Regulation 19 - Proposed Draft Local Plan Submission

First, the HLP should contain a clear mechanism for addressing Leicester’s unmet need beyond 2036 should this arise. Whilst a review mechanism has been incorporated within the HLP, the PPG indicates that strategic policy-making authorities should cooperate to address cross-boundary matters and not defer these issues to subsequent reviews. Further land allocations or reserve sites should be identified to address Leicester’s unmet need should it arise in the current Plan period.

Second, the HLP and its evidence should consider whether an uplift to the housing requirement could be made, and further suitable, deliverable and sustainable sites allocated, to address the need for affordable housing.

Third, the SA should consider a “high growth” scenario across the refined options, consistent with our wider observations in relation to the housing requirement.
The approach to the HLP’s supply-side buffer should be re-considered to align with that consulted upon during the issues and options stage. A buffer of around 20% is appropriate and this should be reflected in the amount of land allocated for development.
Whilst we consider a balanced approach between the Leicester Urban Area and the market towns to be justified, the spatial strategy current cascades significant growth toward the bottom end of the settlement hierarchy. The SA has not considered an approach that would apportion more growth to Lutterworth, which in our view would represent a more sustainable outcome. We encourage this to be considered through the SA process.

See attachment.