Proposed Submission Draft Local Plan Sustainability Appraisal

Please refer to the uploaded documents Land off Uppingham Road, Bushby – Reps to the Evidence Base SA and Land off Uppingham Road, Bushby – Site Opportunity and Promotion Statement submitted in response to the proposed plan objectives and policies DS03, SA01 and DM05.

Appendix F of the Sustainability Appraisal presents a map showing the location of the sites considered for allocation in the New Local Plan. The site being promoted by our clients for up to 850 new homes to the south of Uppingham Road in Bushby was given the reference 21/8150.

Appendix E of the Sustainability Appraisal contains a table which explains the Council’s reasons for selecting or rejecting site options. It confirms that the Bushby site has not been taken forward as a proposed allocation “Given its encroachment into open countryside to the south and east (towards Houghton on the Hill), the site is not considered an appropriate location for residential development when compared with other locations and deliverable sites of a similar scale within the Scraptoft, Thurnby and Bushby area. The site was put forward for mixed use development. As the site is not considered appropriate for residential development, it is unavailable for consideration for employment use.” We would point out that any employment to be considered at this location, would only be included as a supportive use such as small scale convenience opportunities in support of a residential development.

The above notwithstanding, the Landscape Constraints and Opportunities Plan and Concept Masterplan supporting these representations demonstrate how the site could come forward (see Appendix 2) incorporating landscaping and green space to the south, west and east of the site. This would essentially contain the development of the site, which would form a natural extension of the sustainable settlement of Bushby.
The site has been promoted for a mixture of uses, including employment and residential uses, to discount this site on the basis that it would be “unavailable” for employment use is incorrect.
Furthermore, the feedback provided by planning officers at the pre-application stage suggests that officers accept the site is capable of delivering sustainable development and does not appear to have any significant technical constraints to development (subject to further technical assessment).
Paragraph 6.49 notes that mitigation would be required should this site (and others) be considered for allocation through the plan given the “high level of greenfield development, historic assets and Local Wildlife Sites in Harborough district”.
Considering the potential impact of greenfield development, it is reiterated that Bushby is a sustainable location for development, located within the Leicester Urban Area, which is the area of focus to meet the needs of Harborough district and the unmet needs of Leicester City, in accordance with the emerging development strategy. Although development of the site would inevitably result in the loss of some greenfield land, this should be considered against the importance of delivering much needed housing, in sustainable and accessible locations, whilst development would incorporate high quality design, public open space and integrate PROW’s to ensure access is still retained to the countryside beyond the site (see Appendix 2).
Having regard to heritage assets, the Grade II Listed “Milestone” is located beyond the northern boundary of the site off Uppingham Road. There are several listed buildings within Bushby, although these are around 1km to the west of the site. This notwithstanding, during pre-application discussions officers acknowledged that there is little evidence of heritage assets on the site and limited within the vicinity of the site. Officers have recommended a heritage assessment is undertaken to assess any impact on the setting of the Bushby Conservation Area to support a planning application, which is considered to be a standard approach for development on sites such as this.
Paragraph 6.6 of the SA (Chapters) notes that the site could have “significant negative effects as they contain all or part of a LWS, and some are also within 250m of national biodiversity designations”. The Bushby Spinney Local Wildlife Site is located centrally on site whilst the Scraptoft Local Nature Reserve, is approximately 2km to the north west of the site. The site lies within the SSSI Impact Risk Zone associated with several designations to the south-east, the closest of which is approximately 10km from the site. This notwithstanding, during pre-application discussions Officers acknowledged the presence of Bushby Spinney in the southern part of the site, but considered that there would be opportunities to enhance biodiversity on site.
Chapter 7 of the SA presents the appraisals of the proposed site allocations in draft Policy SA01. The scores for a number of the proposed allocations against the SA objectives are set out within the table below (see uploaded document). The Bushby site (land off Uppingham Road) was assessed within the Sustainability Appraisal and is included within the table below.
The Bushby site generally scores at a similar level to the sites chosen to be allocated for development in the New Local Plan and against several objectives, scores more highly.

SA Objective 6: Safeguard and improve community health, safety and wellbeing
The purpose of the objective is to score sites highly that are within walking distance of existing health services and facilities (good access to healthcare), while being in close proximity to open spaces and footpaths and cycle routes (more active lifestyles).
The site has been considered as likely to have significant positive effects (++) as it lies within 720m of all of the referenced assets. This includes a healthcare facility (Bushby Branch Surgery), an area of open space (off Davenports Hill), and footpaths along the A47.
The site’s location, accessibility and connectivity into existing connections will promote health and wellbeing, allowing for access to the surrounding spaces and encouraging sustainable transport methods such as walking and cycling, which in turn will promote good health. There are significant opportunities to reduce levels of crime through careful and considered design initiatives, creating a safe and inviting residential environment. By comparison, sites identified for allocation have scored less favourably, achieving only minor positive effects.

SA Objective 9: Provide affordable, sustainable, good-quality housing for all
All of the residential site options are expected to have positive effects on this objective, due to the nature of the proposed development. It is expected that sites of a larger size may be able to offer a wider mix of housing, including affordable housing, as well as making a greater contribution towards local housing needs.
The site has been considered as likely to have a significant positive effect (++) as it could accommodate over 500 dwellings (up to 850 dwellings). This is a significant opportunity to deliver a wide range of housing, including the delivery of much needed affordable housing, potential for housing for older people, and housing for self-custom build opportunities. The promoter, Mulberry Land, operates an in-house house-building business which delivers housing of the highest quality. Therefore, the quality of housing stock will be improved. This means that not only is the site available, but it is deliverable and achievable in the shorter term given that the promoter specialises in delivery of housing.
Against SA9, sites much smaller than land at Bushby have been scored with a ++, such as land off Frolesworth Road for 475 homes, land west of Warwick Road for 475 homes, and land south of Gallow Field for 600 homes, which are significantly smaller. We question the logic used here, scoring these sites the same as that off Uppingham Road, and we strongly urge the Council to reconsider land at Bushby as a significant opportunity capable of delivering significant positive effects against this Objective, particularly when considering the smaller scale of the sites identified for allocation.

SA Objective 10: Support the sustainable growth of the economy and provide good employment opportunities
The site has been considered as likely to have a minor positive effect (+) as the site is within walking distance (600m) of either: public transport links or one or more Key and General employment area and / or major employment site.
However again this is something we strongly disagree with. The site should be considered as likely to have a significant positive effect (++) as public transport is available directly from the site into Leicester city centre, which provides access to a significant number of jobs. Given the proposed scale of the development at Bushby, there is also the opportunity to route a bus service into and through the site (through dialogue with operators) to enable improved access to employment opportunities.
The site at Bushby presents employment opportunities in support of the local economy given the potential for delivery of a local centre to include convenience shops and services on the site. Alongside this, the promoter has been engaging with a high-end leisure provider, which will provide significant employment opportunities for local people, whilst also diversifying the economy. Such employers offer a wide range of jobs at varying levels.
As an example, it is unclear how and why draft allocation S2 Land at Beeby Road for 175 dwellings is scored more favourably than land at Bushby, particularly given its separation and distance from key services, plus difficult issues surrounding sustainable transport and decent highway linkages.
Accessibility in a north-south direction around the eastern edge of Leicester is problematic from a highways perspective, given that the key routes into Leicester City run from east to west, such as the A47 Uppingham Road. This, couples with the A6 further to the south, is the only route running into the City from the east, capable of handling higher levels of traffic associated with growth. Our concern remains that some allocations presented in the draft plan will simply not be deliverable due to highways constraints.

SA Objective 13: Promote sustainable transport and active travel use
This SA objective considers the proximity of development sites to sustainable transport links, which in turn affects the extent to which people are able to make use of non-car-based modes of transport to access services, facilities and job opportunities.
The site has been considered as likely to have a minor positive effect (+) as the site is more than 1.8km from a railway station but within 450m of a bus stop.
However, the site should be considered as likely to have a significant positive effect (++) as public transport is available directly from the site to Leicester city centre, providing access to Leicester City Railway Station, which in turn provides access to the rest of the UK including direct services to Lincoln, Sheffield, London St. Pancras International, Nottingham, Birmingham New Street and Cambridge.
As previously set out, through engagement with operators, there is an opportunity to route a bus service through the proposed development, thus delivering and promoting the use of an improved sustainable mode of transport. Walking and cycling routes will be enhanced and created throughout the proposed site, not only internally, but delivering connections via routes into Bushby, Thurnby and east to Houghton on the Hill.
Given the proposed scale of the site, reliance on private vehicles will be reduced for future residents, as the services delivered on site will ensure journeys are localised and within shorter distances.

Conclusion
It is abundantly clear that the Bushby site has been found to be as sustainable, if not more sustainable, than most of the sites proposed for allocation for residential development in the New Local Plan. It is also clear that the site scores more highly than several of those identified for allocation by the emerging plan.
As set out above, the key reasons for the site being omitted from the emerging Local Plan pertain to the perceived impact development would have on the landscape, heritage assets, Local Wildlife Site and that it would be unavailable for employment development.
This notwithstanding, Officers confirmed through our pre-application discussions that there are not considered to be any significant constraints to development that could not be addressed through technical assessment and appropriate mitigation supporting a planning application. This has also been confirmed through the initial evidence base work undertaken and submitted with these representations.
Land at Bushby is absolutely developable, including for employment generating uses, given that it is promoted by a house building business who specialise in delivering high quality developments, who have also been liaising with potential providers interested in the site. The land is not restricted in any way and is not subject to any policy designations nor constraints that cannot be mitigated during the technical work required to support a planning application.
We maintain that there is continued strong evidence from the market for housing at this location, and we support a successfully developed residentially led community at Bushby, to introduce small-scale retail and leisure centre uses.
Accordingly, we strongly urge the Council to reconsider this site for allocation.