The Local Plan is unsound for the following reasons:

Not positively prepared:

There is no rationale stated for the figure of 700,000 square metres of additional development for non rail-served strategic storage and distribution. This figure happens to be approximately the sum of the areas of the two outstanding planning applications for storage and distribution buildings adjacent to the existing Magna Park, leading to the conclusions that:
a. the figure of 700,000 square metres was adopted from current commercial planning applications, and is not based on an objective assessment of the need for such development, and
b. The additional development is intended to be located next to the existing Magna Park.

The storage and distribution warehouse area proposed in the Local Plan exceeds the forecast demand for non rail-served sites for Leicestershire presented in the technical report prepared for Harborough District Council: Leicester and Leicestershire Strategic Distribution Study: Update and Refresh of Outputs and Conclusions, September 2016.
To retain this proposed area for non rail-served storage and distribution in the Local Plan would be to ignore the objectively assessed development needs in the report, and would over-provide warehouse floorspace area. If the storage and distribution development was all located next to the existing Magna Park, it would not allow for development in other more suitable areas of Leicestershire.

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that within Leicestershire there is a more plentiful labour supply in the western and northern parts of the county rather than the more rural eastern areas such as Harborough District. These urban areas are therefore likely to be more attractive to operators.
If the proposed development of 700,000 square metres of additional development for non rail-served strategic storage and distribution is located next to the existing Magna Park, it will be contrary to this objective assessment.

The Local Plan Vision "sets out a collective positive vision for the future of the area, as required by the NPPF."
However, in relation to the policy BE2 Strategic Distribution where it is proposed that:
"Additional Development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted...", this is not a positive vision if this additional development is next to the existing Magna Park.

The Local Plan Vision claims that "Harborough District...retains its identity as a predominantly rural area of villages and market towns where local communities enjoy a high quality of life. Residents will benefit from...a wider range of skilled jobs, and high quality services and facilities, all of which promote healthy and safe lifestyles."
However, addition of new storage and distribution warehouses next to the existing Magna Park is contrary to the above vision as it would turn rural green-field land into industrial complexes, providing jobs that are the same skill types as those already offered at Magna Park, not providing a wider range of skilled jobs, so will largely not be filled by local people.

The Local Plan Vision claims that "The diversity and quality of Harborough's countryside, natural and historic environment will have improved for the benefit of residents and visitors. Air and water quality will have been improved while the impacts of noise and light pollution will have been minimised. There will be better access to the countryside and an improved range of open spaces for local people to enjoy."
However, addition of new storage and distribution warehouses next to the existing Magna Park is contrary to the above vision as it would obliterate green countryside, expanding the sprawl of the existing Magna Park and making a huge adverse impact on the landscape. Air quality would be further threatened by an associated increase in traffic, and noise and light pollution would increase. This development would remove open spaces, not provide them.

The Local Plan Vision claims that: "Low carbon design techniques and technologies, increased provision for walking and cycling, and improved access to public transport for new development will have contributed to a reduction in the District's carbon footprint."
Instead, addition of new storage and distribution warehouses next to the existing Magna Park would increase the District's carbon footprint due to the resulting increase in HGV and commuter traffic.

The Local Plan Vision claims that: "Strategic Distribution sites will have adapted to the changing needs of the sector and maintained their significance to the District and the wider area in terms of employment provision."
However, addition of new storage and distribution warehouses next to the existing Magna Park will do very little to provide employment to local people in an area where there is low unemployment, and where a variety of higher-skilled jobs is needed; instead it will result in increased in-commuting where jobs are taken by people from outside the local area.

The Local Plan Vision claims that: "Communities across the District will have embraced neighbourhood planning, affording them the opportunity to shape the future of their environment by ensuring that they have a real stake in the decision making processes that oversee what development takes place and where."
However, communities close to Magna Park have ALREADY embraced neighbourhood planning by engaging in the planning process, taking time to read planning applications and attending planning meetings; local residents have in their hundreds registered their objections to the three planning applications for huge new areas of storage and distribution warehouses on both sides of the existing Magna Park. The first planning application has been granted despite over 900 objections. Local residents need to have a REAL stake in the decision-making processes NOW so that the huge numbers of local objections to the addition of new storage and distribution warehouses next to the existing Magna Park are properly considered, and local people have a real opportunity to shape the future of their environment NOW.

Not justified:

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that most of the region's storage and distribution floor space is playing a national rather than regional role. If the proposed development of 700,000 square metres of additional development for non rail-served strategic storage and distribution is located next to the existing Magna Park it would add floorspace to this national role, and would be of no benefit to the local region.

The Midlands Connect Strategy plan, endorsed by the government, to upgrade the A5 between the A38 at Lichfield and the M1 will not be completed until 2030. Until the A5 upgrade is complete, applications for major logistics warehouses next to the A5 should be rejected. The existing road infrastructure is inadequate to support further developments such as this, and new applications should only be approved where there is a direct rail-head. It is not justified to plan the development of new storage and distribution warehouses next to the existing Magna Park until the new road infrastructure is in place.

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that strategic logistics sites should be "located close to areas of employment need". If the proposed development of 700,000 square metres of additional warehousing floorspace is located next to the existing Magna Park this requirement would not be met as unemployment is low in the area. Storage and distribution warehouses should be located near a town or city with sufficient population density and employee availability to meet the employment needs of the businesses located there. Magna Park is too far away from such populations, so further development of storage and distribution warehouses next to the existing Magna Park will further increase in-commuting with the associated increase in traffic congestion.

Addition of storage and distribution warehouses in an area that already has a high density of such warehouses is not justified as it will have adverse impacts on the local community in terms of increased traffic congestion due to increased volumes of HGV and commuter traffic, increased vehicle exhaust pollution, and loss of natural environment where green-field countryside is destroyed.

Not effective:

One of the three large planning applications for additional warehouse development next to the existing Magna Park has recently been granted. This will provide 100,000 square metres of new floor space. Other new warehouse development applications have been granted nearby recently; another 700,000 square metres would result in an excessive over-supply of warehouse floorspace.

Appendix E of the Local Plan lists Local Plan Objectives, and shows Local Plan policies which address each objective, relevant key issues and relevant strategic priorities.
Out of the fourteen Local Plan objectives listed in Appendix E, only one objective, Objective 2 (Employment), refers to Local Plan policy BE2 Strategic Distribution, but this objective will not be addressed by granting planning permission for additional development of up to 700,000 square meters for non-rail served strategic storage and distribution next to the existing Magna Park, due to the reasons as follows:

Objective 2 includes: "Promote sustainable economic growth by facilitating the sustainable growth of businesses, fostering new local enterprise and helping to create more jobs that meet local employment needs."
However, if the additional development of storage and distribution businesses is located next to the existing Magna Park,
- this growth of businesses would not benefit the local community: Strategic Distribution businesses are nationally-oriented, so economic benefit is national not local;
- growth of these storage and distribution businesses in an area that already has a high density of such businesses will have adverse impacts on the local community in terms of increased traffic congestion due to increased volumes of HGV and commuter traffic in an area of inadequate road infrastructure planning, increased vehicle exhaust pollution, and loss of natural environment where green-field countryside is destroyed.
- it would be more of the same type of business that is already at Magna Park, not new local enterprise;
- the new jobs created would not meet local employment needs: the new jobs would be the same types of job that already exist at Magna Park; local unemployment is low and local people looking for jobs need a variety of types of employment; planning permission has already been granted for a huge new storage and distribution warehouse next to the existing Magna Park, so there will already be more jobs that cannot be filled by local people.

Objective 2 includes: "Contribute to reducing the need for out-commuting and thereby help to increase the sustainability and self-containment of communities, while encouraging the development of a vibrant, diverse and sustainable business community."
However, if located next to the existing Magna Park,
- it would do very little to reduce the need for out-commuting because new jobs created would be in the same type of business and the same skill-types as existing jobs; it would therefore not increase the self-containment of communities;
- it would increase in-commuting because the new jobs created would be mostly filled by people not living locally;
- it would not encourage the development of a vibrant, diverse business community: the new businesses would be more of the same that are already located at the existing Magna Park.

Not consistent with National Policy:

The Local Plan is not consistent with National Policy as it does not follow the National Planning Policy Framework (NPPF) in the following instances:

The NPPF says that Local Planning Authorities should positively seek opportunities to meet the development needs of their area, and local plans should meet objectively assessed needs.
However, the proposed strategic storage and distribution development would provide warehouse floorspace way above the objectively assessed demand estimate given in LLSDS, resulting in an over-supply of warehouse facilities. The proposed development is not needed in the local area around Magna Park.

The NPPF says that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. The countryside around Magna Park is unspoilt green countryside, which although it may not be formally designated as Green Belt should not be approved for a development of the magnitude proposed.

The NPPF says that Local Plans should encourage the effective re-use of land that has been previously developed.
However, if the development is next to Magna Park it will be contrary to this requirement.

The NPPF says that adequate links to the road network are essential.
This requirement will not be met if the proposed development is located next to the existing Magna Park. Links to the road network are currently inadequate. If all HGV traffic to and from Magna Park used solely the direct dual carriageway link to the M1, this would be adequate; however, if the proposed development is next to the existing Magna Park, and HGV traffic uses the A5 in both directions, the A5 road infrastructure is currently inadequate to carry the high volume of HGV traffic.

As stated in the technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017: until fairly recently, the planning system did not actively promote rail-served warehousing. This position has changed, as reflected in the NPS National Networks and NPPF (see SDS Part A Section 7), which now actively promote the development of large scale logistics facilities at rail-served sites (e.g. SRFIs).
However, the proposed strategic storage and distribution development, if located next to the existing Magna Park, would not be at a rail-served site, and therefore not consistent with national policy.