BE2 clause 2

This part of the local plan is completely abhorrent, it implies that the 2 existing planning applications for expansion to and closer to the town from magna park, still awaiting approval are in fact 'done deals' by the council. There is no need for either of these, they will not provide jobs for residents of Harborough, the majority will be low skilled and low paid jobs, not providing high skilled employment foe local people, as stated in the local plan. Nearby new distribution centres in rugby CANNOT EMPLOY SUFFICIENT STAFF and Police are stopping illegal immigrants arriving there on a daily basis to work, all of whom have also driven there illegally. To add even more jobs of this type is ridiculous.

With reference to the overt mention of live planning applications for extensions to Magna Park and others next to MP (presumably the Symmetry application) in this plan.
These planning applications have not been passed and therefore should not form any part of the local plan.
We have been assured it is not a 'done deal' and the matter is ongoing. A wide range of cogently argued objections to the significant extension of the warehousing area can be found online and there is very strong local feeling against these planning applications. Public meetings have been so well attended that the last one needed an aircraft hangar to accommodate the crowd. These objections were aired at the meetings.
However, all these things clearly count for nothing because although those planning applications are supposedly not yet resolved, here they are, firmly included in this Local Plan. The plan suggests 700000 sq m of warehousing will be allocated - exactly the acreage which matches those two applications. It is impossible to regard this is a coincidence.
I have already placed objections to the MP and Symmetry applications. This particular objection relates to the inclusion of them in the local plan as if the planning applications have been passed.
It is appalling that local feelings are ignored in such an important issue which, if allowed, will destroy the area around Lutterworth for ever. The council is neither representing Lutterworth nor working in the town's best interests. It is both underhand and misleading to include them in this plan.

In addition, one reason the Local Plan includes this vast warehousing extension in the Lutterworth area is that the developers also claim this will bring 10,000 new jobs to Lutterworth. There is considerable evidence that most workers in MP already commute to the site from elsewhere. There is no employment crisis locally so even more people will be forced to come by car. In effect, the town and local villages will get little from these proposals beyond pollution, traffic jams and general disfigurement of the area. The roads are already jammed now. The council has been presented with copious amounts of data on these and many other points.
Finally, this part of the Local Plan claims this warehousing development will bring a desirable 'breadth of employment' and satisfy national objectives but how? These developments merely offer more of the same, not a variety of new opportunities. There is no diversity here.
To sum up, this part of the plan should be erased and a new brownfield site to satisfy government targets for industry should be found elsewhere. Lutterworth is already saturated with this type of development and new opportunities less destructive should be sought.

1. The proposed development is on green field land
2. Is not served by a rail terminal (unlike nearby DIRFT),
3. Lutterworth has less than 1% unemployment, so new jobs are not required
4. Any jobs will be low-skilled and not "reduce the dependence of Harborough's residents on commuting" by creating higher paid jobs
5. It will destroy the archaeological site of Bittesby
6. It will destroy footpaths and walking routes for local residents and visitors

Therefore it is not JUSTIFIED

1. The proposed development is on green field land
2. Is not served by a rail terminal (unlike nearby DIRFT),
3. Lutterworth has less than 1% unemployment, so new jobs are not required
4. Any jobs will be low-skilled and not "reduce the dependence of
Harborough's residents on commuting" by creating higher paid jobs
5. It will destroy the archaeological site of Bittesby
6. It will destroy footpaths and walking routes for local residents and
visitors

This conflicts with planning requirement CC1 mitigating climate change, and National Planning Policy Framework (page 94) to reduce greenhouse gas emissions in accordance with the climate change Act 2008. Goods vehicles emit over 30% of UK transport CO2 emissions and this expansion will increase this. Freight should be diverted to rail transport to reduce this. The additional jobs will increase commuter journeys by car exacerbating the problem. No improvement in public transport has been proposed nor any requirement for facilities to be provided for electric vehicles. The proposal will also increase the traffic problems on national roads and locally.

I wish to object the above development as I do not believe the plans are sound.
Currently and for the past several years unemployment has remained at an extremely low level in this region. The roads locally are already very busy and due to the number of new employees required the traffic will increase enormously. The plans should not be passed as there have been several opportunist plans submitted for the same vicinity and it would appear the companies are trying to get the expansion without sufficient reasoning. Warehousing is simply not required of this size without sufficient rail links. The development would be far more suited to a location where unemployment is at a higher level In recent years warehousing of in excess of 1,000,000 sq m has been approved in this vicinity. There is no need for any further development. especially as there is no plan to improve the local road network, already insufficient to local needs, until 2030

Where is the evidence base for 700,000 sq m? Research tells us that Leicestershire will be overprovided with non rail distribution capacity . This figure is simply about enabling approval for 2 existing planning applications but without sound data to support. This is unacceptable for a development with such a dramatic negative impact on the area. Surely a strategic approach , working with near neighbours such as DIRFT where there is rail provision is required? How does this factor in the provision planned around Hinckley? Even Councillors have acknowledged in the public domain that the process in relation to Magna Park planning is likely to be flawed.
This is not sustainable development in that we do not have a robust or viable road infrastructure, no rail facility and air quality is already an issue in Lutterworth. Unemployment in the area is low so the jobs should be sited elsewhere where there is a demonstrable need. Most workers commute by car in to Magna Park so not only will traffic increase through lorries but also personal vehicles. The Midlands Connect Strategy 2017- 30 recognises that the A5 is inadequate but there are no plans for major upgrades during that period around Magna Park. There are many serious accidents at the junctions between Magna Park and the M69 as things stand - how many more lives will be lost or affected if the traffic is allowed to increase by what will be many thousands of additional journeys?
This proposal does not accord with the NPPF requirements in relation to sustainable transport and climate change nor indeed with conserving and enhancing the natural environment - the development is already of a scale that is completely disproportionate and dominates what should be a predominantly rural landscape. We do not have the housing capacity or other services to support a major influx of workers. Enough is enough.

I really object to this expansion of Magna Pak. It really is big enough as it is and there are already spare unrented units so why do we need more of them? A 100,000 sq mt unit (DHL) has already been agreed. We soon will have an over expansion of warehousing in the area with the development of Crick (Dirft development). That has a rail link which I thought was more the way it was going not non rail linked development?
There is not a shortage of work in the area and a lot of current workers are not local and commute.
The A5 does not cope currently in rush hour, particularly when there are issues on the M6 and M1. More development will mean more HGV's and commuter traffic - both on the A5 and local village roads in the area - most villages around are already used as a "rat-run".
It will take away more farm land currently used for walking and ruin protected areas such as Bittesby village.
No plans seem to be in place to help walkers cross the A5.

The proposal for 700000sqmetres of units is far beyond the capabilities of the local infrastucture to cope with. It is opportunist on the part of developers who wish to maximise their profits at the expense of the locality. There are empty units on the DERFT site with rail access and more speculative units being built on the southern edge of Lutterworth. I believe this proposal is being Railroaded by Political decisions and is not justified on the basis of need. The knock-on effect on local roads,traffic ,schools and pollution will be appalling.

There is no need for this additional storage on this site. There is already one unit which has remained unlet for over 12 months. The amount of traffic any extension will cause will only exacerbate the already overcrowded local roads.. Not only with extra pollution from more HGVs but from the staff cars which will work at the site. Staff will have to be drawn from the major conurbations of Leicester Hinckley ,Coventry and Rugby as there is minimal unemployment in the local area
in order to help comply with Government intensions to reduce pollution from HGVs .Warehouse developments of this scale should be sited at railheads of which DIRFT is currently being expanded and there are proposals for another near the M69/A5 junction .The proposed road widening will only facilitate the site and will cause extra bottle necks in the immediate area and elsewhere.. In addition when traffic is frequently divert from both the M1 and M6 these roads cannot cope now

These are my objections:
* The erection of the proposed warehouses will take up even more green belt land and will
be an eyesore on the landscape. In addition, there is no plan to preserve green space
between Magna Park and the area north, including Ullesthorpe.
* As employment in the Lutterworth area is high, the majority of the future workforce will
have to come from outside the area.
* Due to the predicted increase in the workforce, there is bound to be a significant increase
in traffic, not only on the A5 (which has no upgrade planned until 2030) but also through
the surrounding villages.
By example, Ashby Parva already experiences many cars using the village as a quick
route to Magna Park, with some travelling at excessive speed. This can only get worse
with this development.
* As there will be an increase in Heavy Goods Vehicles and Cars, this will have an impact on
air pollution in the surrounding areas..

Proposed expansion to Magna Park is unsound for these reasons:-
Research reports indicate that there is currently a surplus of distribution warehouses as witnessed by those standing empty in the area for a long period of time. Rail head storage a few miles away is obviously preferred.
Consultants advised H.D.C. that the size of development at Magna Park was a political decision and could disadvantage other parts of the county regarding employment opportunity.
There are 2 outstanding planning applications for the same acreage of warehousing as the proposal indicating that the proposal is opportunist, not strategic, nor based on the needs of the area.
Employees of the present Magna Park businesses commute because there is very little unemployment in the local area so more commuters would create traffic problems on the country roads and in the local villages,
The range of employment opportunity in distribution based operations is limited to low skilled, low paid and lack of secure jobs with little provision for higher skilled local people.
Constant movements of H.G.V.s and commuters will congest the A5 route which at present experiences bottlenecks and pollution especially when there is a closure of the M6 motorway.

There are several warehouses that are empty at Magna Park. There isn't strong evidence that additional warehousing, of such large proportions, is necessary. There are very low levels on unemployment in the local area - less than 1.6%. This will mean that employees will have to commute to MagnaPark, increasing traffic and pollution, on less than adequate roads. If employees move into the area this will impact on our current infrastructure which is already under pressure from increasing population, especially housing, GP practices and dentists etc. This will also impact on our greenspace.

This development exceeds identified need. and matches exactly an outstanding planning application
Development not justified as it would offer mainly lower skilled jobs not the higher skilled employment - goal in the local plan.
Out commuting would not be reduced - another goal in the local plan.
Saturates area with distribution parks causing employment problems
Infrastructure needs required with cost falling on Government
No evidence provided
See attached paper.

HDC Core Strategy stated there was no need for 700,000sq. m of strategic storage therefore this policy is deemed unsound.

Not positively prepared. The people of Lutterworth have already put objections (with valid reasons) forward for planning applications related to the building of warehouses at Magna Park. It feels that the only reason these warehouses are in the Local Plan is because a private company has put a planning application in - the council wouldn't be considering this otherwise, as there is no need or want for it. There are many "to Let" signs around Magna Park which suggests to me that there is already a surplus of warehouses in the area.
The roads around the area are all ready at maximum capacity - particularly around "Gibbets Roundabout" where the A426 joins the A5. Already traffic queues back to the M6 daily and I have seen no evidence of this being addressed. I wonder if it's because this road is right on the Warwickshire boarder so Harborough have chosen to ignore it. Traffic would inevitably be queuing back onto the M6 if more traffic was encouraged to this area. Also the A5 has already seen too many fatalities (particularly at the High Cross Junction) and this will only get worse with more traffic - Claybrooke and Ullesthorpe villagers will be forced to take ever increasing risks to turn right onto the A5.
Not Justified. This area has very low unemployment. Building more warehousing would mean staff would have to commute in from elsewhere. As previously stated, the local roads are already dangerous and at capacity. Building new houses will not solve the issue as this will just increase traffic further. The jobs on offer here will not be in line with the strategic plan either - the majority of jobs here will not offer breadth of employment opportunities for the higher skilled residents. My children continually point out the "to Let" signs and ask why the fields have to built on if there's already empty warehouses.
I am very concerned for the respiratory health of the residents in this area - nowhere does this plan consider the asthma and COPD rates of its residents. Living within the M6/M69/M1 triangle already subjects us to very poor air quality (as acknowledged on the Harborough website). I have 2 members of my family with asthma, both of them have only developed it since living in the Lutterworth area. I find it totally unjustifiable to increase traffic and pollution in this area at the cost of our health.
Not effective. There is already lots of new warehousing at Rugby, Northampton and Magna Park (to name just a few). with these spaces not yet filled, it seems totally ineffective to continue to build more at the expense of our children's health and future. They are the ones that will have to live with the decisions made now. There is no mention of protecting green space around the villages near Magna Park.
Not consistent with National Policy. There is a national policy to improve air quality so it seems totally wrong to continue to build in this area - in a valley surrounded by motorways - where the air cannot circulate. There is also a policy stating that warehouses need to be closer to rail networks. Increasing Magna Park goes against both of these national policies.It would not be good for the local economy to have so much of one type of business in such a small area. National policy talks about growing diverse economies - but this plan is all focussed on one, low skilled. low paid area of the economy which could deeply damage the current community.

Magna Park is already one of, if not the biggest such park of its kind in Europe. Increasing its size is both disproportionate and unnecessary as it will increase congestion, increase pollution, and increase the number of vehicles traversing the area each day, to the great detriment of air quality, the rural aspect of the area and the ability for residents and existing businesses to go about their business smoothly and without being hampered or inconvenienced by long queues of increasingly irate drivers.

This plan is completely disproportionate to the area's needs and ability to withstand future development. The current infrastructure, amenities and services cannot cope with the current level of traffic and business use, so to add yet more will be overstretching the roads, services and air quality beyond breaking point. It also bears no relation whatever to competing developments in Rugby, Corby and the surrounding area, so there is every chance that any such development will be left empty and all the destruction to the rural area caused will be rendered pointless.

I strongly object because:
Increased traffic from both lorries and workers commuting throughout the day and night will inevitably cause more accidents and congestion in the immediate area. Additionally, local motorway networks and villages will be adversely affected.

An increase in pollution - air, light and noise, is of huge concern given the unacceptable levels already registered.

The natural environment will be affected negatively and biodiversity in the area will be reduced significantly.

Finally,the HDC Core Strategy CS 7 h specifically restricts further development at Magna Park unless there is a proven need, which has not yet been established.

There is no evidence for the requirement for additional B2 Strategic Distribution, with unoccupied warehousing on current sites in Magna Park, even new build warehousing empty after 2 years and also on many nearby sites.

No evidence for a requirement of 700.00 sq m

Please see our comments on SS1, the Spatial Strategy, 2c.Strategic storage and distribution

In summary I believe elements of the plan are unsound on the basis of Positively Prepared, Justified, Effective and Consistent with National Policy.

More detail is provided against the relevant points below but in summary my view is:

* It will not create a greater breadth of employment opportunities.
* It will not lead to opportunities for local skilled workers to save out commuting.
* As a result, positions will be filled by those having to commute into Magna Park.
* It is not rail served.
* There is no provision to improve the road network in the surrounding area to cope with the logistics and commuter traffic.
* It will have an unacceptable impact on the environment and the landscape.
* It will contribute further to the poor air quality in the area.
* 700k sq mtrs of warehousing is not strategic, it is opportunistic.
* It is likely to lead to an oversupply of warehousing/distribution land.

The local plan should be modified to not include any major expansion of Magna Park over and the above the 100,000 sq mtrs recently approved.

Reconsider how the strategic aims can be met. Further research is required to identify how any expansion of Magna Park could provide an environment that generates higher skilled, higher knowledge-based employment such as the creation of a science and technology park to attract hi tech and innovative businesses. This will fulfil the criteria for:

"Reducing dependence of Harborough's residents on commuting and increasing wage rates by providing a breadth of employment alternatives, including more opportunities for Harborough's higher skilled residents"


The result would be:
* Avoid the mass creation of low skilled jobs that would not be filled by local residents.
* Avoid the unnecessary loss of productive farmland and impact on the landscape
* Avoid adding to the already high levels of traffic congestion and exacerbating the already non-compliant levels of air pollution particularly in Lutterworth.

BE2 2
The evidence for the additional 700k sq mtrs is that there are currently two planning applications equating to this total. Our summation is therefore that the proposal is purely opportunistic / tactical hence not strategic or focused on employment needs in the area.

It is our representation that the proposal to expand Magana Park by 700,000 square metres (over and above that recently approved ) is unsound because of the following:
Key Issue 3 asserts that the local plan should:
"contributing significantly to wider sub-regional land requirements for road based strategic distribution business space"
There is already a huge warehousing development ( rail served which is clearly more environmentally friendly) only a few miles South on the A5 at DIRFT as well as another huge rail served development near East Midlands Airport. We also understand there are plans for another substantial warehouse at the A5 / M69 junctions. Again, are we not looking at a the potential of vast tracts of productive land being covered in warehouses that are not required here?

The NPPF states there is a preference for rail served warehousing locations. Magna Park clearly is not and never will be but only a few miles south on the A5 DIRFT is.
The evidence for the additional 700k sq mtrs is that there are currently two planning applications equating to this total. Our summation is therefore that the proposal is purely opportunistic / tactical hence not strategic or focused on employment needs in the area.

Research suggest that there is not demand for this level of road only served warehousing in the county. As its stands today, there is empty warehouse space in Magna Park so such a development could lead to even more unused space.

The result would be the destruction of farmland, countryside and wildlife which once developed will never come back again

Infrastructure will not support increase in traffic.
Air pollution already one of the highest in the country - any increase will lead to increased respiratory problems particularly for the elderly and children.
Loss of wildlife and recreation space.

The fact that there are already applications for this amount of additional warehousing suggests a political decision.
There have previously been suggestions that this would lead to an over supply.
Unemployment is low in the Lutterworth area so increased numbers of commuters from outside will add to the congestion on the roads. New jobs are also unlikely to offer a variety of skill-based roles.

Why is no green area of separation proposed between Magna Park and Ullesthorpe?

CPRE Leicestershire thinks that the evidence for 7,000 sq m conveniently concurs with the two outstanding planning applications for this area of warehousing. We believe that this proposal is opportunistic and not strategic.
Reports (the LLEP SDSS, 2017) indicate that there is less demand than in this HDC policy. Putting a huge area of warehousing at Magna Park, in an area of low unemployment would be disadvantageous when it could be developed in other areas of the county that have already developed this specialism and have higher unemployment.

This planning application is not strategic, a planning application has been made for a 700,000 sq m and this figure has been used co-incidentally in the local plan. There is no evidence that this area is needed, warehousing is frequently advertised as available in Magna Park. There is no business advantage in grouping such a large number of distribution centres on one site and, in terms of employees, distributing the warehouses across a larger area would result in shorter commutes to work and hence less pollution.

The argument put forward to support provision of an additional 700,000spm of warehousing floorspace is based on a flawed analysis of the available data.

The LLSDS update and refresh of outputs and conclusions (Sept 2017) presents, in Table 2.4, a forecast shortfall in warehousing at non-rail served sites of -5ha in 2020, -48ha in 2031 and -95ha in 2036. However, these apparent shortfalls do not take into account the additional 21.9ha already granted permission at Mere Lane for IDI Gazeley (albeit this is acknowledged in a footnote). Accounting for this additional 21.9ha means that there will be a surplus of provision in 2020 and the projected shortfall for 2031 reduces to only -26.1ha. Why this simple update of the figures was not made at the time of producing this document is difficult to fathom ...

Furthermore, these projections seem to be based on an assumption of "high" demand. Why is this the case and why hasn't a best-estimate assumption been adopted. Please re-present the figures based on a best-estimate assumption and I would also advise an additional factoring-down in order to account for the recessionary pressures likely to result from Brexit (BoE and IMF projections are available).

Also, I would suggest that any prediction out to 2036 is fanciful, and is considered highly unreliable. However, even based on these upper-bound predictions there is no case to support two new developments at Magna Park as this would give rise to a substantial surplus of provision of over 40ha.

I find it incredulous that, in terms of Magna Park, the Local Plan merely re-presents the two pending planning applications. This is lazy and unthinking and represents an incredible turn-around from the previous (and still relatively recent) local plan, which said that development at Magna Park should remain within the boundary of the original airfield site. Also, at previous public planning exhibitions HDC planners have said to me that both developments would not be allowed to go ahead; and yet both are now included in the proposed plan. Why is the local plan so at odds with the wishes of local people and existing local businesses?

No amount of "mitigation" can ever offset the harm that will be done to the environment and to the lives of local people if this plan goes ahead.