Proposed Submission Draft Local Plan Sustainability Appraisal

Support

Representation ID: 14017

Received: 06/05/2025

Respondent: Bloor Homes East Midlands

Agent: Stantec

As part of the supporting evidence base for the Draft Local Plan, a Sustainability Appraisal (February 2025) has been prepared by LUC on behalf of Harborough District Council.

The Sustainability Appraisal lists a series of objectives which include:
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) To support efficient use of resources, including soil
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) To 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) To manage and reduce flood risk from all sources and to 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

The Site scores the following in relation to the above objectives:
1. Negligible effect likely
2. Minor negative effective likely / likely effect uncertain
3. Significant negative effect / negligible effect likely / likely effect uncertain
4. Minor negative effective likely / likely effect uncertain
5. Negligible effect likely
6. Minor positive effect
7. Negligible effect likely
8. Minor positive effect likely / negligible effect likely / likely effect uncertain
9. Minor positive effect likely
10. Minor positive effect likely
11. Negligible effect likely
12. Significant negative effect likely / negligible effect likely
13. Minor positive effect likely
14. Significant negative effect likely / likely effect uncertain

In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in Local Plans must be subject to Sustainability Appraisal (SA). For these documents it is also necessary to conduct an environmental assessment in accordance with the requirements of the Strategic Environmental Assessment (SEA) Directive (European Directive 2001/42/EC), as transposed into law in England by the SEA Regulations and which remains in force despite the UK exiting the European Union in January 2020.

Turning to the assessment of the Site, it is positive to see that the Site mostly consists of positive, negligible or uncertain likely effects.

However, turning to the significant negative effects associated with SA Objective 3 (soil), given the rural nature of Harborough District, the majority of site options are expected to have significant negative effects on this SA objective as they consist of greenfield and agricultural
land. It is therefore essential that sites are reviewed on an individual basis rather than in comparison with other sites to assess the level of effect. Further to this, it is also not possible to avoid building on agricultural land if the required levels of housing are to be met, as discussed
throughout these representations. Bloor Homes therefore do not support the Site’s awarding in this regard and consider that the score should be changed to minor negative effect likely.

With regards to SA Objective 12, the entirety of the Site is located within Flood Zone 1 (as per the EA’s updated flood maps for planning). In terms of surface water flooding, there are nominal areas of this present onsite. This has been considered in the design of the Site with drainage
basins proposed along the northern end of the Site. It is considered that there are no technical concerns which cannot be overcome through appropriate mitigation. In this regard, it is considered that the scoring of significant negative effect likely should be amended to negligible
effect.

In terms of the landscape, the existing landscape and hedgerows will be retained onsite wherever possible to inform new public open space and green corridors. Strong buffer boundaries are proposed onsite and additional landscaping will be introduced. The north and western edges of the Site will comprise primarily of open space and tree planting. This is considered to be of particular benefit in in regard to landscape character. The existing
development to the south forms an abrupt modern boundary with the open countryside. Development of the Site in line with the concept masterplan would create a softer and more visually appropriate boundary with the countryside to the north and west. Therefore, Bloor
Homes consider that the score for the Site should be changed from significant negative effect likely to minor negative effect likely.

In account of the above scores afforded to the Site in relation to soil, flood risk and landscape, Bloor Homes do not support the findings of the Sustainability Appraisal and recommend that the following amendments are made in order for the Sustainability Appraisal to be considered
sound and justified, as per paragraph 36 of the NPPF:
• The Site should score minor negative effect in relation to SA Objective 3 on the basis that the wider Leicestershire area is rural in nature and therefore to ensure that the
District Council meet their development requirements, it will be necessary to develop agricultural land
• The Site should score negligible effect in relation to SA Objective 12 given the Site is located in Flood Zone 1 and proposes a suitable drainage strategy to mitigate any surface water flooding onsite.
• The Site should score minor negative effect likely in relation to SA Objective 14 on the basis that the proposals will retain strong landscaping buffers along the Site boundaries
and also propose large portions of open space and green corridors onsite whilst improving on the existing situation.