Leicester Local Plan (2020-2036) Consultation Response 2023

Page 1

115 Charles Street

Leicester, LE1 1FZ

RE: Leicester Local Plan (2020 to 2036)

27/02/2023

I write to you regarding the most recent and final stage of consultation for the City of Leicester Local Plan I have reviewed the most recent Local Plan draft and the Sustainability Appraisal that informs it I remain of the view that the Local Plan is an exciting opportunity to develop our city and its surrounding areas to prioritise the wellbeing of residents I am also reassured that Leicester City Council appears to be responding constructively and proactively to resident feedback.

However, I continue to have reservations about some of its proposals, which have been highlighted in the Sustainability Appraisal; I have outlined these in the section below. Most significantly, I am struck that the plan is likely to have a net negative impact on the environment. I am also concerned that the social benefits of the plan may not yet outweigh the environmental cost.

Housing

Previously, I raised concerns over the proposed provision of affordable housing. The Sustainability Appraisal has picked up on this too In my previous consultation response submitted in December 2020, I explained that I feared that the housing target might be too low in light of the considerable increases in Leicester house prices over 15 years Specifically, I raised my concern that the target of 30% affordable housing means that the numbers of real social housing (council housing) units will represent only a small fraction of the total numbers built

I explained that a commitment to 30% on all major schemes also implies a majority of units will be developed in partnership with private property companies, which is not always the most efficient or cost-effective means of financing truly affordable housing. Additionally, I emphasised that, although a housing mix is important, there are, at present, 6000 households on Leicester’s housing waiting list, whose needs must be prioritised in the Local Plan.

This is more concerning in light of information provided in Leicester City Council’s draft budget for 2023/24, which illustrates that there has been an increase in the number of families presenting as homeless. To address this rise, I understand that the Council’s budget

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885 Dear Peter,

Tel: 07973816885

has allocated £1m to meet the needs of increasing numbers of homeless families. The Council has also claimed that “there is a plan to address the needs of homeless families through the Housing Revenue Account, which will provide partial relief.”

I am grateful that the Council has responded to the Sustainability Appraisals by amending their plans to increase the provision of affordable and social housing in the City Nevertheless, I continue to have significant reservations about the amount of development planned for greenfield sites and the urgent need to maximise to the highest possible levels of social housing, particularly publicly owned and financed council housing.

I remain very concerned over the possible impact on downgrading the services offered by Leicester General Hospital, which I have consistently opposed, following the sale of land at the site to the Council for housing development These concerns, which I raised in my previous consultation response, are shared by local NHS campaigners, including Save Our NHS Leicestershire, who have criticised the closure of acute care at Leicester General Hospital. During the initial consultation in the Autumn of 2020. I understand that Save Our NHS Leicestershire highlighted, a similar point I made in my own consultation response, that the City’s growing population would make the retention of the land a necessity in order to allow for expansion of hospital capacity to accommodate the resulting growing demand The campaigners claim that their views have been vindicated following the decision by the local NHS to build a new elective treatment centre on the site of the Leicester General as a means of reducing waiting lists; I consider this to be a fair assessment.i

In the context of using the former nurses homes for the provision of additional housing, the Council’s decision to use the site to provide council-owned social housing seems like the most sensible option in unfortunate circumstances I recognise that the decision to sell the land at Leicester General was the responsibility of the Clinical Commissioning Group (now Integrated Care Board). Nevertheless, I would be grateful if the Council would commit to working alongside local NHS bodies to ensure that, in future, NHS land is retained to enable expansion when needed. I will continue to challenge in Parliament and elsewhere, the downgrading of the Leicester General Hospital..

Additionally, I am concerned that the focus on density on strategic sites focused on the City Centre may be counterproductive to the aim of providing the greatest increase in the provision of social housing.ii As experts have made clear, high density housing is not always conducive to the provision of high numbers of council homes This is because it can cost far more in terms of upfront investment to build high rise properties – which tend to require expensive materials and the resources and specialist expertise of profit driven private developers – than to spend the money on relatively low cost, low-rise council developments through public funds I hope that any future changes to the existing plan will continue to ensure that council housing is the priority and all avenues are explored for maximising the provision of council housing through the plan through borrowing from the Public Works Loans Board if necessary, while balancing the need to meet demand for housing and mitigating the environmental impacts of developments. Council housing always pays for its own construction over time and is therefore the best return on investment for Leicester City Council and the most effective solution to pressing housing need.

Transport

In my previous consultation response, I welcomed the Local Plan’s commitment to high quality segregated cycleways on key commuter radial routes, as well as a bike share

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scheme for the City Centre area. Further to this, I noted Leicester’s Index of Multiple Deprivation figure is 33% in comparison to, for example, Harborough, where it is 8.32%, and this scheme may help to sustainably bring visitors and investment into the city to address the disparity in prosperity between the city and other parts of Leicestershire.

In terms of the needs of Leicester East residents, bus travel is not as convenient as it could be, with several changes required for some people travelling between their homes in the constituency and places of work and to other locations east, west, south and north. It is therefore important that Leicester East is served by more streamlined bus routes, that minimises the number of changes required. The new fully electric bus service providing sustainable transport on routes connecting Leicester’s three main hospitals, including the Leicester General Hospital is welcomed and more connections like this will increase and improve public transport use.

Ultimately, I believe buses and public transport use should be more affordable, easier to access, sustainable and in public hands

In addition, I am acutely aware of the impact that the Cost of Living Crisis is having on constituents’ ability to enjoy recreational activities and live fulfilling lives. I understand that the Government has allocated funds to ensure that the cost of single bus fares in Leicester are capped at £2, and that Arriva Midlands, Centrebus, First Bus, Kinchbus, Roberts Travel and Stagecoach are all participating in the scheme.iii Unfortunately, I also understand that the scheme is very short lived and is only in place between 1 January 2023 to 31 March 2023. I would therefore be grateful if, as part of its transport strategy for the local plan, the Council could liaise with bus companies that operate services in the area to explore how costs to those who rely on bus services can be kept as low as possible.

As my previous consultation response explained, providing people travelling in, around and to Leicester with the opportunity to do so safely by bicycle has the potential to transform Leicester’s connectivity with its surrounding areas, while reducing carbon emissions and improving air quality in the long term. I am therefore grateful that the Local Plan supports walking, cycling and public transport, encourages a move away from car use, and support freight transport by canal and rail where possible. However I understand that the Leicester ebike scheme has unfortunately come to an end, due to the collapse of Ride on Scotland, the company that operated the scheme for the Council.iv I agree with the Council that the scheme “did have the potential to increase cycling as a preferred form of transport in the city” and also potentially increase connectivity between areas like the town centre and parts of Leicester East. I would therefore hope Leicester City Council will consider alternative means of providing similar schemes in the future, including via public funds if at all possible.

I am deeply concerned about the increasing number of pavement parking on the narrow streets and roads of Leicester East and the impact this has on walking, disability access and people’s ability to enjoy their neighbourhoods. Given the climate emergency and the significant impact of air pollution, I believe the Council should continue to consult and thoroughly engage with communities towards the development of Low Traffic and Liveable Neighbourhoods.

In addition to measures to combat pollution and poor air quality, measures are also needed to increase road safety in parts of the city, particularly in Leicester East. For instance, since April 2021, when a car crashed into a home on Hungarton Boulevard causing life threatening injuries, I have been working with residents who have been campaigning for greater safety

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measures along this road.v Their demands require no less than a transformation, redesign and rebalancing of the road in favour of people, slowing vehicles to protect vulnerable road users and people living in the comfort of their own homes. The CCTV footage of the impact was truly horrifying. I was pleased to have been able to lend my expertise in community empowerment, but it shouldn’t have taken a near death situation, media focus and a petition to bring about change. I am helping others who have suffered significant life changing injuries following road incidents, but who have been suffering in silence and struggling to secure any form of compensation or justice So, more generally across Leicester East I would like to see more 20mph roads and streets. I would also like to see more streets for children and ‘school streets’ designed and rebalanced in favour of people.

I understand that the Council is imposing lower speed limits on other major roads in the City, including Blackbird Road, Abbey Lane and St Margaret’s Way. I consider these traffic calming measures to be essential to ensuring the safety and wellbeing of residents and look forward to the outcome of the road safety scheme for Hungarton Boulevard.

I am also concerned that the increased population projected for Leicester could increase traffic and make more accidents like this more likely if similar measure are not considered in danger spots across the constituency

Environment and climate change

Previously, I raised my concern about the possible biodiversity loss resulting from development. I understand that this cannot be easily offset by mitigation measures. As I explained, when destroyed, ecosystems that develop around individual trees and green spaces cannot be revived and the latest sustainability appraisal has substantiated this.

The most recent sustainability analysis makes clear that the Local Plan is still very likely to have a negative impact upon the local environment overall. I am therefore opposed to what appears to be the proposal to use a significant portion of the land adjacent to Kestrel Mead Primary Academy for development (Site No. 1041), which I understand is a Local Wildlife Site (LWS) According to the Council’s own Biodiversity Action Plan:

“Local Wildlife Sites are important reservoirs of rare, local and declining native species and are the best examples of typical Leicester, Leicestershire and Rutland habitats. LWS may also be areas of ecological interest that provide people with the opportunity to learn about, appreciate and experience habitats and species of the natural world.”

Preserving this site should therefore be regarded as a matter of priority in line with Leicester City Council’s own stated policy

It is a good sign that the Local Plan recognises that we face a climate emergency and has committed to encouraging greener methods of transportation to cut carbon dioxide emissions. I also welcome the commitment to providing allotments, community gardens, orchards and green roofs, even as I note with concern the potential harmful impact of some development sites on biodiversity. Further to this and as outlined in my previous correspondence, I remain very concerned about the continued proposals to build upon greenfield land formally allocated to allotments at Site No: 190: Lanesborough Road and Site No 219: Rosedale Avenue – Land at rear of, and Harrison Road.

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Business, culture and town centre development

Leicester is already a thriving cultural hub and the further development of Leicester’s beautiful town centre through the Local Plan offers many exciting possibilities. However, the city faces many challenges following the COVID-19 pandemic, which did immense harm to the retail sector, and as a result of the current cost of living crisis. It therefore remains essential for Leicester to continue diversifying its town centre while protecting its heritage and character I continue to be an enthusiastic supporter of the Local Plan’s proposal to give greater encouragement to development that protects and promotes this unique mix

However, as I have previously stressed, the plan needs to reflect the importance of continuous investment for local town centres, retail and business hubs outside of the City Centre including Green Lane, Belgrave Road along the “Golden Mile” and Evington Road These are important assets and areas for local communities and of huge significance to Leicester’s diversity and cultural offer.

In particular, I understand that Leicester and Leicestershire is the UK’s 4th largest textiles and fashion cluster, as well as the most specialised in the country. The industry, which comprises 4.5% of businesses in Leicester and the surrounding area, and 4.6% of jobs, is centred in multiple areas outside the city centre, and with a significant presence in Leicester East. It contributes £1.2bn and accounts for 25,200 jobs according to official statistics. The sector has also driven growth in Leicester since 2010, outpacing the UK industry average by around 20%.

I am therefore pleased that the local plan has taken measures to ensure that the City’s textile area will be supported I am also grateful that plans for housing development are not expected to have a detrimental impact on the operation of the surrounding textile businesses in the LE5 postcode, which overlaps with my own constituency; according to the Local Plan, housing development will only be acceptable where it can be clearly demonstrated that existing constraints can be mitigated.

I am still very concerned that the Local Plan remains silent on the problems centring upon Leicester’s garment factories and worker exploitation in the sector,

According to the most recent figures by the Office For National Statistics (estimates for 2021/22), the median gross annual pay for workers in Leicester is £23,175 By comparison, the national median pay is £27,756, while the mean is 33.402. vi This means Leicester workers are significantly paid less than the UK average. Furthermore, according to the most recent (2019) indices of deprivation, Leicester is among the 32 most deprived local authorities in England (out of a total 317).vii The local economy is therefore characterised by high levels of in-work poverty and low wages” viii Leicester and Leicester East in particular, has been the epicentre of wage exploitation in the garment industry for decades. The median annual pay per person in my own constituency of Leicester East is one of the lowest in the country at £20,300ix , according to HMRC statistics announced in April 2022 using 2019/20 financial records. The national average for the same period was £31,461x, meaning workers in Leicester East are losing a third of their income to inequality. People in Leicester East are also paid less than the comparable figure for the East Midlands region which was £24,700xi .

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Given that employment pay and conditions are a major factor impacting quality of life in the City, it is essential that the issue is tackled and it should be treated as a priority I continue to believe that any industrial strategy and related development must address this issue and seek to contribute to greater regulation of the garment industry, for the wellbeing of Leicester’s workers and the reputation of the City as an economic and industrial hub in the East Midlands. It is therefore of considerable concern that the issue has not been addressed at all in the local plan. In particular, greater scrutiny of planning applications and stronger planning intervention must play a role in ensuring that Leicester’s garment industry is properly regulated.

Furthermore, I understand that Imperial Buildings, the former site of Imperial Typewriters, houses several garment manufacturing companies and is in a state of poor repair. This is one example of similar sites across the City of Leicester but is of particular note due to its community status as a Local Heritage Asset, which has now become an eye-sore. To preserve and enhance the character of the city, and, equally importantly, the wellbeing of workers on the premises, it is essential that this building and others like it are refurbished and reconditioned to bring them up to a good standard. It is also important that it’s historical status is protected. I am disappointed that there is no mention of this possibility in the Local Plan and would be grateful if Leicester City Council would explore how such protection, renovation and refurbishment might be implemented in the future.xii

Health and wellbeing of residents

As I mentioned in my previous consultation response, compared to other UK cities outside London, Leicester has among the highest fraction of mortality attributable to particulate air pollution (close to 6% as of 2017).xiii Although, in 2019, Leicester recorded its lowest ever levels of air pollution, levels of NO2 in the city’s air remain above European and national guidelines of 40 micrograms per cubic metre.

Unfortunately, I note that, although the Sustainability Appraisal assesses that the Local Plan’s aim to provide more than half of the homes needed in Leicester should lessen environmental impacts by reducing the need to travel and allowing for higher density development, it will likely lead to worsened air quality; the plan will therefore mark a backwards step regarding resident wellbeing. I would be grateful if the Council would outline proposals for future plans to mitigate the risk to public health through poor air quality

As I previously explained, although the Local Plan aspires to increase the wellbeing of Leicester’s residents, this is unlikely to be successful if development detracts from the provision of local amenities

I am therefore very pleased, that initial proposals to build on Site No: 604: Linden School Playing Fields, Site No: 653: Rowlatts Hill School Playing Fields, Site No: 546: Herrick Primary School Playing Fields have not been carried forward into the most recent draft of the plan. Nevertheless, I am very concerned over the Council’s plan to build on Netherhall Road Open Space in Humberstone and Hamilton, Site No: 629 and oppose this aspect of the plan This land is the type of residential open space that must be preserved if the health and wellbeing of Leicester residents is to be supported in the future. Furthermore, I note that it is a non-strategic site, which, due to the presence of a brook, requires a drainage strategy and

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is far from being the most suitable land for housing development.. Additionally, residents of Netherhall have expressed worries about other small sites in the area.

In particular, Netherhall Community Association has raised concerns about development on much needed greenspace that is relied upon by the people of the area. I understand that in Netherhall, this includes

• 77 homes on Moorfields/Netherhall Park (Site No: 629, as above)

• 18 homes Rayleigh Green (Site No: 648),

• 13 on Newlyn Parade/Crayford Way (Site No: 631),

• 23 near Elms Farm Cottages/Preston Rise. (Site No: 577)

According to the petition launched by Netherhall Community Association many residents “don’t want homes built in these places, and don’t think they have been given a fair opportunity to express their objections.” xiv

The Community Association has made clear it wishes to ensure that “no development happens locally without the involvement of local residents.” I share these concerns and urge Leicester City Council to work with residents and local community groups and organisations to protect much needed green space for public enjoyment and to ensure that people are reassured that their views and concerns are informing the Council’s policy

I hope you consider this submission as you continue to develop the City of Leicester Plan through its final stages. I look forward to working with Leicester City Council and yourself to build a socially just and prosperous future for our city and its people.

Yours sincerely,

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Member of Parliament for Leicester East House of Commons, London SW1A 0AA

Tel: 07973816885

i http://saveournhsleicestershire.org/2022/10/02/new-elective-treatment-centre-at-leicester-general-showswhy-we-need-to-retain-nhs-land/

ii https://www.oecd.org/social/social-housing-policy-brief-2020.pdf

iii https://www.leicestermercury.co.uk/news/cost-of-living/leicestershire-bus-fares-cut-2-7983857

iv https://www.leicestermercury.co.uk/news/leicester-news/end-e-bike-scheme-leicester-8181816

v https://cabinet.leicester.gov.uk/mgEPetitionDisplay.aspx?ID=128

vihttps://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/earningsandworkinghours/datasets/pl aceofresidencebylocalauthorityashetable8

viihttps://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/835115 /IoD2019_Statistical_Release.pdf

viii https://leicestershelter.org.uk/wp-content/uploads/2022/04/SHARP-Research-Project-Final-26-01-22.pdf

ix https://www.gov.uk/government/statistics/income-and-tax-by-parliamentary-constituency-2010-to-2011

xhttps://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/earningsandworkinghours/bulletins/an nualsurveyofhoursandearnings/2020

xi https://www.gov.uk/government/statistics/income-and-tax-by-parliamentary-constituency-2010-to-2011

xii https://www.theguardian.com/uk-news/2020/aug/30/revealed-shocking-lack-of-regulation-at-leicestergarment-factories

xiii https://www.leicester.gov.uk/media/186425/living-in-leicester-infographic-summary-2020.pdf

xiv https://www.change.org/p/netherhall-response-to-leicester-city-council-s-local-plan

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

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