Regulation 19 - Proposed Draft Local Plan Submission

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There are no new employment opportunities on the east side of Leicester. The roads into Leicester and around the east side of Leicester are country lanes that are already heavily used and where existing commitments will make them worse.
1 d. Thorpebury is to the northeast of Leicester where far more development has been approved and is allocated in the draft Charnwood Local Plan.
There is no clarity regarding the necessary infrastructure or other measures needed to make this location sustainable or achieving its delivery.

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The term Affordable Homes does not mean homes are actually affordable by those who need them most. The delivery of Affordable Homes is one of the first things to be ditched by developers citing viability issues. This apears to have been recognised but it is questionable whether the Viability Appraisal has considered the difficulties of obtaining S106 contributions or even had knowledge of what was being sought or is actually required to create sustainable developments.

Require much higher densities ensuring it is attractive to look at and live in.

The proposed densities are typical of car-dependent sprawl which has characterised most developments outside London and major city centres for several decades. Car ownership on the periphery of most cities in not significantly lower than many rural areas because alternatives are not attractive or do not exist. Sustainable development should be proposing significantly higher densities in conjunction with less space for roads and parking. This facilitates walking, cycling and buses and improves the viability of bus services. Making the best use of land is a very important consideration for CPRE.

Many changes would be required to the Plan to demonstrate it is taking sustainable transport seriously. An unsustainable location and an unsustainable form of development strategy cannot be rectified later.

Tier 3 and especially Tiers 4 and 5 are generally unsuitable locations for sustainable development. Achieving sustainable development in Tiers 1 and 2 will require significant changes to the approach taken for the preparation of this Plan. Key requirements are a good range of local facilities, including employment and secondary schools within walking / cycling distance. Sites also need to be served by an attractive, affordable, comprehensive, frequent, well interconnected bus service operating 7 days a week and throughout the day. For new sites these facilities need to operate from day one and have guaranteed permanence to attract non-car users.

A Plan promoting and demonstrating sustainable development would have far lower car parking standards and developments with no parking at all.

Nowhere in the Plan or any of the supporting evidence does it show what assumptions have been made regarding how it is expected to change the way people travel to reduce congestion or contribute to mitigating climate change. Transport Assessments are typically volumious tick-box exercises based on guidance that hasn't been updated since 2014. Parking standards reflect unsustainable developments with high car ownership.

Be more honest. Look at what is proposed in the JTE and the Leicestershire & Leicester Strategic Transport Assessment Stage 1 which was produced to support the SGP aspirations.

The use of Transport Assessments and Travel Plans does not ensure a sustainable approach to growth. They have been in existence for years and there is no obvious sign of their effectiveness.

Recognise that road capacity is not going to increase in line with forecasts.

The Hinckley National Rail Freight Interchange was rightly rejected. It failed to consider the impacts of traffic generated by the proposals on the surrounding road network. The promoter failed to show it could be mitigated. The need for more logistics sheds is highly questionable as it demonstrates a growth in moving stuff around by road on a road network that is increasingly congested. It is not compatible with mitigating climate change.

See our other comments made using the online system. Some of this may duplicate what is in our other comments. That is a problem with devising two thoroughly inappropriate methodologies for receiving responses.

The Plan is not Legally Compliant because it was not Positively Prepared in a way that demonstrate that it contributes to the mitigation of climate change which is a legal duty. 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. NPPF is also ambiguous, internally inconsistent and vague. It was created in a silo which fails to recognise the need for it to be aligned with other Government policies and the inability to deliver what it seeks. The unfortunate choice of methods used to seek responses to this consultation are very inconvenient. HDC has confirmed that there are no regulations regarding the methodology and that the two methods were chosen for the benefit of the District Council in analysing responses. We note that others have been allowed to use a different format which has the benefit of being able to present a more coherent view of the whole Plan. I have no way of knowing whether you can even read what is in this box as I can't scroll through it.

Summary

The Plan is not Sound. It has not been Positively Prepared and it is not Justified. Problems include:- National Planning Policy (NPPF) is contradictory, ambiguous and vague. NPPF was devised in a silo that gives little consideration to many things including mitigation of climate change; balance of housing / jobs and employment; generated travel; and land-use including greenfield V brownfield.. Local Plan Policies are typically very weakly worded and not specific enough to be clear as to what should be delivered and when. Funding processes do not exist to guarantee delivery of essential facilities and services. The lack of any national transport policy for decades has created an environment where the default is to plan for motor vehicles and ignore the many factors that are required to deliver more sustainable transport - specifically in terms of location.

Critique

The Harborough Local Plan proposes significant amounts of development in places that are never likely to become sustainable locations. They have insufficient facilities within walking or cycling distance and poor or non-existent public transport (essentially buses) to a wider range of destinations and virtually no prospect of any improvement. The 2023 'Settlement Hierarchy Assessment' failed to recognise this.

The English approach to planning developments for around 75 years has been to assume most people will have access to a car and consequently this places few constraints on where development of any type can go. However, places with access to fast roads, or ones with high capacity, have tended to be given higher priority by the market and the planning system. The Plan does not attempt to match housing to employment. Most of the land allocated for employment is at Magna Park in the SW corner of the District, far from most existing and proposed housing.

With very few exceptions public transport has not been seen as important by government and privatisation made it highly fragmented with no co-ordination between modes or operators. Most bus services operate on radial routes to town or city centres which once had a high level of jobs, shops and a wide range of facilities. This is no longer the case, partly due to these being dispersed to more car accessible locations, and the changes arising from the growth of the internet.

Bus services are mostly reliant on them being commercially viable and hours and days of operation can be highly variable. Patronage has been falling for years and there is no guarantee that services will be