Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
1.1
Representation ID: 13499
Received: 30/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
Having read through the documents I fully support the representations submitted by Willoughby Waterleys Residents’ Association. These show that the Harborough New Local Plan is unsound to the effect that modifications are unlikely to result in the plan being made sound.
Having read through the documents I fully support the representations submitted by Willoughby Waterleys Residents’ Association. These show that the Harborough New Local Plan is unsound to the effect that modifications are unlikely to result in the plan being made sound.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.1
Representation ID: 13503
Received: 23/05/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
I have seen and fully support the representations submitted by Willoughby Waterleys Residents' Assocation. I consider that the Harborough New Local Plan is unsound for the reasons set out in those representations. Those reasons are so significant that modifications are very unlikely to result in the Plan being made sound.
I have seen and fully support the representations submitted by Willoughby Waterleys Residents' Assocation. I consider that the Harborough New Local Plan is unsound for the reasons set out in those representations. Those reasons are so significant that modifications are very unlikely to result in the Plan being made sound.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.1
Representation ID: 13504
Received: 22/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
I have seen and fully support the representations submitted by Willoughby Waterelys Residents' Assocation. I consider that the Harborough New Local Plan is unsound for the reasons set out in those representations. The reasons are so significant that modifications are very unlikely to result in the Plan being made sound.
I have seen and fully support the representations submitted by Willoughby Waterelys Residents' Assocation. I consider that the Harborough New Local Plan is unsound for the reasons set out in those representations. The reasons are so significant that modifications are very unlikely to result in the Plan being made sound.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.1
Representation ID: 13511
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
Plan not sound as it doesn’t take into account the consideration of the cancellation of the A46 south east by pass of Leicester.
Don’t think calculation of necessary housing requirements adds up correctly. The buffer is unnecessarily overstated.
Consideration of Willoughby Waterleys Residents' Association suggestions of alternative route to east of Leicester which would be shorter and cheaper. This doesn’t seem to have been given any thought despite repeated representations to HDC.
Look again at the number of house that are really needed.
Plan not sound as it doesn’t take into account the consideration of the cancellation of the A46 south east by pass of Leicester.
Don’t think calculation of necessary housing requirements adds up correctly. The buffer is unnecessarily overstated.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.1
Representation ID: 14057
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan overstates housing need, relies on unviable and likely undeliverable strategic sites and has not considered alternative more sustainable strategic alternatives of development in the sub-area.
The Plan is so fundamentally flawed it cannot be rectified by Modifications.
It is the view of WWRA that the issues raised in our consultation are so significant, that Modifications are not likely to result in a “Sound” plan.
In particular the lack of consideration of Alternative Spatial Strategies, which subsequently impacts on the allocation of unmet housing need, and the concentration and reliance on unviable and hence undeliverable
large-scale development, is fatal to the soundness of the Plan.
Concentrating development to the south and east of Leicester has not been demonstrated as the most sustainable option. It relies on massive infrastructure requirements, which are still not fully identified or costed. Those costs’ inclusion in any site’s viability will make deliverability even more uncertain and unlikely than already assessed.
The Government’s clear objective is to achieve a greater level of housing delivery in pursuit of its overall target to build 1,500,000 houses by 2029. We have not been convinced that Harborough DC will be able to play its part, based on the evidence in the draft Local Plan.
When looked at in total, the whole strategy of allocating development as shown in the SGP, must be reviewed, particularly considering the fundamental change as a result of scrapping the possibility of support for the new A46 Expressway. It is absolutely critical that the delivery of ALL necessary strategic infrastructure is certain before ANY strategic development is allocated.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
3.9
Representation ID: 14061
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
The County’s Authorities meet regularly through the Members’ Advisory Group, to agree where possible, County wide policy. This resulted in the SGP in 2018 as well as a number of Statements of Common Ground over recent years. (Not necessarily in a timely manner! HDC took 18 months to sign the SoCG on unmet housing need).
The HMA authorities have failed to demonstrated that they have given serious consideration to any Alternative Spatial Strategies. This became all the more significant when in 2020 consideration of the main plank of the SGP, the Expressway, was dropped from consideration and no thought has or was given to a change of strategy.
This failure is so significant we do not consider that the duty to co-operate can be deemed to have been complied with.
This failure to give serious consideration to any Alternative Spatial Strategies is so significant we do not consider that the duty to co-operate can be deemed to have been complied with.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
1.8
Representation ID: 14063
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
In order to meet the transitional arrangements of the new NPPF, there has been undue haste to reach the Reg 19 stage, before 12th March 2025. This rush has contributed to the lack of consideration of alternative spatial strategies.
This is further evidenced by the fact that there is no evidence supplied to demonstrate how the required (predominantly transport) infrastructure is to be financed, provided and delivered (highlighted by LCC Local Transport Authority response).
Furthermore the 2022 SoCG allocating Leicester's unmet need is out of data (based on 2024 NPPF housing targets) and the SGP has no relevance (should have been reassessed 5 years ago when the A46 Expressway was withdrawn.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS01 Development Strategy: Delivering Homes
Representation ID: 14066
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
We consider that the Plan proposes more housing than is reasonably required by this definition in the NPPF. It is our view that the numbers stated in the Plan as being required, are overstated by over 1200 homes.
It is WWRA’s contention that the new method of calculating Housing Need in the 2024 NPPF is exactly that and consequently the allocation of unmet need reflected in the SoCG should be re-tested. Particularly given the significant reduction in Leicester City’s housing requirements and subsequent reduction in unmet need by over 10,000 homes. The 2022 SoCG consequently should be considered to have no relevance.
In our view that the Plan has not been Positively Prepared.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
4.2
Representation ID: 14067
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
There has been no evidence presented, showing consideration of alternative spatial strategies. WWRA’s alternative spatial strategy in the sub-area warrants serious consideration and there has been none as far as we can see. The commitment is to the non-statutory SGP which is flawed without the Expressway or an alternative proposition. This is evidenced by the following extract from the County Council’s consultation response and adds weight to our argument that the Plan is not soundly Justified.
It is WWRA’s contention that the lack of consideration of alternative strategies by The HMA and HDC is significant and affects the soundness of the Plan. This together with the lack of evidence justifying the chosen strategic locations to the south and east of Leicester means the draft Plan cannot be considered to be sound from a justified point of view.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
Representation ID: 14068
Received: 28/04/2025
Respondent: Willoughby Waterleys Residents’ Association
Legally compliant? No
Sound? No
Duty to co-operate? No
We have grave reservations over the viability of strategic sites, which questions the deliverability of strategic sites. This is also picked up by the Viability Assessment (particularly re: S1 and O1 [OA1]).
The summary of the uncertainties of two of the bedrock sites in the Viability Assessment is damning. The details from Landowners on minimum land values appear still not to have not been shared. The Report is clear that allocations should not be made until details they have done so. We have also highlighted weakness and omissions in the Viability Assessment, demonstrating that major strategic sites are not going to be policy compliant (affordable housing at 40% will not be delivered and sites may not be delivered at all, once yet unidentified transport infrastructure is identified.
Major uncertainty over viability and delivery over the allocated strategic sites, therefore means the whole Plan cannot be considered to be Effective.
See attachment for full representation document.
