Deposit Draft Policy Number and Title	Proposed Modification / New Policy	Reasons for Proposed Modification
Housing Policy 1: The Quantity of Housing Land	Housing Policy 1: The Quantity of Housing Land Provision will be made for up to ~~59,100~~ 63,000 dwellings within the Plan Area between 1996 and 2016, of which about ~~28,750~~ 31,500 dwellings shall be located in the Central Leicestershire Policy Area. Provision by district and unitary authority area, including an element for the Central Leicestershire Policy Area, will be as follows:	In accordance with Panel Recommendations for the reasons given in the Panel Report to: refer to "provision will be made for…", in the policy preamble (paragraph 4.63) increase the allocation of dwellings to Leicester (paragraph 4.49) remove the column headed "Smaller Greenfield Sites" (paragraph 4.59) subject to: not accepting the recommendations relating to the Plan-area total, the proportion allocated to the Central Leicestershire Policy Area and the allocations to districts and, in response to representations to the deposit draft Structure Plan, updated information on housing supply, and RPG8. Policy Wording Accept the Panel’s wording of the Policy in referring to "provision will be made for…". Plan Area Total A total of 63,000 dwellings is consistent with that proposed in RPG 8 which proposes an annual rate of provision of 3,150 dwellings, 50 per annum less than in the Secretary of State's draft RPG. Whilst RPG 8 covers a different 20 year period (2001-21), it is considered that it would be appropriate to apply the annual RPG 8 figure to the Structure Plan period, particularly as such an approach was supported at the Examination in Public. Central Leicestershire Policy Area The focus on the CLPA proposed by the Panel report is not acceptable for several reasons. Firstly there has been significant under-achievement in relation to the 55% target in the first five years of the Plan period. Secondly the target could only be achieved if substantial amounts of additional greenfield land were to be released for housing within the CLPA. Such releases would undermine attempts to significantly maximise urban capacity and increase housing provision within Leicester. It is considered that the Panel's recommendation that housing provision in Leicester be increased to 19,000 dwellings is incompatible with significant increases in housing provision within the rest of the CLPA outside Leicester. A distribution of dwellings within and outside the CLPA similar to that proposed at the EIP is therefore considered to be appropriate. Distribution to Districts The distribution to districts proposed by the Panel does not take into account the updated supply information provided by the districts and the adjusted urban capacity assessment (see discussion under Housing Policy 2 below). It is considered that a distribution based on the updated supply, and the distribution of Strategic Greenfield Sites, as set out in the proposed Housing Policy 2, is the most appropriate approach to distribution.
Housing Policy 2: New Allocations of Greenfield Land	Housing Policy 2: ~~New Allocations of Greenfield Land~~ *Strategic Greenfield Housing Sites* ~~After taking account of housing supply, including completions, commitments and urban capacity, no more greenfield land than the amounts given below should be allocated for housing:~~ *No more than 50 hectares of new greenfield housing land* should be allocated on Strategic Greenfield Housing Sites in Charnwood, Harborough, Hinckley and Bosworth and Oadby and Wigston. Development of these sites will be phased as follows:	In response to representations to the deposit draft, updated information on housing supply, and RPG 8. It is considered that a policy on the lines of the simplified Housing Policy 2 proposed in the Supplementary Housing Report provides an appropriate level of strategic guidance. This includes the principles relating to phasing that were originally set out in Housing Policy 3. It is important that the Plan is able to specify how much greenfield land should be released, the broad distribution of this provision, and its timing. This will ensure that strategic support is provided for the Plan's objective to maximise urban capacity, supporting Leicester's challenging housing provision target and avoiding the unnecessary release and development of greenfield sites. It will ensure the greenfield development identified in the proposed modification to Strategy Policy 4 is subjected to a maximum land area, is not developed until the last five years of the Plan period and is distributed between the CLPA and the rest of the Plan area. In deriving the distribution of residual greenfield land requirement, information on housing land supply has been updated to a base date of April 2001. In addition the urban capacity assessment has been adjusted. It is assumed that housing land supply in Leicester will total 19,000 dwellings, in line with the Panel's recommendations. This is a more challenging rate of provision than that suggested by existing housing land supply information, and relies on significantly greater amounts of urban capacity coming forward than found in the April 2000 urban capacity assessment. Taken together these indicate a supply of about 59,900 dwellings in the Plan area up to 2016. In addition, it is considered that the urban capacity assessment might be an underestimate, for the following reasons: The Government is placing increasing emphasis on the importance of maximising urban capacity, reflected in the Planning Green Paper and the Greenfield Land Direction; The RPG 8 includes a revised Policy 1 (Locational Priorities for Development) which places greater emphasis on finding suitable sites (whether previously developed or not) within urban areas. This greater emphasis is reflected in the Proposed Modification to Strategy Policy 3A. This strengthening of Government policy on urban capacity could mean more housing land being brought forward in urban areas in the future than might have been previously estimated; The Panel noted that the urban capacity assessment 'may be regarded as taking a somewhat conservative approach to assessing future potential', pointing out a number of areas where future capacity may have been underestimated. In particular, the Panel recommended that the provision of housing within Leicester should be increased from 16,200 to 19,000; Melton BC carried out a detailed urban capacity study in early 2001 which found about 10% more capacity than had been identified in the Structure Plan assessment; There is evidence from recent research that urban capacity assessments and studies may have underestimated urban capacity. A recent report by Business Strategies/ GVA Grimley (A Deepening Mismatch, 2002) argues that there will be a potential oversupply of urban manufacturing land over the next five years, and that this land is well placed to meet increasing demand for residential land; There are indications that some districts are witnessing urban housing sites coming forward more quickly that was previously anticipated. In the light of these strengthening policy pressures, evidence of increased supply of urban land and concerns that the urban capacity assessment was 'conservative', it is considered appropriate to increase the urban capacity assessment by 5%, well within increase suggested by the Melton study. It is applied to all districts except Leicester, where a higher figure of 19,000 is already proposed, and Melton, where the urban capacity study findings are already built into the supply figures. This results in the urban capacity assessment increasing by about 550 dwellings. The total supply of housing land is consequently estimated at about 60,450 dwellings, leaving a shortfall of 2,550 to be met on greenfield sites of which 2,000 is proposed on Strategic Greenfield Housing Sites. In accordance with the Proposed Modification to Strategy Policy 4, it is anticipated that these sites should be generally be identified as urban extensions and allocated for development in local plans. It is proposed that the distribution of the Strategic Greenfield Housing Sites should be broadly similar to that proposed at the EIP, with the increases distributed to ensure a minimum size of 250 dwellings, addressing the criticism that some sites were too small to be strategic. A further change is that to be consistent with the Panel’s recommendation regarding density in Housing Policy 5, a mean density of 40 dwellings per hectare is used to calculate the land take of Strategic Greenfield Housing Sites, compared with 35 dwellings per hectare proposed at the EIP.
Housing Policy 3 The Phasing of New Allocations of Greenfield Housing Land	Delete Policy.	This policy is proposed to be deleted but reference to phasing is retained in a revised Housing Policy 2 in response to representations to the deposit draft Structure Plan. It is considered that a policy on the lines of the simplified Housing Policy 2 proposed in the Supplementary Housing Report provides an appropriate level of strategic guidance.
	*Housing Policy 3: New Housing Provision on Previously Developed Land and through Conversions.* *At least 50% of additional dwellings in the Plan period should be provided on previously developed land and through conversions of existing buildings.* Local plans should put in place policies and select sites to maximise the re-use of previously developed land and conversions of existing buildings, setting appropriate targets in the light of these policies and allocations and the findings of urban capacity studies.	In accordance with Panel Recommendations for the reasons given in the Panel Report (paragraphs 4.42 to 4.43) subject to: setting a target of 50% during the plan period utilising a form of wording that is consistent with RPG 8. RPG 8 requires a target of 60% of additional dwellings on previously developed land and through conversions by 2021, and development plans to put in place policies to achieve appropriate targets for higher levels of re-use of previously developed land than in the past. However, RPG 8 gives a target for the region as a whole, not for constituent structure plan areas. If this principle is followed it is considered inappropriate to provide targets for each district as recommended by the Panel. Current estimates for the Plan area indicate that about 47% of the housing provision could be on previously developed land or found through conversions. In the light of this, it is considered that that the policy should set an achievable and realistic target of 50% and the wording should be consistent with RPG 8 and relate to the Structure Plan period.
Housing Policy 4: Affordable Housing	Housing Policy 4: Affordable Housing Provision will be sought for *made in local plans for* affordable housing for households unable to purchase or rent adequate housing on the open market, to a level identified as a result of local needs surveys and assessments. Policies and proposals to provide for the identified need will be designed to reflect variations in local circumstances in both urban and rural areas. ~~The minimum requirement for affordable housing should be 30% of the dwellings to be provided in Leicester, and 26% in the remainder of the Plan Area. This may vary according to local circumstances.~~ ~~The level and type of local need in both urban and rural areas will be identified.~~	In accordance with Panel Recommendations for the reasons given in the Panel Report (paragraphs 4.66 to 4.74) subject to the exclusion of references to detailed measures. The suggested detailed measures are considered to be too prescriptive for a Structure Plan policy and could prove inflexible for local planning authorities when preparing local plan policies for affordable housing. Current Government guidance in Circular 6/98 does allow for a lower site threshold (15 dwellings/0.5ha) provided that this can be justified by local needs assessments. These detailed measures should be restricted to a reference within the Explanatory Memorandum.
Housing Policy 5: Density	~~Housing Policy 5: Density~~ ~~Minimum net densities will apply in the Plan Area as follows:~~ Within and adjoining a minimum of 50 dwellings Leicester City centre per hectare Within main town centres a minimum of 40 dwellings and other local centres per hectare Other locations within and a minimum of 30 dwellings adjoining Leicester and its per hectare adjoining settlements and main towns, including Strategic Greenfield Sites Other locations a minimum of 25 dwellings per hectare	In accordance with Panel Recommendations for the reasons given in the Panel Report (paragraphs 4.75 to 4.79).
	~~Subject to the above minimum standards, housing development should be of a type and design to achieve as high a net density as possible, taking account of:~~ ~~a) proximity and accessibility to centres;~~ ~~b) the provision of a mix of housing types to establish socially mixed communities;~~ ~~c) good design which moves away from the current standards which encourage lower densities; and~~ ~~d) green space and landscaping requirements.~~
	*Housing Policy 5: Density and Design* *Housing development should be of a type and design to achieve as high a net density as possible, taking account of:* *(a) proximity and accessibility to centres;* *(b) the provision of a mix of housing types to establish socially mixed communities;* *(c) good principles of design and layout which make the most economical use of land and respect the local context;* *(d) green space and landscaping requirements.* *Subject to the considerations set out above, housing developments on sites of 0.3 hectares or more should attain the following net densities:*
	Within and adjoining the A minimum of 50 dwellings centres of Leicester and per hectare Loughborough Within other main town A minimum of 40 dwellings centres, local centres and per hectare other locations well served by public transport and accessible to services and facilities *Other locations* *A minimum of 30 dwellings* *per hectare*