Reg 22 1 Statement of Pre-Submission Consultation ...€¦ · Strategy Pre-Submission DPD. A...
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Charnwood Local Plan Core Strategy Pre-Submission Consultation Statement for Regulation 22(1)(c)(v) of the Town and Country Planning (Local Planning) (England) Regulations 2012 The Town and Country Planning (Local Planning) (England) Regulations 2012 prescribe the documents that a local planning authority should submit to the Secretary of State when preparing a Core Strategy. This statement provides information on: • the activity undertaken to invite people to comment on the Charnwood Local Plan Core Strategy Pre-Submission version; and • the representations received by Charnwood Borough Council in response to the Charnwood Local Plan Core Strategy pre-submission consultation 1 held between 10 June and 22 July 2013. This statement sets out information on the number of representations made and a summary of the main issues raised in those representations. Individual representations are available to view on the Council’s online consultation portal at http://consult.charnwood.gov.uk/portal How the pre-submission consultation on the Charnwood Local Plan Core Strategy was publicised The Charnwood Local Plan Core Strategy Pre-Submission DPD was available for consultation during a prescribed period from June 10 th to 22 nd July 2013. Consultation arrangements were undertaken in accordance with the Charnwood Statement of Community Involvement (2006). The Council issued early warning emails and letters notifying interested parties of the impending publication of the Draft Core Strategy in March and April 2013. These were sent to individuals and groups on the Council’s consultation database, and included statutory consultees, councillors, parish councillors and members of the public. 1 This statement provides information for the purpose of Regulation 22(1)(c)(v) of the representations and main issues raised through consultation undertaken for Regulation 20 on the Charnwood Local Plan Core Strategy Pre-Submission DPD. A Statement of Consultation for the purpose of Regulation 22 (1) (c) (i – iv) providing information on those stages that take place prior to pre-submission (Regulation 18) has previously been published and is available separately. APPENDIX G -1-
Transcript of Reg 22 1 Statement of Pre-Submission Consultation ...€¦ · Strategy Pre-Submission DPD. A...
Charnwood Local Plan Core Strategy Pre-Submission Consultation Statement for Regulation 22(1)(c)(v) of the Town and Country Planning (Local Planning) (England) Regulations 2012 The Town and Country Planning (Local Planning) (England) Regulations 2012 prescribe the documents that a local planning authority should submit to the Secretary of State when preparing a Core Strategy. This statement provides information on:
• the activity undertaken to invite people to comment on the Charnwood Local Plan Core Strategy Pre-Submission version; and
• the representations received by Charnwood Borough Council in response to the Charnwood Local Plan Core Strategy pre-submission consultation1 held between 10 June and 22 July 2013.
This statement sets out information on the number of representations made and a summary of the main issues raised in those representations. Individual representations are available to view on the Council’s online consultation portal at http://consult.charnwood.gov.uk/portal How the pre-submission consultation on the Charnwood Local Plan Core Strategy was publicised The Charnwood Local Plan Core Strategy Pre-Submission DPD was available for consultation during a prescribed period from June 10th to 22nd July 2013. Consultation arrangements were undertaken in accordance with the Charnwood Statement of Community Involvement (2006). The Council issued early warning emails and letters notifying interested parties of the impending publication of the Draft Core Strategy in March and April 2013. These were sent to individuals and groups on the Council’s consultation database, and included statutory consultees, councillors, parish councillors and members of the public.
1 This statement provides information for the purpose of Regulation 22(1)(c)(v) of the representations and
main issues raised through consultation undertaken for Regulation 20 on the Charnwood Local Plan Core
Strategy Pre-Submission DPD. A Statement of Consultation for the purpose of Regulation 22 (1) (c) (i –
iv) providing information on those stages that take place prior to pre-submission (Regulation 18) has
previously been published and is available separately.
APPENDIX G
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There was a large article in the Spring edition of the ‘Charnwood News’ (A Borough-wide newspaper delivered to every household) that explained the forthcoming consultation and this was distributed in June 2013. On publication of the Draft Core Strategy the Council wrote by letter or email to all interested parties for whose details were retained on the Council’s consultation database. This included individuals and groups as well as statutory consultees including:
• Specific consultation bodies (detailed in Appendix 1)
• General consultation bodies (detailed in Appendix 2) As part of the 6 week consultation on the Core Strategy the following actions were taken:
• paper copies of the Draft Core Strategy, Sustainability Appraisal Report, together with, the Statement of Representation Procedure, Equalities Impact Assessment and the Schedule of Saved Local Plan Policies were sent to deposit locations (public libraries, Leicestershire County Council offices and Charnwood Borough Council offices);.
• Town and Parish councils were notified either by email or letter, and were sent a Statement of Representation Procedure, Draft Core Strategy, and Sustainability Appraisal Report;
• Borough Councillors were notified by email and were sent a Draft Core Strategy Document;
• Action Groups were sent a copy of the Draft Core Strategy;
• Post Offices and Supermarkets were sent posters advertising the consultation on the Draft Core Strategy;
• Press notices were also made in the Loughborough Echo and Leicester Mercury for 2 consecutive weeks – one week before the consultation commenced and during the first week of consultation;
• The Council also held a series of exhibitions in venues across the Borough in accordance with the Statement of Community Involvement (2006). In addition, to the 18 exhibitions a further 7 Area Forum events were attended by officers to publicise the plan;
• A set of exhibition Boards were set up in Charnwood Borough Council reception for duration of the public consultation and
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• A dedicated website was designed and all consultation documents were available along with details of exhibitions. The website can be found here: http://localplan.charnwood.gov.uk/
Duly Made Representations 2,793 consultees made representations to the Charnwood Local Plan Core Strategy during the advertised consultation period and they made 3,212 representations in total. The total of 2,793 includes 1,517 pro-forma letters objecting to proposals for sustainable urban extensions (871 for North East Leicester SUE, and 646 for Birstall Direction of Growth). A number of the representations for the West of Loughborough SUE used similar wording that appeared to have been taken from a prompt or template (around 230). In total the Council received around 1,000 individual or bespoke items of correspondence. Table 1 sets out the number of representations by section and policy of the Core Strategy. Table 2 provides a detailed summary of the main issues raised by section and policy of the Core Strategy. The main issues raised are considered to be in summary:
• Whether the Council has satisfied the Duty to Cooperate: Has the Council constructively and actively engaged on an on-going basis in accordance with the legal duty to Cooperate?
• Whether the strategy’s response to Housing Requirements is correct: Does the strategy meet the full, objectively assessed needs for market and affordable housing in the market area as far as is consistent with the National Planning Policy Framework. Is the housing trajectory appropriate?
• Whether the distribution of development and the settlement hierarchy are appropriate: Is the approach taken to the Leicester Principal Urban Area correct, should Shepshed and Loughborough be the focus for development in the north of the Borough, is the approach to service centres correct?
• Are the Sustainable Urban Extensions the right ones: have the right reasonable alternatives been considered and the most appropriate strategy selected?
• Are the Sustainable Urban Extensions deliverable: What is the impact of the infrastructure delivery plan on the sustainable urban extensions, are
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they viable taking into account the policy requirements; is the approach to coordinating delivery correct?
• Are the transport impacts from the growth strategy mitigated: Can the amount of growth and combination of developments be mitigated appropriately, is the right mitigation identified at a strategic level and are the developments viable?
• Is the strategic approach to Regeneration correct: Are the right regeneration needs identified, how have areas of deprivation influenced the strategy?
• Is the strategy for town centre development the right approach: has the right amount of retail development been identified, is it distributed appropriately in the strategy?
• Does the Borough have the environmental capacity for the amount of growth proposed: Has flooding, landscape/settlement identity and heritage been adequately considered and the impact of growth understood correctly. Can the Borough accommodate such a large amount of development?
Early and Late Representations A number of representations were received by the Council during the period between approval of the Core Strategy for pre-submission consultation and the advertised commencement of the consultation. The majority of these were pro-forma letters that had been circulated by organised lobby groups, objecting to specific development options. These pro-formas and a small number of letters continue to be received by the Council following the close of the advertised consultation period:
REPRESENTATIONS RECEIVED OPTION
PRIOR TO JUNE 10TH 2013
POST 22ND JULY 2013
TOTALS
North East of Leicester Sustainable Urban Extension
158 33 191
West Loughborough Sustainable Urban Extension
3 35 38
North of Birstall Direction of Growth
1 24 25
Others - 8 8
TOTALS 162 100 262
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The Planning Regulations make it clear that in law only responses submitted within the time frame specified by the Council may be considered duly made and forwarded to the Inspector. Those representations submitted outside that timeframe (before or after) do not have to be sent to the Inspector and fall to be considered. Legal advice was sought on this point which was clear that the Inspector may ask to see them, but that they cannot be considered duly made.
The representations identified in the table above do not make any comments that were not made during the consultation period. In other words, they would not result in a change to the main issues that have been identified were they made within time or being taken into account. Petitions The Council also received two petitions objecting to the Core Strategy. The first petition was received on the 18th July 2013 (during the consultation period) from the Garendon Park and Countryside Protection Group. It had 3,327 signatures objecting ‘to the destruction of the Green Wedge between Shepshed, Hathern and Loughborough’ resulting from the West Loughborough SUE proposal and supporting ‘the efforts of the Garendon Park and Countryside Protection Group’ in preventing the environmental degradation that would result from the Core Strategy proposals. The second petition was submitted to Councillor Harley (Thurmaston). It had 261 signatures and was addressed to Charnwood Borough Councillors, and requested that they use their influence and vote to prevent ‘the building of 4,500 houses east of Thurmaston.’ The petition was received on the 16th September 2013 (after the consultation period has closed). As with the other late representations, the petition will be made available for the Inspector.
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TABLE 1: DULY MADE REPRESENTATIONS RECEIVED DURING PRE-SUBMISSION CONSULTATION ON THE
CHARNWOOD LOCAL PLAN CORE STRATEGY
NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
� Foreword
8
6
2
5
1
2
0
1
0
1
0
6
Chapter 1: Introduction
� Introduction
20
7
11
2
6
13
1
0
1
0
12
0
8
Chapter 2: Profile of Charnwood
� Profile of
Charnwood
6
5
1
0
2
3
1
1
3
0
3
0
3
Chapter 3: Vision & Objectives
� Vision &
Objectives
19
11
3
5
7
10
2
6
4
1
2
0
10
Chapter 4: Development Strategy for Charnwood
� Development
Strategy for
Charnwood
35
26
0
9
24
8
3
3
8
3
5
0
26
� How much
Development
do we need?
7
6
1
0
1
6
0
2
4
1
5
0
1
� Key Diagram
2
1
0
1
0
2
0
1
2
1
2
0
0
� Where will
development
be located?
8
6
0
2
5
2
1
1
1
1
0
0
6
� Policy CS1
49
38
6
5
14
33
2
13
30
17
18
1
14
� Designing Our
Sustainable
Developments
1
1
0
0
0
1
0
0
0
0
1
0
0
� Policy CS2
4
3
0
1
1
1
2
0
0
0
1
0
3
TOTAL
106
81
7
18
45
53
8
20
45
23
32
1
50
Chapter 5: Meeting Our Housing Needs
� Meeting our
Housing Needs
5
3
0
2
1
3
1
0
1
2
0
0
2
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NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
� Strategic
Housing Needs
4
3
0
1
0
4
0
2
2
2
1
0
0
� Policy CS3
13
11
0
2
2
9
2
3
6
5
2
1
2
� Houses in
Multiple
Occupation
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS4
4
3
0
1
1
3
0
1
1
1
0
0
1
� Gypsies,
Travellers &
Travelling
Show people
2
0
0
2
0
1
1
0
1
0
0
0
1
� Policy CS5
5
4
0
1
3
1
1
0
2
0
0
1
2
TOTAL
33
24
0
9
7
21
5
6
13
10
3
2
8
Chapter 6: Economy and Regeneration
� Economy &
Regeneration
2
1
0
1
1
1
0
0
1
1
0
0
1
� Employment &
Economic
Development
2
2
0
0
2
0
0
0
0
0
0
0
0
� Policy CS6
6
4
0
2
2
4
0
0
3
3
2
0
2
� Our
Regeneration
Strategy
2
0
0
2
0
2
0
0
2
0
0
0
0
� Policy CS7
5
2
0
3
2
3
0
0
3
0
0
0
2
� Policy CS8
6
5
0
1
3
3
0
0
3
1
0
0
3
� Town Centre &
Shops
4
4
0
0
3
1
0
0
1
0
0
0
3
� Policy CS9
12
10
0
2
1
10
1
1
9
3
2
0
2
� The Rural
Economy
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS10
13
9
1
3
8
3
2
0
3
2
4
0
8
TOTAL
52
37
1
14
22
27
3
1
25
10
8
0
21
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NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
Chapter 7: Our Environment
� Our
Environment
10
10
0
0
9
1
0
0
0
0
1
0
9
� Countryside &
Landscape
Character
13
10
0
3
9
2
2
0
2
0
0
0
11
� Policy CS11
19
18
0
1
6
11
2
0
10
6
1
0
8
� Strategic
Green
Infrastructure
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS12
14
14
0
0
6
8
0
0
5
5
1
0
6
� Biodiversity &
Geodiversity
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS13
7
5
0
2
2
3
2
0
1
0
3
0
4
� Heritage
� Policy CS14
6
6
0
0
1
5
0
0
4
4
2
0
1
� Open Space,
Sport &
Recreation
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS15
6
6
0
0
3
3
0
0
3
1
1
0
3
� Sustainable
Construction &
Energy
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS16
14
11
0
3
5
7
2
0
4
4
1
0
6
TOTAL
89
80
0
9
41
40
8
0
29
20
10
0
48
Chapter 8: Access and Travel
� Sustainable
Travel
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS17
15
11
0
4
5
8
2
1
2
5
2
0
7
� Managing The
Road Network
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS18
13
6
0
7
2
10
1
2
9
3
1
0
1
TOTAL
28
17
0
11
7
18
3
3
11
8
3
0
8
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NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
Chapter 9: South Charnwood: Edge of Leicester
� South
Charnwood:
Edge of
Leicester
2
2
0
0
1
0
1
0
0
0
0
1
1
� North East of
Leicester
Sustainable
Urban
Extension
986
27
913
46
8
969
9
0
966
615
910
4
14
� Policy CS19
6
5
1
0
2
2
2
1
1
1
2
0
4
� North of Birstall
Direction of
Growth
694
10
18
666
2
691
1
495
688
662
164
0
3
� Policy CS20
7
5
0
2
3
4
0
0
3
3
1
1
2
� Watermead
Regeneration
Corridor
Direction of
Growth
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS21
7
6
0
1
3
2
2
1
2
2
1
0
5
TOTAL
1700
53
932
715
18
1668
14
497
1660
1283
1078
5
28
Chapter 10: North Charnwood: Loughborough and Shepshed
� North
Charnwood:
Loughborough
& Shepshed
4
2
1
1
0
4
0
1
4
3
1
0
0
� West
Loughborough
Growth Area
236
121
18
97
8
227
1
1
227
42
27
0
7
� West of
Loughborough
Sustainable
Urban Ext
34
21
5
8
1
33
0
1
31
7
5
0
2
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NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
� Policy CS22
688
236
49
403
8
680
0
6
675
377
27
24
9
� Loughborough
University &
Science &
Enterprise
Park
0
0
0
0
0
0
0
0
0
0
0
0
0
� Policy CS23
12
8
0
4
5
6
1
0
3
5
0
0
6
� Shepshed
Direction of
Growth
85
63
7
15
2
82
1
0
79
11
9
1
2
� Policy CS24
63
54
1
8
4
57
2
3
56
24
5
0
6
TOTAL
1122
505
81
536
28
1089
5
12
1075
469
74
25
32
Chapter 11: Infrastructure and Delivery
� Infrastructure &
Delivery
5
2
0
3
0
4
1
1
0
3
1
0
2
� Policy CS25
6
3
0
3
0
4
2
1
0
3
0
0
2
� Policy CS26
5
0
0
5
1
2
2
0
1
0
1
0
3
TOTAL
16
5
0
11
1
10
5
2
1
6
2
0
7
Chapter 12: Monitoring Our Strategy
� Monitoring Our
Strategy
4
1
0
3
0
4
0
0
4
3
1
0
0
Appendix 1: Charnwood Housing Trajectory
� Charnwood
Housing
Trajectory
1
1
0
0
0
0
1
0
0
0
0
0
1
Appendix 2: Charnwood Infrastructure Schedule
� Charnwood
Infrastructure
Schedule
3
3
0
0
3
0
0
0
1
1
0
0
3
Appendix 3: Charnwood Monitoring Framework
� Charnwood
Monitoring
Framework
1
1
0
0
0
1
0
0
0
1
0
0
1
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NUMBER OF REPRESENTATIONS
LEGALLY COMPLIANT?
IS PLAN SOUND?
NOT SOUND
CORE STRATEGY
REFERENCE
TOTAL
RECEIVED
YES
NO
UNSURE
YES
NO
UNSURE
NOT
POSITIVELY
PREPARED
NOT
JUSTIFIED
NOT
EFFECTIVE
NOT
CONSISTENT
WITH
NATIONAL
POLICY
OTHER
NO
RESPONSE
Appendix 4: Glossary
� Glossary
1
1
0
0
1
0
0
0
0
0
0
0
14
OVERALL
TOTAL
3211
840
1036
1335
195
2957
59
548
2873
1835
1229
34
249
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TABLE 2: THE MAIN ISSUES IDENTIFIED FROM PRE-SUBMISSION CONSULTATION RESPONSES
This table sets out the main issues raised by Core Strategy section and policy, during the prescribed period for the pre-submission
consultation from June 10th to 22nd July 2013. The Council’s brief response is also given to identify where no change is required or a minor
modification to the plan is felt appropriate.
MAIN ISSUE
COUNCIL’S RESPONSE
AMENDMENT REFERENCE
Profile
The Plan does not include a factual geographical
context map
No change. The document includes a key diagram
and a description of the area.
The number of listed building entries is only 781.
No change. The number of listed building entries
in the statutory list for Charnwood includes groups
of buildings and the total number is therefore over
1,000. As such the statistic contained in the Core
Strategy is correct.
The terminology used for heritage assets is incorrect
Noted. A minor change to the terminology is
proposed.
MC2/Profile/b
The profile should include references to an ageing
population
No change. Projections for how the population is
expected to change are contained in detail in the
evidence base and the ageing population is
discussed in chapters 2, 4 and 5.
Para 2.1 cites the key diagram on P23. This is the
spatial strategy diagram and is therefore confusing.
No change. The diagram is clear, performs its
function appropriately and relates well to detailed
diagrams and plans elsewhere in the document.
Para 2.2 refers to the Principal Urban Area, which no
longer exists.
No change. Whilst the Leicester Principal Urban
Area was a key component of the Regional
Strategy it is still considered to be the preferred
policy option and as a result remains part of the
development strategy. The Leicester Principal
Urban Area is discussed and defined in chapter 4
and also discussed in the Council’s Strategic
Housing Developments Topic Paper.
Shepshed and Loughborough are not inter-related
and the approach is inconsistent to the treatment
given to Hathern, Quorn and Barrow
No change. The settlement hierarchy, including
the relationship between Shepshed and
Loughborough, is discussed in chapter 4 of the
Core Strategy. Further explanation is given in the
Council’s Strategic Housing Developments Topic
Paper.
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MAIN ISSUE
COUNCIL’S RESPONSE
AMENDMENT REFERENCE
Support for the recognition of deprivation in
Loughborough.
Support Welcomed.
The opportunity to deliver improvements to the A60,
to improve access for Wolds communities at time of
flood, on the back of eastern growth, have been
ignored.
No change. The alternative option for
development east of Loughborough has been
appraised through sustainability appraisal
process, having regard to evidence, including
advice from the Environment Agency and the
Highway Authority and has not been selected as a
preferred development option.
Vision and Objectives
Wording suggestions were made relating to safe
places, an ageing population, promotion of sport or
the health benefits of sport and physical activity and
physical and spiritual heal.
No change. The wording in the vision is
considered to reflect these issues although the
vision is intended to be strategic in nature.
There was disagreement with the term "walkable" in
relation to Loughborough in the Vision.
No change. Loughborough is considered to be a
walkable environment.
The draft Core Strategy accurately reflects the
current Sustainable Community Strategy & the vision
of Leicestershire Together & Charnwood Together
Noted. Support welcomed.
The Strategic Objectives refer to the revoked
Regional Plan, and do not refer to the Duty to
Cooperate
Noted. A minor change is proposed to refer to
housing requirements of Leicester and
Leicestershire Housing Market Area.
MC3/SO17
The Vision has not been translated into the most
appropriate development strategy
No change. Reasonable alternative options have
been objectively appraised through sustainability
appraisal process, having regard to evidence.
Development at Shepshed is not in conformity with
the Sustainable Community Strategy objectives.
No change. The Core Strategy shares the
objectives of the Sustainable Community Strategy.
Shepshed has been objectively appraised through
the sustainability appraisal process, having regard
to evidence.
The Vision does not respond appropriately to
deprivation.
No change. The Vision has been prepared to
respond to issues including deprivation.
An additional strategic objective is required to
‘Protect and enhance the wider environment’ giving
particular attention to dealing with controlled waters
and land contamination.
No change. SO7-13 provide for an appropriate
range of environmental considerations.
Chapter 4: Development Strategy for Charnwood
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The Core Strategy relies on an out of date SHMA
and the revoked Regional Plan and the Council has
not objectively assessed housing needs as required
by the National Planning Policy Framework.
No change. The Council has undertaken an
objective assessment of needs in accordance with
the latest draft guidance issued by the
Government in August 2013 to critically review the
existing evidence on housing need. The latest
objective assessment demonstrates that the
response to housing needs in the plan is robust
and sound. The Objective Assessment of Needs
has been undertaken independently by
consultants in light of the latest data available.
Work is ongoing with partners in the Housing
Market Area to replace the 2008 SHMA but this is
not expected to provide district housing numbers
until February 2014. The determination of unmet
needs and agreement about their distribution will
follow and is likely to present particular challenges
to HMA partners but it is not known when an
outcome will be reached.
The Strategy does not ensure a 5 year supply in the
initial years of the plan when applying the Sedgefield
method and including a 20% buffer for persistent
under delivery.
No change. The Council uses the Liverpool
method for calculating supply due to that method
relating supply to a plan period rather than the
Sedgefield method which requires any under or
over supply to be dealt with in 5 years (rather than
a full plan period). The most up to date evidence
of housing land supply shows that the Core
Strategy provides a five year supply at the point of
adoption.
The strategy does not take account of up-to-date
information about housing completions; it does not
include a windfall allowance, and does not take into
account developments which may come forward in
rural settlements.
Noted. A revised trajectory will be prepared for
the examination process using the most up to date
information reasonably available at that time.
That update will include assumptions about
windfalls following the guidance in the NPPF.
It is not appropriate to extrapolate the PUA
requirement by a further 2 years as the PUA
requirement is a product of the potential for large
SUEs in Blaby and Charnwood and is therefore a
function of the SUE locations
No change. The NPPF requires plans to be drawn
up over an appropriate timescale (preferably 15
years), be based on cooperation with
neighbouring authorities and be positively
prepared. Whilst the now revoked Regional Plan
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only provided a framework to 2026, a plan period
to 2028 is considered appropriate for the Core
Strategy. The amount of development for the
Principal Urban Area conforms to the most
recently agreed development strategy for
Leicester and Leicestershire and has been
supported by our HMA partners under the Duty to
Cooperate.
The overall proposed housing provision across the
Region has fallen by -5.7%.
No change. The respondent is unable to say how
a regional fall in housing provision relates to
Charnwood and the trajectory set out in the Core
Strategy. The Council has undertaken an
objective assessment of needs in accordance with
the latest draft guidance issued by the
Government in August 2013 to critically review the
existing evidence on housing need. The latest
objective assessment demonstrates that the
response to housing needs in the plan is robust
and sound. The Objective Assessment of Needs
has been undertaken independently by
consultants in light of the latest data available.
There is insufficient evidence regarding how new
housing provision could be in part provided through
‘community-led’ housing initiatives, such as new co-
operative housing development, community land
trusts, cohousing schemes, and other similar ‘mutual’
or collaborative endeavour
No change. The Strategy deals with housing at a
strategic level. Policy CS1 recognises the role of
Neighbourhood Plans which could promote
community led housing initiatives and policy CS3
recognises the need for a mix of housing types
and tenures.
Homes for the elderly and retired need to be
considered as part of the development
No change. Policy CS3 refers to the need for an
appropriate mix of types, tenures and sizes of
homes having regard to the identified needs of the
area and paragraph 5.7 and 5.8 recognise the
need to respond to the particular needs of our
community including the ageing population.
The evidence for employment land provision is not
robust.
No change. Employment land evidence has been
prepared in partnership with the Leicester and
Leicestershire Housing Market Area authorities
and is considered to be proportionate, adequate
and robust.
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The Core Strategy is inflexible/over reliant on small
number of large sites which make housing delivery
difficult.
No change. Policy CS1 plans for a range of sites,
as well as growth in the Service Centres and in
other settlements. The most up to date evidence
of housing land supply shows that the Core
Strategy provides a five year supply at the point of
adoption. Housing land supply will be monitored
and reviewed on an ongoing basis in accordance
with the Monitoring Framework.
The phasing and the build rates set out in the
housing trajectory are unrealistic.
No change. The build rate assumptions have been
informed by evidence including the Council’s
Strategic Housing Land Availability Assessment,
delivery statements and through ongoing
discussions with our partners through the
governance arrangements for strategic
developments.
Costly infrastructure will lead to delays in house
building rates.
No change. The viability assessments show our
Strategy is financially viable. The Strategy will
provide for a plan-led approach to growth and the
delivery of Sustainable Urban Extensions will be
pursued in accordance with the arrangements set
out in Chapter 11. The Council takes a project
management approach for delivering strategic
growth options with key partners and for
infrastructure planning which include principal
infrastructure agencies.
Sustainable Urban Extensions & Directions for
Growth Delivery Evidence presumes increase in
prices; the approach to affordable housing viability
testing is flawed and does not include other costs.
No change. The Council’s viability testing has
been undertaken by expert independent
consultants in accordance with recognised
practice guidance.
The advice in the Sustainable Urban Extensions &
Directions for Growth Delivery Evidence (DTZ) has
not been fully followed in the Core Strategy. The
Direction for Growth at Shepshed is programmed to
commence in advance of the SUE at West
Loughborough. This is reflected in the housing
trajectory in appendix 1.
No change. The Delivery Evidence recognises
that the Shepshed development is likely to happen
first (as it is easier) but that ideally the West of
Loughborough SUE would start on site before it.
However, the study concludes that the Shepshed
Direction of Growth should not threaten the
viability of the West Loughborough SUE.
Permission has also been granted for
development within the Shepshed Direction of
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Growth Area and the trajectory reflects that
position.
Development at Cotes is in a different housing sub
market to the West Loughborough SUE and would
help to deliver the housing requirement.
No change. The Council’s Market Testing
concluded that the (dismissed reasonable
alternative option) South West Loughborough
Direction of Growth would be likely to have the
least market impact on the West of Loughborough
SUE, whereas the other three sites (including a
direction of growth at East of Loughborough)
would be likely to have a moderate impact. In
terms of delivering outputs over the full plan
period, the testing concluded that South
Loughborough or East Loughborough Directions
of Growth had the greatest potential to maximise
housing delivery. The study also made
recommendations about the timing of Shepshed
Direction of Growth noting that it should not
threaten the viability of the West Loughborough
SUE. The preferred options for growth were
selected in light of a range of evidence, including
but not limited to, the Market Testing.
The Sustainable Urban Extensions & Directions for
Growth Delivery Evidence does not include the
proposed gypsy and traveller requirement.
No change. Advice was taken from the Council’s
independent consultants in respect of the
proposed gypsy and traveller requirement and the
viability of sustainable urban extensions. The
small scale of gypsy and traveller site was not
considered to be material to the viability of the
urban extensions.
The required infrastructure is not deliverable.
No change. The viability assessments show our
Strategy is financially viable. The Strategy will
provide for a plan-led approach to growth and the
delivery of Sustainable Urban Extensions will be
pursued in accordance with the arrangements set
out in Chapter 11. The Council takes a project
management approach for delivering strategic
growth options with key partners and for
infrastructure planning which include principal
infrastructure agencies.
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Support for the development strategy
Noted. Support welcome.
Strategic Housing Needs
The strategy does not address how the type, size,
tenure and need for affordable housing will be met,
or the need for specific types of housing such as
extra care housing, housing for older people
No change. Policy CS3 sets out the strategic
approach to meeting affordable housing needs,
and seeks an appropriate mix of types, tenures
and sizes of homes having regard to identified
housing needs.
The policy is not justified because the Strategic
Housing Market Assessment is not robust.
No change. The Council has undertaken an
objective assessment of needs in accordance with
the latest draft guidance issued by the
Government in August 2013 to critically review the
existing evidence on housing need. The latest
objective assessment demonstrates that the
response to housing needs in the plan is robust
and sound. The Objective Assessment of Needs
has been undertaken independently by
consultants in light of the latest data available.
The Affordable Housing Economic Viability
Assessment (2010) which has been used to make
decisions on affordable housing thresholds is not
robust.
No change. The Affordable Housing Economic
Viability Assessment was undertaken in
accordance with recognised practice guidance
and there is no evidence to suggest that the
assessment is not robust.
The requirement for Lifetime homes doesn’t appear
to be supported by any evidence and it is not clear if
it has been subject to viability testing.
No Change. Policy CS3 has been informed by the
Equalities Impact Assessment and seeks Lifetime
Homes, where feasible.
Houses in Multiple Occupation
The plan is not justified because there is no evidence
on how Houses in Multiple Occupation will be
prevented, there is no policy on Article 4 Direction,
and there is a need to include reference to balanced
communities.
No change. Policy CS4 provides the criteria
against which the impacts of Houses in Multiple
Occupation will be considered, having regard to
evidence of any impact.
The Policy for student housing is not positively
prepared as it does not require Loughborough
University to build more accommodation.
No change. The approach to Houses in Multiple
Occupation has been carefully developed and
tested through sustainability appraisal, and
working with key stakeholders, including
Loughborough University and residents groups.
Gypsy and Travellers
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The location of gypsy and traveller sites within
Sustainable Urban Extensions and within housing
developments is not justified
No change. The approach to gypsy and traveller
provision has been carefully developed and tested
through sustainability appraisal, and working with
key stakeholders.
The proposed level of provision should be set as a
minimum and kept under review.
No change. The proposed level of provision has
been informed by evidence of need.
Additional wording for Policy CS 5 (Policy CS 5 -
Gypsies, Travellers and Travelling Show people)
regarding flooding
No change. Policy CS16 sets out the approach to
development and flood risk.
Economy and Regeneration
There is a need for an employment land trajectory
and a commitment to monitor against this.
Noted. The Employment Land Topic Paper
discusses the phasing of employment land and
how it will be monitored. The monitoring of
employment land is considered in the monitoring
framework, and the timing of employment land
delivery will be considered through delivery
statements for strategic developments.
The Core Strategy is not consistent with the National
Planning Policy Framework as it does not safeguard
employment sites
No change. The Framework does not require
employment sites to be safeguarded (p.22
requiring long term protection of allocations to be
avoided) although SO18 seeks the safeguarding
of key employment sites. The strategy has been
developed with this in mind and policies CS7,
CS21 and CS23 contribute strongly to SO18.
The approach to employment and regeneration is not
justified because it will encourage commuting, it will
not regenerate Shepshed, it will impact on the
heritage of the Great Central Railway and there is a
lack of approach to cultural facilities and addressing
the evening economy.
No change. The approach to regeneration reflects
the Council’s Corporate Plan, Regeneration
Strategy and has been carefully developed and
tested through sustainability appraisal and
relevant evidence, and working with key
stakeholders. Policy CS8 sets out the strategic
approach to regeneration at Shepshed and policy
CS7 supports the Great Central Railway. The
strategy has been subjected to strategic transport
modelling and is capable of being adequately
mitigated.
Town Centres and Shops
The strategy to accommodate the need for town
No change. The approach to town centres has
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centre uses around Loughborough Town Centre is
not justified, effective or consistent with national
policy.
been carefully developed and has been informed
by the Council’s Regeneration Strategy, the
Council’s Corporate Plan, retail and town centre
evidence, work with key stakeholders and has
been tested through sustainability appraisal.
The approach to town centres sites is inconsistent
and should allow for other town centre uses at the
south east of Loughborough town centre.
Noted. The distribution of town centre uses was
prepared to prioritise the regeneration of the sites
south east of Loughborough town centre.
Support for a comprehensive approach to the
redevelopment of opportunity sites (BID).
Noted. Support welcome.
The policy is not justified as Retail and Town Centre
Study 2013 incorrectly identifies need, capacity and
distribution for retail.
No change. The Retail and Town Centre Study
2013 is considered to be adequate, up to date and
relevant.
The policy does not explain whether or how the
boundary for Loughborough Town Centre Core Area
will be reviewed.
No change. Policy CS9 is clear that
Loughborough Town Centre boundary will be
identified through the Site Allocations and
Development Management Development Plan
Document.
The thresholds for Retail Impact Assessments are
not justified.
No change. The thresholds for Retail Impact
Assessments have been informed by the Retail
and Town Centre Study 2013 and reviewed by
further Retail Advice in October 2013.
The definition of ‘District Centre' is confusing with
terminology in the settlement hierarchy.
No change. The retail hierarchy is established
through Policy CS9 and the Settlement Hierarchy
is established through Policy CS1.
Supports the retail hierarchy and the identification of
Shepshed as a district centre.
Noted. Support welcome.
Rural Economic Development
Clarification sought about whether policy allows for
any development in countryside.
No change. Policy CS10 clearly supports the
sustainable growth and expansion of businesses
and farm diversification in rural areas and Policy
CS11 also makes provision for the support of
particular types of rural development.
The Core Strategy is not justified as 7ha employment
land would not meet demand across the borough
No change. The approach to employment land
reflects employment evidence for the borough and
Leicester and Leicestershire.
Countryside and Landscape Character
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The policy does not provide a framework for
balanced decisions to be made in terms of Areas of
Local Separation
No change. Policy CS11 seeks to protect Areas of
Local Separation, but to support development
where open character is maintained.
The policy should define Areas of Local Separation.
No change. Policy CS11 defines the location and
principles for Areas of Local Separation.
Paragraph 7.14 notes that the existing boundaries
will continue to be saved and reviewed through
the Site Allocations and Development
Management Policies Development Plan
Document.
The strategy is not justified – it should refer to
Leicestershire Historic Landscape Characterisation
Study 2010.
No change. Policy CS11 refers to relevant local
Landscape Character Assessments.
The absence of green wedges around
Loughborough does not include appropriate
protection for settlement identity.
No change. Policy CS2 looks to reinforce a sense
of place and requires new development to respect
and enhance the character of an area having
regard to, amongst other things, landscape.
Policy CS11 requires new development to
maintain the separate identities of towns and
villages.
Some green wedges no longer satisfy the criteria for
a designation.
No change. A Green Wedge Review was
completed in 2011.
Green Infrastructure
The Core Strategy does not define Green Wedges.
No change. The definition of Green Wedges is
included in the policy, and is explained in
paragraphs 7.30 & 7.31.
The role and purpose of Urban Fringe Green
Infrastructure Enhancement Zone is not adequately
explained.
Noted. Minor change proposed to glossary.
MC7/7.29
There is no recognition of the Grand Union Canal as
a non-designated heritage asset.
No change. Non-designated assets are described
in paragraph 7.38. The Core Strategy does not
seek to list non-designated assets. Policy CS7
recognises the tourism potential of heritage
assets, listing the Grand Union Canal.
The Core Strategy lacks clarity and adequate detail
regarding public rights of way.
No change. The Core Strategy includes an
appropriate level of detail regarding public rights
of way, notably within Policies CS2, CS12, CS17
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and those policies referring to strategic sites.
The Green Wedge Review is insufficiently justified
and there are inconsistencies in the assessment of
different green wedge areas. The land between
Shepshed and Loughborough should be identified as
a green wedge as it satisfies the criteria.
No change. The Charnwood Green Wedge
Review 2011 is considered robust.
The Core Strategy is not justified because planting to
National Forest Company guidelines may not always
be appropriate within Charnwood Forest because the
area’s landscape character depends on the mosaic
of land uses and habitats.
No change. National Forest Company Planting
Guidelines allow flexibility.
Biodiversity and Geodiversity
The requirement to provide an assessment of
ecological impact should not apply to all
developments.
No change. Policy CS 13 requires an assessment
of impact where biodiversity and geodiversity is
considered to be an issue.
The approach and language in policy CS13 is not
consistent with the National Planning Policy
Framework in terms of how it refers to net gains,
substantial harm and how it deals with the approach
of avoidance, mitigation and compensation.
No change. Policy CS 13 is consistent with the
National Planning Policy Framework.
There should be greater reference to the Water
Framework Directive.
Noted. Minor changes to the text are proposed.
MC7/7.34
Heritage
The Core Strategy is not justified or consistent with
national policy because it is based on inadequate
evidence about the historic environment.
No change. The Core Strategy has been informed
by proportionate, up to date and relevant evidence
base.
The Core Strategy is not consistent with national
policy because it does not present a positive strategy
for the conservation and enjoyment of the historic
environment
No change. Policy CS14 seeks to conserve and
enhance our historic assets for their own value
and the community, environmental and economic
contribution they make. The strategy has been
tested through sustainability appraisal for its
social, economic and environmental impact.
The Core Strategy is not consistent with national
policy because the terminology used is incorrect.
Noted. Agree minor change to terminology.
MC7/7.38
MC7/7.39
MC7/EvBox
The Core Strategy does not adequately address
negative impacts on rural character and archaeology No change. Policies CS11 and CS14 include
(respectively) appropriate protection for rural
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character and heritage, including archaeology.
Open Space and Recreation
The standards for indoor and outdoor sport are not
based on robust evidence
No change. Standards for indoor and outdoor
sport have been informed by the Open Spaces,
Sport and Recreation Study 2010 which is
considered to be adequate, up to date and
relevant evidence base.
Figure 4 does not clearly state the scale of open
space provision that is required in new
developments.
No change. The scale of open space provision is
set out having regard to population rather than per
home.
The standards for open space provision are not part
of Policy CS15 but written into the reasoned
justification. This means they will not be examined
and can be changed post Examination in Public.
No change. Standards for open space provision
are part of the Core Strategy, and therefore
subject to examination.
It is not clear why policy CS15 is needed if the
Council intends to introduce a CIL.
No change. Policy CS15 is necessary to ensure
appropriate open space provision within new
developments and not to determine any CIL
charges.
It is not clear how the standards in Policy CS15 have
been applied to the SUE.
Noted. The Open Spaces Sport and Recreation
Study 2010 informed the standards in Policy CS15
and provided recommendations for the amount of
open space in the sustainable urban extensions.
Sustainable Energy and Construction
The reasoned justification to Policy CS16 incorrectly
identifies areas of heat stress in Loughborough.
No change. The reasoned justification for Policy
CS16 has been informed by evidence: Mapping
Social Vulnerability and Climate Disadvantage:
Results & Implications: Joseph Rowntree /
University of Manchester (2012)
The caveat concerning viability means development
exceeding Building Regulations are unlikely to be
delivered
No change. Policy CS16 is clearly stated and is
written to recognise national standards, ensure
appropriate flexibility and that development is
deliverable.
The Core Strategy does not identify pre-determined
environmentally appropriate zones for wind turbines.
No change. Paragraph 7.63 explains the potential
for renewable energy, noting the broader potential
for low carbon and renewable energy in relation to
the landscape.
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There has been insufficient regard in the Core
Strategy to existing flooding or the consequences of
flooding due to additional development.
No change. Policy CS16 includes appropriate
measures for managing flood risk.
The approach to encourage a reduction in CO2
emissions compared to the Building Regulations is
not consistent with national policy, is not clearly
expressed, is too onerous and has not been
appropriately tested for viability.
No change. Policy CS16 is clearly stated and is
written to recognise national standards, be
consistent with national policy and to ensure
appropriate flexibility. Standards for the
sustainability of new buildings have been viability
tested in the Code for Sustainable Homes Viability
Testing 2011.
The requirement to reach code level 5 for water
consumption is not justified. There is no evidence to
show this is achievable or viable.
No change. Policy CS16 has been informed by
the Code for Sustainable Homes Cost Review
2010 (DCLG) and considered by sustainability
appraisal. The policy is written to ensure
appropriate flexibility and that development is
deliverable.
Sustainable Travel
The modal shift target in Policy CS17 is not based
upon evidence.
No change. The modal shift target has been
informed by robust transport evidence, in
consultation with the Highway Authority and the
Highways Agency.
The modal shift target in Policy CS17 is un-
ambitious.
No change. The modal shift target has been
informed by robust transport evidence, in
consultation with the Highway Authority and the
Highways Agency.
The modal shift target in Policy CS17 will not be met. No change. The modal shift target has been
informed by robust transport evidence, in
consultation with the Highway Authority and the
Highways Agency.
The sentiments of Policy CS17 are supported but the
provision of new or enhanced bus services where
new development is more than 400m from an
existing bus stop may not be viable in all
circumstances.
Noted. Policy CS25 provides the mechanism for
viability to be considered.
Managing the Road Network
The transport infrastructure requirements are
No change. The transport infrastructure
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inadequate.
requirements have been informed by appropriate
evidence in consultation with the Highway
Authority, Highways Agency and adjoining local
authorities.
Policy CS18 does not consider innovative
transportation solutions such as car sharing, park
and ride or cycle hire.
No change. Policy CS17 sets out an appropriate
range of transport measures which reflects
transport evidence and best practice.
The transport infrastructure is not based on sound
evidence
No change. Transport infrastructure requirements
have been informed by appropriate evidence in
consultation with the Highway Authority, Highways
Agency and adjoining local authorities.
The future maintenance of the A60, to protect it from
flooding, has not been considered in terms of the
proposal for the east of Loughborough.
No change. The Environment Agency has
previously expressed concerns about the
hydrological modelling submitted in support of the
options to the east of Loughborough and that
conclusions cannot be considered until revised
and robust hydrological modelling has been
undertaken. As a result, it is not possible to draw
conclusions about the future maintenance of the
A60 in times of flood.
Further clarity is required over the function/role of
roads within strategic developments.
No change. The function and role of roads within
strategic developments is adequately expressed
within the Core Strategy. However, the detailed
requirements for roads are being pursued through
master planning and development management
delivery arrangements.
There are inconsistencies in the way that the
Strategy talks about infrastructure requirements,
specifically whether the infrastructure shown is the
‘key’ infrastructure or ‘all’ the infrastructure required
for growth.
Noted. The Infrastructure Schedule is drawn from
the Infrastructure Delivery Plan. It includes
strategic infrastructure required to deliver growth.
A minor wording change is proposed to clarify this
point.
MC8/8.31
North East of Leicester Sustainable Urban Extension
Land ownerships mean that the proposed
employment areas will not be delivered at North East
of Leicester Sustainable Urban Extension.
No change. The concept master plan depicted in
the Core Strategy is not development plan policy,
but is shown for illustrative purposes as referred to
in paragraph 9.9. The amount of employment
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land and its location within the development will
be pursued through master planning and
development management delivery arrangements.
The role of the new spine road will have a significant
influence on the approach to the development of the
site. Greater clarity on this is needed in the core
strategy to assist future master planning and
development management
No change. The Core Strategy provides a
strategic context for the sustainable urban
extension and has been subjected to strategic
transport modelling which shows that the growth
can be mitigated. The detailed requirements for
the road are being pursued through master
planning and development management delivery
arrangements.
There should be stronger reference to the need for a
comprehensive approach within the policy to the
planning and implementation of the SUE.
No change. The need for a comprehensive
development is referred to in paragraph 9.36 and
Policy CS19.
The scale of the Local Centre in Policy CS19 is not
considered appropriate.
No change. The scale of the Local Centre has
been informed by the Retail and Town Centre
Study 2013 and reviewed by further Retail Advice
in October 2013.
Is there sufficient evidence to support CS19 that
provision needs to be made for a secondary school? No change. The approach to education provision
in the sustainable urban extension has been
informed by evidence and by working in
partnership with the local education authority.
Paragraph 9.13 does not provide sufficient flexibility
for the delivery of appropriate provision for gypsies,
travellers and travelling show people.
No change. The approach to gypsy and traveller
provision has been carefully developed and tested
through sustainability appraisal, and working with
key stakeholders.
The allocation boundary should be extended to
include land to the north-west of that currently
proposed to allow for flexibility in terms of gypsy and
traveller sites, education provision and a possible
northern link road.
No change. The boundary of the site has been
prepared through the master planning exercise
which has taken into account constraints including
site capacity and landscape.
The provision of electronic communication networks
for the SUE is supported, but cross reference to
Policy CS10 (Rural Economic Development) within
Policy CS19 is considered inappropriate as the SUE
will not be a rural location.
No change. A cross reference is considered
appropriate to link CS19 to the reasoned
justification of CS10.
There should be a flexible approach to sports and
recreation facilities at paragraph 9.32
No change. Paragraph 9.32 references Policy
CS15 which provides for local provision and
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viability to be considered when applying standards
from the Open Spaces Strategy.
There is concern about the environmental impact of
development relating to; agricultural land, settlement
identity and landscape, wildlife, heritage, flooding
and traffic and congestion.
No change. The development North East of
Leicester has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
There is concern about the social impact of
development relating to; services and facilities,
gypsy and traveller sites and recreational space.
No change. The development North East of
Leicester has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
There is concern about the economic impact of
development relating to tourism opportunities.
No change. The development North East of
Leicester has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
North of Birstall Direction for Growth
A development to the North of Birstall is not justified
or effective according to the 'Southern Charnwood
Transport Assessments: Setting Strategic Direction'
No change. The South Charnwood Transport
Study (2009) tested an earlier option for 4,000
dwellings and 20 hectares of employment land at
Birstall. The Direction for Growth included in the
emerging Core Strategy (for 1,500 dwellings and
15 hectares of employment land) has been
modelled with a package of public transport and
highway mitigation measures using the Leicester
and Leicestershire Integrated Transport Model.
The Setting Strategic Direction 2013 Study shows
that growth across the Borough can be mitigated
to an acceptable level.
There is concern about the environmental impact of
development relating to; agricultural land, settlement
identity and landscape, wildlife, noise and light
pollution, heritage and traffic and congestion.
No change. The Direction of Growth North of
Birstall has been appraised through sustainability
appraisal process, having regard to evidence of
the environmental impact and has been selected
as a preferred development option.
There is concern about the social impact of
development relating to; services and facilities,
No change. The Direction of Growth North of
Birstall has been appraised through sustainability
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gypsy and traveller sites and deprivation.
appraisal process, having regard to evidence of
the environmental impact and has been selected
as a preferred development option.
Waterm
ead Regeneration Corridor Direction for Growth
It is not sustainable to locate the majority of
employment land within Thurmaston SUE. Policy
CS21 should include more of the employment
provision.
No Change. The strategy for employment land
has been distributed across the Borough,
including between the sustainable urban
extensions, the Watermead regeneration corridor
and the Science and Enterprise Park and an
amount for Loughborough/Shepshed and the
Service Centres.
Policy CS21 is not justified or effective because the
Leicester Office Market review (Sept 2012) has
confirmed that the city centre and out of town
business parks are distinctive office submarkets
which meet different user requirements and therefore
would not compete with each other. The policy
should be increased to 20,000m2 of office growth.
No change. The approach to office development
takes into account the amount of development for
Charnwood and its relationship with any shortfall
within the City and the Leicester Principal Urban
Area. The amount of office provision proposed for
Watermead is consistent with that evidence and is
considered necessary to distribute office
development in support of sustainable mixed use
development across the area.
Policy CS21 fails to address transport considerations
which could weaken the strategy's effectiveness and
potentially affect the delivery of sustainable
development
No change. Any development proposal would also
have to be considered against Policies CS17 and
CS18. Policy CS21 notes that the specific sites
for development will be allocated through the Site
Allocations and Development Management
Policies Development Plan Document at which
time the detailed arrangements for sustainable
travel will be considered.
West Loughborough Sustainable Urban Extension
The scale of the proposed supermarket in the West
of Loughborough Sustainable Urban Extension is not
justified.
No change. The scale of the Local Centre has
been informed by the Retail and Town Centre
Study 2013 and reviewed by further Retail Advice
in October 2013
There is no detail to show that the restoration and
long term management of Garendon Park is
deliverable, and the costs of delivering the Core
No change. Policy CS22 is clear that the
development should provide for the restoration
and long term management of the park and
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Strategy are not provided.
garden. The detailed requirements for the park
and garden are being pursued through master
planning and development management delivery
arrangements.
The Sustainable Urban Extension at West
Loughborough does not take account sewerage
treatment works and the recycling centre, and any
costs of redeveloping or upgrading them.
No change. The emerging master planning
proposal responds to the constraints of the site
and has been developed in partnership with the
County Council and Severn Trent Water. It is not
necessary to relocate the sewerage works or
recycling centre.
Since 2008, there has been no update of heritage
evidence is relation to Garendon Park and therefore
the approach taken is not consistent with NPPF
paragraph 169
No change. Evidence of the heritage assets and
the associated impact of development on the
historic park and garden is considered robust and
appropriate to inform a strategic plan. Detailed
evidence is also being prepared to support the
emerging master planning proposal.
There is a need for further evidence regarding the
archaeology, restoration of heritage assets
associated with Garendon Registered Park and
Garden
No change. Evidence of the heritage assets and
the associated impact of development on the
historic park and garden is considered robust and
appropriate to inform a strategic plan. Detailed
evidence is also being prepared to support the
emerging master planning proposal.
There is concern about the environmental impact of
development relating to; agricultural land, settlement
identity and landscape, wildlife, heritage, flooding
and traffic and congestion.
No change. The development West of
Loughborough has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
There is concern about the social impact of
development relating to; health and well being,
services and facilities, gypsy and traveller sites and
deprivation.
No change. The development West of
Loughborough has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
There is concern about the economic impact of
development relating to connectivity with the railway
station.
No change. The development West of
Loughborough has been appraised through
sustainability appraisal process, having regard to
evidence of the environmental impact and has
been selected as a preferred development option.
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Loughborough University Science and Enterprise Park
The strategy does not consider alternative uses for
housing on the Science Park.
No change. The strategy for the Science and
Enterprise Park recognises the unique
characteristics of the location and the benefits that
could result from Science and Enterprise Park
uses rather than seeing it lost to alternative
development. As a result, housing is not
considered to be acceptable.
There are doubts about the deliverability of the
Science Park.
No change. The potential to deliver the Science
and Enterprise Park has been considered in
partnership with Loughborough University and the
findings are set out in the Delivery of a Science
and Enterprise Park at Loughborough Phase 1
Report 2012.
The proximity of the Science Park to the M1 means
people will travel further and development should
happen to the East of Loughborough instead.
No change. The strategy for the Science and
Enterprise Park recognises the unique
characteristics of the location and the benefits that
could result from Science and Enterprise Park
uses in close proximity to the University. Any
development would have to have regard to Policy
CS17 in relation to sustainable travel.
The Science and Enterprise Park is not justified or
effective as it there is no reference given to
Garendon Registered Park and Garden and
associated heritage assets.
No change. The heritage impact of the Science
and Enterprise Park has been considered through
sustainability appraisal.
Policy CS23 is not flexible enough in terms of the
required floorspace.
Noted. The floorspace phasing is taken from the
evidence base and is intended to support and
inform the development of a flexible masterplan.
Other university uses must allowed in order for the
University to expand in a sustainable way.
No change. Policy CS23 provides for uses that
directly relate to the University’s own operational
activities. No change.
It is not clear whether the policy itself allocates the
77ha of land for Science and Enterprise Park uses,
or whether the Council in fact, intends to allocate the
land in a future development plan document
No change. The Science and Enterprise Park is
allocated by Policy CS23
Leicestershire County Council welcomes the Science
and Enterprise Park policy which will provide
Noted. Support welcome.
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commitment for the necessary future planning and
coordination required.
Supportive for policy.
Noted. Support welcome.
Shepshed Direction for Growth
There is insufficient transport evidence to show that
the stated policy aims of improved walking and cycle
routes, improved bus services and roads can be
achieved.
No change. The strategy has been subjected to
st rategic transport modelling which shows that the
growth can be mitigated. The detailed
requirements for walking, cycling, public transport
and the roads will be assessed through the Site
Allocations process and through master planning
and development management delivery
arrangements. Viability Assessments have also
been undertaken which have show that the
Direction for Growth is deliverable.
There is concern about the environmental impact of
development relating to; agricultural land, settlement
identity and landscape, wildlife, heritage, flooding, air
quality and traffic and congestion.
No change. The Direction of Growth at Shepshed
has been appraised through sustainability
appraisal process, having regard to evidence of
the environmental impact and has been selected
as a preferred development option.
There is concern about the social impact of
development relating to; services and facilities and
the support for Regeneration of Shepshed.
No change. The Direction of Growth at Shepshed
has been appraised through sustainability
appraisal process, having regard to evidence of
the environmental impact and has been selected
as a preferred development option.
Infrastructure and Delivery
The strategy does not secure sufficient facilities and
services to meet the local need for policing.
Noted. The Infrastructure Delivery Plan has been
prepared to take account of the evidence for CiL
compliant infrastructure. An updated
Infrastructure Delivery Plan has been prepared to
take account of new information. A total of just
over £4m is identified for police contributions.
The plan should explain how the Infrastructure
Schedule will be updated and reviewed as further
work is undertaken to ensure that it remains
effective.
No change. Paragraphs 11.13 and 11.17 explain
how the Infrastructure Delivery Plan will be
monitored and managed.
Charnwood Infrastructure Schedule does not contain No change. The Infrastructure Delivery Plan has
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a full list of infrastructure and the estimated cost of
£188million is not adequately detailed or explained.
been developed in partnership with infrastructure
providers. Paragraphs 11.13 and 11.17 explain
how the Infrastructure Delivery Plan will be
monitored and managed.
Monitoring Our Strategy
The Regeneration of Thurmaston will not be
monitored.
No change. The Monitoring Framework sets out
the indicators that will be used to monitor Policy
CS21.
There should be an indicator relating to the recycling
rate for the plan area.
No change. The recycling rate for Charnwood is a
useful contextual indicator but is not considered to
be necessary for monitoring the implementation or
significant effects of the strategy.
Legal Matters
The Draft Core Strategy is not legally compliant
because it did not comply with the Statement of
Community Involvement
No change. Community engagement and
consultation has been undertaken in accordance
with the Charnwood Statement of Community
Involvement and is evidenced by statements of
consultation.
The Draft Core Strategy is not legally compliant
because it has not complied with the Duty to
Cooperate, in terms the amount and distribution of
development.
No change. A Duty to Cooperate Topic Paper has
been prepared which sets out how the Council
has met the Duty.
The Draft Core Strategy is not legally compliant
because it has not complied with the provisions of
the Localism Act
No change. It is not clear which provisions of the
Localism Act it is alleged have not been complied
with.
Leicestershire County Council welcomes its
involvement in the preparation of the Core Strategy,
the transport evidence and the identification of
infrastructure requirements, but it states that
Leicester City should confirm that it is in agreement
with the transport infrastructure as necessary and
committed to supporting its delivery.
Noted. Leicester City Council has made its own
representation to the Core Strategy. A Transport
Topic Paper has also been prepared in
partnership with the County Council and City
Council as local highways authorities.
Evidence
The Strategic Flood Risk assessment (2008) is out of
date.
No change. There is no evidence to suggest that
the Strategic Flood Risk Assessment is out of
date. However, discussions have taken place with
the Environment Agency to agree the commission
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of a revised SFRA.
The Council hasn't completed a Surface Water
Management Plan.
No change. The development of the strategy has
benefited from an ongoing dialogue with the
Environment Agency. A formal representation to
the Strategy from the Environment Agency has
not raised this as a concern.
There is no environmental health study
No change. The respondent’s claims are not
supported by an explanation of the need for this
study. The Council has a range of environmental
evidence prepared and published by a variety of
environmental studies.
Concerns over the loss of good quality agricultural
land/ lack of evidence of agricultural land quality
No change. The grade of agricultural land has
been taken into account by the Sustainability
Appraisal process.
The species evidence is out of date and certain
areas that are affected by development are not even
included.
Noted. A Phase 1 Habitat Survey for the
development options was completed in 2008 and
was extended to provide Borough-wide coverage
in 2012.
The transport evidence includes technical flaws, and
questionable assumptions. Specific examples of
flaws include:
� planning permissions at University Science
Park, and around Shepshed have not been
taken into account,
� the cost of the mitigation measures is
unproven and lack credibility,
� proposed roads in SUEs contradict transport
evidence.
No change. The Transport Evidence has been
confirmed as being robust by the local Highway
Authorities and Highway Agency
Sustainability Appraisal
The option for growth to the east of Loughborough
for 800 homes have not been independently
appraised by the consultants commissioned to
prepare the Sustainability Appraisal and has not
been considered against the 17 sustainability
objectives.
No change. The option to the East of
Loughborough has been appraised appropriately.
A Sustainability Appraisal Supplementary Report
has been prepared and published to explain how
reasonable alternatives have been considered
and dismissed as part of the process.
The process of sustainability appraisal and the
appraisal of alternatives and the reasons for their
No change. A Sustainability Appraisal
Supplementary Report has been prepared and
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rejection are not clearly set out in the report.
published to explain how reasonable alternatives
have been considered and dismissed as part of
the process.
The selection of the development strategy did not
take account of supporting information submitted by
promoters as a representation to the 2012
Supplementary Consultation, and therefore the
selected growth option is unsound.
No change. Supporting information submitted by
promoters to the Council has been considered
through the process. A Sustainability Appraisal
Supplementary Report has been prepared and
published to explain how reasonable alternatives
have been considered and dismissed as part of
the process.
Environmental considerations should take
prominence over social and economic considerations Not change. The Sustainability Appraisal
assesses environmental, economic and social
issues in accordance with the Directive and the
NPPF.
Policy CS18 is not justified because the sustainability
appraisal has incorrectly assessed the effects upon
Garendon Registered Park and the setting of other
highly designated heritage assets. The assessment
of the policy having an unknown effect is incorrect as
there are likely to be substantial negative effects
No change. The assessment of Garendon Park is
considered to be correct.
The selection of north of Birstall contradicts the
findings of 2008 Sustainability Appraisal report.
No change. The 2008 Sustainability Appraisal
appraises an option for development at North
Birstall of 4,000 homes. It identifies minor and
significant negative environmental effects, as was
the case for the other options at the Principal
Urban Area. The 2008 Sustainability Appraisal
report does not conclude that the site is an
unreasonable option. An up to date appraisal for
a Direction of Growth at North Birstall for up to
2,000 homes is made in the 2013 Sustainability
Appraisal report.
The conclusions regarding Wymeswold Airfield
considered as part of the 2008 Sustainability
Appraisal Report were significantly flawed and
inconsistent with West Loughborough.
No change. Wymeswold Airfield has been
sustainability appraised in 2008 and the reasons
for rejection are clearly set out. A further study of
the development potential of Wymeswold Airfield
was completed in 2012. The reasons for rejection
of the option are also set out in the March 2013
sustainability report.
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Within Policy CS22, the supporting text and the
Sustainability Appraisal, there is an overall reliance
upon mitigation measures to deal with the impact on
heritage, without due consideration in the first
instance to avoid impact as required by the National
Planning Policy Framework
No change. The selection of development west of
Loughborough has been objectively appraised
through the sustainability appraisal process,
having regard to evidence. The wording of policy
CS22 is considered to reflect the NPPF.
The 2008 Sustainability Appraisal process was
flawed because higher regard was given to
regionally important environmental assets, without
due regard to the significance of the heritage assets
at Garendon Park which are of national importance
No change. The Sustainability Appraisal assesses
environmental, economic and social issues in
accordance with the Directive and the NPPF. The
SA recognises assets of a national significance,
including SSSI and the Registered Park and
Garden.
The sustainability appraisal downplays the impact on
air pollution.
No change. It is not clear what is meant by this.
The Sustainability Appraisal assesses
environmental, economic and social issues in
accordance with the Directive and the NPPF.
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APPENDIX 1 - SPECIFIC CONSULTATION BODIES
Company/Organisation
Bardon Parish Meeting
Belton Parish Council
Blaby District Council
British Gas Connections Ltd
British Telecommunications Plc
Broughton & Dalby Parish Council
Cable & Wireless UK
Charley Parish Council
Costock Parish Council
Department for Communities & Local
Government (DCLG)
Department of Transport
East Leake Parish Council
East Midlands Council
English Heritage
Environment Agency
Gaddesby Parish Council
Glenfield Parish Council
Groby Parish Council
Harborough District Council
Hickling Parish Council
Hinckley & Bosworth Borough Council
Hoby with Rotherby Parish Council
Homes and Communities Agency
Hungarton Parish Council
Kegworth Parish Council
Keyham Village Meeting
Kingston on Soar Parish Council
Leicester City Council
Leicestershire Constabulary
Leicestershire Constabulary
Leicestershire County Council (Planning)
Leicestershire County Council (Education)
Leicestershire County Council
Leicestershire Fire & Rescue Service
Headquarters
Local Enterprise Partnership
Long Whatton & Diseworth Parish Council
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Company/Organisation
Lowesby & Cold Newton Parish Meeting
Markfield Parish Council
Melton Borough Council
Mobile Operators Association
National Grid
Natural England
Natural England
Network Rail
NHS Leicester, Leicestershire & Rutland PCT
Normanton on Soar Parish Council
North West Leicestershire District Council
Nottinghamshire County Council
NTL Group Ltd
O2 (UK) Ltd
Oadby & Wigston Borough Council
Orange Personal Communications Ltd
Rempstone Parish Council
Rushcliffe Borough Council
Rutland County Council
Scraptoft Parish Council
Severn Trent Water
Stanford on Soar Parish Council
Sutton Bonington Parish Council
The Coal Authority
T-Mobile Ltd
Transco Plc
Twyford and Thorpe Parish Council
Upper Broughton Parish Council
Virgin Media
Vodafone Ltd
Willoughby on the Wolds Parish Council
Wysall & Thorpe in the Glebe Parish Council
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APPENDIX 2 - GENERAL CONSULTATION BODIES
Company/Organisation
Absail Shipping & Forwarding Ltd
Action Deafness
All Saints Parish Church
All Saints Residents Association (Shepshed)
Angraves Cane Furniture Ltd
Anstey Parish Plan Group
Ashby Road Estates Community Association
Bangladesh Social Association
Barkby & Beeby Womens Institute (WI)
Barkby Local History Committee
Barratts East Midlands
Barrow upon Soar VDS Group
Barrow Voice
Birstall Post
Building Relationships
Burton on the Wolds Parish Plan
Charnwood Arts
Charnwood Bangladeshi Society
Charnwood Carers
Charnwood Disability Forum
Charnwood Shelter Group
Churches Together in Loughborough
City Screen Printers UK) Ltd
Cooke Optics Ltd
Disability Rights Commission
East Goscote Parish Plan
Emmanuel Church
Equality and Human Rights Commisison
Fearon Community Association
FFR Ultrasonics Ltd
Geeta Bhawan
Gorse Covert Community Association
Great Central Railway plc
Hastings Community Association
Hastings Residents Association
Hathern Village Appraisal
Haydon Road Residents Association
Company/Organisation
Help the Aged
Herrick Road Area Residents Group
Human Rights and Equalities Charnwood
Leicester Diocesan Board of Finance
Leicester Mercury
Leicestershire Chamber of Commerce
Leicestershire Food Links Ltd
Loughborough Churches Partnership
Loughborough Churches Partnership
Loughborough Gospel Halls Trust
Loughborough Jansari Centre
Loughborough Mosque & Islamic Cultural
Association
Loughborough United Reformed Church
Manor Farm Community Group
Mariners Quay Residents Association
Meadows Congregation of Jehovah's
Witnesses
Mela Committee
Mountsorrel Village Plan
Mr Percy Hartshorn
Mr Roy Campsall
Neighbourhood Watch (Thurmaston)
Newtown Linford Village Appraisal
Planning Aid Service
Polish Community Centre
Queniborough Village Appraisal
Quorn Village Design Statement
Rearsby Parish Plan / VDS Group
Regen Solutions
Reminiscences Group
RNIB Vocational College
Roundabout the Community
Seagrave Parish Magazine
Shelthorpe Community Association
Shepshed Local History Society
Shree Ram Krishna Community Association
Sidings Park Residents Association
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Company/Organisation
Sikh Temple
Sileby Parish Plan
Sri Niketan Cultural Assoication
St Michael's Church
St Peters Community Association
St Peters Community Association
Syston Local History Group
TES (Shepshed) Ltd
The Abbeyfield Loughborough Society
The Long Furrow Community Magazine
Thrussington Life
Thrussington Village Statement
Thurmaston Times
Thurmaston Times
Utilita Services Limited
Wolds Historical Organisation
Woodhouse and Wooodhouse Eaves Local
History Group.
Woodhouse Eaves Parish Plan Group
Woods Coaches Ltd
Wymeswold Parish Plan Group
Wymeswold Village Design Statement
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