Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7107

Received: 17/11/2017

Respondent: Mrs Anne Rowlands

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

No objective reasons stated for figure of 700,000 square metres additional development for non rail-served strategic storage/distribution.

Exceeds objective forecast demand for non rail-served sites for Leicestershire.

More labour supply in other parts of the county rather than Harborough District.

A5 road infrastructure currently inadequate to carry high volume of HGV traffic.

Will result in increased in-commuting and more commuter-traffic congestion.

700,000 square metres more would lead to over-provision of warehouse floorspace.

Area around Magna Park is unspoilt countryside, so not encouraging effective re-use of land.

Development not at rail-served site, so not consistent with national policy.

Full text:

The Local Plan is unsound for the following reasons:

Not positively prepared:

There are no objective reasons stated for the figure given of 700,000 square metres of additional development for non rail-served strategic storage and distribution. This figure just happens to be approximately the sum of the areas of the two remaining planning applications for storage and distribution buildings adjacent to the existing Magna Park, implying that the figure of 700,000 square metres was arrived at using figures from current commercial planning applications, and is not based on an objective assessment of the need for this development, and it also implies that the proposed storage and distribution development would be located next to the existing Magna Park.

The storage and distribution warehousing 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 include the proposed 700,000 square metres area for non rail-served storage and distribution in the Local Plan would be contrary to the objectively assessed demand in the report, and would result in over-provision of warehousing floorspace area. Rather than locating all the proposed development next to the existing Magna Park, development should be planned 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 warehousing floor-space for non rail-served strategic storage and distribution sites is located next to the existing Magna Park, it will be contrary to this objective assessment.


Not justified:

The technical report prepared for Harborough District Council: Leicester and Leicestershire Strategic Distribution Study: Update and Refresh of Outputs and Conclusions, September 2016, in the section of the document entitled Strategic Distribution Sites - Key Design Characteristics, states that strategic logistics sites must be located adjacent to a junction on the motorway or long-distance dual carriageway network (e.g. A14) which has sufficient capacity available, or within a few kilometres of such a junction via a high quality single/dual carriageway road capable of accommodating significant volumes of HGV traffic (in terms of quality and capacity available).
HGV traffic using the direct dual-carriageway to and from Magna Park to the M1 meets the above requirement, but HGV traffic to and from Magna Park using the A5 in both directions for long distances does not. The A5 is currently not a continuous long-distance dual-carriageway.

The Midlands Connect Strategy plan to upgrade the A5 between the A38 at Lichfield and the M1, endorsed by the government, will not be completed until 2030. Until this upgrade to the A5 is complete, planning applications for major logistics warehousing next to the A5 should be rejected. The existing road infrastructure is inadequate to support further developments such as this. Plans for development of new storage and distribution warehouses next to the existing Magna Park are not justified 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 700,000 square metres of additional warehousing floorspace proposed is located next to the existing Magna Park this requirement would not be met as unemployment is low in this area. Logistics warehouses should be located near an area of higher population and employee availability. Magna Park is in an area of low unemployment, so building of warehouses next to the existing Magna Park will result in increased in-commuting and more commuter-traffic congestion.

Further logistics business warehouses where there are already a large number of warehouses is not justified, as it will impact negatively on the local community due to increased HGV and commuter traffic congestion, increased air pollution, and destruction of green-field countryside.

Not effective:

Planning permission for a further 100,000 square metres of warehouse floor area next to the existing Magna Park has recently been granted. Other warehouse development is already taking place nearby; 700,000 square metres more would lead to over-provision of warehouse floorspace.


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 Plans should encourage the effective re-use of land that has been previously developed.
But if the development is adjacent to Magna Park it will not be consistent with this requirement. The area around Magna Park is unspoilt countryside, which should not be destroyed to build massive warehouses on.

The NPPF says that adequate links to the road network are essential.
If the proposed logistics warehouses are built next to the existing Magna Park, and HGV traffic uses the A5 for long distances in both directions, the A5 road infrastructure is currently inadequate to carry the high volume of HGV traffic.

The NPPF says that large scale logistics facilities should be located at rail-served sites. But if the proposed storage and distribution warehouses are built next to the existing Magna Park, they would not be at a rail-served site, so would be not be consistent with national policy.