Regulation 19 - Proposed Draft Local Plan Submission

Hallam Land supports the development objectives of the Council in particular the need to deliver housing.

Policy DS01 2 b) is justified, effective and consistent with national planning policy and therefore sound.

The identification of Lutterworth is justified and an appropriate strategy having regard to reasonable alternatives. Lutterworth is one of two market towns within the district and has the full range of services and facilities to meet the needs of new residents. The proposed housing allocation at L2 is within walking distance of the existing town which makes it a sustainable location. Locating more growth in other settlements as an alternative to growth at Lutterworth would not promote a more sustainable pattern of development and would not be justified or sound.

The level of housing growth at Lutterworth is effective and deliverable over the Plan period. Lutterworth has delivered 255 homes in the first 3 years of the Plan period at an average of around 85 homes a year. If you assume that rate continued for the remainder of the Plan period, it equates to a further 1530 (85 x 18 years). This clearly demonstrates the need for development at Lutterworth and the requirement to allocate sites at this market town. The level of growth proposed is therefore deliverable by the market and the proposed allocation of L2 and can easily be delivered within the Plan period.

Housing growth at Lutterworth is also consistent with national planning policy. Paragraph 72 of the Framework states that planning policies should identify a sufficient supply and mix of sites, and identity a supply of specific, deliverable sites for five years following the intended year of adoption. The L2 site at for 90 homes, can easily be delivered with the first five of the Plan’s adoption. The site is not dependant on infrastructure to be provided by third parties and is wholly within the control of Hallam Land who are committed to bringing the site forward in a timely manner. Lutterworth has the necessary infrastructure and facilities to accommodate the level of housing proposed.

There is a requirement identified for junction improvements to support the delivery of the site to be funded by the developer of site with an anticipated cost of £2,445,000.000, however, no details are provided as to where the junction improvements are or the relationship between the development’s impacts and associated costs. Given the level of impact the development will have on the local highway network will be minimal, it is considered the amount being sought therefore is not justified and should therefore be removed.

In addition, clarity is required on the approach the Leicestershire County Council (LCC) are proposing to take in terms of seeking developer contributions. Between May and June 2024, LCC held a consultation proposing amendments to the adopted Planning Obligations Policy, proposing several changes in how LCC seeks developer contributions. The proposed changes resulted in a number of objections with the approach by LCC challenged at the Charnwood Local Plan EiP. It is essential for the Plan to be sound there is transparency and an understanding of how infrastructure will be funded, which is viable and deliverable.

Object. This policy is not considered sound as it is not positivity prepared, not justified and not consistent with the NPPF.

This policy sets out that all developments will be supported by the necessary infrastructure required to mitigate the impact of the development and confirms that developers will be expected to either provide direct provision or contribute towards the provision of local and strategic infrastructure as identified in the Infrastructure Plan.

The Infrastructure Delivery Plan dated February 2025, published as part of the Council’s evidence to support the plan details the specific infrastructure required to be delivered for the proposed site allocations. At page 33 of the report it states that:

“The allocation at M1 Junction 20 / Swinford Road in Lutterworth (site L2) is not expected to have an adverse highways impact though access the site may be constrained by its location”.

However, within the same appendix on page 64 reference TR32 there is a requirement identified for junction improvements to support the delivery of the site to be funded by the developer of site with an anticipated cost of £2,445,000.000, however, no details are provided as to where the junction improvements are or the relationship between the development’s impacts and associated costs. Given the level of impact the development will have on the local highway network will be minimal, it is considered the amount being sought therefore is not justified and should therefore be removed.

Highway transport work undertaken by Hallam Land’s transport consultant has identified that no off-site mitigation works are required to be undertaken for a scheme of 90 homes.

The proposed change to the plan being sought is the removal of this requirement as set out under TR32.

In addition, clarity is required on the approach the Leicestershire County Council (LCC) are proposing to take in terms of seeking developer contributions. Between May and June 2024, LCC held a consultation proposing amendments to the adopted Planning Obligations Policy, proposing several changes in how LCC seeks developer contributions. The proposed changes resulted in a number of objections with the approach by LCC challenged at the Charnwood Local Plan EiP. It is essential for the Plan to be sound there is transparency and an understanding of how infrastructure will be funded, which is viable and deliverable

Hallam Land supports the identification of L2 as an allocation for 90 homes and consider it to be justified, effective, and consistent with national planning policy, and therefore sound.

Paragraph 72 of the Framework outlines that planning policies should identify a sufficient supply and mix of sites, and identity a supply of specific, deliverable sites for five years following the intended year of adoption. The L2 site at 90 homes, can easily be delivered with the first five of the Plan’s adoption.

L2 is well located. To the north of Lutterworth Road, there is a recent employment development, while to the northwest lies a mixed-use development that includes business facilities, a hotel, leisure activities, and a recently built Aldi. It is a logical and sustainable addition to Lutterworth, as all key services and facilities are within reasonable walking and cycling distances. For example, Lutterworth town centre is approximately 1 km from the site, with health services 1.3 km, education facilities 1.4 km, and a grocery store (Aldi) just 400m away.


The site is of sufficient scale to accommodate a mix of homes, open space and BNG requirements accordingly. The site is free of significant environmental constraints and not covered by any designations that would preclude its development. The Site is therefore developable in accordance with the definition within the Framework.

The proposed policy L2 sets out four specific policy requirements that any proposal would have to adhere to. As drafted no objections are made in relation to these.

Hallam Land is willing to support the Council as it prepares for the examination of the submission version of the Plan and prepare Statements of Common Ground as necessary.

The policy should amend the wording from “must meet M4(3)” to “should seek to meet”, or “subject to site-specific viability and physical feasibility”. A caveat should provide that “Where the delivery of M4(2) or M4(3) homes is demonstrably unviable or impracticable due to topography, layout, or other physical constraints, alternative approaches to achieving accessibility may be considered”.

Object. The policy is not considered sound as it is not positively prepared, not justified and not consistent with the NPPF.

The Leicester and Leicestershire Housing and Economic Needs Assessments updated June 2022, acknowledges that any policy requirement to increase the supply of accessible and adaptable dwellings and wheelchair user dwellings needs to be applied flexibly, as it is not always possible to be provided, and cites examples of where this may be the case, (due to viability or site-specific circumstances). The policy as currently drafted, fails to include the required flexibility. The change being sought is flexibility to be included within the drafting of the policy.

If the Council does maintain a specific policy on self and custom build housing, the requirement as set out in section 3 of the proposed policy for a marketing exercise to be undertaken over a period of 18 months is considered excessive and should be reduced to six months for the reasons set out above.

Object. The policy is not considered sound as it is not positively prepared, not justified and not consistent with the NPPF.

Hallam Land consider that the best way to deliver self and custom build homes to meet identified needs is to allocate specific sites designed to cater for such homes. This has worked well in other authorities such as Stratford-on-Avon District Council. Sites will be smaller by their nature, and therefore more responsive to market demand and more likely to be attractive to those wishing to develop their own home. Larger sites and strategic allocations can only be efficiently developed by the major housebuilders, and the inclusion of self and custom build within their developments can create health and safety and operational difficulties when homes are being constructed.

No evidence is available to demonstrate whether people would wish to build a self and custom home on a larger development. If there were to be a marketing period, this should be reduced to 3 months on the basis that smaller sites are built out over a relatively short period of time and the cost of re-mobilisation is an issue with an 18-month marketing window which is considered contrary to the NPPF in the requirement to boost the supply of homes. The proposed change being sought is this requirement to be removed.

If the Council does maintain a specific policy on self and custom build housing, the requirement as set out in section 3 of the proposed policy for a marketing exercise to be undertaken over a period of 18 months is considered excessive and should be reduced to six months for the reasons set out above.

The proposed change being sought is to remove this requirement.

Object. The policy is not considered sound as it is not positively prepared, not justified and not consistent with the NPPF.

The approach to ensuring sustainable construction and climate resilience is acknowledged and supported, however, the requirement as set out in paragraph-2 of the policy which requires all new-build residential developments to achieve at least a three-star rating under the BRE Home-Quality Mark-scheme, which as we understand is over and above building regulation requirements and therefore considered unduly onerous on developers and may have implications on the deliverability of schemes.

The proposed change being sought is to remove this requirement.

Hallam Land supports Policy AP01.