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: 13793
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Prudent for the HLP housing requirement to build in; a contingency to address Leicester's unmet needs beyond 2036 and potential wider shortfalls within the HMA, an uplift to address the acute need for affordable housing and a higher supply-side buffer (closer to 20%).
There is a clear and compelling case to test a higher housing requirements and its suggested the overall quantity of growth should be subject to further testing through the SA process.
Spatial distribution to Large Villages and to Great Glen is generally supported as being reflective of the settlement hierarchy and addressing needs close to where they arise. Allocating suitable sites in large villages would provide flexibility and contingency amongst the most sustainable locations, rather than at the lower end of the settlement hierarchy.
We consider that the following modifications should be considered to ensure the HLP’s soundness.
Firstly, the HLP should contain a clear mechanism for addressing Leicester’s unmet need beyond 2036 should this arise. Whilst a review mechanism has been incorporated, the PPG indicates that strategic policy-making authorities should cooperate to address cross-boundary matters and not defer these issues to subsequent reviews. Further land allocations or reserve sites should be identified to address Leicester’s unmet need should it arise in the current Plan period.
Secondly, the HLP and its evidence should consider whether an uplift to the housing requirement could be made, and further suitable, deliverable and sustainable sites allocated, to address the need for affordable housing.
Thirdly, the SA should consider a “high growth” scenario across the refined options, consistent with our wider observations in relation to the housing requirement. The SA process should demonstrate that more sustainable rural settlements (i.e. large villages) are accommodating
housing growth in preference to less sustainable ones. Fourthly, the approach to the HLP’s supply-side buffer should be re-considered to align with that consulted upon during the issues and options stage. A buffer of around 20% is appropriate.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS05 Development Strategy: Supporting Strategic Infrastructure
Representation ID: 13814
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
DS05 1d) We do not consider it practical or necessary to consider cumulative and cross boundary impacts between OA1 and GG1, because they will likely not be constructed in the same time period.
DS05 3. Not clear what this intends to achieve. Its requirements should be rephrased to address specific site-by-site requirements and phasing, for upfront clarity.
DS04c) Not justified, as its a statutory requirement.
DS05 4 d) The bulleted list is insufficiently focused and its not sufficiently clear that contributions should only be proportionate to address the impacts of the specific development.
In respect of Policy DS05 1. d), Sites OA1 and GG1 should not be considered as a “cluster” for assessing cumulative and cross boundary impacts. We requested that Policy DS05 1. d) (ii) is deleted.
We request that Policy DS05 3 is deleted given that it is vague, and its requirements are unclear. Any cross dependencies in infrastructure provision triggering phasing requirements should be fully set out and tested as part of the HLP’s examination.
We request that Policy DS05 4. c) and d) is deleted for plan soundness.
We request that paragraph 4.55 of the supporting text to Policy DS05 is deleted. Requiring a “Joint Infrastructure Framework” in respect of OA1 and GG1 is clearly not proportionate or justified for the reasons set out in our full representation/s.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
GG1
Representation ID: 13828
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Generally support the allocation of GG1, and the need for an Area of Separation between GG1 and OA1.
The following issues are raised about GG1 policy requirements 1,2, 3 and 9; there is no need for a discrete comprehensive masterplan, the text of SA01 should recognise that development greater than 3 storeys is unlikely, it is impractical / unnecessary to consider the transport impacts of GG1 and OA1 cumulatively, and the distance from waste safeguarding sites makes material impacts implausible.
An Agricultural Land Report, confirming the site is entirely sub-grade 3b, is provided to supplement HDC's Stage 4 Technical Site Assessment.
We support the overall thrust of Policy SA01 in proposing to allocate Land to the West of Great Glen for about 400 dwellings and associated infrastructure. The site is deliverable and experiences no fundamental legal or technical constraints. The SA process has clearly shown the overall development strategy of focusing a propriate level of growth to large villages performs against the reasonable alternatives. The proposed site allocation is in conformity with that development strategy.
We request that Policy SA01 is amended to omit references to a comprehensive masterplan as this is unnecessary given that a single developer is working to deliver the site for development.
We also request that the requirement for a heritage impact assessment be focused upon those heritage assets which are most likely to be affected and omit references to Stretton Hall and the associated heritage assets given the Council’s own evidence indicates that impacts are unlikely to occur as a result of development three storeys or less.
Based on the detailed masterplanning undertaken and information on technical constraints, the site can achieve a capacity of about 450 dwellings and request that Policy SA01 is amended accordingly.
The requirement to consider impacts on the A6 corridor and to assess the impact on this and other infrastructure cumulatively with other developments is unjustified. Any proposed development of the site should only be required to address its own impacts and this section should be deleted accordingly, as should the requirement a “coordinated approach” to walking, cycling and overall infrastructure given the significant differences between GG1 and OA1, both in terms of scale and timespans for delivery.
Finally, we request that the reference to not prejudicing the continued operation of two safeguarded waste sites be deleted. Having regard to Leicestershire County Council’s waste safeguarding maps, these are both located a distance from the site with intervening built form and other features. The facilities themselves are also limited in size and unlikely to result in any level of material impact to future occupants.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN01 Housing Need: Affordable Homes
Representation ID: 13839
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Observations are made about the following assumptions made in the Viability Report; allowance for on-site infrastructure is too high, allowance for professional fees for strategic sites is not clear, the use of lower quartile BCIS costs and that economies of scale cannot be universally assumed across an entire site.
It is also not clear how the cumulative policy burdens of the HLP have been factored into the viability appraisal.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN04 Housing Need: Supported and Specialist Housing
Representation ID: 13840
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The evidence on need is based principally on the District's ageing population, a national trend. The Written Ministerial Statement and PGG allows adoption of enhanced technical standards on an authority by authority basis based on local evidence including; accessibility and adaptability of the existing housing stock.
Policy is not currently justified by local evidence including how the threshold of 100 units and the percentage requirement relates to the overall scale of needs.
This policy is not currently justified by evidence and needs to be revisited prior to submission of the Local Plan.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN02 Housing Need: Mix of New Homes
Representation ID: 13841
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
A number of observations are made about; the appropriateness of a blanket percentage across all schemes of a certain size, its failure to contemplate a scenario of lack of demand, and its lack of provision for accomodation to be delivered as market units if an evidenced lack of demand.
The viability impact of the policy does not appear to have been assessed cumulatively with other policy burdens.
Policy lacks justification and should be reconsidered.
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN05 Housing Need: Self and Custom Build Housing
Representation ID: 13842
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Integrating self and custom-build plots within large-scale housing developments is challenging because it; is difficult to co-ordinate construction, poses health and safety risks, comes forward over much longer timeframes and is often not liable to Section 106 contributions towards infrastructure.
Self build should be encouraged using council-owned land or designating specific sites via negotiations with landowners.
Supportive of a mechanism to allow unsold plots to be built out as market housing, however 18 months is overly restrictive. Six months is adequate, with no requirement for plots to be available immediately to validly commence the marketing period.
Policy HN05 is unsound for want of justification and should be deleted
See attachment/s
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM02: Amenity and Wellbeing
Representation ID: 13843
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Generally supportive of a policy requirement to safeguard residential amenity. Development should be opposed on amenity grounds only where it causes material or significant harm to users of nearby land and buildings—not based on subjective thresholds of “acceptability.”
See attachment/s
Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM04: Landscape Character and Sensitivity
Representation ID: 13844
Received: 04/05/2025
Respondent: Davidsons Development Ltd
Agent: Marrons
Whilst generally supportive of a policy requirement to address landscape character and sensitivity, Part 1 d) of the policy refers to restoring and providing equivalent mitigation for damaged features and/or landscapes that would be damaged or degraded as a result of development. It is not clear what this element of the policy requires. It is clearly not practical, viable or developable to expect new development to restore or compensate for the loss of landscapes themselves as all new development will, by its nature, have a landscape impact.
Landscape features lost can be provided for where practicable.
Part 1 d) of Policy DM04 is deleted for soundness
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