Regulation 19 - Proposed Draft Local Plan Submission

We do not require any changes to be made to the Vision section itself, but rather that the comments we have made
on various individual Policies will be adopted.

We greatly appreciate that the Draft Local Plan starts with setting out this Vision. It is clear and concise, and sets out an excellent framework for the policies that have been created.

However, as with all Vision statements, it is only as good as the detail that goes behind it, and we have concerns that the Policies that underpin it will not lead to the Vision being achieved. We have tried to point out in our comments on various Policies where this is the case.

Of particular concern are the policies that should be supporting the Vision statements on climate impacts and climate change; residents in new communities benefiting from improved access to local services; sustainable travel options; residents shaping new developments through effective communication.

In regard to this last point (i.e. public engagement), we feel that the development of the draft Local Plan itself, is a clear example of how HDC do not enable effective communication with the residents of the District. Some particular reflections we would ask HDC to consider are as follows: It is far too hard to input to the consultation process, as was the case at previous stages The format of the on line and Word template is too restrictive to generate proper engagement We feel that council officers and elected members should make far more effort to meet with people, talk to them about what they are planning, and actively listen to what they are told For our group, this has felt like a tortuous exercise, and for most members of the public we suspect it will be far too daunting to even consider making a response It is not feasible to expect individuals or groups to properly digest he vast number of documents and comment on them properly It will be interesting to see how many residents and groups in the District do actually respond Although we have taken a lot of time to put together what we feel are constructive comments, we suspect that no meaningful changes will actually be made to the draft Local Plan

The proposed sites MH2 and MH3 might be viewed as being in sustainable locations due to their relatively close
proximity to a range of services in Market Harborough. However, the travel distance from these sites to the town
centre presents a significant risk that sustainable transport measures will not be sufficiently attractive to encourage
and enable modal shift away from the car. Sites MH2 and MH3 cannot meet the requirements to prioritise
sustainable travel modes as set out in NPPF Paragraphs 115 to 118; nor in Para 12 & 13 of Circular 01/2022 and are therefore not deliverable. We consider this makes the Proposed Submission Draft Harborough Local Plan unsound.
We therefore recommend that sites MH2 and MH3 be deleted from the draft Local Plan.
The requirements of the Masterplan for the remaining MH1 area must be much clearer, and proper assessment of the Net Zero Impacts must be required. We also feel the Policy should be re-drafted to ensure that sustainable
transport modes are prioritised.

Whilst we are not in a position to argue with the overall number of houses needing to be allocated in Harborough District, we do not feel that Policy SA03 is sound, on a number of grounds.

1. Given the size of the proposed sites it will have huge impacts across the town, on top of the huge impacts that have already arisen as a result of the Wellington Place and Overstone Grange developments: roads in the town centre are constantly full of slow moving vehicles leading to poor air quality and frustrated drivers; finding spaces in carparks is getting increasingly difficult; trying to get appointments with a doctor is getting more difficult; it is almost impossible to sign up as a new NHS patient with a dentist; the Leisure Centre is not able to offer enough spaces in some classes; drains and sewers are not always able to cope; and potential Flood Risks are not being addressed adequately. We do not feel that such infrastructure considerations across the whole town have been adequately addressed in this proposal, and SO will not be effective in achieving the Vision set out on page 4, paragraph 2.
2. The location of the proposed site is SO distant from the town centre and key services and facilities (such as Leisure Centre, Health Centre, shops), that we feel it should be treated as a 15 minute community in its own right. i.e. key services and facilities need to be planned into the site, SO that residents can easily access them without the need for a car. Whilst this may be addressed by the proposed Masterplan, we have little confidence that this will be the case, and SO again the Vision paragraph 2 will not be achieved unless 3. The Masterplan must not be completed by a developer(s), but by an independent body such as AECOM; it should be created for the whole of the area, ie MH1, MH2 and MH3, which will involve ensuring residents can easily and safely cross the A6 road; it must be completed before any planning or pre-planning applications from developers are considered. Developers must not be able to split the site up into parcels that can be delivered without reference to the Masterplan, and key
facilities and services such as access roads, public transport, footpaths and cycle routes, schools, primary health facilities, shops and community centres must be built very early in the development of the area. We have seen at both Overstone Grange and Wellington Place that this has not been a requirement, and the communities are suffering as a result. We feel strongly that the Masterplan should specifically lay out a plan for a 15 minute community. If Vision statement 5 is to be effectively achieved, local residents must be properly engaged in developing the Masterplan
4. Within Policy SA03, paragraph 3e, specifically states that 'historic ridge and furrow should be preserved and enhanced where appropriate'. Referring to the map produced by English Heritage in 1999, called 'Turning The Plough' (attachment 1) the proposed site MH1 is almost all identified as Ridge and Furrow, as is a good portion of area MH2. To give some historical perspective Attachment 2, produced by Fred Hartley in 1947, illustrates just how much Ridge and Furrow landscape has already been lost in recent times. We feel that the policy should give much stronger protection to this increasingly rare feature of our countryside, if Vision statement 1 is to be effectively achieved.
5. Whilst reference is made to 'sustainability', the overall impact on the carbon emissions for the town of such a large new settlement has not been addressed. The Climate Action Act requires the UK to have achieved Net Zero by 2050, and HDC and LCC both have policies and strategies that state they support this aim. By the end of the life of the Local Plan in 2041, significant and measurable reductions must be achieved. We feel that assessing the Net Zero implications of creating such a large settlement must be assessed, and in due course monitored. This should include: emissions relating to site clearance; emissions embodied in building materials; operational emissions as the site is developed; any impact of loss of fields, trees and hedges; emissions from homes and other buildings once they are occupied; emissions from cars and other vehicles as they move around the site and to other parts of the town. Vision Statement 1 cannot be effectively achieved without this.
6. ‘Policy SA03: North of Market Harborough’ relates to the cluster of sites to the North of Market Harborough (MH1, MH2 and MH3), identified for new sustainable, residential-led mixed use development. It states: “3. ... The Masterplan for the site must: f) Provide safe highway, footway and cycleway connections that are permeable through the cluster of sites and connecting new schools, community facilities and into the town centre to maximise
opportunities for sustainable modes of transport; “and:
“5.26 Addressing the cumulative transport impacts is necessary to manage increased traffic, ensure road safety, and promote sustainable travel. Safe vehicular access, regular bus services, and high-quality cycle and pedestrian routes are vital to reducing car
dependency and encouraging healthier, more sustainable modes of transport.” The National Planning Policy Framework (NPPF) (December 2024 sets out a presumption in favour of sustainable development. The specification for the Masterplan set out in Policy
SA03 is incompatible with NPPF Paragraph 115 which states that “In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that: a) sustainable transport modes are prioritised …”.
7. We have serious concerns about the proximity of MH2 to the rendering factory on the A6. The Masterplan should explicitly lay out how the nuisance and possible air pollution will be mitigated against. This will require expert advice from independent sources.
See attachment/s for maps referred to in point 4.

Policy DS05 should be rewritten to ensure it is sound. i.e. that they Policies are implementable and effective.

We agree that Supporting Strategic Infrastructure needs to be a key part of the Local Plan. However experience from recent years has shown that planning policies have not been adequate to ensure that infrastructure in Market Harborough has been properly reviewed and appropriate improvements made when large new developments happen Both the Wellington Place and Overstone Park developments have demonstrated this.

Policy 1: We support this policy, but fear that HDC will not have the resources to ensure planning applications submitted by developers are robustly examined, or to ensure that developers are actually delivering what has been agreed in their approved plans Policy 2 we recommend the word 'should' be replaced with 'must' - Policy 3: The use of the word 'timely' is far too open to interpretation. It should be made much clearer what is expected. For example, we have seen that leaving the provision community facilities at both Overstone Park and Wellington Place till such a late stage, means that new residents are unable to start forming a proper community feel.
Policy 4: we recommend the word 'should' be replaced with 'must'
Policy 4a : In the case of settlement SA01 the Masterplan must ensure that primary and secondary schools are built, as existing schools are too far away to be accessible without the use of a car. Also these must be built in time to enable the children of new residents to attend them very soon after they become resident. We feel that the words from Policy 4b relating to accessibility to health provision should also be included in Policy 4a. We feel that it is really important for schools to be open early on in the life of a new development. If they are not, parents will enrol their children at more distant schools, and may then not want to move them to a more local school when it is built. Policy 4c: As a Neighbourhood Forum, we are regularly told by our members that there is too much traffic congestion in the town centre and immediate surrounding areas, and not enough parking for either residents or visitors. We feel that review of Transport Strategies by HDC will need to much more rigorous in future. Similarly members tell us that there are not enough options for sustainable modes of transport and developers must be made to address this properly also our comments on Policy DM06). We feel that it is really important that residents to new developments can quickly and easily get into the habit of using sustainable modes of transport as soon as they move in. If they have to rely on their cars when they move in because safe walking and cycling routes, and public transport are not available, it will be hard to get them to change this habit.
Policy 4d: There should be a requirement for developers to give new residents comprehensive information about the waste and recycling facilities in the District

Policy 4 (Developer contributions): This Policy appears to be mis-numbered, and we think should be 5? This Policy is clearly required, but recent experience has shown that the section 106 funds are not managed as effectively as they could be. There needs to be a much more open process for managing this fund, and local residents must have a way of inputting to the decision making progress. There should be an obligation on HDC to ensure that developers make all of the contributions that are agreed, and that no money ever has to be handed back to the developers because it has not been spent.

Policy 5 (Viability Review): This Policy appears to be mis-numbered, and we think should be 6? Again, this is a really important policy, SO it is vital that HDC have the resources and experience needed to adequately review any requests for variations. We are particularly concerned about the number of occasions when developers appear to 'demonstrate' that they are no longer able to provide the number of affordable houses originally set out in the planning application. Such applications must be robustly countered.

Overall, these comments lead us to feel that this Policy DS05 is unsound, as it will not be effective in delivering the Vision as set on Page 4. We also believe DS05 to be unsound as it is not positively prepared, in SO far as it does not meet the strategic needs of the area and that evidence base used to assess those needs is insufficient. In particular in relation to transport infrastructure and the Infrastructure Delivery Plan does not include clarity of how sustainable infrastructure will be delivered.

Policy DS03 should be rewritten to make specific requirement for Net Zero Impact Assessment for any planned developments.

The thinking behind these policies in this section is to be welcomed, however, we feel they should be strengthened in order for the impacts to fully realised.
In order to be compliant with the Climate Action Law, and HDC's own Climate Emergency Action Plan, we feel that an overarching policy should be included requiring potential developments to create a Net Zero Impact Assessment. It must be demonstrated, and measurable, that any development will lead to a reduction in carbon emissions, and will help move the District towards a Net Zero position by the end of the Plan period.
Instead of 'development will be permitted', we feel that all of the policies should be prefaced by development must'
- We feel that HDC will need to be much better at monitoring and policing these policies in the future than they have been to date. Developers must not be allowed to change their plans to avoid these policies once development is underway, nor to just ignore the requirements as they progress. For example, Policy 3c requires developments to retain woodlands, hedgerows and semi rural habitats. The area of land covered by the SA01 settlement is currently rural landscape, with many hedges and trees. HDC already has one of the lowest levels of tree cover in the country, and it is essential that developers are not allowed to by-pass this policy. Otherwise, paragraph the Plan will not be effective in delivering the first paragraph of the Vision set out on Page 4.
- Paragraph 4.34 states the importance of 'locating residential areas near accessible services'. In the case of settlement SA01, it will be impossible to achieve this based on current services. These must all be built into the settlement, SO that schools, shops, primary car facilities, sports and leisure facilities must all be planned into the settlement from the start, and not just left as an afterthought. As it stands, this Policy will not be effective.

Policy DM06 should be amended to read;
“Policy DM06: Transport and Accessibility
2. All major development is required to fully adopt a Vision Led approach and submit a Transport Assessment which considers the impact of development on the safe, efficient and reliable operation of the transport network. The assessment will also identify the mitigation required to ensure the impact is managed or mitigated effectively. All major development must also:
a) incorporate measures to facilitate and encourage safe access by cycle and on foot along with protection of,
connection to and extension, of existing pedestrian and cycle routes.
Networks and routes should be Coherent; Direct; Safe; Comfortable and Attractive as set out in LTN1/20 Cycle
Infrastructure Design.
b) provide accessible cycle parking;
c) deliver public transport enhancements to mitigate development impacts, including but not limited to bus routes and timetable improvements, information and waiting facilities and behaviour change measures to encourage public transport use;
d) ensure that inclusive design and accessibility is prioritised, and that the transport needs of specific community groups, including the elderly and those with disabilities, are effectively met: and
e) ensure car parking provision sufficient for the location and type of development, and make provision for Car Club spaces and EV charging points; and
f) mitigate any adverse impact on residential amenity and air quality. “

Whilst the explanation for Policy DS03 states "4.34 This policy embeds a sustainable transport hierarchy which aims to reduce high carbon travel modes in favour of more sustainable alternatives like walking and cycling", this is not carried forward to Policy DM06. Given that DM06 relates specifically to Transport and Accessibility this is a significant omission. Furthermore, we contend that neither DS03 or DM06 give sufficient weight to the need to prioritise sustainable transport modes, nor to establishing a hierarchy of travel choices.

The Harborough Local Plan Strategic Transport Impact Assessment (January 2025) states "4.3.1 As noted in Section 1, the requirements for active travel mitigation have become more important in recent years, with the formation of Active Travel England (ATE) and the publication of LTN1/20. Pedestrians and cyclists are now recognised at the top of the transport hierarchy."

The HDC Climate Change and Renewable Energy Study: Policy Review (October 2024) also recommends a number of policy approaches for reducing carbon emissions from transport related to new development (Para 2.119). First amongst those policy options was to "Require a sustainable transport hierarchy" and the example given was from the Suffolk CC Local Transport Plan. A similar approach is taken by Warwickshire County Council in their LTP4.
We RECOMMEND that HDC introduces the principle of a Sustainable Transport Hierarchy within the Local Plan and makes it a requirement to be delivered within all future developments and in any relevant site allocation policies. As travel infrastructure is far more challenging to incorporate at later stages, HDC should also require the sustainable transport hierarchy to be considered at the commencement of any development or master planning process.
The HDC Climate Change and Renewable Energy Study: Policy Review (October 2024) recommends (Paragraph 120) a number of policy approaches to reducing carbon emissions in transport "should not be considered in isolation, but rather, as able to complement and/or supplement each other to strengthen the overall consideration for transport emission sand maximise the benefits to Harborough."
Whilst we welcome the adoption of a number of those recommendations, we consider that Policy DM06 does not fully reflect the requirement to prioritise sustainable travel modes as set out in NPPF Paragraphs 115 to 118 and this makes the Proposed Submission Draft Harborough Local Plan unsound.
We RECOMMEND the following amendments to strengthen Policy DM06 and ensure compliance with NPPF Para 117.

Introduce a new DM Policy that covers Health Impact specifically, and in more detail.

We welcome the requirement for health impact assessments, however consider this should apply to all major development.

Health and Wellbeing is the key to a thriving town and needs its own section in the local plan. The policy should be proactive rather than reactive, recognising that if they are in good health members of our communities will be able to contribute to the economy and the community. With good prevention measures to reduce ill health, their demand on local services will reduce. In turn this will lead to a healthier life expectancy.

Health Impact should have a specific planning policy that has health and wellbeing at its forefront but also continue to have health and wellbeing run like a golden thread throughout the document. It's not either/or.

Such a policy may encourage healthy lifestyles but it can only do that if the wider determinants in Market Harborough - that is the existing infrastructure and environment - makes it possible for people to choose and be able to afford to choose a 'healthy lifestyle'.
The impact on health of all development needs to be recognised throughout the document. All changes and developments within the district will impact in some way on the health of residents and adjustments for this need to be incorporated at the relevant points. Health and health inequalities need to be considered whether we are talking about building more houses, accommodating more businesses, expanding schools, increasing or reducing vehicular traffic or creating more coffee shops!

Policy AP05 should be rewritten to ensure it is sound, and complies with the Climate Change Act.

We feel that a Policy that merely states that 'development of will be permitted' is unlikely to ensure that the requirements of the Climate Change Act will be met in the District.

There needs to be a much higher expectation that developers will use such technology to ensure that great strides towards achieving Net Zero will be made in the life of the Local Plan.

On large new settlements, where an area will have to be cleared before development can begin, developers must be required to install either district or area heating networks SO that ground source heat pumps can be cheaply and efficiently installed as new houses are built; or guarantee that all new houses will have air source heat pumps installed, and sufficient solar PV generated to power them. It must not be possible for houses on new developments to have heating systems that rely on fossil fuels.

More broadly, we feel that the Local Plan should be positively supporting proposed developments for generating renewable energy other than with domestic Solar PV. For example on land that is not suitable for growing crops, or on buildings such as car parks and warehouses, that have poor sustainability profiles. There should also be positive support for Community Energy projects that will enable local communities to benefit, for example Solar PV share offer schemes on schools and community buildings. As it stands we do not feel this Policy is not sound, as it will not be effective, and is not in line with National Policy.