Davidsons Developments Limited: ID 2809

MATTER 4 – The Development Strategy

Issue:

Whether the Development Strategy set out in Policy CS1 is justified, effective and consistent with national policy.

N.B. Detailed issues relating specifically to the proposed Sustainable Urban Extensions and Directions of Growth are dealt with under other Matters.

Questions

1) What is the basis for the proposed distribution of development between different parts of the Borough i.e. the Principal Urban Area, Loughborough and Shepshed, the Service Centres and other settlements?

2) What options were considered for the distribution of development? Why was this option chosen and why were alternative options discounted?

3) What is the basis for the settlement hierarchy set out in Policy CS1? Is it appropriate and justified?

3.1 The overall distribution of development between the PUA and the Rest of District in Policy CS1 is based on the distribution as set out in the now revoked Regional Plan. Given the revocation of the Regional Plan, and the more recent evidence presented in the SHMA 2014 (PSD/14), the rationale for this distribution needs to be reviewed.

3.2 The settlement hierarchy set out in Policy CS1 was informed by the assessment of available services and facilities in settlements undertaken by the Council and set out in the Developing a Settlement Hierarchy Report, 2007 (EB/DS/9), the Settlement Hierarchy Review, 2008 (EB/DS/14) and the Service Centre Review, 2011 (EB/DS/13).

3.3 Pegasus has engaged with the Council through the preparation of the Core Strategy arguing that Anstey represents a suitable location to accommodate further growth. This engagement included previous submissions on the Core Strategy Supplementary Consultation, June 2012 and a more recent response to the Further Consultation on the Sustainability Appraisal Supplementary Report. For ease of reference, copies of these submissions are attached at Appendix 1 for information.

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3.4 The Sustainability Appraisal Supplementary Report (PSD/2) has been prepared by the Council to clarify how reasonable alternatives were identified as part of the Core Strategy Supplementary Consultation in 2012, the reasons for rejecting or selecting alternatives and the implications on the revocation of the Regional Plan on reasonable alternatives for the overall spatial strategy.

3.5 In our response to consultation on the Sustainability Appraisal Supplementary Report we have outlined why we consider the reasons presented for rejecting the option of growth at Anstey are not justified.

3.6 We have also highlighted the failure of the Council to consider a review of the definition of the extent of the PUA following the revocation of the Regional Plan.

3.7 In the Council’s Supplementary Consultation on the Core Strategy, June 2012, the role of Anstey and Syston in supporting the growth of the PUA was assessed as a reasonable alternative in recognition of the strong relationships these settlements have with Leicester City.

3.8 Anstey is identified in the Core Strategy as one of a number of Service Centres where some growth is proposed over the plan period. However much of that growth has already been accommodated and, on the basis of the proposed Core Strategy policy, further growth over the remainder of the plan period may be very limited. It is not considered that this represents the most appropriate approach given the opportunities available accommodate some further growth in these settlements in a sustainable way.

3.9 Anstey is a sustainable settlement and has recently accommodated further growth with the development of some 165 homes to the north of Groby Road by Davidsons Developments.

3.10 Anstey offers a range of services and facilities and is very well located in relation to Leicester City, with regular, high quality bus connections to main destinations in the City including the city centre and hospitals. The fact that, unlike Birstall and Thurmaston, the settlement is not physically connected to the built up area of the City does not diminish the good functional relationship the settlement enjoys with the main urban area in the HMA.

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3.11 There are potential issues with the timing and deliverability of the Council’s preferred SUE to the east of Thurmaston. Provision for some further growth at Anstey as part of an expanded PUA, would provide the necessary flexibility to deal with any delays in progress of the Council’s preferred sites.

3.12 The indicative masterplan proposals submitted as part of the response to the Core Strategy Supplementary Consultation shows the opportunity to accommodate some 500 homes to the south of Anstey without any unacceptable impacts.

3.13 An opportunity associated with further growth to the south of Anstey is also the scope to provide for highway improvements through an all movement traffic light controlled junction with Anstey Lane and the A50. This potential benefit is one that should be taken into account in assessing the sustainability of growth at Anstey as part of a strategy for growth in south Charnwood.

3.14 In our view, Anstey should be considered as a potential location for further growth to help support provision within and adjoining the PUA and address any shortfalls in supply from other sources.

3.15 Even if it is not considered to form part of the PUA, the settlement is a highly sustainable Service Centre capable of accommodating further growth.

4) Is the approach to the scale of development in different parts of the Borough appropriate and justified?

5) Is Policy CS1 sufficiently clear in terms of the scale of development in individual Service Centres, other settlements and small villages and hamlets?

5.1 In response to Matter 2, the findings of Chelmer Modelling undertaken on behalf of a consortium of developers, including Davidsons Developments Limited, is set out. This concludes that the scale of housing development required in the Borough to meet full, objectively assessed needs (OAN) is at least 1,144 dwellings a year. The scale of development to be directed towards different parts of the Borough will need to be re-considered as a result.

5.2 Policy CS1 proposes that at least 3,170 dwellings are directed towards Service Centres, including Anstey over the period to 2028. Figure 1 to the Core Strategy indicates that all but 200 of this requirement had been met through completions and commitments as at 2012. This proposed

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distribution effectively places an embargo on any further development in the more sustainable settlements over the remainder of the plan period. This does not represent the most appropriate or sustainable strategy and ignores the opportunities available, such as at south Anstey, to deliver further development sustainably to help meet future requirements and provide for a degree of flexibility to address shortfalls in provision from other sources of supply.

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Appendix 1: Response to Core Strategy Supplementary Consultation, July 2012

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Land South of Anstey

CONTENTS:

Page No:

1. INTRODUCTION 1

2. KEY CHANGES SINCE 2008 2

3. DIRECTIONS FOR GROWTH 4

4. OPTIONS FOR SOUTH CHARNWOOD 6

5. SUSTAINABILITY APPRAISAL 8

6. SERVICE CENTRES 9

Appendices

APPENDIX 1: PRESENTATION TO MEMBERS, 27TH JUNE 2012 10

APPENDIX 2: LEICESTER PUA CONTEXT PLAN 11

APPENDIX 3: INDICATIVE MASTERPLAN PROPOSALS 12

EMS.2354 July 2012 Land South of Anstey

1. INTRODUCTION

1.1 This submission in response to the Core Strategy Supplementary Consultation has been prepared on behalf of Davidsons Developments Limited who has interests in land to the south of Anstey.

1.2 The submission sets out the reasons why this location should be identified as a Direction for Growth and be included as part of the Council’s preferred strategy to accommodate future housing requirements over the period to 2028. In support of the representations, indicative masterplan proposals have been prepared illustrating the options available to accommodate up to 500 homes in this location. A sustainability appraisal has also been prepared using the refined SA Framework. This has been included as a separate report. A presentation on the indicative masterplan proposals was made to members on the 27th June 2012. A copy of the presentation is attached at Appendix 1.

1.3 At its meeting on the 21st July 2011, Charnwood Borough Council’s Plans Committee resolved to grant outline planning permission for the development of up to 165 dwellings on land north of Groby Road, along with new areas of open space, allotments and an extension to the cemetery. The section 106 agreement has now been concluded and the decision has been issued. As part of the response to the Strategic Housing Land Availability Assessment (SHLAA) a number of potential development sites have been identified to the south of Anstey around Green Farm (PSH4, PSH92 and PSH212). In addition Davidsons made a submission in relation to land to the north of Gynsill Lane (PSH213).

1.4 The following sections set out Davidsons’ comments on the Supplementary Consultation, including comments on the options for South Charnwood.

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2. KEY CHANGES SINCE 2008

2.1 Paragraphs 1.13 to 1.20 of the Supplementary Consultation document set out the key changes that have taken place since the last consultation in October 2008. This includes further work undertaken to establish the scale of additional development to be accommodated over the extended period to 2028. The assessment takes account of expected delivery from Sustainable Urban Extensions (SUEs) and concludes that there is a balance of 2,143 dwellings to be found in the Leicester Principal Urban Area (PUA).

2.2 This assessment is based on an assumption that some 3,750 dwellings will be delivered on the east Thurmaston SUE by 2028. No housing trajectory has been provided as part of the consultation to explain the assumptions made in terms of likely delivery from the SUE.

2.3 Given that the Core Strategy is programmed for adoption by December 2013, it is unlikely that any completions will take place on the SUE until 2014/15 at the earliest. This provides for a 14-year build period which would require an annual average completion rate for the Thurmaston SUE of just under 270 dwellings a year to deliver 3,750 dwellings by 2028.

2.4 This annual build assumption is considered to be overly ambitious and is not supported by any available evidence. The National Planning Policy Framework (NPPF) requires local planning authorities to ensure that local plans are effective and that the proposals can be delivered over the plan period. There is a real risk that the housing requirements will not be delivered in the plan period because of the assumptions on delivery from the SUEs.

2.5 Analysis of build on a number of larger sites across , including land north of Birstall, would suggest a build rate of around 30 dwellings per year per builder would represent a more realistic build rate. For the Thurmaston SUE, this would suggest that around 90 and 120 dwellings a year are likely to come forward on a lager site, depending on the number of builders. This suggests that there is potentially an additional shortfall of between 2,000 and 2,500 homes that would need to be provided for.

2.6 In identifying its preferred development strategy, the Council needs to apply a flexible approach and make sufficient provision to take account of any uncertainties and

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allow for under delivery from other sources of supply. It is considered that the Council should seek to identify Directions for Growth in the Principal Urban Area to provide for at least 4,000 homes in addition to the proposals for a SUE at Thurmaston.

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3. DIRECTIONS FOR GROWTH

3.1 The Supplementary Consultation appraises options for development within and adjoining the Leicester PUA and includes an assessment of Anstey and Syston as locations with the potential to support PUA growth. This is explained on the basis of the limited options available for development within and adjoining the PUA and the strong relationships these settlements have with Leicester City (para 2.6).

3.2 The identification of Anstey as potentially forming part of an expanded Leicester PUA is supported. This acknowledges the strong functional relationships between the settlement and the wider . Whilst not physically attached to the urban area, the settlement enjoys easy access to services and facilities in the city by sustainable modes. The attached context plan at Appendix 2 shows how the settlement relates well to the Leicester urban area. This shows that Anstey is as well related to the Leicester urban area as other settlements forming part of the Leicester PUA.

3.3 Given the imminent revocation of the East Midlands Regional Plan, there is the opportunity to review the definition of the Leicester PUA and provide a more flexible approach. The Leicester and Leicestershire Structure Plan included Anstey and Syston as part of the Central Leicestershire Policy Area in order to direct development towards the main urban area. This reflected identified travel to work areas. This represents an appropriate definition of the Leicester PUA.

3.4 Land south of Anstey has the potential to deliver a Direction for Growth of up to 500 homes and is well located to help meet the strategic housing requirements for the Leicester PUA.

3.5 Paragraph 2.5 of the Supplementary Consultation indicates that land to the south of Anstey was considered jointly with land north of Glenfield but discounted on the basis that the two areas could not be considered as a comprehensive extension to the Leicester PUA.

3.6 As part of this submission an indicative concept masterplan has been prepared and is attached at Appendix 3. This demonstrates that there is the potential to deliver up to 500 homes to the south of Anstey. This should be properly considered as a potential direction for growth alongside options north of Glenfield, north of Birstall and south and south-east of Syston.

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3.7 A Direction for Growth to the south of Anstey also provides a flexible development option with the capacity to accommodate a range of development options, building on the existing consented development to the north of Groby Road. There is scope to provide a development building up from a further 100 dwellings in addition to the outline consent, to some additional 500 dwellings incorporating a new link road between Bradgate Road and Groby Road.

3.8 In support of this submission a Sustainability Appraisal of the South Anstey option has been undertaken, applying the Borough Council’s revised Sustainability Appraisal Framework. This is submitted as part of these representations.

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4. OPTIONS FOR SOUTH CHARNWOOD

4.1 The Supplementary Consultation document outlines 5 options for accommodating the additional growth requirements within and adjoining the PUA, including

Option 1 – 2,000 homes and 15 hectares of employment land north of Birstall

Option 2 – 1,500 homes and 15 hectares of employment land north of Birstall and 500 homes north of Glenfield

Option 3 – 500 homes north of Glenfield, up to 1,500 homes and 10 hectares of employment land south and east of Syston

Option 4 – 1,500 homes and up to 10 hectares of employment land south and east of Syston with a total of 2,000 homes directed to the Service Centres of Anstey and Syston.

Option 5 – Not meeting the housing requirements

4.2 It is considered that the approach to the appraisal of options to accommodate the identified housing shortfall is overly mechanistic and as a result has not considered the range of available options to accommodate the required level of housing within and adjoining the Leicester PUA. The approach is inflexible in applying a 500 dwelling threshold for the consideration of potential directions for growth. It also does not consider alternative combinations of growth options.

4.3 This submission outlines the potential for land south of Anstey to contribute to housing requirements within or adjoining the PUA. As part of the submission, an indicative concept plan has been prepared to show how the location can offer a sustainable option to deliver up to 500 homes. Growth south of Anstey could present an alternative to land north of Glenfield in Options 2 and 3 and could accommodate the remaining 500 dwellings required in Option 4. Alternative options could involve a combination of development north of Glenfield and south of Anstey.

4.4 The Sustainability Appraisal submitted as part of these representations provides supporting evidence to allow a comparative assessment of the alternative growth options adjoining the Leicester PUA.

4.5 Under Option 4, the Supplementary Consultation suggests that Anstey and Syston would be identified as ‘Service Centres related to, but not adjoining, the Leicester

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Principal Urban Area’. It is our submission that Anstey and Syston should form part of an expanded Leicester PUA as they enjoy the same sustainability credentials as other settlements adjoining Leicester. There is no need for any distinction to be made between settlements falling within this revised PUA as they all enjoy the same locational advantages and can potentially accommodate additional development to meet the identified housing requirement.

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5. SUSTAINABILITY APPRAISAL

5.1 The Interim Sustainability Appraisal undertaken by independent consultants LUC appraises the various options identified in the Supplementary Consultation against a refined Sustainability Appraisal Matrix. For the land north of Glenfield, this is appraised under Options 2 and 3 in combination with growth north of Birstall and south and East of Syston. There is no separate appraisal of the Glenfield option. This makes it somewhat difficult to clearly establish how this option performs to enable an informed assessment of the sustainability of each alternative location to establish the most appropriate strategy.

5.2 The Sustainability Appraisal also considers the further directions for growth in combination with the East Thurmaston SUE. Again this makes it difficult to identify the relative sustainability merits of the alternative directions for growth. Because of the approach in the Interim Sustainability Appraisal, a robust comparative assessment of the directions for growth will be difficult. To enable members to make an informed assessment, separate appraisals of individual directions for growth should be undertaken.

5.3 For the potential direction for growth to the south of Anstey the Sustainaibility Appraisal Matrix has been completed and is included with these representations as a separate report. This considers the range of growth options that could potentially be accommodated in this location as illustrated on the indicative concept plans.

5.4 As part of the work to support the outline planning application to the north of Groby Road, a number of technical studies were undertaken. These appraised the wider area to the south of Anstey and provide a robust evidence base to inform the sustainability appraisal of the potential direction for growth.

5.5 The appraisal confirms that the area performs well and represents a sustainable solution to help meet future housing requirements in the Leicester PUA.

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6. SERVICE CENTRES

6.1 Section 4 of the Supplementary Consultation paper outlines broad options for the approach to development in Service Centres. Anstey and Syston are included as two of the seven identified Service Centres outside the Leicester PUA. Options for North Charnwood include an allowance for different scales of development to be directed towards Service Centres, but notes that these options remain realistic, with or without Anstey and Syston.

6.2 We have already set out the reasons why Anstey and Syston should be included as part of the Leicester PUA and we consider this to be the appropriate approach for the Core Strategy. Development in Anstey and Syston would help to meet housing requirements for the Leicester PUA.

6.3 If it is concluded that Anstey does not form part of the PUA, it still offers a highly sustainable location to accommodate further housing growth. The locational advantages of Anstey and its good relationship with Leicester remain, whether it is included in an expanded PUA area or not.

6.4 Of the seven Service Centres it is one of the better locations to accommodate growth. The indicative masterplans attached at Appendix 3 demonstrate that land south of Anstey can provide for a range of development options, building on the existing outline consent to provide between 100 and 500 additional homes depending on requirements. The flexibility of the development opportunity means that the location should be included as a preferred location to help meet the residual housing requirements.

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Appendix 1: Presentation to Members, 27th June 2012

Page 10 EMS.2354 July 2012 Member Presentation 27th June Core Strategy - Planning for Growth

Potential Direction for Growth South of Anstey

James Wilson, Davidsons Nigel Harris, Pegasus Planning

South of Anstey – The Opportunity

• Building on existing consent for 165 homes north of Groby Road • Avoids land in APAC • Avoids critical areas of Green Wedge • A flexible solution that can deliver up to 500 homes • New green infrastructure including new formal recreation facilities as an extension to the Village Green Anstey – A Sustainable Location

• Strong relationship with Leicester • Good public transport links to key services and facilities • Functionally as well related as other settlements forming part of the Leicester PUA

South Anstey In Context

Anstey

Glenfield Hospital Access to Facilities and Services The Indicative Concept Plan Indicative Concept Plan Indicative Concept Plan – Charnwood Forest Indicative Concept Plan – Green Wedges Indicative Concept Plan - Topography Indicative Concept Plan - Footpaths Indicative Concept Plan – Consented Scheme Indicative Concept Plan – 100 homes Indicative Concept Plan – 200 homes Indicative Concept Plan – 300 homes Indicative Concept Plan – 500 homes Indicative Concept Plan – New Link Road Indicative Concept Plan – Green Infrastructure Questions Land South of Anstey

Appendix 2: Leicester PUA Context Plan

Page 11 EMS.2354 July 2012 to Melton KEY to Loughborough Syston J22 Station Leicester City Centre A46 Soar Town Centres

A6 River Local Centres A607 Green wedges to

M1 A50

J21A A563

Leicester Leicester Station General A47 Hospital

A47 Leicester Royal Infirmary University A5460 of Leicester to Hinckley

J21

South Wigston Station

M69 A5199 A56 to Market Harborough

Grand

Canal Union

M1 Land South of Anstey

Appendix 3: Indicative Masterplan Proposals

Page 12 EMS.2354 July 2012 Indicative Concept Plan – Consented Scheme Indicative Concept Plan – 100 homes Indicative Concept Plan – 200 homes Indicative Concept Plan – 300 homes Indicative Concept Plan – 500 homes Indicative Concept Plan

Davidsons Developments Limited: ID 2809

Appendix 2: Response to Sustainability Appraisal Supplementary Report, March 2014

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1.0 Introduction

1.1 This response to the consultation on the Sustainability Appraisal Supplementary Report is made on behalf of Davidsons Developments Limited who has interests in land to the south of Anstey. Davidsons made representations at key stages in the preparation of the Local Plan Core Strategy, including the Supplementary Consultation in June 2012 and the Submission Draft consultation in July 2013. At each of these stages, our submissions were supported by a number of supporting documents outlining the sustainability credentials of potential development to the south of Anstey.

1.2 At its meeting on the 28th October 2013 Full Council considered a report on the proposed submission of the Core Strategy. It was resolved that the Core Strategy be submitted for examination and that the supplementary paper to the Sustainability Appraisal be published for a six week period of consultation following submission of the Core Strategy and any comments received be submitted to the Secretary of State as part of the examination process. The report to Full Council explained that the Supplementary Report was prepared to address shortcomings in relation to the original Sustainability Appraisal report.

1.3 Paragraph 1.1 of the Sustainability Appraisal Supplementary Report sets out the three purposes of the report as being to clarify;

 How reasonable alternatives were identified as part of the 2012 Core Strategy Supplementary consultation;

 The reasons for rejecting or selecting reasonable alternatives;

 The implications of the revocation of the Regional Plan on reasonable alternatives for the overall spatial strategy considered throughout the Core Strategy preparation.

1.4 The following sections of this response deal with these aspects.

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2.0 Identification of Reasonable Alternatives in Supplementary Consultation, June 2012 and Reasons for Rejection

2.1 The Supplementary Consultation, June 2012, considered a range of reasonable alternatives to accommodating the additional housing requirement identified following a review of likely delivery from proposed SUEs and extending the plan period by 2 years to 2028. The consultation included a Sustainability Appraisal Interim report assessing the alternative options.

2.2 Land to the south of Anstey was specifically considered as part of Options 3 and 4, and more generally under and option for further growth in Service Centres.

2.3 The reason for considering options at Anstey and Syston was explained at paragraph 2.6 of the Supplementary Consultation, 2012 on the basis that the settlements had strong relationships with Leicester City.

2.4 On behalf of Davidsons Developments we submitted a comprehensive response to the Supplementary Consultation. This included a Sustainability Assessment applying the Council’s Sustainability Appraisal Framework, a copy of a presentation made to councillors in June 2012, a plan showing the relationship of Anstey with the wider PUA and also an indicative masterplan illustrating the opportunities for development. For completeness a copy of this representation has been included as part of this submission.

2.5 The Sustainability Appraisal Supplementary Report considers the option of development to the south of Anstey at Appendix 1 (pages 30-33), Appendix 2 (pages 160-161), and Appendix 3 (page 55).

2.6 The stated reasons for rejection refer to the location falling outside the PUA and lack of conformity with the Regional Plan, significant negative environmental effects in relation to the separation of Anstey and Leicester and limited scope to deliver significant supporting infrastructure.

2.7 We do not consider that this provides a sufficiently robust appraisal of the option for development to the south of Anstey and therefore the reasons for its rejection are unsound. We remain of the view that the option for growth to the south of Anstey represents a sustainable development solution that can help to meet requirements for development in south Charnwood adjoining the Leicester PUA.

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2.8 The argument that the proposal would not be in conformity with the Regional Plan is of little relevance now that the plan has been formally revoked. We deal with the implications of the revocation below in more detail. One of the clear implications was the opportunity for the Council to review the definition of the PUA, taking proper account of the functional interrelationships of settlements with Leicester and the scope for them to accommodate some growth to meet the city’s needs sustainably. This review does not appear to have taken place.

2.9 In terms of potential impacts on the separation between Anstey and Leicester, the Leicester PUA context plan submitted as part of our representations on the Supplementary Consultation 2012, shows that there is an extensive area of Green Wedge extending to the south of Anstey between Beaumont Leys, Glenfield, Anstey and Groby. The masterplan proposals prepared as part of that submission show how further growth could be accommodated south of Anstey, building on the successful development at St James Gate, without threatening the separate integrity of Anstey or the strategic function of the wider area of Green Wedge.

2.10 As part of our work with Davidsons on the consented development at St James Gate, we have engaged on a continuing basis with Anstey Parish Council and the local community. Through these discussions it is clear that there are local concerns about the potential impacts of further development on the local highway network. Both the Parish and local residents responding to consultations on the St James Gate development proposals, highlighted problems of access to and from Anstey, particularly along the Leicester Road.

2.11 Part of the issue relates to the current left in/left out working of Anstey Lane with the A50. To consider potential solutions to these issues, our highway engineers, Phil Jones Associates, have been in discussions with the local highway authority to investigate the scope for further highway improvements that could be supported by further development to the south of Anstey. This work has identified the potential to provide an all- movement traffic light controlled junction with Anstey Lane and the A50 to replace the currently restricted operation. Initial assessments indicate that this would deliver benefits to the current operation of the local highway network. It is considered that the potential to deliver these improvements represents a significant contribution to supporting Page 3

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infrastructure that should be taken into account in assessing the sustainability of the option for development to the south of Anstey.

2.12 Development to the south of Anstey would complement the Council’s preferred strategy for growth east of Leicester and north of Birstall by providing the flexibility to address possible shortfalls in delivery from the proposed SUE east of Thurmaston.

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3.0 Implications of the Revocation of the East Midlands Plan

3.1 Part 2 of the Sustainability Appraisal Supplementary Report presents an appraisal of the implications of the revocation of the East Midlands Regional Plan. The assessment effectively considers three groups of alternative spatial distribution options and appraises their relative sustainability against the sustainability appraisal framework.

3.2 What the Supplementary Report does not do is consider alternative scales of growth that may be required to meet objectively assessed housing needs. Nor does it consider the potential to redefine the extent of the Leicester PUA to take account of a proper assessment of the relationship of adjoining settlements with the City.

3.3 One of the key implications of the revocation of the East Midlands Regional Plan is that the scale of housing proposed in Policy 13a no longer forms part of the development plan. The NPPF is clear that local planning authorities should look to boost significantly the supply of housing, and use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. The implications of the revocation of the Regional Plan are therefore not just related to the question of the appropriate spatial distribution of housing. There appears to have been little consideration of the implications of alternatives scales of growth following revocation of the Regional Plan.

3.4 In addition there appears to have been no review of the definition of the Leicester PUA following the revocation of the Regional Plan. This is despite recognition by the Council in the Core Strategy Supplementary consultation that the role of Anstey in supporting the growth of the Leicester PUA represented a reasonable alternative given the settlement’s strong relationships with the City.

3.5 The reason for rejecting the option of growth south of Anstey due to issues of conformity with the Regional Plan (Appendix 3, page 55 of the Sustainability Appraisal Supplementary Report) is clearly not justified following revocation.

3.6 It is considered that the Sustainability Appraisal Supplementary Report does not properly appraise the implications of Regional Plan revocation, particularly in relation to the overall scale of development to be provided or the appropriate definition of the Leicester PUA in relation to Charnwood. Page 5

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3.7 The Sustainability Appraisal Supplementary Report is therefore deficient in not considering the key implications of the revocation of the Regional Plan.

3.8 In terms of the appraisal of alternative spatial options, the assessment concludes that the strategy of urban concentration with planned sustainable urban extensions as advocated in the Regional Plan, performs most strongly against the SA objectives (para 3.83). This assessment is reasonable. However, it was important that, as part of the consideration of alternative spatial options, the appropriate definition for the PUA was subject to review. It is considered that this review would have concluded that development to the south of Anstey represents a sustainable option for accommodating growth to the Leicester PUA, complementing the Council’s preferred growth options at Birstall and east Thurmaston and providing the flexibility to deal with changing circumstances.

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