Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7394

Received: 16/11/2017

Respondent: Mrs Avril Tunstall

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

* Opportunistic proposal - not geared to meeting local employment needs
* Amount of land exceeds county's demand for warehousing - create oversupply, deprives jobs elsewhere
* Unsuitable site for more warehouses - very low local unemployment, unlikelihood of filling job vacancies
* Won't increase employment alternative breadths, or meet local employment needs,- skilled work needed
* Fails to reduce out- commuting, but increases in-commuting
* Area lacks necessary highway infrastructure - A5 already inadequate
* Magna Park has no rail head - NPPF preferred option
* Breaches NPFF by increasing air pollution in air quality management area.

Full text:

Not positively prepared:
* The proposal is not strategic or aimed at meeting the District's employment needs, but opportunistic, as the sum of two planning applications, is used as evidence, that this amount of land ( 700,000 sq metres ) is needed here for more warehousing.
* Using this proposed amount of land for more warehousing exceeds the LLEP SDS, 2017 findings for the demand of non- rail warehousing across all of Leicestershire. It ignores the study's recommendation that the shortfall in warehousing should be spread across the county, and has the likelihood of creating an oversupply of warehousing.

Not Justified
* LLEP SDS, 2016 advocates that meeting the demand for more warehousing should be spread across Leicestershire, with Harborough District contributing. As Magna Park has now been granted an extra 100,000sq m warehousing, then allowing more, would rob other areas in the county of employment opportunities.
* LLEEP SDS, 2016 recommends that new warehouses are sited close to areas of employment need , and deem sites unsuitable , if they have an unlikelihood of filling job vacancies . Magna Park is unsuitable, as currently it is struggling to recruit workers, as there is under 2% unemployment , ( The Office for National Statistics 2017), in the district, (especially the Lutterworth area), and competition from other distribution centres , ( like DIRFT, and Rugby Gateway ) in the vicinity.
* The proposed 10,000 job will not meet the plan's aim of increasing the breadth of employment alternative , as warehouses generate a narrow range of job types, with the majority being warehouse operative jobs. These are temporary, low-paid, and unskilled. Consequently, there will be a massive glut of these , and little scope for higher and intermediate - skilled people.
* The proposal contradicts the plan's aims of meeting local employment needs. The plan declares that Harborough has one of the highest skills profile, and wants to encourage a well- educated workforce, therefore it should make provision for well- paid , skilled work, like technology and engineering, not support the creation of 10,000 more warehouse jobs, that in many cases will mismatch people's skills.
* As Magna Park already has job vacancies and most employees commute from outside the District, then providing many more of the same job types , in this area of exceptionally low unemployment, will not achieve the plan's aim of reducing out - commuting. For this to be met, the District needs to provide a variety of employment to match people's different abilities.
* Vastly increasing the number of jobs at Magna Park will greatly increase in- commuting, which together with the increased number of HGV's , will greatly exacerbate the congestion and and delays on strategic and local roads , so hinder employees and the fluency of business.

Not Justified:
* LLEP SDS, 2016 advocates that meeting the demand for more warehousing should be spread across Leicestershire, with Harborough District contributing. As Magna Park has now been granted an extra 100,000sq m warehousing, then allowing more, would rob other areas in the county of employment opportunities.
* LLEEP SDS, 2016 recommends that new warehouses are sited close to areas of employment need , and deem sites unsuitable , if they have an unlikelihood of filling job vacancies . Magna Park is unsuitable, as currently it is struggling to recruit workers, as there is under 2% unemployment , ( The Office for National Statistics 2017), in the district, (especially the Lutterworth area), and competition from other distribution centres , ( like DIRFT, and Rugby Gateway ) in the vicinity.
* The proposed 10,000 job will not meet the plan's aim of increasing the breadth of employment alternative , as warehouses generate a narrow range of job types, with the majority being warehouse operative jobs. These are temporary, low-paid, and unskilled. Consequently, there will be a massive glut of these , and little scope for higher and intermediate - skilled people.
* The proposal contradicts the plan's aims of meeting local employment needs. The plan declares that Harborough has one of the highest skills profile, and wants to encourage a well- educated workforce, therefore it should make provision for well- paid , skilled work, like technology and engineering, not support the creation of 10,000 more warehouse jobs, that in many cases will mismatch people's skills.
* As Magna Park already has job vacancies and most employees commute from outside the District, then providing many more of the same job types , in this area of exceptionally low unemployment, will not achieve the plan's aim of reducing out - commuting. For this to be met, the District needs to provide a variety of employment to match people's different abilities.
* Vastly increasing the number of jobs at Magna Park will greatly increase in- commuting, which together with the increased number of HGV's , will greatly exacerbate the congestion and delays on strategic and local roads , so hinder employees and the fluency of business.

Not effective:
* Leicester and Leicestershire Strategic Growth Plan HEDNA (2017) recognises that since the study 's start in 2011, new developments, or local authorities earmarking land for warehousing, will have continually reduced the need for warehouses. Since the latest report Magna Park has been granted an extra 100, 000 square metres, and several miles from Magna Park, millions of square metres of warehousing land has been agreed during the last 2 years, so an additional 700,000 sq m at Magna Park will create a huge oversupply of warehouse land .
* Green space separation zones are proposed between Magna Park and Bitteswell and Lutterworth, but none are indicated between Magna Park and Cotesbach and Ullesthorpe

Inconsistent with NPPF:
* The NPFF is encouraging warehousing at rail-served sites. Magna Park has no rail head, but close to it are warehouses that do, and another is planned around M69/ A5 junction.
* Disregards NPPF objectives to take into account the cumulative impacts on air quality in an air quality management area. Since 2001, Lutterworth has been an air quality management area, as its nitrogen dioxide levels are exceedingly high, primarily from the huge volume of traffic generated by the 24 hour operation of Magna Park. (2013 Lutterworth AQMAAP for HDC. ) Air Quality Action Plans have aimed to reduce these levels, but to no avail, so they still exceed air quality objectives ( 2017 Annual Air Quality Status Report.) Massively expanding Magna Park will generate enormous amounts of extra traffic that will exacerbate Lutterworth's air pollution.