Regulation 19 - Proposed Draft Local Plan Submission

To make Policy SA03 sound it should be re-drafted to state that sustainable transport modes will be prioritised.

'Policy SA03: North of Market Harborough’ relates to the cluster of sites to the North of Market Harborough (MH1, MH2 and MH3), identified for new sustainable, residential-led mixed use development. It states:
“3. ... The masterplan for the site must:
f) Provide safe highway, footway and cycleway connections that are permeable through the cluster of sites and connecting new schools, community facilities and into the town centre to maximise opportunities for sustainable modes of transport; “
and:
“5.26 Addressing the cumulative transport impacts is necessary to manage increased traffic, ensure road safety, and promote sustainable travel. Safe vehicular access, regular bus services, and high-quality cycle and pedestrian routes are vital to reducing car dependency and encouraging healthier, more sustainable modes of transport. “
The National Planning Policy Framework (NPPF) (December 2024) sets out a presumption in favour of sustainable development. The specification for the Masterplan set out in Policy SA03 is incompatible with NPPF Paragraph 115 which states that “In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that: a) sustainable transport modes are prioritised …”. We consider that Policy SA03 does not fully reflect the requirement to prioritise sustainable travel modes as set out in NPPF Paragraph 115 and this makes Policy SA03 in the Proposed Submission Draft Harborough Local Plan unsound.

To make Policy SA03 sound, the proposed sites MH2 and MH3 should be deleted from the draft Local Plan.

The travel distance from the town centre to the median points of MH2 and MH3 is more than 2.7km, and the walking journey time is 32 minutes - downhill. Travel time, uphill, from the town centre to the proposed developments would be greater still.

In the STIA Para 2.4.3 it notes “Circular 01/2022 [Strategic road network and the delivery of sustainable development] states that: “12. New development should be facilitating a reduction in the need to travel by private car and focused on locations that are or can be made sustainable. In this regard, recent research on the location of development found that walking times between new homes and a range of key amenities regularly exceeded 30 minutes, reinforcing car dependency. Developments in the right places and served by the right sustainable infrastructure delivered alongside or ahead of occupancy must be a key consideration when planning for growth in all local authority areas.”

Circular 01/2022 goes on to say “13. … where developments are located, how they are designed and how well delivery and public transport services are integrated has a huge impact on people’s mode of travel for short journeys. National Highways will therefore expect strategic policy-making authorities and community groups responsible for preparing local and neighbourhood plans to only promote development at locations that are or can be made sustainable and where opportunities to maximise walking, wheeling, cycling, public transport and shared travel have been identified.”

The proposed sites MH2 and MH3 might be viewed as being in sustainable locations due to their relatively close proximity to a range of services in Market Harborough. However, the travel distance from these sites to the town centre presents a significant risk that sustainable transport measures will not be sufficiently attractive to encourage and enable modal shift away from the car. Sites MH2 and MH3 cannot meet the requirements to prioritise sustainable travel modes as set out in NPPF Paragraphs 115 to 118; nor in Para 12 & 13 of Circular 01/2022 and are therefore not deliverable. We consider this makes Policy SA03 in the Proposed Submission Draft Harborough Local Plan unsound.

To make Policy DM06 sound, Para 2 should be amended and the following changes made to i) require a vision-led approach to identify transport solutions that deliver well-designed, sustainable and popular places and ii)
prioritise sustainable travel modes as set out in NPPF Paragraph 117
(Please see Full Text attachment for proposed policy amendments)

The National Planning Policy Framework (NPPF, December 2024) states that “109. Transport issues should be considered from the earliest stages of plan-making and development proposals, using a vision-led approach to identify transport solutions that deliver well-designed, sustainable and popular places.”

In the Harborough Local Plan Strategic Transport Impact Assessment (January 2025) it states “1.3.3 It is noted, however, that information within documents supporting the new LTP (such as the Bus Service Improvement Plan, Local Cycling and Walking Infrastructure Plan and proposed Multi Modal Area Investment Plans, MMAIPs) continue to evolve. It is also expected that transport consultants working with individual developers – particularly for the largest sites and those in urban areas – will work within this evolved policy context to identify site-specific proposals to maximise the use of sustainable transport. As such, whilst sustainable modes have been considered first within this STIA, it is recognised that more work will be required for each site (within a site specific TA) to fully adopt a Vision Led approach through to the build-out phase.”

The HDC Climate Change and Renewable Energy Study: Policy Review (October 2024) recommends (Paragraph 120) a number of policy approaches to reducing carbon emissions in transport “should not be considered in isolation, but rather, as able to complement and/or supplement each other to strengthen the overall consideration for transport emission sand maximise the benefits to Harborough.”

The failure to require a ‘vision-led’ approach to identify transport solutions, and to prioritise sustainable travel modes in Policy DM06 makes it unsound.

To make Policy DM06 sound the draft Local Plan should be amended, and a revised Policy should state:

Policy DM06: Transport and Accessibility
1. Development will be permitted, subject to:
a) prioritising sustainable travel modes above use of the private car, encouraging walking and cycling over cars for short journeys, and
b) ensuring the safe, connected and convenient movement across the transport network, accessible to all users, including a joined-up network of walking and cycling links and new or enhanced public transport services, and
c) providing safe access, servicing and parking arrangements as defined in this policy and having regard to Highway Authority guidance and standards; and
d) ensuring that additional traffic movements are not detrimental to highway safety or result in the residual cumulative impact on the road network being severe.

In ‘Our reasons for this Policy’, prior to Para 8.22, a new paragraph should be inserted establishing the principle of a Sustainable Transport Hierarchy and making it a requirement to be delivered within all future developments and in any relevant site allocation policies. As travel infrastructure is far more challenging to incorporate at later stages, it should also require the sustainable transport hierarchy to be considered at the commencement of any development or master planning process.

NPPF Paragraphs 115 to 118 set out the Government’s development planning policies with respect to transport. These paragraphs focus on, and emphasise, the promotion of sustainable transport. i.e.

“115. In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that: a) sustainable transport modes are prioritised taking account of the vision for the site, the type of development and its location;” and “117. Within this context, applications for development should: a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;”

Policy DS03 Development Strategy: Tackling Climate Change and Enhancing the Natural Environment states “1. Development will be permitted where it a) Prioritises sustainable active travel modes such as walking, cycling, or public transport above use of the private car.” In ‘Our reasons for this Policy’ Para 4.34 states “This policy … embeds a sustainable transport hierarchy which aims to reduce high carbon travel modes in favour of more sustainable alternatives like walking and cycling”.

However, the need to i) prioritise sustainable transport modes and ii) establish a hierarchy of travel choices, as set out in NPPF Paragraphs 115 and 117, is omitted from Policy DM06. Given that Policy DM06 relates specifically to Transport and Accessibility this makes the Proposed Submission Draft Harborough Local Plan unsound.

The Harborough Local Plan Strategic Transport Impact Assessment (January 2025) states “4.3.1 As noted in Section 1, the requirements for active travel mitigation have become more important in recent years, with the formation of Active Travel England (ATE) and the publication of LTN1/20. Pedestrians and cyclists are now recognised at the top of the transport hierarchy.”

The HDC Climate Change and Renewable Energy Study: Policy Review (October 2024) also recommends a number of policy approaches for reducing carbon emissions from transport related to new development (Para 2.119). First amongst those policy options was to “Require a sustainable transport hierarchy” and the example given was from the Suffolk CC Local Transport Plan. (see Full Text attachment)