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: 13741
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The housing requirement should be reconsidered because no provision is made for: Leicester's unmet beyond 2036, or potential wider shortfalls in the HMA via a Statement of Common Ground to 2041. It would be prudent to address rather defer this issue to a plan review.
There is a clear and compelling case to test a higher housing requirement, through the SA process, to respond to these longer-term strategic challenges.
The plan should also support an uplift in delivery to address the acute need for affordable homes and provide a higher buffer of closer to 20% to address the inherent risks associated with the delivery of very-large scale development.
The overall apportionment of growth to the Leicester Urban Area follows the settement heirarchy. We agree generally that a balanced spatial distribution of growth should occur at all levels of the heirarchy allowing towns and villages to grow proportionately. Flexibility and contingency, in terms of the housing supply trajectory, can be delivered through allocatimng small and medium size sites in the more sustainable villages rather than cascading to settlements with less sustainability credentials.
Firstly, 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.
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 need for affordable housing.
Thirdly, the SA should consider a “high growth” scenario across the refined options, consistent
with our wider observations in relation to the housing requirement.
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.
Fifthly, whilst we consider a balanced approach between the Leicester Urban Area and the market towns to be justified, the spatial strategy cascades reasonably significant growth down to the lowest lower end of the settlement hierarchy (i.e. the small villages). The SA has not considered an approach that would apportion more growth toward the more sustainable rural settlements which in our view would represent a more sustainable outcome. We encourage this to be considered.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS04 Development Strategy: Preserving and Enhancing our Heritage and Rural Character
Representation ID: 13748
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Generally supportive of the retention of the extent of the Scraptoft Green Wedge. However we disagree with the fundamental conclusion of the Harborough Green Wedge Assessment, as it disregards the imperative to balance retention with the requirement to accomodate development needs in the most sustainable location.
Object to elements of the Green Wedge assessment including; the policy analysis, assessment findings regarding the contribution of sub-area GW1B (preventing merging, guiding development form) and the methodology for assessing recreational resource.
Agree the assessments recommendations about the Scraptoft East allocation are justified and can be addressed through appropriate masterplanning.
We do not raise any objections to the retention of the extent of Green Wedge as shown on the Policies Map, which are consistent with the wider findings of the Green Wedge Assessment. We request that the Assessment or a separate topic paper acknowledges the wider role in the
Leicester fringe in meeting Harborough’s own housing needs and Leicester’s unmet need for housing in the most sustainable location.
We also request that wider analysis around the strength of the existing Green Wedge between Scraptoft and Thurnby/Bushby is reviewed in line with our comments to ensure the findings in this regard remain methodologically robust and consistent.
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Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy DS05 Development Strategy: Supporting Strategic Infrastructure
Representation ID: 13754
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
We agree that all developments within the wider catchment, including Sites S2 and TB1, should make proportionate contributions toward the delivery of the primary school at Scraptoft East.
Limb 4c) of the policy is not justified and any planning condition or obligation securing this would be unreasonable.
Limb 4d) the measures to be delivered as part of the Transport Strategies within the bulleted list are not sufficiently focused and its not sufficiently clear that contributions should only be sought where proportionate to address the transport impacts of the specific development.
In respect of Policy DS05 1. d) as regards the Scraptoft, Thurnby and Bushby cluster of proposed allocations, it should be made clear that Sites S2 and TB1 should make financial contributions towards aiding the delivery of the new primary school at Scraptoft East.
In respect of Policy DS05 4. c), the effect of this clause is to effectively make the provision of sufficient foul water treatment capacity the responsibility of the developer through restricting timescales for unit occupation when utility providers are under a statutory obligation to provide sufficient capacity. This element of the policy is unjustified and should be removed.
Policy DS05 4. d) in respect of Transport Strategies requires fundamental revision to make it clear that contributions to highways and public transport improvements will only be sought where these are proportionate to a development’s impact as quantified through Transport Assessment.
Tying mitigation measures to generic measures within Transport Strategies will sever the link between the project’s impact and the mitigation secured, resulting in disproportionate burdens which cannot be justified through the statutory CIL tests. In addition, the Transport Strategies referred to do not form part of the HLP or its evidence base nor are they available elsewhere. We request that the reference to Transport Strategies is deleted entirely for plan soundness.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy SA04: Scraptoft East
Representation ID: 13762
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Concerns are raised about the need for and wording of policy criterion 1d, 1f, and 1g.
We agree its sensible to limit the number of very large sites to 1 per refined option. In respect of the site selection / assessment process we have a fundamental concern about the methodology Stage 3 criterion 6 (impact on Green Wedge) being an absolute constraint. Directing growth towards the Leicester Urban Area, must necessarily involve a review of Green Wedge, and the methodology should be amended or clarified to reflect the Councils approach.
The sites technical assessment demonstrates that it has no fundamental constraints that cannot be overcome. Supporting evidence is provided regarding Agricultural Land Classification. The need for a detailed Minerals Assessment is disputed.
We support the overall thrust of Policy SA04 in proposing to allocate Scraptoft East for about 950 dwellings and associated infrastructure. The site is deliverable and experiences no fundamental technical constraints. Part of the site is designated as Green Wedge. However, it is appropriate to review these designations to ensure that development needs can be met in the most sustainable locations. The SA process has clearly shown the overall development strategy of focusing significant growth on the edge of the Leicester Urban Area performs well against the reasonable alternatives. The site allocation is in conformity with that development strategy.
We request that Policy SA04 is amended to omit references to a comprehensive masterplan as this is unnecessary given that each developer is working together to deliver the site. We also request that the reference to the site addressing existing cumulative transport impacts to the southeast of Leicester is reviewed. This should either be deleted entirely or edited to clarify that Scraptoft East should only be required to mitigate its own impacts on the highway network.
Lastly, a detailed Minerals Assessment is not required given the depth of the resource is not sufficient to support a standalone minerals extraction operation and given the proximity to sensitive receptors (i.e. residential development). The clause of the policy requiring a Minerals Assessment should therefore be deleted.
The site has undergone a thorough and proportionate evaluation, as well as an objective selection process. While we disagree with treating the Green Wedge as an absolute constraint, this has not impacted the assessment outcomes. However, we encourage the Council to provide additional evidence on its approach to the Green Wedge, perhaps in the form of a topic paper or similar document, to supplement the existing evidence base on this issue.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN01 Housing Need: Affordable Homes
Representation ID: 13769
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Detailed concerns are raised about the Viability Report in terms of; the analysis of opportunities and constrains of the Scraptoft East site, engagement between the developer and the viability consultants, and the assumptions made in the report.
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Support
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN04 Housing Need: Supported and Specialist Housing
Representation ID: 13772
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
The evidence on need is based principally on the District's ageing population, a national trend. The Written Ministerial Statement and PGG allows adoption of enhanced technical standards on an authority by authority basis based on local evidence including; accessibility and adaptability of the existing housing stock.
Policy is not currently justified by local evidence including how the threshold of 100 units and the percentage requirement relates to the overall scale of needs. Appropriateness of a blanket approach is questioned. Policy does not contemplate a scenario where there is a lack of demand, or for units to be delivered as market units should a lack of demand be evidenced.
Policy lacks justification and should be revisited.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN05 Housing Need: Self and Custom Build Housing
Representation ID: 13780
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Integrating self and custom-build plots within large-scale housing developments is challenging because it; is difficult to co-ordinate construction, poses health and safety risks, comes forward over much longer timeframes and is often not liable to Section 106 contributions towards infrastructure.
Self build should be encouraged using council-owned land or designating specific sites via negotiations with landowners.
Supportive of a mechanism to allow unsold plots to be built out as market housing, however 18 months is overly restrictive. Six months is adequate, with no requirement for plots to be available immediately to validly commence the marketing period.
Policy is unsound for want of justification and should be deleted.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM02: Amenity and Wellbeing
Representation ID: 13783
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Generally supportive of a policy requirement to safeguard residential amenity. Development should be opposed on amenity grounds only where it causes material or significant harm to users of nearby land and buildings—not based on subjective thresholds of “acceptability.”
DM02 1a) recommend deleting the phrase “which cannot be mitigated to an acceptable level”, as it introduces unnecessary ambiguity.
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Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy DM04: Landscape Character and Sensitivity
Representation ID: 13786
Received: 04/05/2025
Respondent: Davidsons Developments Limited and Jelson Homes Limited
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Whilst generally supportive of a policy requirement to address landscape character and sensitivity, Part 1 d) of the policy refers to restoring and providing equivalent mitigation for damaged features and/or landscapes that would be damaged or degraded as a result of development. It is not clear what this element of the policy requires. It is clearly not practical, viable or developable to expect new development to restore or compensate for the loss of landscapes themselves as all new development will, by its nature, have a landscape impact.
Landscape features lost can be provided for where practicable.
We propose that Part 1 d) of Policy DM04 is deleted for soundness.
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