We wish to register our objection to Policy BE1 as it is not effective or justified when considered against reasonable alternatives. Specifically, we object to the following:

1. the lack of sufficient options/ alternatives for the delivery of employment land in Lutterworth during the early stages of the Plan;
2. the absence of suitable allocations for the provision of B1 office use.

It is noted that only two sites in Lutterworth have been allocated to provide the 26 hectares of additional employment land required during the Plan period. The majority of the 26 hectares is proposed to be provided as part of the 'East of Lutterworth Strategic Development Area (SDA)' which the Council acknowledges will be delivered "over an extended time period" (Local Plan, para 15.2.27). Whilst the Council have indicated that 'Land to the south of Lutterworth Road/ Coventry Road will ' " ...provide new employment land for Lutterworth prior to the provision to be made as part of the East of Lutterworth SDA" (Local Plan, para 15.4.1), it is our view that the policy is too limited in terms of options for delivery,
particularly in the early stages of the Plan period. Specifically, Policy BE1 is overly reliant on the delivery of employment development from sites which form part of the SDA. It is clear from the Strategic Employment Land Availability Assessment (SELAA) that wider improvements to the highway network are required to facilitate the delivery of employment land from the SDA (a timeframe of 6-10 years is indicated in the SELAA). However, should there be delays in the delivery of employment land associated with this site, there would be a significant impact on employment delivery in Lutterworth. This has the potential to undermine the Council's spatial strategy and stifle the sustainable growth of the settlement. As such, Policy BE1 is currently unsound. Additional land should be allocated to provide a greater level of certainty that adequate employment land will be delivered in Lutterworth in the short to medium term.

In addition to Policy BE1's lack of sufficient options/ alternatives for employment delivery in Lutterworth during the early phases of the Plan, it is our view that the policy is currently deficient in terms of the range of employment types to be delivered. As mentioned previously, the policy relies on just two site to deliver the 26 hectares of employment land required in Lutterworth during the Plan period. It is noted that half of the employment land allocated (13 hectares) comprises B8 storage and distribution uses, with the remainder split between B1 office/ light industrial and B2 general industrial uses. Given the size and location of the allocated sites (particularly the SDA), it is considered unlikely that smaller scale office and retail uses (i.e. those uses most suited to town centre locations/ compatible with existing residential uses) will be delivered. As such, we consider Policy BE1 to be ineffective and, as such, unsound. It is our view that additional land close to the town centre should be allocated to ensure the delivery of a greater range of employment types (including smaller scale B1 office use). The allocation of additional employment land for B1 office use would contribute positively to the Local Plan's effectiveness by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth in accordance with national policy (NPPF, para 7 - emphasis ours).