H6 clause 1

Support these proposals /Sound.

The plan includes propsals to provide suitable sites for gypsies and travellers but there is no definition of the meaning of the words used. For example how often do travellers have to travel to be considered as travellers?
HDC some years ago was aked by central Government to list sites suitable for these people but no such list was prepared resulting in an increase in non registered sites with little council control

Using the words "travellers" is misleading as most of the people so defined do not travel but remain in one place. Alternatively enforced movement of "static" travellers should be introduced say evry two years.

There are Travelling Showpeople sites in the district that are under occupied or not occupied at all. There would appear to be a reduction in the overall need for show people sites as there is a reduction in attendance at fairgrounds nationally

Where does the number of 5 pitches come from, this number is totally indeqaute bearing in mind the size of this community living on approved sites and non approved sites

BE2 STRATEGIC DISTRIBUTION
There is no evidence that 700,000 sq meters is needed for warehousing. Is it coincidence that there are 2 application for warehousing coming forward both together equal 700,000 sq meters? There is no local unemployment therefore the Local Plan is unsound.

According to research, the demand is for less warehousing especially with no rail link and therefore will lead to an over-supply in one area. Employment opportunities should be spread across the district. Key issue 3 states that the Local Plan should reduce Harborough's residents on commuting and increase wage rates by providing employment alternatives including more opportunities for higher skilled residents. In reality there are none or very few opportunities for higher skilled jobs. The jobs provided are warehouse work, lorry driving, cleaning, catering etc. Present employess travel in from afield causing serious traffic issues especially during shift changes adding to the already serious air pollution in Lutterworth and surrounding villages. The addition of 10,000 of
The same type of jobs, low skilled, low paid and zero hour contracts which magna Park already provides in abundance will not be beneficial to local residents. The National Planning Policy Framework says that there is a preference for warehousing to be based near rail links. With the addition of more HGV's and 10,000 commuters to an already over-crowded road network will cause chaos for local residents.

H6 GYPSY, TRAVELLER & SHOWMAN SITES
The Local Plan states that a further 26 showman plots are required up to 2031. Lutterworth already has six sites in and around the town. There are two sites on Moorbarns Lane in Lutterworth which have stood empty for approximately 3 years. The owner has on more than one occasion applied for housing on one of these sites, the most recent application was refused and the appeal upheld. Subsequently, an application for a further 8 showman plots on this site were approved due to need. The owner is now in the process of re-submitting the site for 36 houses again.

The second site on Moorbarns Lane was granted permission for additional showman's plots under delegated powers, omitting any notices being given. To date, both sites remain unoccupied. There is no substantial need for 26 more plots and is therefore unsound decision making. The GTRAA 2017 was not publicly available and the evidence is questionable. The showman figures have not been properly reflected and plots have been missed out.

L1 EAST OF LUTTERWORTH STRATEGIC DEVELOPMENT AREA

Lutterworth Town Council supported the SDA in principle, however this was on the basis that a dual carriageway (now down-graded to a spine road) should be constructed in the early stages of development to alleviate air pollution and traffic congestion.

Consideration should be given to imminent future housing development on the A426 in the Blaby District and the emerging grown plan. This housing intensification will add to the problems of an already congested A426 especially at times of Magna Park shift changes. Traffic congestion is having an effect as far away as Rugby.

I consider the plan not sound and not compliant because;
Access to consultation form was made difficult, it disadvantaged ordinary residents to put forward a view.
Public advertising of the consultation in the local media was very limited.
Access to information for members to make educated decisions was limited , a lot of information was presented via verbal briefings only , some information was deemed as confidential and not provided.
Visions and objectives are good but empty rhetoric, not backed up with strong enough policies to achieve these goals.
The plan appears to focus mainly on the provision of housing rather than placing an additional focus on providing variety and access on suitable housing that will meet the needs and the diversity of residents.
The Harborough District has an above national average of an aging population and a larger focus should have reflected the needs of these residents by ensuring policies advocate more bungalows.
Provision of Extra Care and Specialist Accommodation is not deliverable .Targets are too high and policies remits are confusing.
There are mistakes and discrepancies in supporting information.
Some supporting information was not taken into consideration.
There is no guidance where to find relevant information and what has been superseded by what. The process is messy and confusing.
The Sensitivity Study was commissioned to confirm housing needs alongside employment /logistic options .These were supposed to be allocated across the HMA not just Harborough District.
The Sensitivity Study is not of merit to determine the amount of logistic provision therefore rendering policy BE2 not sound

Comments relating to the following (sections / policies) :

1.2 The Option Consultation: secured an overwhelming public response .The public objected to a major expansion of Magna Park .The Sustainability Appraisal Interim Report 2015 and 2016 rejected an Option of 700 000sqm which echoed demand not need for 3 planning permissions submitted .Officers stated the conclusion of the SAIR would not be affected in the future and Planning officers concurred by stating that approving all 3 application submitted would not be sustainable.
However without evidencing any proper process this evidence was overruled.

1.5 The Duty to Co‐operate: was not fully adhered to by consulting all neighbouring LA's in any of the early stages .There are only notes of DtoC meetings from
May and July 2017. These minutes state foregone conclusions without having followed proper democratic process.

1.7 Supplementary Planning Documents: As well as other evidence has not been readily available throughout the process and parishes and other stakeholder have not been given the timeframe to consider background information. It is not clear what is valid, some reports are superseded, reports are not all in one place and the evidence base is confusing.

2.1 Local Plan Vision and 2.3 Objectives: The vision and objectives are lordable but the policies with in the LP do not reflect the desired aims to achieve these objectives.
To secure a wide range of skilled jobs for an highly educated population has always been a supported council policy.
The objective, stopping young people from leaving the district is not served by focusing mainly on providing unskilled, temporary, low paid jobs in the logistic industry.
A focus on sustainable , diverse and vibrant job market is not possible without creating the opportunities.
Reducing impact of traffic on local communities in Objective 10 is not a deliverable policy in line with the proposal of policy BE2 either and Objective 7 to protect the historic environment is also compromised by policy BE2 . The protection of heritage is highly supported by the NPPF and featured in the draft Growth Plan but the policy is not strong enough . The objectives and policies are contradicting themselves in places .

3.1.2 to 3.14
Recognises a fair geographical spread , long term strategic growth by providing a diverse , fair , economic strategy across the region and Leicestershire placing resources where there is need and higher unemployment Policy BE2 in this LP adds considerable more than the identified long term requirement of non -rail storage /logistic to a already considerable land bank of logistics permissions granted but not build out.
Furthermore BE2 is disadvantaging other operators in other geographical areas by oversaturating the market.

5.1.4: The HEDNA was to identify housing and employment need. However all this important detail of employment /logistic provision and the correlation thereof was omitted until very late in the process .The Sensitivity Study was an add on, not fully commissioned and was not made available until July.
The study has not been objectively assessed , scrutinised , it is confusing , contains flaws and is based on assumption not on evidenced facts.
The scenarios used to underpin the need for 700 000sqm of logistics floor space are disregarding all previous, confirmed evidence , consultation result and a democratic members decision.
The study that alleges 19 % of HD residents work at Magna Park. If to be considered as factual, one needs to be mindful that this has taken over 20 years to achieve.
To raise this to 25 % ( 3000 workers approximately ) in an area of low unemployment (at it's highest 1100) without effective policies and no means of enforcement this seems unachievable.

5.1.9: A buffer of 20% was applied by a proper democratic process to assist other LA's with unmet housing needs in March 17 .This need has not yet been evidenced and was agreed on the provision of 2 letters received ( 5.1.6 )
Not adhering to a proper democratic process the 20% buffer provision was split into 15 % unmet need and 5 % ( 5.1.9 ) to meet the impact of policy BE 2.
The March decision was ignored and these figures were already placed in all the draft Local Plan documents before being agreed by the Executive in September 17.
How can the Local Plan with no provisions and policies to enforce, underpin or secure the ambitious commitment to house Magna Park workers in the district ?

BE1: The Full Council has always voted to encourage and promote knowledge based industries to the district but policies or actions do not actively reflect this ambition.

BE2: Comments from members and residents ignored, evidence flawed, contradiction to previous evidence applied, proper process not followed in order to accommodate a policy that advocates unnecessary ,over allocation of storage, logistic provision to consider with applications submitted which will be decided at a planning meeting before this plan is evaluated.
The applicants stating their proposals are promoted via the LP and that the policy of the emerging plan supports their application.
This policy is ambiguous, will saturate and monopolise the non‐ rail storage and logistic market to the disadvantage of neighbouring authorities. This policy supports greed and does not identify need.

H1: Sets out housing commitment to 2031. The infrastructure document are difficult to access. It should be explained that dwelling should not just be taken as houses but could be apartments /flats. The policy should reflect a need for this provision to aid the accumulation of much required social housing.
It refers in 5.1.8 to 557 per annum or 11140 over the plan period .There is no correlation of the figures.
H1 ( SS1 2a ) states a minimum of 12800 but should state a maximum.
All of this is very confusing and it will be difficult to implement and to achieving a clear basis on which a 5 year housing supply is calculated which is clear and defendable.
Previous housing trajectory identified that no 5 year housing supply has been achieved previously in the Harborough District with a far lower annual housing requirement. It is therefore ambitious and unrealistic to add a 20 % buffer on ONA as this is unlikely to be achieved possibly rendering the Local Plan impotent.

H2: 40 % is not viable or sustainable and will not aid the provision of affordable housing when only up to now only 19 % was achieved and at present only 4000 units are outstanding to be build.

H4: More emphasis needed to ensure specialist housing is provided , policy impossible to achieve and confusing. Is the 10% on top of 40% affordable ?

H6: Provision at Bonham's Lane is not required and the special status of the site should be recognised.GTAA was not an open and public consultation
There would be no requirement for additional Showpeople plots if officers would stop supporting present sites for housing development against planning inspectors advise thus losing the district the existing provisions.
Travelling Showpeople plots have been allocated to non‐ guild members , there have been statements to the fact that there are no further requirements.
5.11.2 refers to the amount of pitches for G/T and showpeople .However, Parish Council 's have unsuccessfully requested up‐dates on occupation of the sites. It is therefore assumed that the illustrated figures are questionable as there have been no detailed evaluations.

There is enough provision for travellers in our community already, albeit it is not actually in Market Harborough it is pretty much on the border.