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This allocation of BA1 should be considered in the context of soundness concerns with the wider strategy for Broughton Astley and the sustainability appraisal should be reviewed as these currently indicate the conclusion that this allocation is not justified.
In Broughton Astley, only one site (BA1) is proposed for allocation, delivering 475 dwellings. The Sustainability Appraisal scores for this site are almost identical to those for Land off Crowfoot Way (14/10175), with the exception of SA3 (Efficient Use of Resources, Including Soils) and SA6 (Safeguard and Improve Health, Safety, and Wellbeing), where BA1 scored marginally higher.
This allocation does not currently benefit from planning permission. This further raises concerns in regard to Paragraph 69 of the 2023 NPPF (72, 2024 NPPF) expects plans to “identify a sufficient supply and mix of sites…including specific, deliverable sites for years 1–5 and developable sites or broad locations for years 6–10 (and, where possible, 11–15)”. Relying on a single, large strategic allocation at BA1 provides no small sites or broad locations, leaving the first five‐year supply in Broughton Astley as at risk of significant delay and failing to support the Plan on adoption.
The trajectory in Appendix 5 shows no completions from BA1 until 2030/31, leaving Broughton Astley without any scheduled housing delivery in Years 1–5. To address this, the Council should allocate one or more small, immediately deliverable sites—such as Land off Crowfoot Way—to ensure the neighbourhood area contributes to the early years of the trajectory.
The justification for BA1’s allocation, as noted in the Sustainability Appraisal, states:
“The site is considered to meet the criteria for potential site allocation and is in line with the Local Plan objectives and spatial strategy. The site is in keeping with the character and landscape setting of the existing settlement and would have a low impact on the edge of the settlement and is considered an appropriate location for development. The site is adjacent to the recreation space and primary school and would enable land to be provided to expand the school.”
In contrast, the assessment of Land off Crowfoot Way simply states: “Delivery uncertainty”, with no further justification to not take the land forward for allocation. Given that the site is in single ownership, adjoins an existing residential development, and could commence development immediately following planning approval, it is unclear why such a conclusion has been reached. Under Annex 2 of the NPPF, the site would be classified as 'deliverable' upon securing planning permission.
We note that Broughton Astley Parish Council has registered an objection to the draft Local Plan, citing concerns that they were not meaningfully consulted and that their preferred alternative sites were not fully considered. During the development of the plan, we have sought to engage with the Parish Council and have submitted the site through a formal pre-application in January 2025 under Harborough District Council’s pre-app service. We await feedback on scheme layout, access and landscaping. A public consultation for this proposal ran from April 8th 2025 until April 22nd 2025 during which all comments have been duly recorded and will be taken into consideration. Therefore, an application submission for this site is imminent.
The assertion that BA1 would have a “low impact on the edge of the settlement” is also questionable. A development of 475 dwellings represents a significant expansion of Broughton Astley, with the allocation nearly matching the scale of the existing north-western part of the settlement. In contrast, Land off Crowfoot Way is a smaller, more proportionate extension that would integrate more seamlessly with the existing built form.
SA3 – Efficient Use of Resources, Including Soils
BA1 is scored as having a significant negative effect/uncertain impact under SA3, likely due to its current agricultural use. While this is a reasonable assessment, it is important to recognise that all greenfield development impacts land resources.
Land off Crowfoot Way, however, is assessed even more negatively, with a significant negative effect/uncertain or minor negative effect likely. This is difficult to justify, as the site is currently undeveloped and largely underutilised. Unlike BA1, it is not in active agricultural use but rather a vacant parcel of land on the edge of an existing housing estate. Given that the NPPF encourages the use of underutilised land, it is unclear why BA1 is considered preferable in this regard..
SA6 – Safeguard and Improve Health, Safety, and Wellbeing
The Sustainability Appraisal assigns a significant positive effect to BA1 under SA6, while Land off Crowfoot Way is rated as having only a minor positive effect. The justification appears to rest on BA1’s provision of land for school expansion.
While additional school land can be beneficial, it is important to consider the wider impacts of the allocation. The BA1 allocation of 475 dwellings is likely to place substantial additional demand on local infrastructure, notably Orchard Church of England Primary School, which currently has a capacity of 210 students with 192 enrolled. Even with the provision of extra land, it remains uncertain how the school would accommodate the increased demand.
There is also uncertainty regarding the actual provision of this additional land. It is not clear whether this will be secured through a Section 106 agreement, as no planning application is currently in place on the site. Given the current climate, with rising building costs and the potential for planning obligations to be renegotiated (PPG Reference ID: 23b-020-20190315), there is a risk that viability concerns could be raised, potentially resulting in the removal of this obligation.
In contrast, Land off Crowfoot Way would deliver a much smaller number of homes, generating a lower impact on local services, and contributing proportionately to local infrastructure needs. Given that both sites would provide much-needed housing for Broughton Astley, the reasoning for BA1’s higher SA6 score requires further clarification.
Given that both sites perform almost identically across the other Sustainability Appraisal objectives, Land off Crowfoot Way should be considered equally sustainable for development. The decision to allocate a large, strategic site in a more rural setting, while dismissing a smaller, deliverable site, raises questions about the rationale behind site selection.
Large strategic allocations often experience longer lead-in times and slower build-out rates, which could delay housing delivery. According to Lichfields’ "Start to Finish" (3rd Edition) report:
A site the size of BA1 (475 dwellings) typically takes 2.8 years in the planning system (from application validation to detailed permission being first granted) before detailed permission first permitting development is achieved.
Once permission is granted, it then takes a further 3.2 years to first delivery, meaning a total of 6 years from validation to first delivery.
Large sites tend to deliver at a slower annual rate, with an average build-out rate of 44 - 49 dwellings per annum, implying that full delivery of 475 dwellings would take approximately 9.7–10.8 years at these rates.
In contrast, Land off Crowfoot Way is proposed for 30 dwellings with approximately 2,000 sqm of informal green space, making it far more deliverable in the short term. Smaller sites such as this can make an immediate contribution to the housing trajectory and five-year land supply, a key requirement of national policy.
Given that BA1 and Land off Crowfoot Way scored almost identically in the Sustainability Appraisal, it is unclear why BA1 has been allocated while Land off Crowfoot Way has been dismissed under "Delivery Uncertainty."
Land off Crowfoot Way offers:
A more proportionate extension to the existing settlement.
A deliverable site with fewer infrastructure constraints.
A quicker contribution to housing supply.
Policy compliant levels of affordable housing and a sustainable housing mix, complementing and increasing variety in the mix and tenure of available stock and diversifying provision relative to the existing Crowfoot Way development.
A more efficient use of underutilised land than BA1.
It is therefore requested that Land off Crowfoot Way be reconsidered for allocation within the Local Plan, ensuring a balanced and justified site selection process.
According to the 2024 SHELAA Update, Land off Crowfoot Way (Site ref: 24/10175) is assessed as suitable and available, with no red constraints identified. The site is considered capable of housing approximately 32 dwellings at a density of 30 dph, which is consistent with its role as a small infill development. Its current status as an underutilised parcel—currently a construction site and grassland—and its adjacency to established residential areas underscore its potential for timely and efficient development. This contrasts with BA1, where the larger scale of development may result in longer lead-in times and slower build-out rates.
The site’s location reinforces its effective use of land. Situated on the southern boundary of Broughton Astley, it is bounded by existing residential development to the west and north, while an unused railway line to the east serves as a natural buffer that restricts further sprawl. To the south, adjacent agricultural land further delineates its boundaries. This context demonstrates that the development of Land off Crowfoot Way would constitute logical infill—complementing the existing built fabric without overwhelming local infrastructure. In light of these factors, the "delivery uncertainty" label appears unwarranted, and the site should be reconsidered as a deliverable contribution to local housing supply.