BE2 clause 2

I am commenting to objecting to the increase in Magna Park. Reasons being are below

Infrastructure - The town is not cut out for an increase in this magnitude. the roads are already small and the A5 in particular is hazardous at the moment. An increase in Magna Park would only make this worse and increase over-crowding, delays getting around town and lifestyle impact. never mind the lack of shops and amenities, the area just simply wouldn't be able to cope. there is no major railway which puts all the burden on the roads which are a nightmare anyway at the moment during peak commuting times.

Jobs - With the expansion of Magna Park a big benefit is seen as there will be extra jobs available but people in Lutterworth and the surrounding villages have very low unemployment rates so this will mean people commuting from Nottingham, Birmingham, Rugby etc... which will already put the infrastructure under more strain than it already is. there are other areas of the East Midlands who would benefit from this increase and totally negates the argument put forward in favor of local jobs.

Countryside - A massive impact on the countryside, C02 emissions and noise/air/traffic pollution which is the main benefit to living in the countryside it will bring danger to wildlife, farms and the natural beauty.

Lifestyle - An estimated 10,000 extra commuters will bring unprecedented levels of traffic increase and massively decrease happiness in this area, it will lead to lower house prices with less demand.

There are many better sites around the Midlands that could cater for this expansion rather than disrupt so many villages.

100,000 sq mts has already been approved, surely this is significant enough.

Magna Park is big enough!

Magna Park is not a sustainable location for BE2:2.
The A5 is recognised as inadequate for current traffic conditions and there is little likelihood of it being upgraded by 2013 (Midlands Connect Strategy 2017-2031). Doubling the size of MP alongside other developments along the A5 will lead to constant traffic jams (wasting time and money), more pollution and accidents. Building on a rail-head would partly resolve this issue.

Local villages are already used as rat runs and will be made worse by further expansion - more pollution, delays, noise and accidents.

The sustainability of even the current MP must be in question because of the current lack of suitably skilled employees. With the low unemployment levels in the district and surrounding area and the advent of BREXIT the sustainability of adding another 10,000 jobs must be called into question.

Policy BE2 appears to be tailor-made for two applicants, dbSymmetry and IDI Gazeley, who each have an outline planning application awaiting determination (15/00865/OUT and 15/01531/OUT) and whose combined total floorspace is 710,634 sq.m. Having said in its Core Strategy (2011), which ruled out any further expansion of Magna Park, that "there are more suitable sites (both rail and non rail-linked) than Magna Park within the the region and sub-region to meet forecast need for strategic distribution to 2026" (para. 5.74) HDC does not now say that this is no longer the case.

My own internet search, conducted in October 2017, of approvals of applications to build strategic ( 9,000 + sq.m.) warehousing/distribution centres within Leicester and Leicestershire, both full and outline, since the LLEP SDSS reports of 2014 and 2016 (also known as the MDS Transmodal studies), reveal upwards of 570,000 sq. m. of approvals. Some of this has been speculative and is currently advertised. The Local Plan ignores the AECOM Sustainability Appraisal (September 2017 on-line version) which states (para.19.5.2) that "Completions and commitments in the district and across the HMA are sufficient to meet mimimum need without selecting a site for allocation." The same paragraph continues "A criteria based policy is favoured to guide future growth above the minimum to avoid prejudicing the treatment of pending applications....." The two applications referred to were submitted before work on drafting the local plan was started, in the full knowledge that the council's Core Strategy ruled out further expansion at Magna Park. It was opportunistic and intended to take advantage of the NPPF before any new local plan was in force.

My survey of recent completions also showed up 14,719 sq.m. at Rugby Central currently vacant and being advertised while at Rugby Gateway 161,972 sq.m. has been completed since late 2014 (a 16,722 sq.m. unit is still unlet). Both these sites, adjoining junction 1 of the M6, are less than 6 miles from Magna Park and are also within the so-called 'golden triangle'. Harborough DC should be taking into account the wider availability of sites outside the district but close to it. In addition to these recent developments, Rugby Borough Council, in its draft local plan submitted for examination, allows for 180,000 sq.m. of warehousing/distribution space on a site adjoining the M45/A45 junction just outside Rugby.

Claims that policy B2 would bring much need employment to the district and 'out-commuting' will be dealt with elsewhere in my responses.

I strongly object to this proposal.

The resulting increase in traffic volume on the A5 would be unsustainable.

The A5 is already heavily congested particularly at peak times. Queues are the norm.

The increase in both air and light pollution is not acceptable.

The loss of vast areas of open countryside and farmland with the resulting loss of wild life
habitat cannot be tolerated.

In reality such developments create only relatively low numbers of poor quality jobs.

The negatives far outweigh any positive gains.

b. Provision of strategic distribution facilities.
There is generous available provision, with rail, M1 and A5 connections, at DIRFT, only 5 miles away. Additionally, provision is being provided at junction 1 of the the M6, 3 miles away.

e. The above will add considerable traffic to the same road network as any addition to Magna Park. Without these additions yet being on stream, there are already tailbacks and hold-ups, particularly on the M6-A5 link road (A426.

f. The extension of Magna Park will be extremely detrimental to the environment adjacent to the village of Ullesthorpe, both visually and practically.

There is confusion as to 700,000 sq. m. Does this include the two planning applications currently lodged with HDC.If it does it is supported. However if the 700k an addition to those two applications it is not acceptable. The local area is already subject to excess of heavy & light vehicle traffic both on larger roads as we3ll as B class roads (rat-runs). Additional traffic will bring the roads in the area to 'grid lock'. At certain times of the day The Whittle roundabout on the A4303/A426 is 'grid-locked' now.

The Council has asserted that there are more suitable sites elsewhere in the County. It has ignored recent completions and commitments which meet minimum forecasts of need, as pointed out in the recent Sustainability Appraisal.

Contrary to Key Objective 3 as it will not provide higher skill employment opportunities. Contrary to Objective 2 and Policy BE2.2 as it will not create new jobs that meet local employment needs. Unemployment in the Harborough District is negligible. 60% of the Magna Park workforce already travels from outside the district. Substantial increase in commuting, further pressure on the area particularly on already overcrowded local roads/rat runs through villages. No adequate highway infrastructure. Not consistent with National Planning Framework with regard to rail freight access. Deprives other areas of Leicestershire of potential employment opportunities.

There should be no further development of warehousing for storage and distribution in this area. The proposed expansion is too large, exceeds all estimates of need (LLSDSS study) and there are many other sites needing local employment in other areas of Leics. It will add substantial traffic to already congested roads. Clearly the proposal is made solely in response to developers' pending planning applications and it seem that approval will inevitably follow without testing by representations from local residents.

There are currently two outstanding planning applications for warehousing in this area, which leads me to believe that this proposal is not based on any strategic plan but one of opportunity. This further leads me to believe that the focus of this proposal is not to meet the employment needs of the area.

All the research I have gathered (LLEP SDSS, 2017) shows there is less demand in this area for non-rail warehousing which indicates that this location would lead to an over supply of warehousing.

Also placing such a huge area of warehousing in this location would deprive other areas in Leicestershire of employment opportunity and seems much more political than it would be benficial to the area, therefore I don't believe these pans are justified.

Currently Magna Park have a lot of recruitment issues due to competition from DIRFT, Rugby and the East Midlands. As there is low unemployment in the area I don't see how the development would benfit the area and the additional workforce needed would need to communte from outside of the council district even with any new housing developments built. This increased communting will put pressure on an already inadequate A5 which has already been recognised in the Midlands Connect Strategy 2017-2030 but with no plan for any major upgrades.

No where in the plan have I found that there will be a preservation of green land between Magna Park and Ullesthorpe, which deeply concerns me to the plan ineffectiveness.

There is not any justification for the 700,000 sq m of development other than it is approximately what the two interested developers have applied for. The L&L SSSD suggests that this would provide an OVERSUPPLY of non-railserved warehousing for all of Leicestershire beyond 2031, therefore restricting development elsewhere in the county, and appears to be an entirely opportunistic inclusion in the Local Plan.

Low unemployment locally would mean more in-commuting as most MP workers already live outside the district, with an attendant increase in traffic and pollution. Development beside a scheduled momunment is not safeguarding our historic heritage.

I object to both the expansion of the existing Magna Park site and also to the approval of warehousing for storage and distribution on any other nearby land, in close proximity and acccessing the same local roads (A5, A426, A4303)
This is unsustainable development in relation to generation of vehicular traffic and also adverse effects on the open, rural character of the local landscape. It has adverse effects on residents' access to amenities and facilities, will pass on a deterioration of the environment to the next generation and therefore is in conflict with the NPPF.

There is little need to destroy the beautiful landscape as the area does not have an low unemployment rate. I am also led to believe that Magna park, it currently does not have a full capacity of employment, therefore extending is pointless.
The increase of traffic not only due to building but also more commuters would affect my business as I drive around the area and cannot afford any further delays, I already get delays around the A5. yet there are no plans to improve this.
There is no green mention of preserving green space where i live.

The 700000 sq m is solely the amount being requested by developers per recent planning applications and the planning policy should not be adjusted to suit developers.
Furthermore the current structure plan clearly states no further expansion of Magna Park and that there are adequate other suitable sites within the district.
Further expansion will severley increase traffic and pollution and already the A5 is almost impossible or too dangerous to cross due to high speed dense traffic

The proposal has not been positively prepared for the following reasons:

This proposal is not strategic, but opportunist and is not focused on supporting the employment needs of the the district. This is evidenced by the fact that there are two outstanding planning applications for warehousing there.

The report LLEP SDSS, 2017 has identified that there is less demand for this area of non-rail connected warehousing across Leicestershire. This should not therefore be focused on one single sire, but spread across Leicestershire.

The proposal is not justified:
There are very low levels of unemployment in Harborough District and particularly in Lutterworth, less than 2%. There is already competition from the other local distribution centres at DIRFT, Rugby and East Midlands to name a few. Therefore the addition of 10,000 of the same type of jobs will have very little impact on an already very low employment rate. The job types are low skilled and will requires a substantial increase in commuting for areas well outside the district, with significant increases in traffic a to fulfil the jobs. This goes directly against one of the plan goals to reduce out-commuting.

The increase in commuter traffic and lorry movements will be on roads that are not suitable. The inadequacy of the A5 is recognised on the Midlands Connect Strategy 2017 - 2030. This local plan strategy does not envisage a need to upgrade the A5 around Magna Park, going against the report referenced above.

The strategy is not consistent with the national plan, which states that preference should be given to warehouse and distribution sites that have access to rail freight terminals. Magna Park has no direct access to a rail head, whereas other local sites such as DIRFT does.

I am given to understand that the Core Strategy states that there would be no further development of Magna Park without the provision of a railhead. There are no plans for such a railhead.

Magna Park is already huge, it is dwarfing the surrounding villages and making travel and quality of life a misery.

What a co-incidence that the propopsal for 700,000 sq metres is the same as that required to complete the two proposed planning applications that have already been lodged with HDC!

Magna Park is big enough. The lorries and private cars clog the road network and pollute the environment, and the number of road accidents is unacceptable.

The evidence for the need of 700,000 sq mts of warehouse/distribution land at Magna Park is based on the two outstanding planning applications to build around this area. The purpose of the Local Plan is to provide appropriate employment for local residents and the expansion of Magna Park will not do this. In fact it will do the reverse - it will provide more employment for people outside Harborough District and Leicestershire and therefore increase traffic congestion and increase prosperity elsewhere.

It will not contribute to the vision of "a diverse and thriving economy". Again it will do the opposite by bringing a greater concentration of low/unskilled, mainly low paid and insecure, jobs to the area. This again contradicts the objective in the LP of providing a breadth of employment alternatives.

The LP states that it will reduce out commuting - but if people in HD wanted the type of job that will be created at MP they would already have taken them up at the existing MP which continually struggles to recruit staff.

The distribution sector employs a limited number of people with high skill levels. The expanded Magna Park will be partly managed by managers at the existing site and so the number of high skilled employees required will be limited. Again this does not contribute to achieving "more opportunities for higher skilled residents".

The Lutterworth area has very low unemployment - less than 50 people on JSA when last checked. The vast majority of employees at MP are from outside the Lutterworth area (and outside HD and Leicestershire) with a high percentage of people from the EU. The advent of BREXIT calls into question the ability of employers at MP to recruit to the 10,000 jobs that will be created by the expansion.

There is therefore a non-alignment between the purpose of the Local Plan and the inclusion of 700,000 sq mts of expansion at Magna Park.

Local residents have continued to express their concerns about the inappropriate plans for expanding Magna Park. They did this in the LP consultation process in 2015 and also during planning application processes for the three applications from IDI Gazeley and dbSymmetry.

There are long lists of reasons why these applications are inappropriate - lack of appropriate highway infrastructure, loss of countryside and biodiversity, increased pollution, impact on heritage site etc

However the inclusion of the 700,000 sq mts expansion at MP in the LP calls into question the purpose of the Local Plan. BE2;2 is under the heading of Employment.

It is true that the expansion will bring 10,000 new jobs. However the Lutterworth and wider HD area has very limited unemployment and one of the main issues in the area is the lack of higher skilled jobs. The lack of suitable jobs in the area means that residents commute out to find jobs that suit their skills and aspirations. If people wanted jobs at MP they would already be working there as employers at MP are constantly struggling to recruit staff. The majority of employees at the current MP site are from outside HD and Leicestershire, a very high percentage coming from the EU. The question needs to be asked about where the 10,000 new employees will come from.

The LP seeks to address the community in and commuting out issues but will in fact make things worse not better.

Having more employment in warehouse/distribution will lead to a greater concentration of the same type of job rather than expand the range of skills and working opportunities.

BE2:2 needs serious reconsideration if it is to achieve the objectives of the LP and meet the needs of local residents.

My response below is organised according to the required criteria, but first I would like to comment on the undemocratic nature of this Local Plan consultation:
1. While I accept it has to address complex issues, it requires completion of a vastly over-complicated form and process which local people are in many cases struggling to respond to. Thus the decision-making reverts to a mystifying process conducted by a select few who are 'in the know' where it is very difficult for those most affected to interrogate and influence the decisions made.
2. The Department for Communities and Local Government states that the Local Plan should a)'set out a vision and a framework for the future development of the area' and b) provide 'a critical tool in guiding decisions about individual development proposals, as Local Plans ..... are the starting-point for considering whether applications can be approved' (my italics). Alarmingly, the cart seems to have been put before the horse: local district councillors will be expected to make a decision on the 700,000 square feet of new strategic distribution space in the Magna Park area very shortly after the Local Plan public consultation period ends. This would be before the Inspector can adjudicate on whether the proposals are even sound/appropriate as part of the Local Plan. This makes a mockery of HDC's Statement of Community Involvement.

I do not think that the proposal to expand Magna Park by 700,000 square feet is sound for the following reasons:

It is not positively prepared:
See my comment at 2 above. Additionally, the 700,000 sq ft significantly exceeds the requirement for non-rail warehousing for the whole of Leicestershire, (without taking into consideration the large amount available nearby along the A5 corridor), and does not therefore represent a strategic response to employment need.

It is not justified:
The strategy of concentrating so much Strategic Distribution resource in this one area seems misguided from various points of view:
a) there are very low levels of unemployment in this district, and we know that recruitment is already a problem at other distribution centres in the vicinity. As a result, this would become a highly congested hot spot, with thousands more commuters entering the area from considerable distances, in addition to the vastly increased lorry traffic.
b) the road network (in particular the A5) is not built to accommodate this traffic increase, and the Midlands Connect Strategy, which acknowledges the inadequacy of the A5, does not promise a major upgrade in the foreseeable future.
c) such a concentration of logistics-based jobs would not provide the variety needed for a thriving local economy.
All of these factors fail the condition of a Local Plan that is sustainable and appropriate.

It is not effective:
The huge increase in the size of Magna Park appears to be disproportionate and does not appear to be part of an overall regional development strategy, but smacks of being primarily a profit-driven enterprise:
a) it would create an OVER-supply of distribution jobs and sites in the vicinity,
b) it would create a severely clogged road network which would be playing catch-up for many years beyond the Local Plan period while having a hugely detrimental effect on the lives, environment and sustainability of local communities.

This proposal is opportunist and is not focused on the needs of employment in this district. There is no demand for non-rail warehousing

Providing this many acres in this location will potentially lead to over supply and not allow spread across the county

Will increase in commuting. And there is no planned highway infrastructure

* our surrounding roads and highways are already congested with vehicles coming and going from The Magna Park development,small village roads cannot cope with the extra loads there's been many a near accident.
*Noise and air pollution are a huge concern for the public living in and around Lutterworth. Magna Park extensions will only add to the already most polluted town in the country.
* This expansion isn't necessary there are much better rail and motorway links over at Rugby and Crick
Proposals concerning Magna Park represent an unacceptable intrusion into the countryside,And have a massive impact on the surrounding area.

Significant negative impact on the village of Ullesthorpe (traffic flow, noise, emmissions). The key point is that there are other options to expand the park that are less impactful on neighbouring villages/populated areas. Build to the South or Southwest of the existing park.

Magna park expansion, as there are two outstanding planning applications for warehousing in this area , I feel this is an opportunist proposal which does not meet the needs for employment in this district as unemployment is already low. Reports from the LLEP SDSS 2017 indicate that there is less demand for non - rail warehousing in this area,this should be allocated across Leicestershire. The addition of upto 10,000 jobs coming at a time of low unemployment in this area means most of the workers would be drawn from outside Harborough leading to increased traffic both from commuting and HGVS leading to future over crowding on unsuitable road structures. The plan does not give thought to local green space between ullesthorpe and Cotesbach.

Catastrophic consequences to wild life habitat - many animals including owls, and mammals are already greatly on the decrease. Newts are living in ponds in the area these are protected! There will be an even greater increase in the amount of noise and light pollution. Pollution emitted from cars/lorries will greatly spiral. The amount of building in the area will destroy the rural nature of the villages affected - with warehousing near enough being in the back garden of homes. The whole infrastructure and feel of the area will be completely destroyed and devastating for those who live their.

I wish to register my objection to the inclusion of 700,000 square feet of new warehousing space at Magna Park in the new Local Plan.
My concerns are as follows:

This proposal is not positively prepared:
The LLEP SDSS 2017 reports that this amount of non-rail distribution resources are not even required throughout the whole of Leicestershire. It would therefore be totally strategically inappropriate to locate so much warehousing at Magna Park.

This proposal is not justified:
One of the Local Plan goals is to reduce out-commuting. If there is such a high concentration of similar distribution-based jobs at Magna Park, and also such a low level of unemployment in this area, then out-commuting to access a wider range of employment opportunities is bound to increase. The proposal does nothing to enhance the economic health of this part of the district if it merely provides thousands of predominantly low-paid, low-skilled jobs filled by thousands of employees from outside the area. We need a varity ofjobs, including those which are skilled and pay higher salaries.
The knock-on effect of the above would be a rapid worsening in the congestion on the A5, which in places is already at a standstill for significant periods during peak hours. This has been acknowledged by the Midlands Connect Strategy 2017-2030. The environmental cost would be huge, given the loss of countryside, damage to small roads and villages, and pollution levels, and there are no proven economic benefits to outweigh these costs.

This proposal is not effective:
The amount of new warehousing approved in the vicinity of Magna Park in recent years (in addition to the recently approved extra 100,000 square metres next to Magna Park) will create an OVER-supply of these kinds of sites, to the severe detriment of the local economy and environment, and at no benefit to the distribution industry. Warehousing should be distributed across a wider geographical area.

* The local area has very low unemployment and the creation of new jobs will not benefit the local people. Magna park already has to recruit people from Nottingham and Leicester in order to fill the positions it has. The new development would not benefit the local people who it will effect and will not offer a breadth of employment opportunities.
* With the increased recruitment from further a field and the vastly increased number of HGV's arriving at Magna Park the local areas will not be able to cope with the traffic. The A5 is already notoriously congested and unfit for purpose, adding more cars and lorries will only compound the issues. Local village roads will become 'rat races' endangering village children and increasing levels of pollution..
* Already there are empty warehouses at the current Magna Park and also at DIRFT. I have seen no evidence of the need for these extra warehouses; especially in the very close vicinity of many other warehouses.

This is an area of low unemployment so almost all future employees will need to commute. This, with the extra traffic generated by additional businesses will increase traffic issues and already high pollution levels in this area.

I object to this plan due to the increased traffic, noise and pollution that this development would bring.
The reason given for this development is due to the demand for warehousing, if this is so, then why are new warehouses built nearly a year ago still empty??
With the development going ahead at DRIFT, where there is a rail head, this just doens't make any sense as this would more than cater for the warehousing requirement.
As this develpoment would see a large area of green field being lost, where would the crops that would have been grown there now be sited?
The impact on the water courses and wildlife would be significant, resulting in the loss of habitat.

The proposed additional development of up to 70,000 sq. metres for non rail-served strategic storage and distribution is, in my opinion, unsustainable as it will increase traffic congestion, air pollution and have a detrimental effect on the surrounding countryside. Magna Park is already a huge development and if this goes ahead, it will double in size. Surely this level of expansion is completely unnecessary as we have neither the road infrastructure to cope, nor the need in this area for the enormous number of jobs that would be created as unemployment is extremely low in the Lutterworth area.. Magna Park employers already have difficulty in recruiting.