BE2 clause 2

There is already adequate supply of warehousing in this area as can clearly be seen by the number of large warehouses to let, and other projects in progress on the A5 corridor, particularly towards DIRFT with its rail link.
This proposal will erode the green space and rights of way that Ullesthorpe enjoys.

Magna Park is already too big, extending it will cause massive traffic congestion especially on the surrounding villages whose roads are too small to accommodate large vehicles. Plus the A5 will become gridlocked with lorries. Also in line with the new government polices on Diesels, the air pollution will be massively increased affecting everyone. There is also the effect on the environment turning green fields into concrete hangers. This in turn will destroy any local wildlife and there habitats. You won't see the sky anymore also because of the light pollution.

There is no strategic justification for the figure of 700000 sq m. This is based on two current planning applications so is purely opportunistic.

Local unemployment is low and unsuited to low level manual jobs that this development will generate.

Local roads are congested. The traffic study is flawed and takes no account of the frequent lengthy queues that build up on the A486 between the M6 and A5.

The local area has enough warehousing to sustain jobs for the local population & is detrimental to creating a diverse employment structure within the area. Any expansion of Magna Park will increase traffic congestion & pollution with the additional trucks & commuter vehicles It will attract to a road structure that cannot cope at peak times. It is very clear that the council has written this plan to coincide with current planning applications & not based on what the area really needs.

I object to this for the following reasons
The Local plan for warehousing allocation is not a futuristic plan but rather a plan to looking to accommodate what is already on the table. By putting all the 700k sqm in one area of the county in one go does not allow for other potential expansion by other companies big or small in the next 25 years in and around the district.

By over concentrating the logistics and employment in one area it will harm the infrastructure which is already stretched.

This contradicts the policy which is not to lead to excessive traffic congestion anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside. By having an additional 10,000 workforce commuting in to the area this will undoubtedly lead to this negative impact occurring.
Also it will not ensure 24 hour operations do not have an unacceptable environmental, community or landscape impact in the immediate and wider surrounding area. It is already seen that in change shift times the traffic coming through villages and towns is higher than it is designed to take.
Concentrated light pollution in one area is harmful to the area
By making the plan fit the current figures for the current applications and therefore using all allocated space the lack of use of brown field sites is harmful to the area over the long term.

This proposal is based on very flawed evidence. There is no evidence that Magna Park requires additional warehousing. Vast areas of land are being converted at the former Rugby Wireless Station site and there is more than enough capacity for further growth at the DIRFT site. Both of which are closer to motorway access and Rail Freight access affording easier lorry access. Proposals to build a further 700,000 sq metres on a site that is only accessible from the already overused A5 road can only be seen as speculative and has no relationship to real warehousing requirement

It is not positively prepared to allocate B8 based on exactly the same floorspace as two outstanding planning applications

The additional development is unsustainable and will cause a serious impact on traffic congestion, air pollution and damage the countryside.

This will be more than double the size of the current site. This is not required.

This proposal will cause a serious impact on traffic congestion and air pollution in the small village of Ullesthorpe. The village does not have the infrastructure, services or facilities to cope with the level of proposed development. The proposal will significantly impact lifestyle and will completely destroy the rural character of the environment.

Monks Kirby parish council represents an area adjacent to the proposed expansion of Magna Park, to the west within Warwickshire.
The Councils concerns are the affect on the local infrastructure and in particular the A5.
The A5 at present is overcrowded and no plans are in place to upgrade. This is recognised by the Midlands Connect Strategy 2017 - 2030. Any further expansion will exacerbate the issue. MK will suffer unduly as if the main trunk route becomes congested the more minor routes through our Parish, unsuited to greater traffic flows, will be overused by both HGVs and staff commuting.

We have enough ware house space in this area and your own local plan states we should have less ware house space not more.

Currently small rural communities co exist with the expansion of Magna Business Park and Lutterworth. However I feel quite simply the site is big enough, and that we have had our share of development. By eating further into the countryside adjacent to Ullesthorpe, Bitteswell and Lutterworth will inevitably destroy the natural hinterland/ boundary between industry and rural living. The effects on the environment will change the area for good, having a very detrimental effect on public health, both physically and mentally. Any economic benefits for the area are very short term and of minimal impact for the local community.

I object to the proposal on the following grounds:employment in the local area is already at optimum levels and an increase in warehousing and therefore employment requirements can only be met from a population outside of the area. This then in turn will put an increase on the housing market which is already over subscribed and can only put undue pressure on the traffic in the area, particularly that on the A5 which is already operating at maximum often very dangerous conditions which can only be made much worse by this proposal.

There is not demand for this amount of non- rail warehousing, as shown by research (LLEP SDSS 2017).
Bringing 10,000 largely low- skilled jobs to an area with an unemployment rate of less than 2%, where already 60% of staff travel from outside the area, is not good planning. The local roads are already congested, the A5 is known to be inadequate and pollution levels in Lutterworth are very high.
There is insufficient safeguarding of local countryside eg no green barrier for Ullesthorpe & Cotesbach.
Not in keeping with national plan as not near rail.

There is not the need for the amount of warehousing proposed
The Lutterworth area has a very low employment rate so workers would have to travel from afar
There would be a huge increase in the amount of traffic in an already congested area
The extremely congested A5 road would not cope
Surrounding villages would have increased traffic at change over times from workers commuting
There would be greatly increased pollution in an area of residential housing and several schools
An increased development at Magna Park would deprive other areas of Leicestershire with greater needs including high employment from developments

I object strongly to the proposed plan for the extension of magna park. As a resident of claybrooke magna i will see increases levels of traffic not only through thr village but on the already busy A5. This will lead to high levels of pollution and huge losses to the wildlife in tne area.
I chose to live in Claybrooke because of its rural and peaceful location, this will all be ruined by expanding Magna Park and making the whole area look like a giagantic distribution centre with lorries everywhere!

I support this statement but ask why this does not apply to the agricultural land at Bittesby? This is productive land and the above statement should be applied and not ignored just to suit greedy speculative development which if permitted would not bring sufficient benefit to outweigh the harm.

I support this statement but question it's true worth if the speculative Magna Park expansion of 700,000 sq Mts is allowed, clearly it would be worthless.

This proposal is not justified. It does not meet the employment needs of the district community, will negatively impact on the road systems and environment, and is a significant risk to the reputation and financial sustainability of Harborough. The proposal will not increase the diversity of employment opportunities in this area, nor will it bring employment benefits to borough residents. Significant developments within a 10-mile radius are already providing sufficient opportunities for this type / level of workforce, and there is a concern that this does not meet a market need.

The road traffic generated by such a disproportionately large extension will significantly overload the rural roads in and between the villages in the vicinity of the site. This will increase road safety dangers, air emissions, and impact on the health of those living, working, being educated and walking in those areas.

Walcote Parish Council wishes to make the following representations concerning the Harborough Local Plan.
Misterton with Walcote Parish Council is concerned that the consultation process has not been used to inform a number of policies proposed in the Harborough Local plan. This does not encourage participation, as the public has had no opportunity to express its views concerning these policies and indeed it seems that some new policies are entirely at odds with the opinions expressed in the earlier consultation.

The explanation for allowing Magan Park to expand is based on increasing employment in the district. Harborough District has very low levels of unemplyment thought and particulalry Lutterworth (less thatn 2%). Therefore this expansion will not support the local area, but will be detrimental, due to loss of countryside, significant increases in traffic, resulting in a further detrioation of air quality and safety. The plan highights infrastructure issues due to the high levels of traffic, but does not make any plan for how to alleviate this.

The Magna park jobs are low skilled and will be filled by those having to commute from outside the area. With increased level of automation even this nnumber of jobs will decrease over a relatively short time. There are already examples of automation in outer wharehouses replaces 100's of jobs and this will continue to hapen.

Planning Consultants advised HDC that the choice of how much development to allow at Magna Park was a political decision. Placing such a large area of warehousing at MP would deprive other parts of Leicestershire of the employment opportunity.

The location of the park goes against the National Planning Policy that state there is preference for access to rail fright assetts. Magna Park is now where close to a rail head, where as other sites, such as DIRFT are.

The evidence for the 700,000 sq mts is that there are two outstanding planning applications for
this area of warehousing. This indicates that the proposal is opportunist, not strategic or
focused on meeting the employment needs of the district.

This area, in particular Lutterworth, has very little unemployment. On seeing the amount of distribution warehouses that have applied for permission, surely consideration for such an expanse of warehousing should be to areas which, according to statistics, have an unemployment problem.

Therefore, at present the workers already employed by the existing warehouses in Magna Park come from other areas which then increases the road traffic. Pollution in this area is already high. Indeed an article in a newspaper this very week confirms the adverse effect to health that high pollution has on the population.

Warehouse work does of course provide positions for unskilled workers (although as pointed out no unemployment problem in this area) it does not provide any opportunity for skilled workers.I do see however that there are still warehouses to let at the Rugby Gateway Site. Are you sure that this extra warehousing is necessary?
As you are aware, the surrounding areas of Lutterworth have been designated for housing development which I believe many applications have been given the go ahead. Thus again increasing traffic to not only the A5 but roads in villages around the Magna Park area.

Daventry District Council do not consider that the approach set out in policy BE2 is effective because the level of growth identified in the policy is not based on a thorough assessment of capacity. Such an assessment should consider at least all of the factors proposed as criteria in the policy. The District Council considers further cross-boundary work with stakeholders is required to fully take into account potential impact of different growth scenarios which could in turn indicate the amount of floorspace to be provided for at Magna Park.
In addition the level of growth planned for under policy BE2 is not considered to be justified by evidence. The Leicester and Leicestershire Strategic Distribution Sector Study identified a need for non-railed served provision of 152 hectares by 2031. Policy BE2 identified a quantum of 700,000 square metres which relates to the sum total of the undetermined planning applications (approximately 427,200 and 278,709 sqm). The total quantum of land based on the supporting information for the respective planning applications equates to a total site area of approximately 327 hectares. Whilst it is evident that not all the of the land provided will be floorspace, for example infrastructure will be provided and one proposal features a country park it is still in excess of the identified need in one location and therefore not considered to be justified.

Impact on Countryside: The development would have an overbearing impact on the countryside, being an unwarranted intrusion into the pleasant Leicestershire landscape. The loss of a great swathe of open countryside would be visually detrimental, as well as having a devastating impact on wildlife and ecology. The development would be very prominent due to its mass and bulk.
Traffic: The enormous increase in the amount of traffic generated by the proposed development, in addition to the existing high volume of traffic, would have an immense impact on the surrounding area and villages. The vehicles of the employees would use the local roads through the villages, which already suffer from the amount of traffic accessing Magna Park. The increase in the number of HGVs in the area and the resulting pollution would add to the already heavily polluted atmosphere to an unacceptable degree.
Housing: The increase in the number of people employed at Magna Park, particularly those in lower paid jobs, would increase the demand for housing. There is already a lack of affordable housing for young people and those on limited incomes in the area. This development would exacerbate the shortage of such accommodation.

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 am writing to you in order to make formal representations for the Harborough Local Plan on behalf of the Harborough District Council residents in my constituency of South Leicestershire.

As a Member of Parliament for South Leicestershire, I have listened attentively to the view of my constituents on a range of matters that are outlined within this proposed Local Plan submission. As such I should like to make formal representations on the following areas:-

HOUSING
With regard to house building in the District, I do, in principle, agree with the Government's guidance that further, more expansive housing building is required across the country. This guidance is in line with national population increases as well as the large number of people either wishing to take their first step onto the housing ladder or are awaiting social or affordable housing via a local authority or housing association.

With this in mind however, I should like to see 'appropriate' house building, whereby new developments will be built in an environmentally sound manner and will be built to meet the crucial economic and domestic needs of my constituents in South Leicestershire and other residents within the District.

In addition, I have been closely following the plans for the large-scale development known locally as 'Lutterworth East' for some time. I acknowledge that while these plans have not yet been finalized, they are nevertheless are source of some concern for my constituents. Given that these are 'embryonic' plans, I am unable to commit fully until I see further detailed plans.

MAGNA PARK
In concern of the proposed expansion of Magna Park, I should like to reiterate once again my objections to these proposals as originally outlined following my election as MP in 2015. In keeping with the thoughts and concerns of many of my constituents, I believe that the proposed expansion would be counter-productive to the local area's needs and to residents in terms of pollution and congestion, where the town of Lutterworth has historically experienced detrimental issues.

In closing, I should like to sincerely thank Harborough District Council for carrying out this consultation and for giving my constituents and the other residents of the district an opportunity to have their views and opinions heard on this vitally important matter.

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.

The Local Plan is unsound for the following reasons:

Not positively prepared:

There is no rationale stated for the figure of 700,000 square metres of additional development for non rail-served strategic storage and distribution. This figure happens to be approximately the sum of the areas of the two outstanding planning applications for storage and distribution buildings adjacent to the existing Magna Park, leading to the conclusions that:
a. the figure of 700,000 square metres was adopted from current commercial planning applications, and is not based on an objective assessment of the need for such development, and
b. The additional development is intended to be located next to the existing Magna Park.

The storage and distribution warehouse area proposed in the Local Plan exceeds the forecast demand for non rail-served sites for Leicestershire presented in the technical report prepared for Harborough District Council: Leicester and Leicestershire Strategic Distribution Study: Update and Refresh of Outputs and Conclusions, September 2016.
To retain this proposed area for non rail-served storage and distribution in the Local Plan would be to ignore the objectively assessed development needs in the report, and would over-provide warehouse floorspace area. If the storage and distribution development was all located next to the existing Magna Park, it would not allow for development in other more suitable areas of Leicestershire.

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that within Leicestershire there is a more plentiful labour supply in the western and northern parts of the county rather than the more rural eastern areas such as Harborough District. These urban areas are therefore likely to be more attractive to operators.
If the proposed development of 700,000 square metres of additional development for non rail-served strategic storage and distribution is located next to the existing Magna Park, it will be contrary to this objective assessment.

The Local Plan Vision "sets out a collective positive vision for the future of the area, as required by the NPPF."
However, in relation to the policy BE2 Strategic Distribution where it is proposed that:
"Additional Development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted...", this is not a positive vision if this additional development is next to the existing Magna Park.

The Local Plan Vision claims that "Harborough District...retains its identity as a predominantly rural area of villages and market towns where local communities enjoy a high quality of life. Residents will benefit from...a wider range of skilled jobs, and high quality services and facilities, all of which promote healthy and safe lifestyles."
However, addition of new storage and distribution warehouses next to the existing Magna Park is contrary to the above vision as it would turn rural green-field land into industrial complexes, providing jobs that are the same skill types as those already offered at Magna Park, not providing a wider range of skilled jobs, so will largely not be filled by local people.

The Local Plan Vision claims that "The diversity and quality of Harborough's countryside, natural and historic environment will have improved for the benefit of residents and visitors. Air and water quality will have been improved while the impacts of noise and light pollution will have been minimised. There will be better access to the countryside and an improved range of open spaces for local people to enjoy."
However, addition of new storage and distribution warehouses next to the existing Magna Park is contrary to the above vision as it would obliterate green countryside, expanding the sprawl of the existing Magna Park and making a huge adverse impact on the landscape. Air quality would be further threatened by an associated increase in traffic, and noise and light pollution would increase. This development would remove open spaces, not provide them.

The Local Plan Vision claims that: "Low carbon design techniques and technologies, increased provision for walking and cycling, and improved access to public transport for new development will have contributed to a reduction in the District's carbon footprint."
Instead, addition of new storage and distribution warehouses next to the existing Magna Park would increase the District's carbon footprint due to the resulting increase in HGV and commuter traffic.

The Local Plan Vision claims that: "Strategic Distribution sites will have adapted to the changing needs of the sector and maintained their significance to the District and the wider area in terms of employment provision."
However, addition of new storage and distribution warehouses next to the existing Magna Park will do very little to provide employment to local people in an area where there is low unemployment, and where a variety of higher-skilled jobs is needed; instead it will result in increased in-commuting where jobs are taken by people from outside the local area.

The Local Plan Vision claims that: "Communities across the District will have embraced neighbourhood planning, affording them the opportunity to shape the future of their environment by ensuring that they have a real stake in the decision making processes that oversee what development takes place and where."
However, communities close to Magna Park have ALREADY embraced neighbourhood planning by engaging in the planning process, taking time to read planning applications and attending planning meetings; local residents have in their hundreds registered their objections to the three planning applications for huge new areas of storage and distribution warehouses on both sides of the existing Magna Park. The first planning application has been granted despite over 900 objections. Local residents need to have a REAL stake in the decision-making processes NOW so that the huge numbers of local objections to the addition of new storage and distribution warehouses next to the existing Magna Park are properly considered, and local people have a real opportunity to shape the future of their environment NOW.

Not justified:

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that most of the region's storage and distribution floor space is playing a national rather than regional role. If the proposed development of 700,000 square metres of additional development for non rail-served strategic storage and distribution is located next to the existing Magna Park it would add floorspace to this national role, and would be of no benefit to the local region.

The Midlands Connect Strategy plan, endorsed by the government, to upgrade the A5 between the A38 at Lichfield and the M1 will not be completed until 2030. Until the A5 upgrade is complete, applications for major logistics warehouses next to the A5 should be rejected. The existing road infrastructure is inadequate to support further developments such as this, and new applications should only be approved where there is a direct rail-head. It is not justified to plan the development of new storage and distribution warehouses next to the existing Magna Park until the new road infrastructure is in place.

The technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017, says that strategic logistics sites should be "located close to areas of employment need". If the proposed development of 700,000 square metres of additional warehousing floorspace is located next to the existing Magna Park this requirement would not be met as unemployment is low in the area. Storage and distribution warehouses should be located near a town or city with sufficient population density and employee availability to meet the employment needs of the businesses located there. Magna Park is too far away from such populations, so further development of storage and distribution warehouses next to the existing Magna Park will further increase in-commuting with the associated increase in traffic congestion.

Addition of storage and distribution warehouses in an area that already has a high density of such warehouses is not justified as it will have adverse impacts on the local community in terms of increased traffic congestion due to increased volumes of HGV and commuter traffic, increased vehicle exhaust pollution, and loss of natural environment where green-field countryside is destroyed.

Not effective:

One of the three large planning applications for additional warehouse development next to the existing Magna Park has recently been granted. This will provide 100,000 square metres of new floor space. Other new warehouse development applications have been granted nearby recently; another 700,000 square metres would result in an excessive over-supply of warehouse floorspace.

Appendix E of the Local Plan lists Local Plan Objectives, and shows Local Plan policies which address each objective, relevant key issues and relevant strategic priorities.
Out of the fourteen Local Plan objectives listed in Appendix E, only one objective, Objective 2 (Employment), refers to Local Plan policy BE2 Strategic Distribution, but this objective will not be addressed by granting planning permission for additional development of up to 700,000 square meters for non-rail served strategic storage and distribution next to the existing Magna Park, due to the reasons as follows:

Objective 2 includes: "Promote sustainable economic growth by facilitating the sustainable growth of businesses, fostering new local enterprise and helping to create more jobs that meet local employment needs."
However, if the additional development of storage and distribution businesses is located next to the existing Magna Park,
- this growth of businesses would not benefit the local community: Strategic Distribution businesses are nationally-oriented, so economic benefit is national not local;
- growth of these storage and distribution businesses in an area that already has a high density of such businesses will have adverse impacts on the local community in terms of increased traffic congestion due to increased volumes of HGV and commuter traffic in an area of inadequate road infrastructure planning, increased vehicle exhaust pollution, and loss of natural environment where green-field countryside is destroyed.
- it would be more of the same type of business that is already at Magna Park, not new local enterprise;
- the new jobs created would not meet local employment needs: the new jobs would be the same types of job that already exist at Magna Park; local unemployment is low and local people looking for jobs need a variety of types of employment; planning permission has already been granted for a huge new storage and distribution warehouse next to the existing Magna Park, so there will already be more jobs that cannot be filled by local people.

Objective 2 includes: "Contribute to reducing the need for out-commuting and thereby help to increase the sustainability and self-containment of communities, while encouraging the development of a vibrant, diverse and sustainable business community."
However, if located next to the existing Magna Park,
- it would do very little to reduce the need for out-commuting because new jobs created would be in the same type of business and the same skill-types as existing jobs; it would therefore not increase the self-containment of communities;
- it would increase in-commuting because the new jobs created would be mostly filled by people not living locally;
- it would not encourage the development of a vibrant, diverse business community: the new businesses would be more of the same that are already located at the existing Magna Park.

Not consistent with National Policy:

The Local Plan is not consistent with National Policy as it does not follow the National Planning Policy Framework (NPPF) in the following instances:

The NPPF says that Local Planning Authorities should positively seek opportunities to meet the development needs of their area, and local plans should meet objectively assessed needs.
However, the proposed strategic storage and distribution development would provide warehouse floorspace way above the objectively assessed demand estimate given in LLSDS, resulting in an over-supply of warehouse facilities. The proposed development is not needed in the local area around Magna Park.

The NPPF says that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. The countryside around Magna Park is unspoilt green countryside, which although it may not be formally designated as Green Belt should not be approved for a development of the magnitude proposed.

The NPPF says that Local Plans should encourage the effective re-use of land that has been previously developed.
However, if the development is next to Magna Park it will be contrary to this requirement.

The NPPF says that adequate links to the road network are essential.
This requirement will not be met if the proposed development is located next to the existing Magna Park. Links to the road network are currently inadequate. If all HGV traffic to and from Magna Park used solely the direct dual carriageway link to the M1, this would be adequate; however, if the proposed development is next to the existing Magna Park, and HGV traffic uses the A5 in both directions, the A5 road infrastructure is currently inadequate to carry the high volume of HGV traffic.

As stated in the technical report commissioned by HDC: Wider Market Developments: Implications for Leicester and Leicestershire, Final Report, January 2017: until fairly recently, the planning system did not actively promote rail-served warehousing. This position has changed, as reflected in the NPS National Networks and NPPF (see SDS Part A Section 7), which now actively promote the development of large scale logistics facilities at rail-served sites (e.g. SRFIs).
However, the proposed strategic storage and distribution development, if located next to the existing Magna Park, would not be at a rail-served site, and therefore not consistent with national policy.