Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
Policy DS01 Development Strategy: Delivering Homes
Representation ID: 13637
Received: 04/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
BDW considers the broad thrust of the HLP to be sound. However, appropriate provision should be made for addressing Leicester’s unmet need between 2036 and 2041.
The housing requirement should be re-considered in light of wider evidence in respect of affordable housing need. A supply-side contingency of least 20% should be introduced for flexibility. The SA process should consider higher growth scenarios across the refined distribution options, which should also consider an option based upon more limited growth to the tiers of settlements at the lower end of the hierarchy.
Gallow Field Road, Market Harborough has been rejected by virtue of its location within Foxton AoS without an objective review of the Foxton AoS. We therefore request that the site selection evidence base and the AoS Study us updated as appropriate.
The following modifications should be considered to ensure the HLP’s soundness:
1. Firstly, the HLP should contain a clear mechanism for addressing Leicester’s unmet need beyond 2036 should this arise. Whilst an early review policy has been incorporated, 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.
2. Secondly, 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 acute need for affordable housing.
3. Thirdly, the SA should consider a “high growth” scenario across the refined options, consistent with our wider observations in relation to the housing requirement. The SA process should demonstrate that more sustainable settlements (i.e. market towns) are accommodating housing growth in preference to less sustainable ones.
4. Fourthly, 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.
If sites are to be assessed and rejected based on Green Wedge or Area of Separation designations that this decision should be solidly grounded in evidence. At present, no part of the evidence base, including the AoS Study, appropriately reviews and responds to the Foxton AoS, despite this being the sole reason or rejecting sites 8019 and 8222. The study and the wider evidence
base should be updated as appropriate.
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
Representation ID: 13638
Received: 04/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Omission site Land at Gallowfield Road, Market Harborough (combining Site Reference 8019 Land West of Harborough Road and 8222 Land North of Gallowfield Road) is promoted for allocation.
That the assessments are updated to coincide with the parcel of land now subject to promotion by BWD, as shown edged red (see attachment)
See attachment/s.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Our Local Plan Vision
Representation ID: 13773
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
Assuming adoption in Dec. 2026, the plan period needs extending to achieve a minimum 15 year period.
- 2020 start date is inappropriate and should be 2025. Most of the evidence published after 2020.
- Council should commit to early review to meet increased housing requirement under new standard method.
- Vision should have regard to catering for Leicester City’s unmet need and effective delivery.
- Vision should state specifically the Plan's housing
requirement to outline clearly the aims of delivery across the plan period.
- Over reliance on large strategic sites. Needs greater emphasis on provision of smaller, more deliverable sites to complement larger schemes.
- Link between jobs and homes needs further consideration.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
3.1
Representation ID: 13775
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
We question why the Council have decided to ‘water down’ the previous objectives drafted and consider the updated objectives do not accord with NPPF Paragraph 15.
We consider the revised objectives proposed as part of the Regulation 19 consultation are not reflective of the broad range of spatial planning issues currently present within the District. The objectives proposed at Regulation 18 stage were more appropriate and covered a broader range of topics than the revised objectives. On this basis we consider the Council should review the proposed objectives and ensure the accord with the aims of NPPF Paragraph 15.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS01 Development Strategy: Delivering Homes
Representation ID: 13777
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
To meet the District's needs, the housing requirements should be reviewed to ensure a suitable level of housing is provided. As currently planned for, HDC are at risk of either not meeting the required 80% of the new standard method as per the transitional arrangements, or are at risk of breaching the Statement of Common Ground and not providing the agreed housing on behalf of Leicester City, as it has not been made clear which the Council are prioritising.
The housing distribution needs to ensure that the housing that is being delivered is distributed suitably where there has been a need for housing identified (i.e. large villages such as Fleckney). Currently, the Plan focuses only on the Leicester Urban Area/market towns.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
4.9
Representation ID: 13778
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
We agree with the assessment as Fleckney as a
large village. We consider it is appropriate for a reasonable level of growth to be directed towards Fleckney to cater for housing need and also support and maintain the use of existing facilities and service provision. Although the proposed F1 housing allocation has been put forward for 150 dwellings we consider further growth and
development should be directed here to support the housing requirement across the District. The additional
allocation of the landowners site, which lies to the north of the proposed F1 allocation, is a sustainable location.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA01: Site Allocations
Representation ID: 13779
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
Site selection methodology: We welcome growth being directed to Fleckney but consider further allocations should be recognised in smaller settlement hierarchy tiers rather than overall provision to support growth across the plan period. The approval of Wistow Lodge Solar Farm has significantly impacted on Land west of Leicester Road's relationship with the surrounding countryside and perceived encroachment. Given this change in context, the site should be reassessed and carried forward for detail assessment as part of the Site Selection Methodology.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA02: Land South of Gartree Road Strategic Development Area
Representation ID: 13784
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
- Housing delivery on the site (as set out in the trajectory) is overly optimistic both in terms of commencement and build out rate. This is supported by the Lichfield 'Start to Finish Report 3'.
- The site is a cross-boundary site. Time needs to be provided for within the Housing Trajectory to account for delays which may be incurred in working with two local authorities.
- Regarding affordable housing, the Viability Report found that the site is only marginally viable when a 40% requirement is applied.
- Contamination on site could create further delays.
We consider the commencement of delivery from this strategic allocation should be amended to 9 years following adoption of the Local Plan. If the Local Plan is adopted in 2026 (as anticipated within the current Local Development Scheme adopted in March 2025), this would see delivery pushed back to 2035/36.
In addition to the delivery of the first dwellings on site, the build out rate also needs to be considered. Appendix 5 currently proposes a build out rate of 150 dwellings per annum. We consider that this build out rate should be reduced to be more realistic. Within Lichfield’s Start
to Finish Report, sites of a scale of 2,000 dwellings or more on average deliver 138 dwellings per annum. The build out rate of the site should be based on the evidence and a build out rate which has been shown to be achievable. This will ensure that a realistic and achievable
build out rate is provide, which assists in ensuring that Harborough is not subjected to under delivery of needed dwellings.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA03: North of Market Harborough
Representation ID: 13785
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
The Housing Trajectory provides a series of commencement years for the different sites, despite the allocation requiring a singular masterplan needing to be in place for all the sites. The Housing Trajectory should align with the proposed policy, to ensure that a carefully designed masterplan is brought forwards to provide direction for development across the allocation area. The commencement of delivery of the allocation should commence from 2032/33 to allow for agreement in how development is brought forward. Given the lack of consideration re: financial contributions or onsite infrastructure, the site should be put back in the Housing Trajectory to allow for greater certainty and details to be provided, to ensure that the site is viable.
We suggest that commencement of delivery is pushed back to commence from 2032/33 for all sites included within Policy SA03. This will ensure that housing delivery in the short term is not jeopardised and expected delivery does not slip back due to complications in agreement from landowners, as well as allowing for a suitable masterplan to come forward.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA04: Scraptoft East
Representation ID: 13787
Received: 02/05/2025
Respondent: Barratt David Wilson North Midlands
Agent: Boyer
Legally compliant? No
Sound? No
Duty to co-operate? No
The trajectory is overly optimistic in terms of when the site will start delivering dwellings and build out rate (Lichfield's Start to Finish Report). This should be reflected in the Housing Trajectory.
Marginal viability when providing 40% affordable housing on site and existing cumulative traffic issues, further support the need for the delivery of housing to be delayed in the trajectory to allow for additional time for confirmation the proposed allocation is indeed viable, with the ability to provide the affordable housing, with the needed mitigation works on the identified highways.
Suggest that commencement of delivery should be 2031/32 rather than 2030/31 as currently expected.
To ensure an accurate delivery rate is provided on site, from the second year of delivery the build out rate should be amended to 68 dwellings per annum. This will see a total delivery of 662 dwellings in the plan period.
See attachment for full representations, including those relating to the promotion of the site 'Land to the west of Leicester Road, Fleckney'. These representations have been prepared by Boyer on behalf of Barratt David Wilson
Homes (North Midlands) and Mr Charles John Halford Brooks.