Regulation 19 - Proposed Draft Local Plan Submission

Recognise this fact and do not propose any more development than absolutely necessary to meet a local need.

The settlement hierarchy fails to consider whether settlements are capable of being called sustainable locations. It is highly subjective with no analytical approach. Most are in locations which could never be regarded as sustainable and where most people choosing to live there would rely on car ownership and use .

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4.13 and 4.14 attempt to justify the distribution of housing. The importance of rail station and the current bus network in Harborough is overstated as a contribution to reducing traffic. The prospects for buses to make a significant contribution to reducing traffic have not been demonstrated and neither have the necessary requirements for achieving this. 4.14 claims that reducing the need to travel long distances by car is critical for reducing carbon emissions and tackling climate change. Nowhere does it show how the Plan will achieve the legal requirement to demonstrate that it contributes to the mitigation of climate change.

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Reducing the need to travel long distances by car to access services or work is critical for reducing carbon emissions and tackling climate. Local Plans have a legal duty to demonstrate that they contribute to the mitigation of climate change and the Plan does not demonstrate this. The methodology used to create a hierarchy of settlements fails to consider that most settlements in Harborough are incapable of being regarded as sustainable locations due to their location and lack of facilities. It does not demonstrate an understanding of the requirements or delivery issues to achieve sustainable development in those settlements at the top of the hierarchy.

The plan did not consider this from the start.

DS02 does not show a credible balance between housing allocations and jobs. It does not align employment locations to housing locations which should be the starting point for achieving sustainable development.

Stop mentioning the Golden Triangle. Accept that established infrastructure has reached its capacity and that Magna Park does not have a credible public transport network.

The intention seems to be to accept the seemingly unendless demand for many hundreds of Hectares of greenfield land to be lost to meet the logistics industry's desire to make greater profits without considering the traffic generated by HGVs or by the people travelling to them. Magna Park, DIRFT and Rugby North all take access off the A5 which is unsuitable for such growth. There are no current schemes to increase the capacity of the A5 and Highways England has made it clear that this is not a priority.

The Harborough District Council: Climate Change and Renewable Energy Study October 2024 made recommendations for changes to Policy wording. These were far too late to influence the Plan wording. There are now several adopted Local Plans which include appropriate policies.

Para 2.19 notes that road transport is the largest source of emissions, accounting for 55% of the overall emissions from the District. It recognises the strong need to reduce transport emissions by promoting sustainable transport options. Sustainable transport requires a sustainable pattern of development but the Plan does not propose that.
The Harborough District Council: Climate Change and Renewable Energy Study October 2024 made recommendations for changes to Policy wording and the need to ensure that policies are considered from the outset for major developments and are fundamental to the creation of a masterplan.

Para 1.18 reminded HDC that Development Plans, such as this Local Plan, have a legal duty to show they contribute to the mitigation of climate change. Section 19(1a) of the 2004 Planning and Land Compensation Act 2004 as amended.

The Plan is not Sound because it was not Positively Prepared in a way that recognised the legal duty above, most notably it terms of the location of development and the lack of consideration of the travel that would be generated, mainly by cars.

NPPF 9. Promoting Sustainable Travel states that transport issues should be considered from the earliest stages of plan making. Previous studies have identified the limited capacity of the road network and the high generation of traffic and the Evidence Base on transport provides further confirmation. The Plan does not show how the impacts could be mitigated in a cost-effective way or at all.

The Plan is not Justified because it adopts an inappropriate strategy. In part this stems from the non-statutory Leicester & Leicestershire Strategic Growth Plan (SGP) which did not consider climate change at all. The SGP was conceived around large strategic roads, which are very unlikely to materialise, serving greenfield car-dependent sprawl.

The Plan is not Effective because cross-boundary strategic matters relating to transport and travel have not been dealt with and there is no Statement of Common Ground regarding this.

The Plan is not consistent with National Policy. That is inevitable because NPPF does not pay sufficient regard to the mitigation of climate change and there is not a national transport policy.

The monitoring in IM03 and Appendix 3 refers to a single indicator ‘Reduction in carbon emissions’. It provides no information on how this will be assessed. It does not refer to a baseline or set regular targets to show whether the Plan is achieving the necessary reductions. If development of the wrong type is put in the wrong places where it generates significant travel and a desire for carbon intensive infrastructure it cannot be undone.

Words thoughout the Plan to prioritise sustainable active travel modes such as walking, cycling, or public transport above use of the private car are not demonstrated through the development strategy; essential wording to make it effective; or a credible delivery and funding strategy.

The Plan cannot be declared Sound as it did not take the right approach from the start.

The policy title is about ‘Supporting Strategic Infrastructure’. It is not clear why this includes the word 'strategic'.

The Plan proposes development sites without showing what strategic infrastructure is required or even defining what it means. Sustainable development requires far more than strategic or even non-strategic infrastructure. It requires the right location; the right format of development; and one where effective and attractive sustainable transport is designed in from the outset; where it can be funded and delivered when needed; and continues in perpetuity until replaced by something better or it is no longer needed.

a) the robust evidence does not exist. It should have been considered from the start in order to inform the choice of sites, their design and the cost of all factors needed to make them successful and sustainable locations.
b) uses words like ‘reasonable’ and ‘appropriate’ which provide no clarity as to what is required and therefore cannot be taken into account in viability assessments or land transactions. It refers to ‘infrastructure needed to mitigate the impacts, when the sustainable solution would be to avoid the need for infrastructure or do something else. Numerous problems have arisen with Section 106 agreements including scale, phasing, apportioning to sites and viability. It does not provide certainty. Section 278 has separate issues.
c) refers to enabling infrastructure to be delivered to provide serviced, accessible and prepared land when the infrastructure; its purpose; and delivery mechanism is not known.
d) refers to the planning application process and clusters of sites which may be promoted and phased independently. That creates many problems in terms of a ‘comprehensive approach’, considering cumulative and cross-boundary impacts and funding and delivery of infrastructure or sustainable transport.

SA02 Transport 9 ‘aspects that must be adhered to’
a) does not say what is meant by ‘comprehensive sustainable transport links’, ‘across the site’, ‘good connectivity’ or where they go to in any of the three areas mentioned.
b) Transport Assessments are not required to consider the impacts on the wider strategic and local highway network or how they will be mitigated. This can not be done at a site level and cannot have regard for phasing.
c) Does not define ‘high quality’ or ‘safe’. It does not explain what is meant by ‘existing nearby networks’ or ‘other adjacent allocated sites’.
d) Does not explain what is meant by ‘a connection across the site’ or explain its purpose’. It does not consider the extent to which additional traffic on the A6 or Gartree Road will make surrounding roads less safe.
e) Does not state hours or days of bus operation or how it would ‘connect into the wider service network’. Nowhere does it state what the expected usage would be; at what stage it would be provided; or provide any requirement for it to continue in perpetuity.
f) Does not say how an appropriate number of bus stops would be determined. There is no way of ensuring buses must use them. Many recent developments show no attempt to make buses attractive or efficient. The aim seems to be to make routes tortuous in a way to reduce walking distance.
g) There is no obvious attempt to publish information to demonstrate whether Travel Plans within Leicestershire have been effective in terms of reducing car use.

12. Delivery and Phasing

The phasing and delivery of large sites has proved problematic in Leicestershire and the policy does not tackle this. The rate of delivery of housing and infrastructure on at least seven urban extensions in Leicestershire has been far behind expectations. This has meant that LPAs have been unable to demonstrate a 5 year supply, opening them up to speculative development on sites where sustainable transport is not an option. Approval of speculative sites, sometimes on appeal, will inevitably delay progress of the larger sites, which were labelled 'sustainable' (SUEs). Some of the speculative sites are in close proximity to them, so effectively competing for the same market. Currently, 4 of the 5 sites under construction have houses but no facilities or buses. The most advanced at Lubbesthorpe, which is around 25% complete, only has a primary school and a vestigial bus service.

The Infrastructure Delivery Plan does not show what is proposed for transport. The 125 measures are said to cost £90.05m with 60% for Junction 'Improvement' measures; 33% for Walking and Cycling; 6% for buses; and 1% for Travel Plans. This excludes 'County wide mitigation measures' of unspecified scope and nine other items including those relating to all the major development sites.

The reasons given for this policy ignore many insurmountable issues and are unrealistic. The County Council's March Cabinet report adds some more detail from its perspective as a Local Transport Authority. It has recently shown that it continues to prioritise highway capacity over sustainable transport. The County Council did not publish information on individual Section 106 Agreements for transport in recent Annual Monitoring Reports.

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The Policy fails to do all the things claimed. The Infrastructure Delivery Plan does not say what infrastructure is required or how it will be funded.

This problem is not one that can be overcome by the Plan.

It is not evident that a co-ordinated approach can be considered in a comprehensive manner for clusters of sites being promoted separately and where phasing is uncertain. The Melton North and South developments highlight some of the problems from the initial concept to delivery.

The Plan needs greater clarity regarding costs and ensuring guaranteed delivery.

Affordable housing is usually the first thing to be jettisoned or be severely reduced. The Scraptoft Golf Course site which was included in the last Plan has now been dropped.

The treatment of transport costs (infrastructure or other items) in the Local Plan Viability Assessment appears trivial. It mentions a cost of £20,000 per unit and states that it relies on HDC figures for Section 106 and Off-site mitigation costs. For SA02 with 4,000 units that would equate to £80m. The Typologies Matrix for transport S106 / S278 / Planning Conditions shows £53 for Travel Packs and £750 for Bus Services. It is not at all clear what site SA02, or any of the others sites should provide or what they will cost or how they will be delivered.