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: 13794
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? No
We support the HLP’s provision for Leicester’s unmet need but note that this does not apply throughout the Plan period. Beyond 2036. the HLP makes no provision to address potential wider shortfalls within the Housing Market Area (“HMA”)
We consider that the following modifications should be considered to ensure the HLP’s soundness.
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.
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.
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 are accommodating
housing growth in preference to less sustainable ones.
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.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy IM01: Monitoring and review of the Local Plan
Representation ID: 13796
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? No
A further matter Policy IM01 should address is the differential between the HLP’s annual average housing requirement (657 dpa) and the more recent local housing need (“LHN”) for Harborough District calculated using the new Standard Method (723 dpa). Given the differential between these figures and the fact that it will widen even more significantly from 2036 onwards, we expect that the Council will be required to progress a review and an update to address the District’s own needs regardless of events within the wider HMA.
A further matter Policy IM01 should address is the differential between the HLP’s annual average housing requirement (657 dpa) and the more recent local housing need (“LHN”) for Harborough District calculated using the new Standard Method (723 dpa).
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN01 Housing Need: Affordable Homes
Representation ID: 13798
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? No
The HENA identifies a need for affordable homes in Harborough of 421 dpa compared with an annual average requirement for overall housing of 621 dpa. Given that affordable housing can only be viably delivered at 40% based on the HLP and its evidence base, the overall housing requirement will not address the objectively assessed needs for affordable homes. There is no indication within the HLP or its evidence base that the relationship between the overall affordable housing needs and the housing requirement has been considered and an increased housing requirement would clearly facilitate the delivery of more affordable homes overall, which would help to alleviate the District’s significant affordability challenges.
HLP should support an uplift in delivery to address the acute need for affordable homes. The decision not to uplift the housing requirement to address affordability concerns in line with the PPG lacks justification.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
4.9
Representation ID: 13804
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? No
we agree that RO3 (balancing growth between the urban area and the market towns, with a medium level of growth directed towards the large villages) is the optimal approach and endorse the SA’s findings in this regard.
We note that Policy DS01 allocates 350 homes to Small
Villages through settlement specific apportionments to be delivered through neighbourhood plans, with an additional 452 homes directed to Medium Villages. This represents a significant share of growth at the lower end of the settlement hierarchy and must be supported through evidence within the SA.
we agree there remains a clear role for growth across all tiers of the hierarchy.
See attachment for full representation document.
Object
Regulation 19 - Proposed Draft Local Plan Submission
4.11
Representation ID: 13811
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
Legally compliant? No
Sound? No
Duty to co-operate? No
Table 2 HLP has a supply buffer over and above the minimum requirement of about 12%.
The HLP appropriately recognises the difficulties of over-reliance on strategic sites and should therefore provide a meaningful contingency of supply from alternative sources
The HLP’s housing trajectory at Appendix 5 should be supported by objective analysis to underpin its assumptions regarding the timing and rate of delivery across all components of housing supply
Given the risks inherent within the spatial strategy, we would expect to see a higher buffer of closer to 20% rather than the 12% proposed. We would therefore encourage HDC to consider a greater supply-side buffer of about 20% in line with the approach suggested in the issues and options consultation.
We consider that the following modifications should be considered to ensure the HLP’s soundness.
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.
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.
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 are accommodating housing growth in preference to less sustainable ones.
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.
See attachment for full representation document.
Support
Regulation 19 - Proposed Draft Local Plan Submission
HH1
Representation ID: 13845
Received: 02/05/2025
Respondent: Clarendon Land
Agent: Marrons
For the avoidance of doubt, Clarendon Land & Development support the draft allocation
The draft allocation for the site (reference HH1) is for around 80 dwellings. Clarendon Land and Development has submitted a planning application (awaiting registration) , supported by a constraint-led masterplanning exercise, which indicates that up to 90 dwellings are capable of being delivered on site whilst meeting policy requirements for open space and the ambitions for development to occupy the eastern part of the site.
See attachment for full representation document.
