Regulation 19 - Proposed Draft Local Plan Submission

We recommend that the site at Land to the north of Covert Lane, Scraptoft should be allocated for up to 100 dwellings, to help meet the area’s objectively assessed needs and would help to ensure that the plan is positively prepared and is effective and justified in its overall approach.

SUBMISSION OF COVERT LANE, SCRAPTOFT REPRESENTATION TO THE HARBOROUGH DISTRICT REGULATION 19 DRAFT LOCAL PLAN SUBMISSION (MAY 2025)

Thank you for the opportunity to comment on the Reg 19 version of the plan. There are a number of comments that we wish to make in objection to the plan and its preparation, which are set out below.

This Representation has been made on behalf of Parker Strategic Land in relation to land being promoted at Covert Lane, Scraptoft, on the former Stoneygate Rugby Football Club site. This land is currently the subject of a live planning application (ref 23/01690/OUT) for up to 100 dwellings.

Housing Number Target

It is noted and acknowledged that the housing target for Harborough has increased to 723 per annum (pa) with an additional 5% buffer, as a result of the new Standard Method within the updated National Planning Policy Framework, taking the figure to 759 pa.

We acknowledge that as the Regulation 19 Consultation commenced on the 10th of March 2025, and meets the criteria for the first section of Paragraph 234a in the NPPF, which states:

“For the purpose of preparing local plans, the policies in this version of the Framework will apply from 12 March 2025, other than where one or more of the following apply:

a. The plan has reached Regulation 19 (pre-submission stage) on or before 12 March 2025, and its draft housing requirement meets at least 80% of local housing need ”

Therefore, for this Paragraph to be engaged, the Council must also show that they have identified land to meet 80% of the new Standard Method figure (759 pa). We calculate that 80% of this figure is 607.2 houses pa. This figure is therefore 73.2 houses pa more than what the Regulation 19 plan is providing. Thus, identifying a shortfall in the Council’s allocated sites.

However, this has not been reflected in the Regulation 19 Plan Policy DS01 where it states the annual housing requirement to be 657 houses pa for the period between 2020 and 2036, to account for Leicester’s unmet housing, and then 534 houses pa for the period between 2036 and 2041.

We would also like to raise concerns over the current unmet housing needs in Leicester. The addition of 123 homes pa between 2020 and 2036 came as a result of the ‘Statement of Common Ground relating to Housing and Employment Land Needs’ by Leicester and Leicestershire Authorities in June 2022. We therefore question whether this figure remains accurate. The 2023 Housing Delivery Test illustrated that between 2020 and 2023, Leicester only delivered 57% of the housing required in the area, further demonstrating the potential increase in housing need that Harborough may need to help deliver.

As a result, we do not consider the method used in the Regulation 19 plan to calculate their housing requirement to be sound. We therefore ask the Council to revisit this figure to be able to deliver a sufficient supply and mix of housing in accordance with Paragraph 72 of the National Planning Policy Framework (2024).

The plan proposes a shortfall in allocations and, therefore, does not meet the increase in dwellings. To ensure that the Council is able to deliver much-needed homes for the district, additional allocations should be considered.

As was set out at the time of the previous representation to the Council’s Reg 18 Plan, there are concerns surrounding the timescales of delivering strategic sites. Within Lichfield’s report ‘Start to Finish – How quickly do large-scale housing sites deliver’ dated March 2024, one of the conclusions is as follows:

“Only sites of 99 dwellings or fewer can, on average, be expected to deliver anything in a five-year period from validation of a planning application, with delivery of the first dwelling on average taking 3.8 years. By comparison, sites of 1,000+ dwellings take on average five years to obtain detailed planning permission, then a further 1.3 - 1.6 years to deliver the first dwelling.”

Coupled with this Paragraph 73 of the NPPF, “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area”.

In light of the above, there is considered to be strong justification for allocating smaller sites to deliver dwellings within the first 5 years of the Plan post adoption . This includes our client’s land at Covert Lane, Scraptoft.

From a local perspective we note that 950 homes have been allocated at ‘Scraptoft East’ (Land between Scraptoft and Bushby – 950 new homes). We note that this is a sensitive site, particularly from a landscape perspective. It is considered that locating 950 new homes on this site will cause more than limited harm to the character and appearance of the area. To try and resolve this, it is firmly believed that the allocation should be reduced by at least 100 homes. Those 100 homes could then be located at Land north of Covert Lane, to both address any shortcomings in the first 5 years of housing delivery on the strategic site, in addition to addressing the sensitivity of the strategic site.

As stated in Paragraph 22 of the NPPF, “Strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities”. To ensure that the Plan covers the full 15 years on adoption, it would require it to be adopted on time with no holdbacks. If the programme gets pushed back at all, i.e., adoption by December 2026, with expiry by 31 March 2031, this will cover just under 15 years of supply. We believe this is not a realistic timeframe for the Council to meet. However, if the plan period were to be increased to accommodate this, it would further increase the housing need. The plan would then be at risk of being unsound by not delivering sufficient housing to meet the needs of the settlement.

The site we believe should be allocated is set out in further detail below.


Land to the north of Covert Lane, Scraptoft

It is acknowledged and agreed that Scraptoft is defined within the Tier 1 hierarchy of settlements, adjacent to the principal urban area of Leicester, and is therefore a very sustainable location for growth. As aforementioned in our Representation to the Regulation 18 Plan, given the Site’s location to the east of the built-up area of Scraptoft, it forms a logical location for a new, sustainable community to meet Scraptoft and Leicester’s housing needs. Vehicular access will be via the existing access to the site, on Covert Lane.

The conclusions within the previous representation were that this site should be allocated for housing. No changes are proposed, and as such, the comments made previously are still relevant.

A planning application has been submitted for this site on behalf of Parker Strategic Land on the 28th of November 2023 for up to 100 dwellings. The existing built-up area of Scraptoft borders the western boundary of the site. The Site is immediately bounded to the north and east by an established hedgerow and mature trees. Beyond the hedgerow to the east is Aylestone St James Rugby Football Club. To the west is woodland, a hedgerow and housing. The southern boundary is bound by Covert Lane.

The site was formerly utilised as a sports facility, occupied latterly by Stoneygate RFC, and was therefore designated as an Open Space Sport and Recreation Site. Current policy looks to protect these designations, however, through Parker Strategic Land taking ownership of the site, this constraint no longer applies for the following reasons:

• Stoneygate RFC has relocated to Uppingham Community College and Leicester Tigers surrendered their lease in return for a payment from Parker Strategic Land which funded 3 new rugby pitches at Brooksby Melton College. The associated surrender of the Leicester Tigers lease was only triggered when the 3 new replacement rugby pitches at Brooksby Melton College were complete, and furthermore upon receipt of evidence that these new pitches had been brought into use. Thus the surrender of the existing lease for sports pitches at Covert Lane was therefore intrinsically linked to the new and improved facilities for Stoneygate RFC and Leicester Tigers;
• The rugby pitches on the Site are no longer in use and have been redundant for the past 4 years. Subsequently the club house located on the site was subject to vandalism and burnt down; and
• There is an existing RFC located immediately adjacent to the site.

All matters are generally agreed, with the exception of the loss of sports provision. We believe that the Council has not taken this site into consideration as it has wrongly stated that the site is outdoor sports facilities land given that the test set out under paragraph 104 c) of the NPPF has been satisfied. As a result, it should no longer have the protection afforded in the current Local Plan. What’s more, the site lies adjacent to the settlement of Scraptoft and forms a logical site for the provision of new housing.

Furthermore, the planning application that has been submitted to the Council demonstrates that the site is deliverable imminently and can help positively contribute to the Plan’s housing needs. We believe that the open space designation is erroneous, given that sports provision is now provided elsewhere in the district.

Concluding Comments

In conclusion, Parker Strategic Land welcome the opportunity to comment on the Regulation 19 Proposed Draft Local Plan Submission. Considering this, it is requested that this representation and our previous representation are taken into account.

We recommend that the site at Land to the north of Covert Lane, Scraptoft should be allocated for housing to help meet the area’s objectively assessed needs and would help to ensure that the plan is positively prepared and is effective and justified in its overall approach.

It is requested that Ridge and Partners LLP be kept informed of all stages of the Local Plan Review.

From a local perspective, we note that 400 homes have been allocated at ‘GG1 - Land north of London Road and east of Leicester Grammar School – 400 new homes’. It is a sensitive site, particularly from a landscape perspective, including coalescence. It is considered that locating 400 new homes on this site will cause more than limited harm to the landscape and to the objective of preventing coalescence with Leicester given that it lies in an Area of Separation. To try and resolve this, it is firmly believed that the allocation should be reduced by at least 100 homes. Those homes could then be located at Land south of London Road, to both address any shortcomings in the first 5 years of the Plan period post adoption and address the sensitivity of the strategic site.

SUBMISSION OF GREAT GLEN REPRESENTATION TO THE HARBOROUGH DISTRICT REGULATION 19 DRAFT LOCAL PLAN SUBMISSION (MAY 2025)

Thank you for the opportunity to comment on the Reg 19 version of the plan. There are a number of comments that we wish to make in objection to the plan and its preparation, which are set out below.

This representation has been made on behalf of Parker Strategic Land, in relation to land at Land South of London Road, Great Glen.


Housing Number Target

It is noted and acknowledged that the housing target for Harborough has increased to 723 per annum (pa) with an additional 5% buffer, as a result of the new Standard Method within the updated National Planning Policy Framework, taking the figure to 759 pa.

We acknowledge that as the Regulation 19 Consultation commenced on the 10th of March 2025, and meets the criteria for the first section of Paragraph 234a in the NPPF, which states:

“For the purpose of preparing local plans, the policies in this version of the Framework will apply from 12 March 2025, other than where one or more of the following apply:

a. The plan has reached Regulation 19 (pre-submission stage) on or before 12 March 2025, and its draft housing requirement meets at least 80% of local housing need ”

Therefore, for this Paragraph to be engaged, the Council must also show that they have identified land to meet 80% of the new Standard Method figure (759 pa). We calculate that 80% of this figure is 607.2 houses pa. This figure is therefore 73.2 houses pa more than what the Regulation 19 plan is providing. Thus, identifying a shortfall in the Council’s allocated sites.

However, this has not been reflected in the Regulation 19 Plan Policy DS01 where it states the annual housing requirement to be 657 houses pa for the period between 2020 and 2036, to account for Leicester’s unmet housing, and then 534 houses pa for the period between 2036 and 2041.

We would also like to raise concerns over the current unmet housing needs in Leicester City Council. The addition of 123 homes pa between 2020 and 2036 came as a result of the ‘Statement of Common Ground relating to Housing and Employment Land Needs’ by Leicester and Leicestershire Authorities in June 2022. We therefore question whether this figure is accurate. The 2023 Housing Delivery Test illustrated that between 2020 and 2023, Leicester only delivered 57% of the housing required in the area, further demonstrating the potential increase in housing need that Harborough may need to help deliver.

As a result, we do not consider the method used in the Regulation 19 plan to calculate their housing requirement to be sound. We therefore ask the Council to revisit this figure to be able to deliver a sufficient supply and mix of housing in accordance with Paragraph 72 of the National Planning Policy Framework (2024).

The plan proposes a shortfall in allocations and, therefore, does not meet the increase in dwellings. To ensure that the Council is able to deliver much-needed homes for the district, additional allocations should be considered.

As was set out at the time of the previous representation to the Council’s Reg 18 Plan, there are concerns surrounding the timescales of delivering strategic sites. Within Lichfield’s report ‘Start to Finish – How quickly do large-scale housing sites deliver’ dated March 2024, one of the conclusions is as follows:

“Only sites of 99 dwellings or fewer can, on average, be expected to deliver anything in a five-year period from validation of a planning application, with delivery of the first dwelling on average taking 3.8 years. By comparison, sites of 1,000+ dwellings take on average five years to obtain detailed planning permission, then a further 1.3 - 1.6 years to deliver the first dwelling.”

Coupled with this Paragraph 73 of the NPPF, “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area”.

In light of the above there is considered to be strong justification for allocating smaller sites to deliver dwellings within the first five years of the Plan post adoption. This includes out client’s land at Great Glen.

From a local perspective, we note that 400 homes have been allocated at ‘GG1 - Land north of London Road and east of Leicester Grammar School – 400 new homes’. It is a sensitive site, particularly from a landscape perspective, including coalescence. It is considered that locating 400 new homes on this site will cause more than limited harm to the landscape and to the objective of preventing coalescence with Leicester given that it lies in an Area of Separation. To try and resolve this, it is firmly believed that the allocation should be reduced by at least 100 homes. Those homes could then be located at Land south of London Road, to both address any shortcomings in the first 5 years of the Plan period post adoption and address the sensitivity of the strategic site.

As stated in Paragraph 22 of the NPPF, “Strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities”. To ensure that the Plan covers the full 15 years on adoption, it would require it to be adopted on time with no holdbacks. If the programme gets pushed back at all, i.e., adoption by December 2026, with expiry by 31 March 2031, this will cover just under 15 years of supply. We believe this is not a realistic timeframe for the Council to meet. However, if the plan period were to be increased to accommodate this, it would further increase the housing need. The plan would then be at risk of being unsound by not delivering sufficient housing to meet the needs of the settlement.

The site we therefore believe should be allocated is set out in further detail below.

Land south of London Road, Great Glen

It is acknowledged and agreed that Great Glen is defined within the Tier 3 hierarchy of settlements and is, therefore, still a very sustainable location for growth. As aforementioned in our Representation to the Regulation 18 Plan, given the Site’s location to the east of the built-up area of Great Glen, it forms a logical location for a new, sustainable extension to meet the settlement’s housing needs. Important everyday facilities are accessible within reasonable walking/ cycling distances of the site, within Great Glen. Great Glen also represents one of the closest settlements to the economic offer of Leicester, within the entire Harborough District.

The previous representation concluded that this site should be allocated for housing or for alternative uses that would address a specific requirement as set out in the Local Plan. No changes are proposed, so the comments made previously are still relevant.

The site comprises six small fields, separated by overgrown hawthorn hedgerows. The overall shape is triangular, defined with hedgerow and planting, across the northern and southwestern boundaries. The eastern boundary is defined by light tree cover adjacent to London Road and Station Road.

Beyond London Road lies the existing built-up area of Great Glen. The southwestern boundary of the site is adjacent to the Leicester Road (the A6), and beyond that is the open countryside. The southernmost corner of the site lies adjacent to the A6 roundabout.

The Site offers sustainable transport options for connections to the local facilities together with the wider area. Bus route X3 can be accessed approximately adjacent to its southeastern boundary, at the bottom of the site along Station Road. It provides hourly services Monday to Friday between 6am-9pm to other areas of Great Glen, nearby towns of Oadby and Market Harborough, and Leicester city. It also provides services on Saturdays. It is considered that the site’s location provides residents with a realistic opportunity to travel by modes other than the private car. In terms of accessibility the site is sustainable.

Heritage is a potential constraint of the site, and has to be carefully considered. The Church of Cuthbert is a Grade II* Listed Building located approximately 50 metres east of the site [List Entry Number: 1061596]. Similarly, the Old Vicarage, a Grade II Listed Building is located just under 100metres east of the site [List Entry Number: 1180195]. Both of these heritage assets are separated from the site by London Road, and sensitive landscaping would ensure their settings are preserved. The site’s masterplan, landscaping and green infrastructure provision would seek to mitigate any potential heritage impact.

The Great Glen Neighbourhood Plan Review (NP), adopted 2020, allocates much of the site, under ‘GG/LGS/02 Grazing fields southwest of St Cuthbert’s Church (178-179-180-181)’, for Local Green Space under Policy GG12: Designation of Local Green Spaces. The policy states:

“Development proposals that would result in the loss of, or have an adverse effect on, the following designated Local Green Spaces (shown in figure 5) will not be permitted unless in very special circumstances…”

We note from Paragraph 107 of the NPPF (2024) the reasons under which Local Green Space (LGS) designations are applied. The site does have some historical significance given the heritage assets which are in close proximity to the site (particularly the Grade II* Listed St Cuthbert’s Church). The ‘Draft Framework Plan’ (Appendix C) takes account of the site’s historic significance and utilises it. The layout allows people to make use of the existing Public Rights of Way and appreciate the relationship between the site and the Grade II* Listed St Cuthbert’s Church. In our opinion, we believe the Local Green Space designation could be reduced to constitute a smaller portion of the site, which would preserve the site's importance, whilst enabling the delivery of up to 112 residential units.

The dwellings themselves would be set back from the eastern site boundary, respecting the setting of St Cuthbert’s Church. Similarly, dwellings would be set back from the northern site boundary, respecting the setting of 26 London Road. Trees and hedgerow would border all site boundaries, allowing limited views onto the site. Trees and hedgerow will also be situated within the site.

Concluding Comments

In conclusion, Parker Strategic Land welcome the opportunity to comment on the Regulation 19 Proposed Draft Local Plan Submission. Considering this, it is requested that this representation and our previous representation are taken into account.

We recommend that the site at Land South of London Road, Great Glen, be allocated to help meet the area’s objectively assessed needs and ensure that the plan is positively prepared and effective and justified in its overall approach.

It is requested that Ridge and Partners LLP be kept informed of all stages of the Local Plan Review.