Regulation 19 - Proposed Draft Local Plan Submission

Object

Representation ID: 13838

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy DS01 should be modified so that the housing requirement reflects the higher growth option and incorporates Leicester’s Unmet Need until the end of the plan period rather than until 2036.
The plan should be supported by an updated Statement of Common Ground between the Leicester and Leicestershire authorities which apportions the unmet need from Leicester beyond 2036 taking account of the authorities progressing under the transitional arrangements such as Harborough District Council. Or an interim position should be agreed between the authorities to demonstrate that the existing agreed SoCG housing figures meet the needs of the Housing Market Area based on the pre- 2024 NPPF change to the standard method, including the unmet need from Leicester and if so agree to carry these figures forward beyond 2036 until further work is complete to confirm the scale of unmet need.
The plan period should be rebased to 2024 or potentially 2025 and the plan period extended by at least a year.
Additional growth should be provided at sustainable locations such as Kibworth.

Object

Representation ID: 13867

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The site selection process set out in the Sustainability Appraisal is unclear and requires further explanation.

Policy SA0 1is not positively prepared or justified. Policy SA01should be modified to include Land at Wentworth Close as an allocation for residential development as it is a site that is one of the best performing sites within Kibworth against the Sustainability Appraisal criteria.

Object

Representation ID: 13868

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HN02 states proposals for residential development will deliver an appropriate mix of housing types, tenures and sizes considering the latest evidence on housing needs in the district published by the Council unless it can be demonstrated to the satisfaction of the Council that an alternative mix of homes is appropriate.

It is considered that the policy should allow for consideration to be given to other factors in negotiating the most appropriate mix for individual sites. This should include viability, design considerations and the character of the area and be flexible to deal with the individual
circumstances of sites.

Policy HN02 also states all homes will be expected to meet accessible and adaptable M4(2) Building Regulations and all major residential development sites will be expected to provide a minimum of 5% of market homes meeting Building Regulations technical standard M4(3)A. Additionally, a minimum of 10% of affordable homes must meet standard M4(3)B.

These standards are set out in the Building Regulations therefore is it not necessary for planning policy to cover these matters as any requirement will be superseded by changes to Building Regulations. The Government Response to ‘Raising accessibility standards for new
homes’ sets out that the proposal is to mandate the M4(2) requirement in Building Regulations as a minimum for all new homes. This would be implemented through the Building Regulations.

In addition, there can be significant challenges of delivering wheelchair adaptable and/or accessible housing therefore the policy should consider any site constraints that in some cases may not make it practical to accommodate these requirements, for example, flooding
or site topography as outlined at Paragraph: 008 (Reference ID: 56-008-20160519) in the Housing: Optional Technical Standards section of the Planning Practice Guidance.

Support

Representation ID: 13875

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Although our client supports the principle of self or custom build (CSB) plots, it is considered that the policy approach should be refined and supported by robust evidence.

Evidence suggests that since the Council introduced a joining fee the number of registrations has dropped. No use of secondary data.

There is no clear rational for the threshold of 40 dwellings for qualifying developments nor the percentage provision of at least 10% sought. The choice of threshold and level of provision sought are considered potentially onerous.

The Local Plan Viability Appraisal has not specifically assessed the impacts of CSB plots delivered with larger residential schemes as it considers that the provision of CSB plots is a deliverability rather than viability matter.

There is no consideration of the impacts of unsold plots. Also 18 months is far too long and impractical for some sites and therefore it is suggested that this should be shortened to 6-12 months.

The Council’s policy approach should be realistic to ensure that where self / custom build plots are provided they are delivered and do not remain unsold. no ambiguity.

Support

Representation ID: 13876

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Policy AP01 sets out the proposed settlement hierarchy made up of five tiers with the Urban Areas at the top and Large Villages (including Kibworth) in the third tier. This hierarchy is supported as it reflects the evidence of sustainability and the important role and function of the Large Villages in the district.

The reclassification of Kibworth as a Large Village is supported as it has a good range of important and supporting services and facilities that meets the day-to-day needs of residents and serves surrounding rural communities. In addition, it has regular bus services
to Leicester, Market Harborough, Northampton to provide sustainable modes of transport to larger settlements in the district and beyond. Alongside the services and facilities, it has a range of employment opportunities within one Key Employment Area and one General Employment Area, which are defined and protected in the current Local Plan. Land south and west of Priory Business Park on the northwestern edge of the village has planning permission
for employment uses with development underway.

The policy sets out that in addition to the sites allocated in Policy SA01, development will be permitted on land adjoining the existing built-up areas of settlements in Tiers 1 to 5 of the settlement hierarchy where this meets requirements certain criteria. This includes criteria (f) that the development relates to a settlement in Tiers 1 – 4 of the settlement hierarchy and is necessary to meet strategic housing need established in Policy DS01 where net homes delivered against the number of homes required falls below 85% in the previous three-year period’.

This policy approach is supported as a pragmatic approach to the potential to need additional sites in the plan period outside the allocations and provides the Council with a policy framework within which to assess speculative applications.

It is unclear, however, why the policy does not also include scenarios where a five-year supply of deliverable sites is not available as well as when the Council is failing the Housing Delivery Test. To be effective and positively prepared, it is important this scenario is also included in
the Policy.

Support

Representation ID: 13877

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Given that Policy AP01 allows development on land adjoining the existing built-up area, where the relevant criteria are met, then this land is likely to occur on land designated as countryside.

Object

Representation ID: 13878

Received: 02/05/2025

Respondent: Colecar Strategic Land

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DM09: Sustainable Construction and Climate Resilience is not justified or effective.

The Policy states that it relates to all development and states that all development must, amongst other things “minimise carbon emissions during construction”. It is not clear what the threshold is for compliance with this policy. It does not comply with NPPF para 16 as it is not evident how a decision maker should react to development proposals. The lack of clarify about compliance with this policy means that is uncertain whether it has been robustly tested through viability.