Regulation 19 - Proposed Draft Local Plan Submission

It is recommended that the Council should prepare and publish a revised Regulation 19 Local Plan document with an increased housing requirement set out in the updated standard method.

The National Planning Policy Framework (NPPF) dated December 2024 (as updated in February 2025) sets out the transitional arrangements in Annex 1 (Paragraph 234). For these arrangements to apply, the draft housing requirement should meet at least 80% of Local Housing Need calculated using the standard housing method published in December 2024.

The housing requirement set out in the Regulation 19 version of the Local Plan does not meet the threshold of 80%.

Paragraph 4.6 of the Local Plan document states that the Local Housing Need figure is 534 dwellings per annum.

The current standard method figure is 723 dwellings per annum.
534 dwellings per annum only represents 73.8% of 723 dwellings per annum.

Paragraph 4.6 also states the District Council adds the Leicester unmet need figure of 123 dwellings per annum resulting in a total of 657 dwellings per annum. This figure represents 90.8% of the current standard housing method figure of 723 dwellings per annum.

In summary, the District Council annual housing figure only meets the threshold of 80% of the updated standard method figure if it includes the figure for Leicester's unmet needs. This figure for Leicester's unmet need should clearly be additional to the Council's annual housing figure.

Paragraph 62 of the NPPF (December 2024) states that any needs that cannot be met within neighbouring areas should be in addition (my emphasis) to the local housing need figure, stating.

'To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.'

In conclusion, the Leicester City unmet need figure of 123 dwellings per annum should be in addition to the Local Housing Need assessment for Harborough. It should not be included in the local housing need figure. This would mean that the Harborough figure of 534 dwellings per annum is 73.8% of the updated standard method of 723. The Leicester City figure of 123 dwellings per annum should be additional to the District figure of 723 which would result in a combined annual figure of 846 dwellings per annum.

This means that the plan does not benefit from the transitional arrangements and should be subject to the requirements of the NPPF (December 2024) including the updated standard method figure of 723 dwellings per annum plus the unmet need associated with Leicester City 123 dwellings per annum for the duration of the plan period.

It is recommended that the Council should prepare and publish a revised Regulation 19 Local Plan document with an increased housing requirement set out in the updated standard method. An increase in the housing requirement will require additional housing allocations to be identified in a revised Regulation 19 Local Plan document. The additional housing need should be directed to sustainable locations in the District including proposals which would offer strategic infrastructure benefits to local communities such as land at North East Kibworth (see attached).

Land at North East Kibworth should be identified as a proposed Local Plan allocation for circa 1,500 dwellings, 25 hectares of employment land and a relief road consistent with the description in the SHELAA.

This representation should be read in conjunction with the other Savills representation on behalf of Bellway Homes in relation to Policy DS01. This states that the housing requirements should be increased in order for the Regulation 19 Local Plan to be consistent with the requirements of the NPPF.

Policy DS01 - Development Strategy also refers to the distribution of development across the District together with a settlement hierarchy which includes the figure of 475 dwellings in Kibworth which is designated as a large village.

The Harborough SHELAA refers to land at North East Kibworth (Site Reference 21/8060) on Pages 332 and 333. The site area is listed as 164.62 hectares with capacity for 1,489 dwellings and 25 hectares of employment, together with a relief road which will act as a bypass for Kibworth.

This area is owned largely by two landowners, namely Merton College of Oxford University and the Leicester Diocesan Board of Finance.

Bellway Homes is working with the two principal landowners to promote the area through the local plan process. Bellway Homes is a national housebuilder with a track record of delivering housing development in Harborough District. The involvement of Bellway Homes means that this site will be deliverable.

This comprehensive proposal as shown in the SHELAA (Site Reference 21/8060) offers the potential to fund and deliver a relief road for the village of Kibworth. Provision of a relief road would allow through traffic on the A6 to be diverted away from the centre of the village. This would allow improved amenity for existing village residents and the opportunity for environmental improvements such as improved public realm on Harborough Road and Leicester Road. The principle of such a relief road is supported by the Kibworth Villages' Neighbourhood Plan (2017 to 2031). The proposed strategic allocation could also offer a range of planning benefits including affordable housing, job opportunities through the provision of circa 25 hectares of employment land, new local community facilities such as educational provision, health provision, recreational facilities and improved public transport.

Adjoining land (Site Reference 8236) could also be included as part of a comprehensive proposal if the landowners wish to bring that site forward. It has an estimated capacity of circa 200 dwellings. The wider proposal on land owned by Merton College and the Leicester Diocesan Board of Finance is not dependent on the this site being brought forward for development.

The proposal for a local plan allocation at North East Kibworth would allow a mixed use development in a sustainable location which provides a major improvement to local transport infrastructure in the form of a new relief road for the village of Kibworth. An indicative masterplan (Reference MP01) dated April 2025 is attached.

The A6 north of the A14 and south of Oadby includes a bypass at Desborough, a bypass at Market Harborough and a bypass at Great Glen. Kibworth is the only town or village without a bypass on this stretch of the A6.

Land at North East Kibworth should be identified as a proposed local plan allocation for circa 1,500 dwellings, 25 hectares of employment land and a relief road consistent with the description in the SHELAA.

The local plan period should be extended by at least one year.

Policy DS01 states that the plan period is 2020 to 2041.

Advice in Paragraph 22 of the NNPF clearly states the following.
'Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.'

The timescale for the formal adoption of the local plan remains unclear.

A plan period which ends in March 2041 would require formal adoption in March 2026 at the latest, i.e. in less than 12 months. The annual monitoring of housing completions is based on the 12 month period from 1st April to 31st March of the following year.

The most recent indicative Local Plan timetable as set out in the Harborough Local Development Scheme (LDS) dated February 2025 states the following.

Timetable - Key Stages
Reg 18 Issues and Options Consultation: January and February 2024
Reg 19 & 20 Proposed Submission Local Plan Consultation: Between March and May 2025
Reg 22 Submission of Local Plan for Examination: September/October 2025
Reg 26 Local Plan Adoption: October- December 2026*

*Indicative only at this stage as dependent on detailed arrangements for Examination by the Planning Inspectorate and decisions/recommendations by the Inspector including the need for and scope of any main modifications arising out of the Examination.

Based on the Council's own LDS, the Local Plan is expected to be adopted in October / December 2026. This is considered to be a very optimistic view and it is considered that the Local Plan is more likely to be adopted in 2027.

This means that the local plan period will be less than the minimum of 15 years set out in Paragraph 22 of the NPPF.

In order to meet the requirements of the NPPF, the plan period should be extended by at least one year to March 2042 and potentially longer. This would mean that the housing requirement for the Local Plan document should be increased accordingly by the equivalent of at least one year.

The additional 123 dwellings per annum to help meet Leicester’s unmet housing need in the period to 2036 should be extended by a further five years to at least 2041 to be consistent with the local plan period.

Policy DS01 refers to the housing requirement. This representation should be read in conjunction with the other representations submitted on behalf of Bellway Homes in relation to North East Kibworth.

Policy DS01 states that the plan period is from 2020 to 2041.

Paragraph 4.5 and 4.6 of the Local Plan refers to the Statement of Common Ground which relates to meeting Leicester's unmet housing needs. This states that an additional 123 dwellings per annum will be added to the Harborough housing requirement for the period 2020 to 2036.

The period 2020 to 2036 is different to the Local Plan period which is 2020 to 2041.

The two periods should be consistent and it is recommended that an additional 123 dwellings per annum to help meet Leicester's unmet housing need should be extended by a further five years to at least 2041 to be consistent with the local plan period. If Leicester City has unmet housing needs in the period to 2036, such unmet housing needs are very likely to continue in the period after 2036.

This would increase the overall local plan housing requirement by an additional 615 dwellings over the plan period.

The District housing requirement should meet the standard housing method figure of 723 dwellings per annum plus the Leicester City unmet housing need figure of 123 dwellings per annum which results in a combined figure of 846 dwellings per annum.