Proposed Submission Draft Local Plan Sustainability Appraisal

Object

Representation ID: 13790

Received: 02/05/2025

Respondent: Barratt David Wilson North Midlands

Agent: Boyer

Overall, although it is welcomed that HDC have considered a more proportional approach to housing distribution we consider this could go further in order to support growth at all scales of the settlement hierarchy. We also consider an appropriate buffer and higher growth scenario need to be implemented in order to ensure the soundness of the Plan.
Also we consider that our client's site at west of Leicester Road, Fleckney scores the same if not better than F1 in relation to the SA objectives but has not been put forward as a proposed allocation. We consider it should be reassessed taking into account the location context and
planning permission for recent solar scheme.

Object

Representation ID: 14197

Received: 04/05/2025

Respondent: Barratt David Wilson North Midlands

Agent: Marrons

The Sustainability Appraisal (“SA”) process considered three options in relation to the overall level of housing growth. Option B (HDC’s LHN plus 123 dpa to address Leicester’s unmet housing need) was selected as the preferred option. We disagree that only meeting the District’s own LHN is a “reasonable alternative,” as this would be tantamount to the HDC turning its back on
Leicester’s unmet housing need, which would not be consistent with national policy or the legal
Duty to Cooperate.

Regarding the "high" growth option, a figure of 936 dpa has been tested, which is higher than the long-term average of 637 dpa since 2011 (the base year of the adopted local plan). However, relying on historical housing delivery trends to test future housing requirements may not fully address the ongoing challenges related to housing affordability and supply. The NPPF emphasises the need to “boost significantly” the supply of housing, reinforcing the importance of a forward-looking, evidence-based approach. We believe that reasonable alternatives for housing growth should not be benchmarked against past delivery rates but should instead focus on strategies to enhance housing supply, support economic growth, and address affordability concerns. We encourage the SA process and the wider evidence base to consider such an
aspirational growth scenario.

Recent housing delivery trends in Harborough show an average of 891 dpa from 2021/22 to 2023/24, which is close to the "high growth" scenario. This suggests that the District can practically sustain this rate of homebuilding. However, the SA does not clearly explain why the "high growth" option was rejected, though the Development Strategy Paper provides some reasoning, indicating that the “high” growth option would have the most negative impacts across all six spatial options. Table 4.1 of the Regulation 19 SA suggests that the differences between
the "high" and "medium" growth options are not significant for most SA objectives. There is no clear reasoning for why the “high” growth option was not taken forward.

In addition, neither of the six initial spatial distribution scenarios were taken forward in their totality. Refined distributional options were subsequently tested. By that time, however, the overall level of growth had already been fixed in line with Option B and the SA process did not test
the refined options against a higher or lower housing requirement. To support the HLP’s housing requirement, we consider that the refined spatial options for growth should be tested alongside the “high” growth option.

There is a clear and compelling case to test a higher housing requirement not only because of recent housing delivery trends mentioned above, but because of the wider issue of an HMA-wide shortfall over the plan period beyond 2036. A higher growth figure could provide sufficient headroom to respond to this longer-term strategic challenge and this has not been addressed
given that alternative scales of growth were not tested beyond the initial spatial options.

Given these considerations, the overall quantity of growth has not been fully explored through the SA process.