with the Government's objective to boost the supply of homes and ensures that a sufficient amount and variety of land comes forwarded where it is needed and the specific housing needs are met.
The Government has never been more concerned about housing delivery and addressing the lack of housing supply. The new Government has retained the commitment to deliver 300,000 new homes in England per year, many of the reforms that have taken place to planning are focused on understanding housing land needs, supply and delivery. The approach is to ensure that housing delivery is used as a tool to positively support and ensure delivery of the homes that people need in line with the Government's objectives to boost supply to significantly greater levels than seen in the past. The Government describes the current delivery of housing as a crisis and one which links to economic growth objectives, critical to the economy of the country as a whole.
The Government has introduced a new calculation as the standard method for calculating housing need. Whilst this Local Plan for Harborough is progressing under transitional arrangements and therefore under the former NPPF, it is noteworthy that for Harborough, the calculation of Local Housing Need as a minimum figure increase from this current plan requirement of 534 dpa to 723 dpa, an increase of some 35.4%. This is a significant increase - it highlights the clear direction of travel in respect of housing need, and where this Local Plan has the ability to plan for more than the minimum under the previous NPPF, it gives some clear, proactive justification to increase the housing requirement in the plan to more than minimum at a time of a housing crisis and support earlier delivery. Planning for a significantly greater housing requirement, will also increase the level of affordable housing which we mention further below.
This is in circumstances where the Plan housing requirement proposals is actually looking to reduce housing growth in the District from that within the previous Local Plan which had a housing requirement of 557 dpa. At a time of a national housing crisis, significant evidence of need (which are actually increasing), this is a plan which takes a negative approach to planning for housing, rather than embracing and planning for a step change increase in housing delivery, is actually going backwards and reducing housing delivery compared to the previous Local Plan. This is not a positively prepared plan.
It is important to recognise that the development of new housing will bring forward additional economic benefits to the area. The relationship between economic performance in an area and housing is complex, but having the right quantity, quality and balance of housing in an area is necessary for economic growth. This is recognised within the Framework, paragraph 82. The development of new housing can therefore support local economic growth, both through direct job creation through the construction phase of the scheme, but also through the increased population which will increase sustainable local jobs from the increased demand for goods and services. This provides an important sustainable development opportunity.
The government has linked new housebuilding to economic growth objectives - the HBF has reported on "The Economic footprint of house building in England and Wales", which shows that housebuilding in England and Wales was worth £38bn a year, supporting 700,000 jobs. House building activity contributes economically in different ways including providing jobs, tax revenues and contributing funding for local infrastructure and communities. House building supports the economy in a wider sense through being a driver for economic growth; delivering jobs and economic value; supporting labour market mobility; creating skills and employability; enhancing place competitiveness; creating quality of place and reusing brownfield land. An important conclusion of the report and the wider economic benefits is that a healthy, well- functioning labour market requires a good supply of housing that is affordable for local people to enable them to move jobs freely and match up skills supply with employer demand. A dysfunctional housing market can inhibit labour market mobility, in turn stifling economic growth.
Planning for a significantly greater housing requirement, will increase the level of affordable housing. Affordable housing need is significant where the 2022 Housing and Economic Needs Assessment (HENA) identifies and annual affordable housing need for 321 dp for Harborough (some 60% of the overall housing requirement in the plan). Principal delivery will be through and alongside the delivery of market housing - the housing requirement figure has not been increased to address the affordable housing need identified - a higher housing requirement will deliver more affordable homes and the minimum housing requirement should be increased further to address affordable needs. Affordability adjustment is important to ensure that the minimum housing need also addresses affordability of homes. Settling for a position which would deliver only a small proportion of the affordable housing need is unacceptable and not sound. PPG confirms that where recent assessments of housing need are significantly greater than the outcome from the standard method, authorities will need to take this into account when considering if it is appropriate to plan for a higher level of need. The is noteworthy given that the affordable housing requirement within the plan is only 40% such that it is unlikely that the level of affordable housing need will be met. There is also some likelihood that the viability of some sites that may mean they are not viable in delivering full policy requirements for affordable housing, again suggesting that the delivery of affordable homes will be less.
There is no evidence to suggest that the District would not be able to deliver higher levels of housing and where permissions have been granted a track record in positive annual rates of delivery. PPG confirms that that there may occasionally be situations where previous levels of housing delivery in an area are positive, authorities will also need to take this into account when considering if it is appropriate to plan for a higher level of need.
Further and finally as highlighted above, the plan doesn't align to the Leicester Local Plan where Leicester Council are proposing to commence an immediate review of the Plan following its adoption to address development needs beyond 2036, and has agreed to set this out as a policy commitment in the Plan. Harborough District do not commit to such a similar early review. The needs of Leicester which will be re-calculated under their review will be significant, noting that the standard method for Leicester increases their housing need from 1296 dpa to 1580 dpa. It will also be the case, that without administrative boundary changes, the ability to accommodate this need will be even more constrained and reliant upon neighbouring authorities. A proactive approach to positively plan for housing in Harborough would be to recognise this clear issue and increase the minimum housing requirement.
The Framework (paragraph 61) is clear when determining the 'minimum' number of homes to be planned for policy and guidance is also clear that the standard methodology is a starting point for preparing the housing requirement. The PPG explicitly states that the standard methodology does not produce a housing requirement figure and the above points to clear factors which suggest the housing requirement in the plan should be higher.
There are a number of factors which suggest that the minimum housing requirement of the plan which is merely a starting point, should be increased including;
1. The national housing crisis
2. The known increase in housing need under the new standard method which highlights the clear direction of housing needs increasing
3. That the plan is actually planning for a reduction and scaling back of housing delivery compared to the previous Local Plan
4. The potential to delivery greater economic benefits and a time of economic growth needs
expressed by government.5. To support the delivery of more affordable homes and make it more likely that full affordable housing needs will be met
6. In acknowledgement of the opportunity to delivery with a District which has the ability to delivery growth
7. In acknowledgement of the committed early review of the Leicester Plan and its significant increases in housing need which cannot be met in its administrative area.
In this context, it is essential that the new plan provides for an appropriate level of housing. Government policy is advocating a step change in the delivery of new housing and the Framework sets out to boost significantly the supply of homes and ensure that a sufficient amount and variety of land can come forward where it is needed. The level of housing now being planned for in the Local Plan should be increased above the proposed 657 dwellings per annum as it does not align with the national objective to boost the supply of housing and support the national objectives to build more homes.
Criterion 2 of the Policy sets a broad distribution of development across the District. Of the 13,182 housing requirement of the plan, some 1968 dwellings are for unmet needs from Leicester (123 X 16 years to 2036), with 11,214 dwellings for Harborough's needs. It is unclear from the Plan which sites precise meet the Leicester need although it is noted that seemingly an higher provision of some 2,450 dwellings is set out in sub criterion a) seemingly related to the Leicester Urban Area. This location gets the largest single proportion. The Market Towns see a total of 1,670 dwellings, with 1500 to Large Villages. It is not completely clear as to the nature of and reasoning for these percentage splits, in circumstances where there are a number of locations which are clearly sustainable for growth as set out in the accompanying topic paper including the January 2025 Settlement Hierarchy Assessment. The hierarchy is not one which has many layers, with the Main Towns only being Market Harborough and Lutterworth, with then the Large Villages next in the hierarchy, but with a fairly limited role, comparatively. There seems to be little consideration of the location of some of the settlements comparative to others where some settlements could have a greater roles which they are in fact very close to higher order settlements or not in fact distant from the edge of the Leicester Urban Area.
Within the broad distribution, specific dwelling allocations are identified for settlements. Again there is little in terms of transparency and reasoning for the split. We note for example that Fleckney which gets only an allocation of 150 dwellings, in fact scores and ranks equally to Great Glen in the Hierarchy Assessment, but yet Great Glen sees an allocation of 400 dwellings. Broughton and Kibworth are defined as large villages like Fleckney yet get a housing allocation of 475 dwellings, 216% higher than Fleckney. There is clearly evidence to support a greater role for Fleckney in the delivery of new homes.
In respect of medium villages, the allocated numbers are quite modest, with some greater potential still within these settlements and many score well even comparative to large villages and there are more of them.
More generally, the distribution as set out does appear very prescriptive. The approach shouldn't rule out the potential exceedance of this distribution in empirical terms, where development comes forward which is still sustainable. They should not be seen as a cap or upper limit, especially if need is evident, and proposals don't offend the overall strategic hierarchy. This should be explained in the text.
The minimum housing requirement of the plan which is a starting point and should be increased to reflect the national housing crisis, the clear direction of housing needs increasing, deliver greater economic benefits and a time of economic growth needs expressed by government and to support the delivery of more affordable homes. It also align to expected early review of the Leicester Plan and its significant increases in housing need which cannot be met in its administrative area. The suggested distribution of housing should be revisited, clarifying the way the plan meets the calculated unmet need from Leicester, and better reflecting opportunities within settlements. The distribution should be explained further to ensure its not seen as a cap to otherwise sustainable development proposals coming forward.