BE2 clause 2

The proposal is for a virtual doubling of Magna Park but:
1 there is no evidence of demand for more warehousing capacity in the area
2 unemployment in the Lutterworth area is very low so the 10,000 jobs[an estimate I have heard ]would mainly have to be filled by people from other areas.
3This wd have a massive impact on amount of traffic around Lutterworth..

The two planning applications already submitted indicates a strong possibility that warehouse space may be left empty, as is it is currently on the existing site where I walk every week. There are currently unfilled vacancies. The case for further jobs is not true.

I do not believe that there is a need for 700 000sq m of additional distribution allocation when the Core Strategy proposed no increase. This is too great an increase.

Not justified
- appears opportunistic as Developers have outstandinding applications for a total of 700,000 sq mts, impossible not to note that the sizes are identical and fulfill what the Developers want/expect from HDC
-recent reports express extreme concerns over growing air pollution and it's effect on health, so emphasis should be on rail served warehousing
-original draft local plan did not suggest this amount of warehousing at Magna Park, this is a recent change and so a huge change to local expectations
-unemployment is very low in the area,, 10,000 low skilled, low paid and often temporary jobs are not needed and so cannot justify development.
-inevitably there would be a huge increase in traffic, both HGV and cars adding to existing traffic misery. The A5 is known to be inadequate and Lutterworth suffers congestion and villages rat runs
-there are many competing warehouses in close proximity, Rugby Gateway, DIRFT etc, they already experience recruitment difficulties and so workers would be needed from even greater distances, so more pollution and congestion
-HDC should be planning for more high skilled, high paid employment for future generations in LE17 , offering apprenticeships, development not just bottom of the ladder jobs.
-we all know new housing is needed but few employees at Magna Park will be able to afford any properties in and around the area, so more commuting
-there is no mention a green space between Magna Park and Ullesthorpe so no protection of the village
- the impact of 24 hour operations will bring misery, noise, air pollution and affect human life and well being
-loss of valuable agricultural land
- a threat to wildlife habitat
-local residents views should be respected

This will lead to over supply of land for warehouses. There are already empty warehouses on magna park that can not be filled without additional warehouses being added.
Will increase traffic in and around surrounding area. The A5 is already inadequate without the addition of more lorries and commenters.

Not consistent with National Policy:
-Non railhead location makes the site unsuitable due to impact upon local infrastructure and increased CO2 and NOx emissions as outlined in the Climate Change Act (2008).

Not prepared or justified:
-The proposal has outlined the development of warehousing in an area which is not beneficial to the county as a whole as LLEP SDSS 2017 has indicated that there is less demand for non railhead served warehousing.
-There are already two outstanding planning applications for the site and others within a 10 mile radius (albeit in another county) providing concern the application is opportunistic, not strategic.
-There is low unemployment in the area (ONS 2017 <2%) whereas other areas in Leicestershire would benefit from the warehousing more i employment terms. Coupled with DIRFT expansion employers may struggle to fill employment roles locally.
-In commuting from wider areas would add further pressure on inadequate infrastructure and increase emissions contrary to guidance given in the Clean Air Strategy 2015.
-60% of people employed at Magna Park currently are from outside areas. This will not change and no discussion is evidenced in the policy on how employers will benefit already low local unemployment.
-The A5 is already inadequate as recognised in the Midlands Connect strategy and no plans for improvement have been outlined in the strategy period.
-There is potentially an over supply of warehousing in the area due to developments further down the A5 at DIRFT and surrounding.
The plan outlines the need to green belt between Magna Park, Bitteswell and Lutterworth but not for Ullesthorpe and Cotesbatch and Magna Park whck are Geographically closer!

In summary we 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 our 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.
* 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.
* It will have an unacceptable impact on the environment and the landscape.
* It will contribute to the poor air quality in the area.
* It is likely to lead to an oversupply of warehousing/distribution land.

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.

Summary

* It is not rail served.
* There is no provision to improve the road network in the surrounding area.
* It will have an unacceptable impact on the environment and the landscape.
* It will contribute to the poor air quality in the area.
* It is likely to lead to an oversupply of warehousing/distribution land.


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

We note with great concerns
That as Magna park has expanded from site to near full capacity
The units thereon have been built and some now reach capacity & look for more space ,the traffic volumes large and small , trucks vans and cars . the legal A5 speeds have increased for hgvs which means that at our pinch point of single carriage way it's is nearly impossible to safely exit from our village onto the a5 at shift Change or Rush hour periods ..

Future plans if granted would increase volume & exarcerpate the issue , of safe access to our homes and businesses.

Increases in construction followed by employment and logistics traffic arise from granting expansion units permission, would obviously make the roads more dangerous and risk our Families and visitors safely even more . .

1. New warehouses not needed already many empty ones
2. Why use good farmland when there are brownfield sites available..
3 Already clogged roads A5 not wide enough for lorries
4 IS the UK able to be self sufficient in future with food production if all the farmland is built upon??

The local infrastructure of roads and community services such as schools & doctors cannot support a development of this size. Air and light pollution will damage the local environment.

Not justified
- appears opportunistic as Developers have outstandinding applications for
a total of 700,000 sq mts, impossible not to note that the sizes are
identical and fulfill what the Developers want/expect from HDC
-recent reports express extreme concerns over growing air pollution and
it's effect on health, so emphasis should be on rail served warehousing
-original draft local plan did not suggest this amount of warehousing at
Magna Park, this is a recent change and so a huge change to local
expectations
-unemployment is very low in the area,, 10,000 low skilled, low paid and
often temporary jobs are not needed and so cannot justify development.
-inevitably there would be a huge increase in traffic, both HGV and cars
adding to existing traffic misery. The A5 is known to be inadequate and
Lutterworth suffers congestion and villages rat runs
-there are many competing warehouses in close proximity, Rugby Gateway,
DIRFT etc, they already experience recruitment difficulties and so workers
would be needed from even greater distances, so more pollution and
congestion
-HDC should be planning for more high skilled, high paid employment for
future generations in LE17 , offering apprenticeships, development not
just bottom of the ladder jobs.
-we all know new housing is needed but few employees at Magna Park will be
able to afford any properties in and around the area, so more commuting
-there is no mention a green space between Magna Park and Ullesthorpe so no
protection of the village
- the impact of 24 hour operations will bring misery, noise, air pollution
and affect human life and well being
-loss of valuable agricultural land
- a threat to wildlife habitat
-local residents views should be respected

On the basis of the previous draft of the local plan there is no call for this amount of warehouse distribution space.
LLEP SDSS, 2017 has indicated that it may not even be required across the whole of Leicestershire ; it therefore seems unsound to place the entire requirement on the extreme of the county within close proximity to other large scale distribution schemes.

The plan aims to increase the diversity of skilled employment opportunities. This development would only restrict further the variety of jobs available within the area. The number of high skilled jobs created by the plan would be very small

This development is not condusive to the local environment. It will adversely affect road traffic and air quality. It will not have any impact on job requirements within the Lutterworth and surrounding villages.

National Planning policy says that major distribution sites should be located with access to Rail freight points such as DIRFT.
The development plans to provide a lorry depot to shuttle containers between Magna Park and DIRFT. This is patently paying lip service to the national plan when there is already adequate distribution at the DIRFT railhead.

I feel that such a large development will result in a substantial reduction of quality of life for those who have decided to buy a home and live in the surrounding area.

I consider the argument put forward by those who propose this development to be inaccurate and untruthful.

This is another one of those developments designed to put more money into the pockets of already inconsiderate persons.

Magma Park is already too big, we do not need this as we have Re lately low unemployment, an increase again on traffic and pollution including light pollution.

Magna Park is big enough. The road infrastructure is already overloaded. The resulting air quality locally is a danger to residents health. Surrounding Towns and villages are already suffering the impact of the current development. Surrounding countryside should be preserved not covered under tonnes of concrete and tarmac which would increase flood risk again impacting on local residents while profiting big business. You must know this is wrong, please do the right thing and stop this nonsense

An additional 700,000 sale metres is a major unsubstantiated increase from the previous limit of 400,000 sq metres.

Such a large development at this non rail serviced location would adversely affect the nearby Daventry Rail Freight Terminal.

It would also significantly increase HGV and other traffic on the A5 , particularly at the Gibbet roundabout and on the A426 to & from the M6 junction 1.

700,000 sq mts is opportunist not strategic
▪ It will lead to an over supply of land for warehousing
▪ It will not meet the employment needs of Harborough residents as outlined in Key Issue 3
e.g. greater breadth of employment alternatives, increased wage rates, opportunities for
higher skilled residents
▪ Will increase in-commuting and not reduce out-commuting
▪ Not on a railhead
▪ No adequate highway infrastructure and non planned before 2030.

Will adversely effect local residents quality of life

700,000 sq mts is opportunist not strategic
▪ It will lead to an over supply of land for warehousing
▪ It will not meet the employment needs of Harborough residents as outlined in Key Issue 3
e.g. greater breadth of employment alternatives, increased wage rates, opportunities for
higher skilled residents
▪ Will increase in-commuting and not reduce out-commuting
▪ Not on a railhead
▪ No adequate highway infrastructure and non planned before 2030

Will disrupt local community- already to large a development- Traffic disruption and a blight on the rural landscape. Light pollution. No benefit to local community.

Exponential increase in traffic already causing problems for the population, any further increase would stretch the present road system to beyond breaking point. With government cutbacks, the likelyhood of Highways England being able to fund the enormous amount of work required is NIL in my opinion.

There is no need to increase employment. All that will happen is an increase in traffic, pollution, congestion etc as workers will need to be shipped in or they will need extra affordable housing.
I don't know whether the plan is legally compliant as I am not a lawyer but I can only submit if I say it is so I have ticked yes.

No increase in Magna Park and changing unusable buildings into ones that are appropriate for this day and age.
It will increase traffic and pollution. There is low unemployment so instead people will be transported in.
Noise pollution will increase.
Buildings that are not fit for purpose need to be knocked down and rebuilt appropriately instead of using green or farm land.
I don't know whether the plan is legally compliant as I am not a lawyer but I can only submit if I say it is so I have ticked yes.

Not justified
- Magna park is not full currently. Why do we think any more warehousing is required?
- Is it just coincidence that the Developers outstanding applications are exactly the same as whats included in the HDC? I don't think so
- additional warehousing (IF required) would be better placed in around railway accessed warehousing, reducing air and light pollution
- the additional plan did not include this amount of additional warehousing and is a massive change to what I expected as a local resident
- we live in a virtually nil unemployment area. 10,000 low skilled, low paid and
often temporary jobs are not needed and so cannot justify development. People will have to travel into the area creating a lot of additional pressure on already overloaded roads. There is no rail link and bus routes are few and far between.
- the A5 is notorious as rammed with traffic in this area and this expansion would only lead to an increase. Local villages often act as rat runs for cars and HGV's alike; this would only get worse
-Rugby Gateway,DIRFT etc, offer competing warehousing in local proximity. They often experience recruitment difficulties and so workers would be needed from even greater distances, so more pollution and congestion
- few employees at Magna Park will be able to afford any properties in and around the area, so more commuting will occur
-where will Ullesthorpe village start and Magna park end; there is no mention a green space between them. Where is the protection for our village?
-loss of valuable agricultural land
- a massive threat to wildlife habitat
-local residents views should be respected

The previous core strategy established in conjunction with residents defined that no further expansion of Magna Park would be allowed. It also stated that there were adequate alternate sites available within the district for future development.
Additionally two major developers have submitted planning application for the 700,000 sq m refered so this clause solely seeks to satisfy the wishes of the developers contrary to current policy and the wishes of most residents

The Core Stratergy, which is still a legal document, stated that there would be no expansion of Magna Park unless a railhead was provided. This new proposal makes no provision for a railhead. It also seems strange that the proposal of 700,000 sq m is the same total as the 2 proposed planning applications lodged with HDC. This smacks of coercion and coruption between the applicants and HDC.
There is already massive expansion of warehouse distribution sites at Dirft, Rugby, Hinckley and the East Midlands. Why do we need more in this area.

Research reports used to prepare the Local Plan show that 700,000 sq mts of non-rail warehousing at Magna Park would result in an over supply of warehouse space in Leicestershire - not just in Harborough District. When we (the public) were last consulted on the possible expansion of Magna Park in 2015 three options were proposed: Option A to provide land for 15/00919/FUL: Option B to provide an addition to A land for 15/00865/OUT: Option C to provide land for 15/01531/OUT in addition to Option B. Planning permission has already been granted for 15/00919/FUL (Option A) despite opposition expressed in the consultation process and by nearly 1,000 residents during the planning process. In granting the planning permission the Core Strategy was over-ruled by the Planning Committee - Core Strategy stated that there should be no increase in the footprint at Magna Park. In the 2015 consultation process it was stated that Option C ...... "would exceed significantly the undersupply of non-rail strategic distribution land set out in the Leicester and Leicestershire Strategic distribution Sector Study (2014) for the whole of Leicester and Leicestershire, and would potentially be contrary to its recommended strategy of providing a range and choice of sites" Since 2015 there have been planning approvals for non-rail warehouse sites in and around south Leicestershire that exceed the stated need. The decision to put 700,000 sq mts into the Local Plan was made at the very last minute and appears to be favouring the demands of the developers rather than considering the needs of local residents. This development will not achieve the objectives of the local plan:
- to bring a wide range of local skilled jobs (the jobs in warehousing cover a narrow range of skills and many are low/unskilled and have proved difficult to fill - people being drawn from a wide area across the UK and Europe),
- to reduce out-commuting (there are constantly vacancies at MP which cannot be filled. If out commuters wanted this type of job they would already have applied for them),
- more opportunities for higher skilled residents (there will be a limited number of skilled jobs created at Magna Park - as there are at present)
Allowing 700,000 sq mts of development at MP will not support the objectives of the Local Plan and will bring loss of countryside, reduced biodiversity, increased air pollution, further traffic congestion on roads that government already admits are not fit for purpose.
There are other more suitable sites for this warehousing including at DIRFT (A5/Jn18) which is on a rail head - thus complying with the governments desire for these developments to be on rail rather than road.

The only case that has been made for including 700,000 sq mts of warehouse land in the Local Plan is that there are outstanding planning applications for this amount of land. This figure was added to the Local Plan only weeks before the final draft went out to public consultation. To this date there had been no evidence that this area of land was required - quite the contrary - in the previous consultation in 2015 it was stated that this level of supply &quot;would exceed significantly the undersupply of non-rail strategic distribution land set outing the Leicester and Leicestershire Strategic Distribution Sector Study (2014). Since the last consultation there have been a number of successful planning applications for land which about equals the current proposal for Magna Park. In addition there are other large scale applications for expansion at DIRFT and Sapcote - both of which are/will be on rail-heads (NPPF states a preference for this type of development).
The logic for expansion at MP is that developers own land there, the existing infrastructure and its position in the golden triangle. For local business and residents there is no logic - expansion will create more traffic congestion, local businesses will struggle even more to recruit locally (already a major concern for some employers e.g. care sector) and the type of job we would like to work in will not be created (otherwise we would already be working at MP as they struggle to recruit at the present time). Even the consultants who produced the various reports stated that the decision as to how much warehouse land to put into the Local Plan was a &quot;political&quot; decision.

The focus on employment in the warehouse/distribution sector does not achieve the vision of a diverse and thriving economy. Most people will commute in and the businesses at MP contribute little to the other businesses in the area, and specifically they take employees away from other organisations e.g. care sector.

Key issue 3 in the Local Plan states that the plan will:

- reduce the dependence of Harborough's residents on out commuting and increasing wage rates by providing a breadth of employment alternatives, including more opportunities for Harborough's higher skilled residents..

The major focus of the employment section of the plan is on warehouse/distribution employment. There is already a large dependence on this type of employment in the district and this will be increased if this plan is implemented. Thus over the district the breadth of employment alternatives will have been reduced - and there will be a greater concentration of lower paid jobs. If HD residents were interested in the type of job that will be created they would already work at MP as they are constantly struggling to find suitable employees. The vast majority of current employees at MP are from outside the district and most are from outside Leicestershire and many from outside the UK. Higher skilled workers will continue to commute because the type of work they are experienced at will not be available in numbers by expanding MP.

Key issue 4 states:
Restricting inappropriate development in the countryside whilst promoting rural diversification.

The current MP was welcomed by many residents as it brought employment to an area with very high unemployment and it renovated a derelict site. However any further development will take place farmland and will come up to Ullesthorpe, changing the very nature of the village. This is further concentration not diversification and will change the environment of the village for the worst e.g. traffic, pollution, loss of social amenity, loss of biodiversity etc.

Key issue 5:

addressing the biodiversity deficit in the district through provision of multifunctional space that includes a range of habitats ....

The expansion of MP will take place on agricultural land which is also used a social space for walkers etc and which supports a range of flora and fauna. By building warehouses (even with the provision of some green space) there will be a reduction in the biodiversity and space for walkers etc. Walking alongside 23 meter high sheds is not what people want in their leisure time.

Employment levels in HD are very low. Currently in Lutterworth there are less than 50 people on job seekers allowance. MP employers are constantly advertising for employees and having to reach out further and further to get suitable people. The advent of BREXIT calls into question the sustainability of the current employment patterns at MP without the need to employ a further 10,000 people. At the same time there is increasing competition for employees from DIRFT, Rugby Gateway and East Midlands Gateway.

The A5 has been recognised as inadequate to cope with the current traffic flows. Although this is recognised it is unlikely that there will be any upgrading of the section between Jn2/M69 and Jn18/M1 before 2031 (see Midlands Connect Strategy 2017-2031). Developing Magna Park further will bring more HGVs and commuters onto the A5 and through our villages. Further congestion on the A5 causes losses for businesses, long journey times for commuters and higher risks in terms of accidents and pollution.

The villages around MP are already used as rat runs by employees. The volume of traffic will only increase with the risk of more accidents, pollution and congestion at shift change times.

- the Local Plan also talks about green space and proposes that green space should be preserved between MP, Bitteswell and Lutterworth. Ullesthorpe and Cotesbach also need to be preserved as rural villages and not be encroached on by further development at MP.

The Local Plan does not recognise that 100,000 sq mts of warehouse land has already been given planning permission at MP in 2016. This was fiercely opposed by residents and some local businesses and was contrary to the current Core Strategy. Businesses opposed to further development because they are finding it harder and harder to find employees to work locally because of the low unemployment and the constant demand from the current employers at MP. Prolgis have objected to further development as they believe it will lead to an oversupply of warehousing. Prologis warehouses are on a rail- head along the A5 near Jn18/M1.

HDC have dismissed consideration of other proposed sites.