Regulation 19 - Proposed Draft Local Plan Submission

N/A

Support the Vision of the plan, particularly where it seeks to offer a range of housing options. Whilst development of new homes is mainly focused around areas near Leicester and the Borough of Oadby and Wigston, the vision sees a role for other locations. It is important that the whole District benefits from the development of new homes, where proportionate housing growth will still be sustainable.

The land identified at Fleckney should be allocated for housing development in the plan.

An additional allocation of land south of Kilby Road (East) (Site Reference 21/8086) at Fleckney should be included in the plan and will go some way to address the deficiency in the housing requirement, support early delivery of new homes in the Plan period.
The site is under the control of Catesby. It is a logical extension to the village, a sound allocation and is suitable, available and achievable to contribute to the need for housing identified within the Plan.
Fleckney is a Large Village Settlement. Its assessment within the SHELAA 2024 Update is positive and it is unclear as to why it has been rejected in favour of another site in the village. The assessment confirms that Fleckney is a sustainable location for growth. Access to the site can be achieved, the site is suitable for development, available and achievable.
Mention is made of Public Rights of Way, and advocates their retention.
The site is shown to have a potential for 166 dwellings within the SHELAA, with Catesby’s assessment closer to 150. Such an allocation would still be broadly consistent with the strategic growth hierarchy. A vision document has been prepared for the site which shows how the site can deliver a positive high quality development to the locality with a mixed range of new homes including affordable homes, including the following principles;
• Maintaining a landscape led frontage and gateway entrance to Fleckney through provision of a green around the site entrance and a landscape buffer to the western boundary of the site.
• Creating a series of public open spaces and greens throughout the development offering areas for biodiversity and landscape enhancement, as well as public spaces for leisure use and children’s play.
• Tree planting within streets and open spaces will provide enhanced public realm and filtered views both within and towards the site.
• Providing wide landscape, open space corridors around the existing public rights of way and bridleway.
• Surface water drainage ponds to be placed around the lowest topographical points of the site within public open spaces and combined with conveyance swales located within green corridors within the body of the development.
• Children’s play features can be included within the extensive open space network.
• All site boundaries will all be enhanced by new landscape buffer planting, supporting biodiversity,
landscape integration and protecting the amenity of neighbouring residential properties.
• A new site access in the form of a ‘T-Junction’ will be created from Kilby Road. An access can also be formed from Priest Meadow if desirable.
• A new street through the site will provide access to a hierarchy of side streets, lanes and private
drives. All streets, and particularly the main street will contain tree planting.
• A range of new leisure footpath routes can be looped around the site, and connecting to the existing
footpath routes, supporting health and well being objectives. Routes will also support access towards
the adjacent bus stops, local facilities, and services within Fleckney.
• Potential to deliver a range of children’s play opportunities through formal and informal features within
the extensive open space network.
• Extended public open space provision for the village with new footpath routes throughout and connected with existing public footpath and bridleway routes.
• 40% affordable provision on site in a mix of types tenures and sizes meeting housing demands in the
area.
• Pedestrian connectivity through establish footpath routes
• Existing hedgerows retained and integrated into green infrastructure which will form a large
component of the development in line with Policy
• New extensive open space and landscaped areas which will be multifunction, comprising areas managed for sustainable drainage and ecology gains as well as recreation opportunities extending existing facilities adjacent to the site
• The integration of these existing landscape features creates a landscape led structure for the whole Site, whilst significant areas to the edges will include new planting, surface water attenuation areas all adding to biodiversity value.
The Site is an immediately available and developable opportunity to accommodate new housing supporting
growth to meet the housing needs. It is in a sustainable location for this scale of growth.
The Site represents a straightforward opportunity for new housing with no undue constraints to development.

The land identified at Houghton on the Hill should be allocated for housing development in the plan.

An additional allocation of land south of Uppingham Road (Site Reference 21/8047) at Houghton on the Hill should be included in the plan and will go some way to address the deficiency in the housing requirement, support early delivery of new homes in the Plan period.

The site is under the control of Catesby. It is a logical extension to the village on the western side, adjoins the existing edge of the village and enclosed by new housing recently constructed to the south – it is a sound allocation and is suitable, available and achievable to contribute to the need for housing identified within the Plan.

Houghton on the Hill is a Medium Village Settlement. The site’s assessment within the SHELAA 2024 Update is positive and it is unclear as to why it has been rejected in favour of two other site in the village. Those allocated sites in Houghton are objected to. The land north of Uppingham Road as allocated is more open, and less well related to the village, more of which is located south of Uppingham Road.

The land allocated to the south of the village is in a sensitive location, adjacent to the conservation area and in the setting of heritage assets. The Catesby site is better related to the settlement and has the ability to provide for a more sympathetic approach to the village, better resolving the existing housing edge of those properties off Deane Gate Drive.

The SHELAA assessment confirms that Houghton is a sustainable location for growth. Access to the site can be achieved direct from Uppingham Road, the site is suitable for development, available and achievable.

Mention is made of the HSE Major Hazardous Facilities, but these only affect the western extent of the site which in any event would be open and landscaped, and ensure a proportionately scaled development for the village.

The site is shown to have a potential for 105 dwellings within the SHELAA. Such an allocation would still be broadly consistent with the strategic growth hierarchy. The site can be deliver a positive high quality development to the locality with a mixed range of new homes including affordable homes, including the following principles;
• A landscape led frontage and gateway entrance to the village through provision of a green infrastructure containing the western boundary of the site.
• Creating a series of public open spaces and greens throughout the development offering areas for biodiversity and landscape enhancement, as well as public spaces for leisure use and children’s play.
• Tree planting within streets and open spaces
• Surface water drainage ponds to be placed around the lowest topographical points of the site within public open spaces and combined with conveyance swales located within green corridors within the body of the development.
• All site boundaries will all be enhanced by new landscape buffer planting, supporting biodiversity,
landscape integration and protecting the amenity of neighbouring residential properties.
• A new site access in the form of a ‘T-Junction’ will be created from Uppingham Road.
• A new street through the site will provide access to a hierarchy of side streets, lanes and private drives. All streets, and particularly the main street will contain tree planting.
• Routes will also support access towards nearby bus stops, local facilities, and services within the village
• 40% affordable provision on site in a mix of types tenures and sizes meeting housing demands in the area.

The Site is an immediately available and developable opportunity to accommodate new housing supporting
growth to meet the housing needs. It is in a sustainable location for this scale of growth.

The Site represents a straightforward opportunity for new housing with no undue constraints to
development.

The Plan should make a clear commitment to an early review to accommodate future housing needs.

Context to comments set out here can be taken from representations made elsewhere here in respect of housing requirement of the plan and the duty to co-operate.

First and foremost, the plan does not meet the requirements of paragraph 236 of the Framework which states that "if the housing requirement in the plan to be adopted meets less than 80% of local housing need the local planning authority will be expected to begin work on a new plan, under the revised plan-making system provided for under the Levelling Up and Regeneration Act 2023 (as soon as the relevant provisions are brought into force in 2025), in order to address the shortfall in housing need. The housing requirement of the plan is made up of a 534 dwellings for Harborough and 123 for unmet needs from Leicester. The calculation using the former standard method of 534 is only 73.4% of the new standard method figure of 723 dwellings per annum. The policy should highlight the need for an immediate review. In order to be at least 80% of the new LHN calculation, the plan requirement for Harborough should be at least 580 dwellings, which over the 21 year plan period would be a further increase of 966 dwellings.

Secondly, Leicester are making a commitments in their plan to an early review. The plan is short of the 15 year plan period, housing needs for Leicester are significantly increasing and they are again unlikely to be able to meet their needs within their administrative area. The policy suggests a review, but only if needs are 'significantly greater'. The terms here are too vague. The policy should give a clear commitment to a review.

Notwithstanding the provisions of the new NPPF, the Local Plan should recognise that 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 increases from this current plan requirement of 534 dpa to 723 dpa, an increase of some 35.4%. Over a new minimum 15 year plan period this would amount to an additional need of some 2,835 dwellings. In the absence of an early review, making provision for this additional unmet need will be significantly delayed.

The policy should include for circumstances where policy would be out of date, including in relation to housing land supply where a tilted planning balance should apply.

The policy sets out circumstances where development may be permissible within or adjoining settlements in addition to the allocations within the plan. The policy could be important to maintain supply over the plan period depending on changing circumstances. Support is given to development adjoining settlements in certain circumstances including for example where it is meeting a need in a Neighbourhood Plan or where delivery has fallen short of the need identified in the plan. More generally the policy would be an opportunity to incorporate the tilted planning balance from the Framework where policy could be out of date at a future point, including in relation to housing land supply.

The policy should include for circumstances where policy would be out of date, including in relation to housing land supply where a tilted planning balance should apply.

The plan should include a critical review of commitments in order to establish the clear residual requirement to be allocated.
A five year supply calculation and trajectory of sites and plan requirement delivery over the plan period should be provided and consulted upon.

This Table (Table 2) is important in that it sets out the components of housing land supply to meet the housing requirement of the Plan. The Table calculation nets off commitments and completions as of March 2023, creating a residual housing requirement which is then made up from settlement hierarchy distribution allocations as well as an allowance for windfall. Commitments amount to circa 5,000 dwellings, yet there is not list of these commitments, nor any testing of delivery expectations.

Whilst the Council's exceedance of the suggested requirement is welcomed in principle, the plan needs a trajectory and a 5 year supply calculation to show it will deliver over plan period.

The Framework describes the purpose of the planning system to contribute to the achievement of sustainable development. There are three overarching objectives which are central to the achievement of sustainable development: economic, social and environmental.

The economic objective is to "help build a strong, responsive and competitive economy by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure" [Paragraph 8, NPPF).

Plans are required to be prepared positively and in a way that is aspirational but deliverable, and ensure that strategic policies look ahead over a minimum of 15 years from adoption in order to anticipate and respond to long term requirements and opportunities such as those arising from major improvements in infrastructure. Strategic policies include the scale and quantity of development and making sufficient provision for housing (including affordable housing), employment, retail, leisure and other commercial development alongside infrastructure and community facilities.

The following must be addressed;

The contribution from "Commitments" should be critically assessed to ensure they are genuinely expected to be delivered though the plan period. This is also vital given the need to demonstrate a 5 year supply position on adoption

The contribution from previous Allocations not yet developed also needs to be critically reviewed. The draft Plan essentially rolls forward a number of allocations, and whilst many may well have the ability to deliver, the Council need to critically assess this source which have yet to gain planning permission.

A trajectory needs to be prepared and consulted upon

A 5 year supply position assuming adoption needs to be prepared and consulted upon

The above speaks to issues around consistent delivery but also required provision of a range of smaller and medium sized sites as well as a choice and range of sites. These sites have the potential to maintain supply in the shorter and medium term whilst bigger sites can take longer to deliver. A trajectory for site delivery is important to ensure delivery over the plan, including where it is noted that some sites in commitments are carried forward and potentially should have been delivered to date.

The plan should include a critical review of commitments in order to establish the clear residual requirement to be allocated.
A five year supply calculation and trajectory of sites and plan requirement delivery over the plan period should be provided and consulted upon.

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 would 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.

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.

The Local Plan needs to align to the Leicester Plan and commit to an early review in order to address unmet housing needs from Leicester, in line with a similar commitment in the Leicester Plan.

The Plan needs to identify which sites are meeting the needs of Leicester and which are for the District’s needs, noting that it is only 123 dpa of the Local Plan housing requirement which is for the needs of
Leicester.

Collaborative working with partner organisations on strategic cross boundary matters is a key matter for this Local Plan given the challenges which Leicester faces to meet its full housing needs within its administrative boundary. Harborough District's physical relationship and proximity to Leicester mean that there are clear opportunities for housing which will more be meeting the needs of Leicester than they will be meeting the wider needs of Harborough. The plan recognises cross boundary unmet housing needs and reflects those within the plan with an increase in the housing requirement to 2036 of 123 dwellings per annum. Reference is made to the Duty to Cooperate Statement which forms part of the evidence base and which identifies the strategic cross boundary issues the Council have been working on with each of our partner organisations, the methods deployed to collaborate on an ongoing basis and the outcomes of that collaboration. The Statement seeks to demonstrate that the Council have met their responsibilities under the Duty to Cooperate however of principal concern are the following;

1. The approach to the Duty to Cooperate within this plan doesn't align to the Leicester Local Plan where the Inspectors examining that Plan in their 6th January 2025 interim findings letter has raised concerns that the Leicester Local Plan will only run for a period of 11 years to 2026 from adoption. The submitted Leicester Local Plan runs to 2036, meaning that, on adoption, there would only be around 11 years of the Plan period remaining, when paragraph 22 of the National Planning Policy Framework (NPPF) expects strategic policies to look ahead a minimum of 15 years from adoption. Extending the Plan period for the cross-boundary strategic planning has implications for Harborough and has consequences for all the surrounding boroughs and districts. However, in light of the short Plan period, the 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 seek to address this in Policy IM01 which highlights circumstances which may trigger a review but concerns are expressed elsewhere in these representations about the wording of that policy. In all other circumstances, the Council in fact suggest (wrongly - see below), that the plan makes provision for at least 80% of Local Housing Need calculated under the new standard method and therefore expressly don't need to undertake an early review in line with provisions of the new Framework. Those 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.

2. The Plan does not state which of the allocated housing sites specifically address the needs of Harborough (534 dpa) and which meet the unmet needs of Leicester (123 dpa to 2036). Without such an understanding it is difficult to understand the way the plan is meeting the different locational need.

Paragraph 35 of the Framework sets out the tests of soundness and establishes that 'Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are 'sound' if they are Positively prepared - providing a strategy which as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet needs from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.

The Local Plan needs to align to the Leicester Plan and commit to an early review in order to address unmet housing needs from Leicester, in line with a similar commitment in the Leicester Plan.

The Plan needs to identify which sites are meeting the needs of Leicester and which are for the District's needs, noting that it is only 123 dpa of the Local Plan housing requirement which is for the needs of Leicester.