SS1 clause 2c. Strategic storage and distribution

In justifying policy BE2 the Proposed Submission relies heavily on the LLEP MDS Strategic Distribution Sector Study 2014, updated in 2016, and the HEDNA report 2017. The LLEP reports forecast the need for additional (i.e. new build) for both rail linked and non-rail linked warehousing/distribution space in Leicestershire. The high estimate forecast (later called a minimum) is for 320k. sq. m. of non-rail linked space by 2021, 435k. sq.m. by 2026 and 607k. sq.m. by 2031. Para. 6.3.1 of the Proposed Submission states "This policy [permitting 700,000 sq. m] contributes towards meeting the requirement .... to 2031." In fact, it does not just contribute to the requirement but exceeds the figure for the entire LLEP area by about 100k sq. m. In doing so it also ignores the fact that since 2014 local authorities have continued to approve, in outline or full, a number of large ( > 9,000 sq.m.) warehousing/ distribution centres. The Sustainability Appraisal prepared by AECOM (August 2017 in the print version, September 2017 in the on-line version) in time for the adoption by the Council of the draft states that "Completions and commitments in the district and across the HMA are sufficient to meet minimum need without selecting a site for allocation," (para18.5.1). Many of these are currently advertised or under construction. The proposed 700,000 sq.m. will lead to a potentially significant and unsustainable over-supply of warehousing in Leicestershire, offering largely low skilled and low paid jobs and heavy in-commuting into areas such as Harborough where unemployment is extremely low and where house prices are the highest in the county. Conclusion: The policy fails to meet the test of soundness. It is not positively prepared in that it far exceeds objectively assessed development needs and ignores new build warehousing at Rugby Gateway, less than 6 miles from Magna Park at junction 1 of the M6. It is not justified in that it has not considered reasonable alternatives. It is not effective in that required road improvements to the A5 are outside the council's (and even Leicestershire County Council's) remit, that essential improvement to the A426 between the M6 and A5 are another county's responsibility, and that there is no plan foreither of these to be deliverable within the plan's timeframe, and is inconsistent with government policy on sustainability and rail-linked strategic distribution.

This type of devlopment generates poor quality, low payed jobs and the area proposed sees already large numbers of people travelling daily to existing warehousing

Traffic levels in the area are already high at peak times and some routes, e..g. Between Lutterworth and Rugby, can be extremely congested. As more vehicle traffic is added to support expanding Magna Park operations there is a serious risk of gridlock on some roads. Much of the traffic volume seems to be driven by workers travelling into the area and as the number of commutes has increased there is evidence that traffic volumes through the villages is increasing. There seems little consideration in any of the plans to the risk of damage and injury to property and people due to busier roads in villages that were not designed to handle modern vehicle traffic. The number of incidents is increasing but the details of most accidents are not on record to enable proper assessment of the impact.

Traffic volumes impact Air Quality. It is well known that Lutterworth has failed to achieve acceptable air quality levels for a number of years despite regular plans to address the issue. With more traffic through the expansion of Magna Park the air quality can only get worse. Where is the evidence that air quality is being factored into the development decision?

It would appear that expansion of Magna Park is considered an important factor in the overall local area development in terms of providing more jobs in the future. I understand that current unemployement in the area in very low and that workers travel into the are to Magna Park and other logistics parks in the area. Something that I believe has not been considered in the plan is the effort of those same logistics operators to actually reduce the number of employees through the automation of warehouse functions. This approach may in fact reduce the overall employment levels at Magna Park in future years rather than provide a steady increase in numbers.

An additional factor that is likely to impact future logistics operations in the immediate area is the lack of a rail connection which is likely to make Magna Park less ideal as the choice for national distribution centres in the future.

I would note also that the current plan to expand Magna Park by 700,000 square meters uses the total land area planned for expansion up until 2031 in one immediate hit. That is also at a time when other logistics developments have also recently started in the immediate vicinity - suggesting that the estimated target allotment of 700,000 square metres by 2031 has already been exceeded.

The area is potentially rich in historic sites dating back to the Roman and Middle Ages. So far much of the land has been protected by farming. I would like to see clear assurances that any discoveries of historic finds uncovered in the process of any future developments will be given appropriate visibility and assessment by suitably qualified interest groups.

3.0 Policy SS1 The spatial strategy
3.1 Policy SS1 sets the overall framework for the Local Plan, setting out the proposed scale and distribution of new development by reference to existing and emerging growth plans for the sub-region of Leicester and Leicestershire and to the existing hierarchy of settlements within the District, with a focus on those at the higher levels of the hierarchy. With regards to employment land Policy SS1 (2)(b) states:
"Business: safeguard important existing employment areas, identify sites to meet future economic development needs and replace losses in the stock of employment land for offices (B1(a) and (b)), industry (B1(c) and B2) and non strategic storage and distribution (B8) as follows:
i. about 16.5 hectares of employment land already completed or committed, including through planning applications, resolutions to grant permissions and allocations in made neighbourhood plans;
ii. about 23 hectares of employment land in the East of Lutterworth SDA;
iii. about 35.5 hectares of employment land on other sites allocated in this Local Plan.
c. Strategic storage and distribution: safeguard existing provision at Magna Park and ensure further sites contribute towards meeting the future requirement for non rail-served land across Leicester and Leicestershire in accordance with Policy BE2.
Consideration of Policy
3.2 Policy SS1 (2)(c) seeks to safeguard existing provision at Magna Park and ensure further sites contribute towards meeting the future requirement for non rail-served land across Leicester and Leicestershire in accordance with Policy BE2. Prologis UK Limited and RRSLP object to the provisions of Policy SS1 (2) (c) because the amount of employment land quoted in the spatial strategy is not an up to date reflection of the position in the District. The Council has granted planning permission for the erection of a 100,844sqm Storage and Distribution centre (B8) with ancillary B1(a) offices on land adjoining and linked to Magna Park, including formation of access road from Magna Park, erection of gatehouse, creation of roundabouts, partial realignment of Mere Lane and upgrading of A5 to dual carriageway, creation of SuDS facilities and associated infrastructure and landscaping works [LPA ref: 15/00919/FUL]. This site measures 55.41ha and therefore has not been reflected in the drafting of the policy or referred to in the Reasoned Justification.
3.3 Prologis and RRSLP consider that Policy SS1 is misleading in terms of the actual amount of employment land needed in the District. It is unclear why the Council has not stated its entire employment land requirement including strategic B8 as a minimum or a maximum amount in its spatial strategy.
3.4 The reasoned justification [para 3.1.1] states that Policy SS1 sets the overall Framework for the rest of the Local Plan, setting out the proposed scale and distribution of new development by reference to existing and emerging growth plans for the sub-region of Leicester and Leicestershire and to the existing hierarchy of settlements within the District, with a focus on those at the higher levels of the hierarchy. With regards to employment land Prologis and RRSLP consider that it does not clearly set out the scale and distribution of new employment development nor does it properly reflect the scale of the proposed extension to Magna Park.
Tests of Soundness
3.5 Prologis and RRSLP considers that Policy SS1(2) (c) fails to meet the following tests of soundness because it is not:
1 Positively Prepared: Policy SS1(2) (c) is not based on a strategy which seeks to meet objectively assessed development and infrastructure requirements. The scale of employment land quoted in the policy is not an accurate reflection of the position nor does the policy clearly identify the entire employment land requirement for the District.
2 Justified: The Council has not robustly justified the amount of strategic B8 development needed within Harborough. The Council proposes an extension to Magna Park which will deliver strategic B8 development and associated facilities on 383 ha of land-more than double the requirement for non-rail served sites required in Leicestershire as well as delivering in excess of the gross land requirement for strategic B8 development by 2031. Further work needs to be undertaken in order to justify this amount of road based B8 development specific to Harborough and in the context of Leicester and Leicestershire.
3 Effective: The policy is not effective as it fails to clearly identify the total minimum amount of employment land that is needed within the District including strategic B8. The SEELA (2017 Update) sets out the Borough's Employment Land Needs 2011-2031 but excludes strategic B8 development because it is identified within the L&LSDSS. Policy SS1 is confusing as drafted as it does not provide a clear and comprehensive approach to the amount of employment land needed. This is needed so it is clear for monitoring purposes going forward to 2031 and beyond.
4 Consistent with National Policy: The Plan should enable the delivery of sustainable development in accordance with the polices in the Framework. The proposals at Magna Park conflict with the overall strategic aims of the Framework which seeks to reduce carbon emissions through promoting sustainable transport modes, and the Government's National Networks National Policy Statement ('NPS') which prioritises distribution and warehousing sites served by rail.
Recommended Change
3.6 In order to address the conflicts identified above and ensure that Policy SS1(2) (c) is sound, it is requested that Harborough Council:
1 Provides an up to date assessment of their existing employment commitments and allocations which is reflected in the drafting of the policy. This should include strategic B8 development given the scale of the proposals.
2 Provides evidence justifying why it is appropriate for the Council to extend Magna Park and justify why it is appropriate for the District to allocate more than double the requirement for non-rail served sites required in Leicestershire as well as delivering in excess of the gross land requirement for strategic B8 development for Leicester and Leicestershire by 2031 in one location.
3 Provides evidence that the Council has robustly fulfilled its duty to cooperate with regards to meeting the concerns of Daventry and North West Leicestershire in terms of allocating in excess of the identified need for the whole of Leicester and Leicestershire in one location.

Harborough Local Plan 2011-2031: Proposed Submission Representation
17 November 2017


1. Gazeley UK Ltd are the developer of Magna Park - Harborough District's single largest employer and the focus of Policy BE2 in the Proposed Submission Local Plan (PSLP). Gazeley are also the applicant for an extension to Magna Park to provide a further 419,800 sq m of strategic distribution floorspace together with a range of ancillary uses, including an Innovation Centre, Logistics Institute of Technology and Railfreight Shuttle and Terminal. The ancillary uses are aimed both at creating the efficiencies of the logistics cluster that Magna Park stands to become and at capturing the benefits that would follow for the industry, its employees, local communities and the environment. Almost uniquely in the sector, Magna Park is proactively managed by Gazeley. That fact, coupled with the concentration at Magna Park of blue chip logistics businesses, generates the opportunities that Gazeley's extension proposals would realise.

2. Gazeley welcome and support Harborough's PSLP. The PSLP provides a welcome strategic platform for achieving the ambitions for Magna Park, and in particular for ensuring that Harborough's economy, communities and environment gain accordingly.

3. This representation sets out the basis for Gazeley's support for the PSLP, together with suggested amendments to Policies GD3, HE1 and BE2.2. The change to GD3 is needed to make it consistent with BE2.2; the change to HE1 is needed to bring the policy into line with NPPF 132-135; and the changes to BE2 are suggested to strengthen the policy's expectation that large scale distribution development around Magna Park should create a valuable logistics industry cluster that will benefit local communities as well as the economy and in all other ways constitute sustainable development as defined by NPPF 15-149.

The PSLP policies Gazeley particularly welcome

4. Gazeley particularly welcome the following policies for the reasons explained.

* SS1 The Spatial Strategy and the accompanying written statement, because of:

i. the recognition of the significant role the district plays in the strategic distribution sector because of its competitive advantages (strategic infrastructure, land, labour and cluster efficiencies)

ii. the recognition of Magna Park's role in the significance of the sector for the district, county and region

iii. the recognition that with more employment in the district, there is a chance that out- commuting for work could reduce (no chance otherwise) - and in that context note the wide range of occupations in strategic distribution and the sector's a good match with the district's skill set;

iv. the consistency with the Strategic Economic Plan for the Leicester and Leicestershire Local Enterprise Partnership (LLEP) and with the Midlands Engine for Growth strategy;

v. the use made of the extensive evidence base commissioned by LLEP, the Leicestershire authorities and HDC on the strategic distribution sector; and

vi. the acknowledgement that the evidence is a projected need for a minimum quantum of 608,000 sq m in the county to 2031, provided in market-facing locations, offering development plots of a scale and with the flexibility required to meet the increasing size needs of the sector, with sequential approach to site selection starting with a first preference for extensions to existing sites.

* CC1 - Mitigating Climate Change, because of the obligations CC1 places on major developments to provide and use renewable energy, minimise resource consumption and reduce carbon emissions.

Policy not sound as drafted: Policy GD3 Development in the Countryside

5. Policy GD3 is not sound as drafted, but solely because it fails to account for Policy BE2.2, the delivery of which will require development in the countryside for a use which Policy GD3 precludes.

6. Policy BE2.2 is not accompanied by a site allocation, but requires the development of land in the countryside to deliver the up to 700,000 sq m of strategic distribution floorspace that BE2.2 locates next to Magna Park. Therefore, as drafted, GD3 is neither positively prepared nor effective.

7. To make GD3 sound, we suggest simply adding a new criterion 'j.' to refer to BE2.2, and to renumber the remaining criteria in GD3 as follows: criterion j., and renumber the remaining criteria as follows:

8. Should a site or sites ultimately be allocated for Policy BE2.2, then the change to Policy GD3 would clearly not be necessary.

Policy BE2 Strategic Distribution: sound but would benefit from setting a higher bar for what would constitute sustainable development

9. Gazeley welcome policy BE2 and its criteria-based approach, and in particular the recognition of the particular merits of the Magna Park location in meeting the needs of a growing and dynamic logistics sector for which Harborough has compelling competitive advantages.

10. Nonetheless - and with regard to the sheer scale of development that is promoted by BE2, the concentration of an additional 700,000 sq m of strategic distribution space on land that extends or adjoins Magna Park and the concerns of local communities (voiced since the first planning permissions were granted for Magna Park) - Gazeley take the view that the policy is less ambitious than it should be. Magna Park itself is already unique: its existing size (some 772,000 sq m of large B8 units); its occupation solely by blue chip companies; its dominance by national distribution centres; and the high share of the site given to landscape, habitat and woodland (Gazeley planted over a million trees to create the publicly accessible Magna Wood). Magna Park is also in the open countryside but close not just to the strategic highway network but to a small town and many smaller rural villages. These factors, together with the prospect of a further 700,000 sq m of large B8 units, combine to present a singular opportunity for Harborough - not just to meet the floorspace needs of the logistics sector in an optimal location, but in doing so also to optimise the economic efficiencies for the competitive growth of the industry by promoting Magna Park as the centre of a logistics cluster and, at the same time, setting a new bar for socially responsible and environmentally sustainable logistics development.

11. The key challenges to the logistics industry's competitive growth are, alongside securing an adequate supply of optimally located land, its image, the availability of suitably skilled and qualified labour, and its environmental footprint. These are all closely related: the ability of the industry to grow productively as well as sustainably is fundamentally dependent on attracting and providing people with the skills needed to drive up innovation in the sector, reduce the costs of the supply chain, improve its value to end users and minimise its environmental effects. The sector's ability to do this is, in turn, fundamental to the performance of UK plc, including environmentally.

12. These considerations create the opportunity for policy BE2 to drive and support the singular opportunity to build on the standing and scale of the existing Magna Park and to both drive and capture the benefits of the logistics cluster that BE2 is capable of creating. A cluster is a group of similar and related firms in a defined geographic area that shares common markets, technologies, worker skill needs, and which are linked by buyer-seller relationships. Clusters are drivers of economic efficiencies, innovation and productivity resulting from competition and inter- trading between firms and the further efficiencies entailed in resources, factor inputs, labour skills and markets.

13. The logistics industry has particular features of its operation that makes it particularly well-placed to secure the economic benefits of clustering. One feature of this is pure geography. There are a limited number of optimal locations with supporting infrastructure from which logistics operators can most efficiently fulfil demand. Magna Park is one. But there are also particular operational advantages for logistics from cluster activity. Moving between large centres of freight activity rather than highly dispersed centres lowers transportation costs and almost certainly creates greater reliability as well. In any competitive cluster environment these costs savings get passed on to the logistics operator's customers and hence lower costs across the economy as a whole.

14. Logistics clusters also tend to encourage value-added activities such as product differentiation, repair and servicing - and increasingly, amongst the more innovative, also various forms of 'trialling' of new systems of supply change management and other forms of R&D and its application. Long and complex manufacturing supply chains, for example, mean that firms often have to respond quickly to changing technologies, fashions and consumer tastes to stay relevant to the market. The closer and later this can be done to point of delivery to market, the greater the competitive edge for the selling firm. Logistics clusters provide the ideal base to perform such value added functions. Thus the notion, particularly in the Golden Triangle, that the National Distribution Centres that tend to dominate the occupier base, 'only' do stock-holding and distribution is incorrect, and increasingly so.

15. The other merit of the scale of development promoted by BE2 is the cost savings achievable in the development process itself. For example, shared infrastructure means the costs of providing it are lower per unit of occupation. The margins achieved can be diverted to less commercial, but nonetheless needed and valued services to the cluster are greater. Gazeley, for example, is capturing those margins to promote, as part of its application to extend Magna Park:

* a Logistics Institute of Technology (LIT) in partnership with Aston University and North Warwickshire and South Leicestershire to address the industry's rising needs for more skilled, better qualified labour and for the kinds of applied research innovations needed to continue to drive the industry's sustainable, competitive, growth;

* an 'innovation centre' to supply easy-in, easy-out small business space to encourage new firms to start up and grow on the back of the out-sourcing opportunities the Park provides and the output of the applied research functions;

* a Driver Training Centre to address the shortage of skilled and professional HGV drivers;

* a railfreight shuttle - using low or no carbon fuelled traction units - to provide and 'on- demand' service to nearby DIRFT and on-site container storage, to overcome these hurdles to the take-up of railfreight by Magna Park's largely road-based distribution firms;

* an HGV park, fuelling station and vehicle wash;

* a 70 ha country park and meadow supported by public car parks, public lavatories and shared use of the innovation centre's café - targeted on local communities but also occupiers' employees;

* the dual use of the LIT's campus facilities, including playing fields, with the community and again with Magna Park employees;

* a Local Heritage Centre to exhibit and explain the history of the site's habitation in its landscape and the economic forces that have shaped both, with focuses that include parts of the Key Stages 1 (heritage) and 2 (climate change) curriculum; and

* the re-use of a non-designated heritage asset on the site as a conferencing centre and marketing suite.

16. The value that the logistics cluster is able to return to the economy, environment and local communities is very significantly increased by the addition of these complementary uses. Yet the market - in the absence of the kinds of margins that large scale schemes create - could not and would not be able to deliver these wider uses. Though these uses deliver public benefits in line with policy, constraints on the public finances make it unlikely that funding for such uses will be forthcoming for the foreseeable future.

17. Their delivery at Magna Park is made possible for Gazeley by the sheer scale of the extension scheme, the existing concentration at Magna Park of blue chip logistics businesses to provide an initial customer base for these complementary uses and by Gazeley's proactive engagement with partner bodies for their delivery. The commercial return for Gazeley is achieved by the competitive advantages gained from attracting the industry's best and most socially responsible occupiers.

18. Finally - and again in recognition of how firmly Magna Park is already embedded in the community which hosts it - Gazeley convene and chair a 'Community Liaison Group' which meets quarterly to listen and respond to the concerns of local parish councils and residents groups, operates a community fund of £20,000 per year which awards project funds on a competitive basis to local schools, community groups and charities and hosts annually a family fun day at Magna Park open to the wider community as well as the Park's employees.

19. With all of this in mind, Gazeley suggest the amendments and additions to policy BE2 that are set out below. We also request that a site allocation(s) be made (which if done would obviate the change requested to policy GD3). The certainty of a site allocation(s) would, in Gazeley's view, greatly assist the industry and local communities.

20. The amendments proposed to policy BE2.1 acknowledge the cluster benefits of the concentrating logistics businesses around Magna Park and the consequences for the growth of related but ancillary activities that support or are spun out of the cluster; and the amendments to BE2.2 aim to take advantage of the scale of the development(s) to benefit the community and local environment as well as the wider economy. While it is appreciated that additional criteria are covered by development management policies in other parts of the Proposed Submission Local Plan, these are generic. The scale and nature of the BE2 development and its concentration at Magna Park merits in Gazeley's view a more specific set of criteria.
BE2.1 As drafted)

BE2.1a (As drafted)

BE2.1b. any new building or the change of use of an existing building is only for Class B8, ancillary uses to Class B8 only, or for a use for which a location as part of the Magna Park logistics cluster is necessary and beneficial

BE2.1c. the proposal for any non-strategic storage and distribution use is small-scale, proportionate in scale and function to Magna Park's strategic storage and distribution use and ancillary to the use of individual plots

BE2.2 Additional development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted where it would:
BE2.2a form an extension of, or be on a site adjoining, Magna Park;
BE2.2b support or at least have no adverse impact on the viability and deliverability of existing or further Strategic Rail Freight Interchanges (SFRIs) within or serving neighbouring authorities and Leicestershire;
BE2.2c increase employment opportunities for local residents, including training and apprenticeships;
BE2.2d include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District;
BE2.2e not lead to severe traffic congestion anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside; and
BE2.2f ensure 24 hour operations do not have an unacceptable environmental, community or landscape impact
BE2.2e: mitigate significant adverse impacts on the not lead to severe traffic congestion anywhere on the nearby strategic and local road network to achieve nil detriment or better particularly the A5, whether within Harborough District or outside;
BE2.2f include measures to encourage car-sharing, cycling and sustainable alternatives to private car use;
BE2.2g include measures for regular community liaison;
BE2.2h include measures for publicly accessible green infrastructure;
BE2.2i optimise the bio-diversity of the site and its capacity to sequester greenhouse gases;
BE2.2j make use of optimal technologies for the construction of buildings and their operation to reduce resource consumption and optimise the use of renewable energy sources;
BE2.2k achieve the highest practicable environmental standards for buildings;
BE2.2l adopt a design approach to the buildings, materials and lighting to minimise the visibility of the buildings during the day and at night time;





BE2.2m site buildings and service infrastructure to respect the character of the landscape;
BE2.2n site gatehouses, yards and HGV circulation routes so that visual intrusion and noise beyond the site is minimised; and
BE2.2o mitigate landscape and visual impacts using, in particular, tree planting and other species that will optimise carbon sequestration.

The landowners of Whetstone Pastures, duly object to the failure of the Council to recognise the potential to:

* Identify land within Whetstone Pastures as a future logistics park; and more over
* Recognise the ability of land within Whetstone Pastures to deliver a new Garden Village as part of a large strategic allocation extending over the administrative boundaries of both Blaby and Harborough.

2 On this basis objections are duly made insofar as SS1 - The Spatial Strategy is not 'sound' insofar as it is not:

* Positively Prepared as it fails to meet objectively assessed development needs and infrastructure requirements, including, where they arise, potentially making an appropriate contribution towards meeting unmet requirements from neighbouring authorities;
* Justified in that the plan is not based on the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
* Effective in that the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy as the plan does not enable the delivery of sustainable development in accordance with the policies in the NPPF.

3 With regard to SS1 it is submitted the following strategic priorities of the Local Plan (pp. 9) are not fully met:

* SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas;
* SP2: Assisting other local authorities to meet their unmet housing need; and
* SP3: Meeting regional and national demand for strategic distribution (logistics) development.

4 This is predicated on the basis that:

* Policy H1 - fails to make provision for sufficient new housing for the Plan period;
* Policy BE1 - fails to make provision for sufficient new business development for the Plan period; and
* Policy BE2 - fails to identify land at Whetstone Pastures as a potential logistics park.

5 Policies H1, BE1 and BE2 are effectively drafted on the basis of Harborough meeting its own objectively assessed needs. Accordingly, the draft Plan fails to recognise the wider needs of its neighbours as established in January 2017 when the Leicester and Leicestershire Authorities (including Harborough and Blaby) and LLEP jointly published its HEDNA which identifies the future quantity of housing and employment land needed in Leicester and Leicestershire up to 2031 and 2036.

6 The HEDNA has identified an Objectively Assessed Need for 117,900 dwellings between 2011 and 2036 across Leicester and Leicestershire. The need for larger more strategic warehousing and distribution units across Leicestershire is set out in the Leicester and Leicestershire Strategic Distribution Study 2015 (updated in 2017).

7 Leicester City Council has indicated that there will be unmet housing need within the City. A letter from Leicester City Council to all the other local planning authorities in the HMA dated 13th February 2017 stated that;

"the scale of the need [OAN] set out in the HEDNA is of such magnitude that it is concluded that there will be an unmet need arising in the city'. An additional letter sent on the same day to the Planning Inspector for the examination of the North West Leicestershire Local Plan set out 'our formal declaration of unmet housing need arising in the city."

8 In addition to setting out the future housing and employment requirement the document recognises that there is a need for all authorities within the Leicester and Leicestershire Housing Market Area to work collaboratively to account for the distribution of any identified unmet need.

9 On the basis of the foregoing local authorities have a statutory Duty to Cooperate over such matters and to identify how any such needs would be met. A Memorandum of Understanding (MoU) is currently being prepared by the 9 local authorities within the HMA (including Harborough). This document will identify how any unmet housing needs will be accommodated and will be signed by each authority as a binding agreement.

10 Given that the unmet needs of Leicester City Council should be addressed within the period of the Harborough emerging Local Plan the landowners are very concerned that there is no flexibility within the Plan to demonstrate how Harborough will accommodate unmet need through policies H1, BE1 and BE2 to meet this need.

Harborough DC - New Local Plan Options

11 The Council will be aware of representations made to Harborough DC - New Local Plan Options document (2015) by Nathaniel Lichfield & Partners (NLP) on behalf of Prologis UK Limited (Prologis). The representations principally related to proposals for a new logistics park on land between junctions 20 and 21 of the M1.

12 In broad terms the landholding related to an area in excess of 185 ha to the east and west of the proposed new M1 junction 20a (Whetstone Pastures Estate). The land is located to the south east of Cosby and west of Willoughby Waterleys. The Estate straddles the administrative boundaries of both Harborough and Blaby.

13 At the time of the submission the landowners and Prologis were promoting:
A new motorway Junction 20a on the M1 to relieve congestion at Junction 21 and to help remove an obstacle to further economic development;
* A new motorway service area to replace the existing Leicester Forest East motorway service area allowing for the managed motorway programme to be introduced; and
* A new 370,000 sq m logistics park on approximately 80 ha next to the proposed Junction 20a that would deliver over 6,000 high quality jobs in a wide range of roles.

14 Representations were duly made and recorded as follows:

* New Local Plan Options (September 2015), (rep. ID 2680 / 4242); and
* 'Sustainability Appraisal - Second Interim Report Appraising Options for Strategic Distribution Growth (February 2016) (rep ID 5327 / 5326 and 5245).

15 The representations were endorsed by the landowners in a follow up written submission lodged by Strutt & Parker on the 28th June 2016.

A New Garden Village

16 Since these submissions Blaby District Council, with the support of Leicestershire County Council and the Leicester and Leicestershire Local Enterprise Partnership (LLEP), made a submission in response to the Department for Communities and Local Government (DCLG) and Home and Communities Agency's (HCA) invitation for Garden Village proposals in July 2016.

17 The proposed Garden Village would be focused around a new M1 junction at 20a. The total site area would extend to approximately 400 hectares and would include the 185 hectares previously identified for the logistics park. Whilst the majority of the site falls within the administrative boundary of Blaby some 15% of the southern part of the landholding lies in Harborough. Please see attached map for more detail.

18 Whilst the bid was not successful the HCA in their individual letter of response went on to encourage the continued pursuit of the Garden Village idea:

"The HCA is responsible for delivering the Garden Villages Programme for the DCLG and we recognise the potential of your proposal. We would like to have a conversation with you around how we can best support you in progressing your Garden Village ambitions. There is scope for us to offer support from our planning Team ATLAS, from delivery specialists in our teams and in HCA's Land Team. We hope to open another round of Garden Village Funding in 2017/2018 and offer guidance in preparing applications."

19 Blaby District Council are continuing to work with the landowners to deliver a shared vision for the Garden Village proposals.

20 The proposals are at an early stage. However, the Local Authority and landowners have a shared goal to develop the ideas into fully-fledged proposals over the next 12-24 months. In broad terms it is envisaged that the Garden Village would offer a unique opportunity to deliver truly sustainable strategic growth; comprising of a new community, large scale employment opportunities and considerable benefits for the surrounding highways network. Specifically the plans would ensure:

* The delivery of a new M1 Junction (J20a):
* Approximately 280,000 sqm employment and logistics park; and
* In excess of 3,500 homes.

It is envisaged that this sustainable new community would deliver facilities including schools, healthcare and sports, and green and blue infrastructure, new local shops and other community facilities, all set within an attractive landscaped network of streets and parks. All this on a site located approximately 5km from the major commercial hub of Leicester City Centre.