BE2 clause 2

Dear Harborough District Council,

Thank you for the opportunity to comment on your proposed Local Plan. Please see below the consultation response on behalf of Rugby Borough Council, which is given at Officer level.


Comments on the proposed plan:

It is not clear from the plan or supporting evidence how the impact of the proposals on the highway network and transport outside of the Leicestershire boundary has been considered and what the likely effects will be. The Jacobs Preliminary Impact Assessment 2016 appears to exclude areas outside of Leicestershire, even though there are main routes adjoining or crossing into neighbouring counties (in Rugby Borough's case the A5 and A426, which are near to the Magna Park and Lutterworth proposals), and analysis is not apparent in other documents. It is queried whether sufficient consultation has taken place with Warwickshire County Council Highways Authority to ensure the local plan's implications on cross-county matters have been taken into account.

In addition to the effect on the connected road network, it should be considered how the proposals for growth in Rugby Borough's proposed Local Plan (currently being examined by the Planning Inspectorate) have been taken into account. Further consultation with Warwickshire County Council is encouraged.

It is unclear in the Jacobs Preliminary Transport Assessment 2016 how the figures used in the assessment relate to the local plan targets. Clarification should be given as to how the total amount of growth proposed in the plan has been tested in the assessment and appropriate mitigation identified.

The August 2017 Magna Park Employment Growth Sensitivity Study is welcome, although it is queried whether the position of the other HMA authorities on employment and unmet housing need has been agreed between appropriate authorities and if the Duty to Co-operate has been satisfied. It should be ensured that the draw of employment from surrounding areas as a result of the expansion of Magna Park has been fully considered and also factored in by other authorities, in order to ensure there would not be over provision in the market area as a whole. It is acknowledged that within the plan that the expansion of Magna Park will result in an increase to the overall housing requirement from 532 to 557 dwellings per annum to align the housing with the employment growth and that this will also meet some unmet need from elsewhere in the HMA. However, it is not clear the position of unmet need across the HMA as it is also noted within the plan that Leicester City Council have stated they will have unmet housing need but that the extent is not yet established.

Overall, Harborough District Council has progressed its local plan, and this progress is noted and welcomed. It should be ensured that the impacts of the proposals on cross boundary matters have been fully considered, and that due regard has been given to Rugby Borough's proposed growth. Matters of employment and housing on Duty to Co-operate should be agreed between relevant authorities to ensure overall need has been properly accounted for and to avoid over-provision.

Very low levels of unemployment in Harborough District (Less than 2% "Office for National Statistics 2017") which will result in increased commuting adding further congestion and pollution. Adding a further 10,000 of similar type jobs at MP would contradict one of the local plan goals to reduce out-commuting, An additional 100,000 sq mtrs of warehousing has already been agreed along with further developments only a few miles of MP which will lead to over supply of warehouse land, NPPF states that there is a preference for warehouse/distribution sites to be based on railheads

The planned development will have a definite impact on local roads, especially the A5. This is already a dangerous road at certain times of the day particularly around the Wibtoft section. Further traffic will cause further congestion and accidents.

There will be an increase in pollution from lorries and additional commuting traffic as well as further light pollution.

Local wildlife and and vegetation will be adversely affected.

Forecast need of additional non rail=linked warehousing and distribution space in Leicester and Leicestershire (the area covered by the LLEP Strategic Distribution Sector Studies, 2014 and 2016) for 2031 has already been, or is close to being met. The high estimate forecast (later called a minimum) is for 320k. square metres of non rail-served space by 2021, 435k. sq.m. by 2026, 607k.sq.m. by 2031 and 792k. sq.m. by 2036. Para. 6.3.1 of the Proposed Submission states: "This policy [permitting 700,000 sq. m] contributes towards meeting the requirement .... to 2031". In fact, it does not just contribute to the requirement but exceeds the figure for the entire LLEP area by almost 100K sq.m.

Across the LLEP area many strategic distribution schemes (i.e. 9,000+ sq.m) have been approved in outline or in full, or are being speculatively built or are ready and vacant. The same is true of an area such as Rugby which immediately borders on to the A5 alongside Magna Park. The draft local plan treats Harborough District as if it were not part of a wider area.

Over-provision for warehousing and logistics space in the area seems inevitable and a sound plan is needed to avoid this.

Further development of Magna Park is NOT essential, there are already Warehouses standing empty the past 2 years, Already an over supply of warehousing. Research has indicated there is no requirement for this type of warehousing where it does not link up with rail-freight terminals. We do not need a rail link.
Un-Employment is already low in Lutterworth and people are being brought in, which causes more congestion, traffic problems and pollution. Increased HGV traffic causes toxic particles which will eventually cause, serious medical issues, including heart attacks, strokes etc. Should residents of Lutterworth be subjected to this toxic air.

Traffic levels in the area are already high at peak times and some routes, e..g. Between Lutterworth and Rugby, can be extremely congested. As more vehicle traffic is added to support expanding Magna Park operations there is a serious risk of gridlock on some roads. Much of the traffic volume seems to be driven by workers travelling into the area and as the number of commutes has increased there is evidence that traffic volumes through the villages is increasing. There seems little consideration in any of the plans to the risk of damage and injury to property and people due to busier roads in villages that were not designed to handle modern vehicle traffic. The number of incidents is increasing but the details of most accidents are not on record to enable proper assessment of the impact.

Traffic volumes impact Air Quality. It is well known that Lutterworth has failed to achieve acceptable air quality levels for a number of years despite regular plans to address the issue. With more traffic through the expansion of Magna Park the air quality can only get worse. Where is the evidence that air quality is being factored into the development decision?

It would appear that expansion of Magna Park is considered an important factor in the overall local area development in terms of providing more jobs in the future. I understand that current unemployement in the area in very low and that workers travel into the are to Magna Park and other logistics parks in the area. Something that I believe has not been considered in the plan is the effort of those same logistics operators to actually reduce the number of employees through the automation of warehouse functions. This approach may in fact reduce the overall employment levels at Magna Park in future years rather than provide a steady increase in numbers.

An additional factor that is likely to impact future logistics operations in the immediate area is the lack of a rail connection which is likely to make Magna Park less ideal as the choice for national distribution centres in the future.

I would note also that the current plan to expand Magna Park by 700,000 square meters uses the total land area planned for expansion up until 2031 in one immediate hit. That is also at a time when other logistics developments have also recently started in the immediate vicinity - suggesting that the estimated target allotment of 700,000 square metres by 2031 has already been exceeded.

The area is potentially rich in historic sites dating back to the Roman and Middle Ages. So far much of the land has been protected by farming. I would like to see clear assurances that any discoveries of historic finds uncovered in the process of any future developments will be given appropriate visibility and assessment by suitably qualified interest groups.

REASONS TO REJECT MAGNA PARK PLANS

1. The Magna Park plans are truly immense in scale. If plans were approved, it would be the equivalent of building 7 O2 Arenas or Millennium Domes upon farmland in rural South Leicestershire. One single warehouse could house 16 full-sized football pitches!

2. It's more intelligent to build logistics centres at locations with railheads (like DIRFT only 10 miles away) or at motorway junctions (like Rugby Gateway only 3 miles away). Magna Park has neither of these two important strategic advantages.

3. The road infrastructure around Magna Park already struggles very badly to cope with existing traffic volumes. Traffic congestion and road traffic accidents would inevitably and significantly increase if these massive plans were approved.

4. Leicestershire is one of the worst counties in the country for road fatalities.
6th= out of 43 counties. We do not want South Leicestershire to become the most dangerous road death area in the country.

5. The A5 and A426 would clog up more often with the extra traffic created by these plans that would substantially increase the size of the existing Magna Park. Blocked roads with lengthy queues at junctions and small roundabouts (especially the Gibbet) would result in even longer journeys and commutes, and more lost productivity.

6. Some HGVs do not follow approved routes, travelling dangerously through tiny villages on small rural roads.

7. It's smarter to build warehouses nearer to people who would take up the new jobs being created. The area around Magna Park has almost zero unemployment. The thousands of new jobs would therefore have to be filled by those having lengthy commutes into the area, generating even more traffic congestion around Magna Park.

8. Lutterworth already has some of the worst air quality in Leicestershire, alongside that of Leicester City Centre and East Midlands Airport. It doesn't presently meet EU standards.

9. Logistics sites that serve the nation should properly be planned strategically in the Midlands rather than be approved in a fragmented and uncoordinated way by a large number of different district or borough councils all vying for additional business rates' income.

10. There were over 1,800 written objections to the Magna Park plans, including those submitted by our local MP, Alberto Costa. I would contend these could well be the most unpopular plans in Harborough District Council's history.

11. Approving the three Magna Park plans could generate over £16M a year for the local authorities. HDC currently spends about £30M a year. Are the Magna Park plans really about greed (more money for Harborough District Council & the two developers) rather than about need?

12. Opposing the expansion of Magna Park is most definitely not "NIMBYism." We already have Europe's biggest dedicated distribution centre in our backyard!

Currently there are two outstanding planning applications for 700,oo0 square meters of warehousing on which your evidence is based indicating the proposal is not strategic but opportunist not focusing on meeting employment needs of the district. In addition creating 10,000 similar type jobs at MP would not achieve one of the Local Plan goals of reducing out-commuting, Currently over 60% of MP employees travel in from outside the district, I see no evidence this would change, There are very low levels of unemployment in Harb Dist less than 2% with MP suffering recruitment issues now -we don't need this here.

The land for 700,000 sq.m will impact on the landscape of local rural villages and well as reducing agricultural land in the local area
The current site is already visible from Bitteswell, Ullesthorpe and Claybrooke and will encroach further into the make up of the rural communities

MAGNA PARK EXPANSION PLANS WOULD FURTHER DECREASE THE QUALITY OF AIR IN & AROUND LUTTERWORTH

1. The Magna Park plans are truly immense in scale. If plans were approved, it would be the equivalent of building 7 O2 Arenas or Millennium Domes upon farmland in rural South Leicestershire. One single warehouse could house 16 full-sized football pitches!

2. It's more intelligent to build logistics centres at locations with railheads (like DIRFT only 10 miles away) or at motorway junctions (like Rugby Gateway only 3 miles away). Magna Park has neither of these two important strategic advantages.

3. The road infrastructure around Magna Park already struggles very badly to cope with existing traffic volumes. Traffic congestion and road traffic accidents would inevitably and significantly increase if these massive plans were approved.

4. Leicestershire is one of the worst counties in the country for road fatalities.
6th= out of 43 counties. We do not want South Leicestershire to become the most dangerous road death area in the country.

5. The A5 and A426 would clog up more often with the extra traffic created by these plans that would substantially increase the size of the existing Magna Park. Blocked roads with lengthy queues at junctions and small roundabouts (especially the Gibbet) would result in even longer journeys and commutes, and more lost productivity.

6. Some HGVs do not follow approved routes, travelling dangerously through tiny villages on small rural roads.

7. It's smarter to build warehouses nearer to people who would take up the new jobs being created. The area around Magna Park has almost zero unemployment. The thousands of new jobs would therefore have to be filled by those having lengthy commutes into the area, generating even more traffic congestion around Magna Park.

8. Lutterworth already has some of the worst air quality in Leicestershire, alongside that of Leicester City Centre and East Midlands Airport. It doesn't presently meet EU standards.

9. Logistics sites that serve the nation should properly be planned strategically in the Midlands rather than be approved in a fragmented and uncoordinated way by a large number of different district or borough councils all vying for additional business rates' income.

10. There were over 1,800 written objections to the Magna Park plans, including those submitted by our local MP, Alberto Costa. I would contend these could well be the most unpopular plans in Harborough District Council's history. Many commented about the poor quality of air in the Lutterworth area.

11. Approving the three Magna Park plans could generate over £16M a year for the local authorities. HDC currently spends about £30M a year. Are the Magna Park plans really about greed (more money for Harborough District Council & the two developers) rather than about need?

12. Opposing the expansion of Magna Park is most definitely not "NIMBYism." We already have Europe's biggest dedicated distribution centre in our backyard! We have to breathe the air in the Lutterworth area.

This matter should correctly be recognised as a grave public health issue.

Any material expansion of Magna Park would irretrievably erode the segregation area between Magna Park and Cotesbach, Bitteswell and Lutterworth itself.

Our village of Cotesbach is approximately 2 miles away from Magna Park site. It's clearly visible from our homes and lights up our night sky.

Our village, for energy saving reasons and to avoid light blight, has no street lights but it is now illuminated by the spaceships that are Magna Park.

The plans to substantially expand Magna Park would bring new warehouses to around a mile away further increasing the night light blight, noise & traffic congestion.

This proposal exceeds the demand for such warehousing across the whole of Leicestershire and such a concentration in a very small area cannot be justified.
The unemployment levels in Harborough District are very low so commuter levels would rise and other areas of the County would be deprived of the employment opportunities.
The local road system cannot cope with the greatly increased commuter and HGV traffic associated with all the distribution centres already in existence in the immediate area, so a huge expansion would be crippling.
The over-development on green field land on this scale cannot be justified.

The two massive plans to expand Magna Park do risk detriment to our bio-diversity, eco systems and natural wildlife within the rural Swift Valley.

To plan to build 7 new O2 Arenas or Millennium Domes is bound to impact immensely upon the rurality of our area.

So will the thousands of additional HGVs & commuter cars belching out their poisonous emissions, which damages the health of all species.

As a resident of Cotesbach, which is approximately 2 miles to the south east of Magna Park, I am gravely concerned about the adverse impact this substantial amount of building will cause.

The massive plans to substantially expand Magna Park would significantly increase the carbon emissions and footprint of our supposedly rural area.

Not only in its construction phase but due to the thousands of additional HGVs & commuter cars that would flood out onto our inadequate local road transport network.

Lutterworth already experiences some of the worst quality air in the County, which can only deteriorate still further with all these extra motor vehicles belching out their poisonous emissions.

These developments pose a grave public health issue as well as increasing the carbon footprint of the hitherto rural area around Lutterworth.

Local roads around Magna Park are already over-crowded. Adding more HGVs and commuters using cars will create even more bottlenecks on the A5. This increased traffic will have a negative impact on people living nearby.
I think that there is little unemployment in Lutterworth. If more jobs are created at Magna Park these would probably be low pay, low skilled jobs, like the kind on offer now. There seems to be difficulties in recruiting for these jobs meaning people are travelling from further afield, having more impact on local congestion. We need opportunities for higher skilled people who live locally.

I have reviewed the local plan and consider there are several key points as to why I wish to object:
- Un-suitable employment types & overcrowded roads.
I am expecting the local plan is to create suitable employment for the local area (including for my family),.However I believe there are low levels of unemployment locally at present, I'm informed recruitment is a challenge at Magna Park with competition from nearby locations (including DIRFT).
The addition of thousands more job vacancies at an expanded \Magna Park will just exacerbate the problem, and lead to more commuting into the area. Instead BE2 should be focused on bringing a greater variety of jobs into the area, especially more high skilled jobs.
This leads to the next challenge of the road infrastructure which is woefully inadequate at the moment, and with the addition of more commuting, along with additional truck loads, will significantly add to the traffic on already congested roads. Although the A5 is already inadequate the strategy and these proposals do not envisage any major upgrading of the A5 around Magna Park, which will degrade the quality of life for many of us local residents.

I do not believe the proposal is strategic. There are currently 2 planning applications for 700,000 sq mts of warehousing, this suggests that the proposal is not part of a strategic approach but has been put together to fit the planning applications which happen to have been submitted .
This would lead to over-supply of this type of land-use in the area. I believe that (and there are policy reports confirming this) the strategy should be to focus more warehousing on rail-linked warehousing. This is important for the environmental impact of more heavy diesel traffic which should be being moved to rail transport in order to protect the environment for all of us - the local plan needs to support the council's commitment to minimise our impact on the environment (and specifically global warming)
Coupled with the employment and road challenges this would suggest that the strategy is not properly thought out in any form

I'm a local graduate who recently started full-time employment. I have to travel outside the area for skilled work. My journey is already delayed by a congested A5.. This proposal will only make things significantly worse.
I'm in my 20s with long-term lung problems, so am concerned that this proposal will only worsen the air quality of where I live.Proper plans to address A5 congestion have not been included, nor proposals to link distribution to the rail line.
Please consider the health of your local residents and do not increase the warehousing in this area

The local plan options presented to the public whilst compiling the draft local plan stated that the 700000 sqm option was not the desired option to be included as there was not a requirement for this scale of non rail served distribution in this locality or surrounding area. the evidence does not support this option. Any new post options consultation evidence generated appears to have been excessively weighted towards justifying 2 planning applications. totalling 700000 sq metres. And pacifying a costly
judicial review on HDC plannings process being brought by one applicant

As a local graduate who's recently started full-time employment I have to travel outside the area for skilled work. I am already delayed along a congested A5,. This proposal will only make things significantly worse.
I'm in my 20s with long-term lung problems, so am concerned that this proposal will only worsen the air quality around my home as proper plans to address A5 congestion have not been included, nor proposals to link distribution to the rail line.
Please consider the health of your local residents and do not increase the warehousing in this area.

I am writing as a student expecting to graduate in the next 8 months and living within a mile of Magna Park.
I like the local environment and Harborough area, but am looking for a local plan to create a range of jobs & skill types in the area. There are already plenty of relatively low skilled distribution jobs in the area. I am looking for more highly skilled technical jobs so I don't have to move away from the region to work, or contribute to further congestion by commuting along the already congested local roads

I wish to strongly object to the proposed 700,000 sq mts of warehousing for the following reasons:-

I believe the development is based purely on opportunity and not on strategic planning.
There are already empty warehouses at the current Magna Park site with key companies having recently moved out.
There are huge warehousing sites already being developed at Rugby. I do not believe there is a true balance of need for extending Magna Park to the proposed 700,000 sq mts especially when the Government are supposed to be promoting rail links - Magna Park does not have a rail link!

We do not have an unemployment problem in the area & therefore we do not need the proposed jobs plus it will not deliver any employment benefit to Harborough residents as outlined in Key Issue 3 e.g. greater breadth of employment alternatives, increased wage rates, opportunities for
higher skilled residents. The jobs will be low paid and mainly unskilled.

I find it shocking that the highways believe that there will be no increase to traffic on A5 & that it is sustainable. The inadequacy of the A5 has been recognised in the Midlands Connect Strategy 2017-2030. I travel that road daily and I have found in the last couple of years it has become more and more congested. It is a frightening road to cross over and there has been many accidents and fatalities - why would anyone wish to increase the amount of traffic and put more lives in danger?

The proposed development is not for the benefit of the people who live around the area but it is for the benefit of the developers and Harborough District Council - the fact that it is rumoured that it is a 'done deal' even before any consultation has taken place just rings of opportunism & not planning strategy.

The allocation of 700,000 sq. m. is fundamentally different from previous consultation documents, this figure has not been tested through consultation. There are two outstanding planning applications for warehousing in this area totalling 700,000 sq. m. These statements underpin the view of the Parish Council that the allocation of 700,000 sq. m. is not a strategic allocation, it is an allocation to accommodate approval of the two outstanding planning applications for warehousing in this area. In HDC's existing Core Strategy (2011) Policy CS7h clearly states 'Protect Magna Park's unique role as a strategic distribution centre (B8 uses / Min unit size 10,000m2) of national significance and an exemplar of environmental performance. No further phase of development or large scale expansion of the site, beyond the existing development footprint (to be defined in the Allocations DPD) will be supported'. One of the explanations provided for this statement is that 'there are more suitable locations and sites (both rail and non rail-linked) than Magna Park within the region and sub-region to meet forecast need for strategic distribution to 2026'. The Local Plan does not deny that there are more suitable sites elsewhere, neither does it claim that Magna Park is now the only suitable site.

From my understanding of the local plan option consultation there was no weight of supporting evidence for an extremely large scaled development upto 700,000 sq mts in the magna part area and location. 700,000 sq mts is unjustified for inclusion, it exceeds the requirements for non-rail served freight distribution in the whole of Leicestershire. There are more environment and pollution friendly sights directly adjacent to motorways already being built and developed within the larger area, some of which are rail served which is the governments preferred strategy. There is no evidence for more low skilled jobs

Policy BE2 conflicts with the statement 'the district will have a diverse and thriving economy', by allowing such a large expansion in one sector which is low paid and low skilled the opposite effect will be achieved. In the District, there are approximately 45,000 working people, the creation of c.10,000 new jobs would represent a gross over-supply. If the vision is to achieve a more diverse economy why is HDC not following the Leicester and Leicestershire Enterprise Partnership (LLEP) strategy which aims to encourage a broad range of business development, HDC have signed up to this strategy.

National Planning Policy Framework states that rail freight is preferable and that warehousing and distribution sites should have access to rail. There are other locations close to Magna Park where this is possible

The A5 is already an inadequate road for current traffic volumes. No major upgrading is envisaged

This would lead to a clear oversupply of warehousing. There are already empty units at this location

Ullesthorpe village already experiences HGV traffic which should not be using High Cross Road where there is a 7.5T limit except for loading. this is not policed and will inevitably be worse in future

Research has shown the demand for non-rail freight warehousing is lower than this across the WHOLE county. This indicates an oversupply in a small area. National Policy preferences are to have distribution sites with rail freight access

The local road infrastructure is already under pressure and the A5 is inadequate already. There is no indication of major upgrades. Commuting into the location will increase putting further pressure on the infrastructure

There is no mention of green space preservation between Magna Park and Cotesbach or Ullesthorpe

There are already empty units now without further development

A development of this size far exceeds the forecasted need for non-rail served warehousing and distribution space for the entire Leicester & Leicestershire Enterprise Partnership (LLEP) area for 2031. No consideration appears to have been given to planning consents given by councils in Leicestershire since 2014 or consented sites currently under construction, which combined, amount to a minimum of 577,000 sq. m. Further development of 700,000 sq. m potentially contributes to a huge over-supply of non-rail served warehousing and distribution space in the local area, it does not allow spread across the LLEP area. This potentially leads to a huge influx of workers from further afield exacerbating local congestion and traffic issues, further over-loading local villages with additional commuter traffic and conflicting with available housing in the area.

The proposal in the plan is not strategic, but opportunistic. trying to fit in two new applications on to a site that had previous been deemed not suitable for expansion in the previous local plan. Two applications have been submitted that total the 700,000 sq mts in the plan demonstrating it is opportunistic.
Research reports (the LLEP SDSS, 2017) have indicated that there is demand for less than this
area of non-rail warehousing across Leicestershire. Thus providing this area of land in one
location would not allow spread across the county and potentially lead to an over supply of
warehousing.

There are very low levels of unemployment in Harborough District, particularly Lutterworth
(less than 2%, Office for National Statistics 2017). Magna Park employers have significant
recruitment issues at the current time with increasing competition from developments at
DIRFT, Rugby and East Midlands amongst others. The low value jobs will therefore be filled from those travelling from outside the ares, impacting on both transport, safety and air quality, which is already very poor in the area.

The plan is not consistent with national policy, which states that distribution should be located near railheads. This is not the case with Magna Park and other sites next to rail heads are already being developed such as at DIRFT.

A development of this size far exceeds the forecasted need for non-rail served warehousing and distribution space for the entire Leicester & Leicestershire Enterprise Partnership (LLEP) area for 2031. In addition, no consideration appears to have been given to planning consents given by councils in Leicestershire since 2014 or consented sites currently under construction, which combined, amount to a minimum of 577,000 sq. m. Further development of 700,000 sq. m potentially contributes to a huge over-supply of non-rail served warehousing and distribution space in the local area, it does not allow spread across the LLEP area. This potentially leads to a huge influx of workers from further afield exacerbating local congestion and traffic issues, further over-loading local villages with additional commuter traffic and conflicting with available housing in the area.

The Local Plan is unsound for the following reasons:

Not positively prepared:

There are no objective reasons stated for the figure given of 700,000 square metres of additional development for non rail-served strategic storage and distribution. This figure just happens to be approximately the sum of the areas of the two remaining planning applications for storage and distribution buildings adjacent to the existing Magna Park, implying that the figure of 700,000 square metres was arrived at using figures from current commercial planning applications, and is not based on an objective assessment of the need for this development, and it also implies that the proposed storage and distribution development would be located next to the existing Magna Park.

The storage and distribution warehousing 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 include the proposed 700,000 square metres area for non rail-served storage and distribution in the Local Plan would be contrary to the objectively assessed demand in the report, and would result in over-provision of warehousing floorspace area. Rather than locating all the proposed development next to the existing Magna Park, development should be planned 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 warehousing floor-space for non rail-served strategic storage and distribution sites is located next to the existing Magna Park, it will be contrary to this objective assessment.


Not justified:

The technical report prepared for Harborough District Council: Leicester and Leicestershire Strategic Distribution Study: Update and Refresh of Outputs and Conclusions, September 2016, in the section of the document entitled Strategic Distribution Sites - Key Design Characteristics, states that strategic logistics sites must be located adjacent to a junction on the motorway or long-distance dual carriageway network (e.g. A14) which has sufficient capacity available, or within a few kilometres of such a junction via a high quality single/dual carriageway road capable of accommodating significant volumes of HGV traffic (in terms of quality and capacity available).
HGV traffic using the direct dual-carriageway to and from Magna Park to the M1 meets the above requirement, but HGV traffic to and from Magna Park using the A5 in both directions for long distances does not. The A5 is currently not a continuous long-distance dual-carriageway.

The Midlands Connect Strategy plan to upgrade the A5 between the A38 at Lichfield and the M1, endorsed by the government, will not be completed until 2030. Until this upgrade to the A5 is complete, planning applications for major logistics warehousing next to the A5 should be rejected. The existing road infrastructure is inadequate to support further developments such as this. Plans for development of new storage and distribution warehouses next to the existing Magna Park are not justified 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 700,000 square metres of additional warehousing floorspace proposed is located next to the existing Magna Park this requirement would not be met as unemployment is low in this area. Logistics warehouses should be located near an area of higher population and employee availability. Magna Park is in an area of low unemployment, so building of warehouses next to the existing Magna Park will result in increased in-commuting and more commuter-traffic congestion.

Further logistics business warehouses where there are already a large number of warehouses is not justified, as it will impact negatively on the local community due to increased HGV and commuter traffic congestion, increased air pollution, and destruction of green-field countryside.

Not effective:

Planning permission for a further 100,000 square metres of warehouse floor area next to the existing Magna Park has recently been granted. Other warehouse development is already taking place nearby; 700,000 square metres more would lead to over-provision of warehouse floorspace.


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 Plans should encourage the effective re-use of land that has been previously developed.
But if the development is adjacent to Magna Park it will not be consistent with this requirement. The area around Magna Park is unspoilt countryside, which should not be destroyed to build massive warehouses on.

The NPPF says that adequate links to the road network are essential.
If the proposed logistics warehouses are built next to the existing Magna Park, and HGV traffic uses the A5 for long distances in both directions, the A5 road infrastructure is currently inadequate to carry the high volume of HGV traffic.

The NPPF says that large scale logistics facilities should be located at rail-served sites. But if the proposed storage and distribution warehouses are built next to the existing Magna Park, they would not be at a rail-served site, so would be not be consistent with national policy.