Proposed Submission Draft Local Plan Sustainability Appraisal

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Representation ID: 13903

Received: 02/05/2025

Respondent: Ashfield Land

Agent: Pegasus Group

The Sustainability Appraisal (SA) (February 2025, Doc S-NLP4) published alongside the Reg 19 Proposed Submission Version Local Plan refers to the options and reasonable alternatives considered for employment land development in Harborough at Chapter 4.

NPPF paragraph 33 identifies that local plans should be informed throughout their preparation by an SA which meets the relevant legal requirements, and which should
demonstrate how the Plan has addressed relevant economic, social, and environmental objectives. The purpose of the SA is to assess the sustainable development implications of the proposals presented in the Proposed Submission Draft Local Plan, where the SA outputs should have informed the Council’s Vision, Objectives, Spatial Strategy and policies.

The SA has utilised a Framework to evaluate how the different reasonable alternatives for growth and the policies of the emerging Plan perform against the 14 SA objectives, identified in Chapter 3 of the SA. These are:
1 – Minimise greenhouse gas emissions and develop a managed response to the effects of climate change
2 – Protect, enhance and manage biodiversity and geodiversity
3 – Support efficient use of resources, including soils
4 - To conserve and enhance the historic environment including the setting of heritage features
5 – Protect and improve air quality
6 – Safeguard and improve health, safety and wellbeing
7 – Achieve social inclusion and equality for all
8 – Provide access to services, facilities and education
9 – Provide affordable, sustainable, good-quality housing for all
10 – Support the sustainable growth of the economy and provide employment opportunities
11 – Reduce waste generation and increase levels of reuse and recycling
12 – Manage and reduce flood risk from all sources and protect the quality and quantity of water resources
13 – Promote sustainable transport use and active travel
14 – To conserve and enhance the character and distinctiveness of the landscape

Within the SA, three options were considered in terms of the amount of employment growth that the Plan would provide for. These are identified as ‘low’, ‘medium’ and ‘high’ levels of growth but no quantums or size parameters are included in the SA.

The SA concludes that the ‘low’ level of growth would not be appropriate, and goes on to discuss the medium and high level options, but again there is no discussion on the quantums of development that are being assessed.

There are also three spatial options considered in the SA for the location of employment development. None of those options include new locations that would meet locational requirements and aspirations. Particularly for B8 uses, where the Council’s own evidence base sets out the locational requirements, and identifies optimum locations, for such development, including rail freight locations that would have access to other facilities particularly now the Hinckley NRFI has been refused.

The SA is not considered to have fulfilled its legal requirements to justify the Local Plan strategy. In neither referring to the quantums of development being considered at each ‘growth level’ for employment land, nor including for all reasonable alternatives in terms of the location of that growth, it is failing its legal requirements and the Local Plan itself cannot be considered to have proposed a sustainable strategy.

The SA has appraised the Ashfield Land’s interests south of Gibbet Lane, as well as the proposed allocations of land for strategic B8 employment development at Magna Park.

Ashfield Land’s land interests perform better than the proposed allocation of land of 15.8 hectares south of George House, Coventry Road with reference to Objective SA6 regarding safeguarding and improving health, safety and wellbeing, and comparatively for all other objectives.

Further, it is considered that the assessment of the land south of Gibbet Lane in respect of SA Objectives 12 and 14 should be reconsidered. Consultant work is being undertaken on flood risk and drainage to ensure the development will not increase the risk of flooding elsewhere, and detailed advice has been provided on landscape such that the development can be adequately assimilated into the landscape with no long-term significant adverse effects. As such the impact for both SA Objectives 12 and 14 should be neutral and minor
adverse or neutral respectively. Similarly, with a requirement to deliver 10% BNG, Objective SA2 should be considered neutral, or even minor positive. The proposed development will have no impact on any heritage assets and therefore the impact should be neutral.

Other matters have been considered based on site knowledge and any ambiguity such as the use of ‘question marks’ has been addressed.

Taking those matters into account it will actually perform better than the two proposed strategic B8 allocations, Table 1 provides a visual comparison.

In order to fulfil the relevant legal requirements, the SA must be reviewed and updated, or the Plan cannot be found sound. In addition, all SA Objectives and site reviews should not result in ambiguity over potential effects but take into account site specifics for each and provide a view on the potential impact on the relevant objective.