BE2 clause 2

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 live near Magna Park and use the A5 every week day to get to school. The traffic is always heavy and this can cause lots of delays. Adding more lorry traffic from Magna Park, if it expands, will make this worse. It will cause more pollution for the local environment

I wish to object to the above proposal because -

1:There is a low level of unemployment in the area (2%) and so we do not need the number of new jobs this increase in warehouse space would generate.
2: Additional workers would need to be drawn from a wider area thus increasing traffic and also pollution.
3: the type of employment is generally low skilled, low paid and so will not serve the needs of Harborough residents as outlined in Key issue 3
4:The proposed site is not near a preferred rail freight access
5The site will cause light pollution and increase the amount of debris that accumulates along the grass verges of theA5 ( collecting litter does not appear to be high up on the councils agenda )
6: the buildings will spoil the rural landscape and destroy wildlife habitat ( the UK is positioned 189 out of 218 of the most biodiversive depleted countries ).

APPENDIX
HARBOROUGH LOCAL PLAN 2011 TO 2031 PROPOSED SUBMISSION
LEICESTERSHIRE COUNTY COUNCIL RESPONSE

Transport

1. Leicestershire County Council, in its role as Local Highway Authority (LHA), has been working closely with Harborough District Council as part of the Local Plan making process. As such, the LHA is content that the draft submission document is appropriately evidenced and also appropriately deals with transportation considerations at this stage in the planning process.

2. Subject to Harborough District Council's continued commitment to the policies and delivery approaches set out within the document, the LHA supports the submission of the Local Plan and looks forward to working with Harborough District Council in its delivery.

Education

3. Policies F1, MH2 and MH3 include no reference to securing suitable contributions for educational facilities. It may be that the intention is that these are covered by Policy IN1 - Infrastructure Provision, however whilst this policy refers to the Leicestershire Planning Obligations Policy (LPOP), it only does so in terms of waste, it does not refer to education.

4. Policies L1 and SC1 refer to delivery of Primary Schools 'soon after 300 dwellings'. The County Council would normally, and has with Harborough District Council, requested that the intended provision be available for opening in the September prior to the occupation of 300 dwellings.

Ecology

5. It is acknowledged that the de-declaration of the Scraptoft Local Nature Reserve is also currently being consulted on, and that its de-declaration would enable land to come forward for development as part of the Scraptoft North Strategic Development Area (SDA). The County ecologist has and continues to be actively involved, working through an approach which ensures the retention and management of areas of ecological value whilst enabling the release of some land for future development. This may involve the designation of a Local Wildlife Site.

Waste Management

6. The Local Plan needs to recognise that Waste Management considers proposed developments on a case-by-case basis and, when it is identified that a proposed development will have a detrimental effect on the local civic amenity infrastructure, appropriate projects to increase the capacity to offset the impact have to be initiated. Contributions to fund these projects are requested in accordance with Leicestershire's Planning Obligations Policy and the Community Infrastructure Legislation Regulations.

Economic Growth

7. The County Council supports the new employment land allocated in association with the Lutterworth SDA and recognises a similar approach is not necessarily appropriate with the Scraptoft North SDA with opportunities to access existing B use employment sites and proximity and ease of access to the City for employment.

8. The proposed portfolio of B use employment land in the Local Plan, which will provide the opportunity to deliver a range of jobs and economic prosperity in the District and wider area, is supported.

9. The County Council supports the approach taken to strategic storage and distribution (strategic B8 use) at Magna Park in the Local Plan, which has been informed by recent evidence commissioned by Harborough District Council. In particular, it supports additional strategic distribution proposals at Magna Park needing to meet the six criteria set out within the second part of Policy BE2, which sets a limit of 700,000 square metres for non-rail-served strategic B8 use in the Plan period.

10. The emphasis on the vitality and viability of the town centres is supported, and the regeneration emphasis on Lutterworth town centre although it is considered there is scope to strengthen this further, beyond the focus on vacant units absorbing identified need in Lutterworth town centre.

Strategic Assets

11. Comments from Strategic Assets are made in relation to the County Council's role as landowner. Its main interests in Harborough District are:

* land at Misterton County Farms Estate which forms part of the East of Lutterworth SDA (for which a separate detailed collaborative response will be submitted on behalf of the landowner consortium), and;
* potential smaller scale sites within Market Harborough, Lutterworth and rural settlements throughout the District.

12. Query whether the settlement hierarchy requires further consideration, to enable settlements which are better serviced than others in the same tier of the hierarchy to be more clearly distinguished and potentially receive more development.

13. In general terms the distribution of housing across the settlement hierarchy is supported; however, considers that there needs to be more clarity regarding the future housing needs of key settlements and seeks more flexibility for future housing numbers for smaller settlements.

14. The allocation of the East of Lutterworth SDA as a preferred strategic housing allocation is, in particular, strongly supported. The Objectively Assessed Need (OAN) supported by the Housing and Economic Development Needs Assessment (HEDNA) should therefore inform and provide strategic guidance to the development of later SPDs and Neighbourhood Plans. In considering the distribution of housing in the lower tiers of the hierarchy the Plan needs to demonstrate that those key centres and rural centres with neighbourhood plans will deliver housing numbers based on the current OAN rather than those contained within existing plans which were based on an earlier, much lower, OAN. Without this clarity the methodology could be open to criticism.

15. The integration of the social element of housing for older people and specific groups should be incorporated within the quantum and mix of affordable housing in order to mitigate any negative effect on site viability.

16. The County Council requests that planning consents at Airfield Business Park, Market Harborough (BE1.1a (ii)) and the land south of Lutterworth / Coventry Road, Lutterworth (BE1.1b (ii)) should be shown as existing commitments. Further, the consented site at Gaulby Road, Billesdon (a former highways depot), should also be shown as a commitment.

17. Whilst recognising the desire to concentrate strategic distribution at Magna Park, the proposal in Policy BE2.2 to allocate sites capable of delivering units of at least 9,000 sqm is seen as logical, as is the desire to stimulate economic growth by delivering sites that meet regional and sub-regional demand.

18. Policy BE3 on existing employment areas is supported; BE3.1 being seen as of particular relevance in ensuring that development meets the needs/demands of the wider sub-regional market in addition to local businesses in order to attract inward investment.


19. The allocation of both convenience and comparison retail floor space within the Lutterworth East SDA in Policy RT1 is supported, as is the additional provision within Lutterworth town centre which will complement the development of the new local centre and maintain a balance across the expanded community.

20. Policy L1- East of Lutterworth SDA is strongly supported. Being situated in the M1 corridor within one of the priority areas for economic growth in the Strategic Economic Plan it is clear that Lutterworth should be the focus of major strategic development within the District. The East of Lutterworth SDA is seen to meet best the criteria set out in Key Issues section of the plan and compliments the further development of Magna Park. Further, it is confirmed that the site, which is recognised as the most sustainable location for major development within the district, is available, being owned by a consortium of willing landowners, deliverable and capable of supporting a viable development.

21. Policy L2 - Land south of Lutterworth Road/Coventry Road. Outline planning consent has been granted and accordingly it should be regarded as an existing commitment for the purposes of the Local Plan.

5.0 Policy BE2 Strategic Distribution
5.1 Policy BE2 states:
1. Magna Park, as identified on the Policies Map, is safeguarded for strategic storage and distribution (Class B8). Proposals for redevelopment at the existing site will be permitted where:
a. each unit has at least 9,000 sq.m. gross floorspace; and
b. any new building or the change of use of an existing building(s) is for Class B8 and ancillary use only; or
c. the proposal for any non-strategic storage and distribution use is small-scale, proportionate in scale to the strategic storage and distribution use and ancillary to the use of individual plots.
2. Additional development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted where it would:
a. form an extension of, or be on a site adjoining, Magna Park;
b. support or at least have no adverse impact on the viability and deliverability of existing or further Strategic Rail Freight Interchanges (SRFIs) within or serving neighbouring authorities and Leicestershire;
c. increase employment opportunities for local residents, including training and apprenticeships;
d. include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District;
e. not lead to severe traffic congestion anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside; and
f. ensure 24 hour operations do not have an unacceptable environmental, community or landscape impact in the immediate and wider surrounding area".

Consideration of Policy
General Comments
5.2. Prologis and RRSLP do not seek to repeat comments made above on the scale of the Magna Park extension but note that Prologis and RRSLP are concerned that the Council has not taken full account of evidence in the L&LSDSS which states that "in order to maintain and enhance the competitive position currently enjoyed by the region/sub-region, it is vitally important that the market in future is offered a geographical spread of commercially attractive sites available to satisfy individual operator locational requirements" [para 3.9]. Prologis and RRSLP considers that the Council has not robustly justified the spread of sites and in particular the implications of directing a substantial amount of their employment land requirement to the Magna Park Site. It is also considered that there are a significant number of strategic distribution sites within close proximity to each other and whilst the Council has drawn the line within the Leicestershire FEHMA it is considered that the implications of the Magna Park extension go beyond this area and affect the future success of DIRFT III and other rail linked sites.
5.3. The L&LSSDS notes that there is a need to maintain competitive advantage with continued development of new commercially attractive strategic sites in the East Midlands, a significant proportion of which will need to be directly rail-served (in addition to the usual requirements for high quality connections to the strategic highway network) (para 2.2.9). Whilst here is a need for road based strategic distribution development it is considered that this scale of development in one location is not justified.
5.4. The L&LSSDS notes Leicestershire and Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across their area and work together with neighbouring authorities and Local Enterprise Partnerships to prepare and maintain a robust evidence base to understand both existing business needs and likely changes in the market (para. 3.5). Prologis and RRSLP consider that the Council's evidence has not fully considered the implications of promoting such a substantial road based B8 allocation in this part of Harborough.
5.5. Whilst the L&LSSDS Update identifies that there are Key Areas of Opportunity for road linked and rail linked strategic distribution development and Magna Park falls within this area of need, the L&LSSDS Update does not specifically recommend that the entire Leicester and Leicestershire B8 employment land requirement should be provided at Magna Park. Indeed, it recommends that "delivering new commercially attractive strategic sites within at least two of the key areas of opportunity simultaneously cannot be undertaken by local planning authorities working alone. The NPPF now places a duty to cooperate on planning authorities when covering issues that cross administrative boundaries, particularly those which relate to the strategic priorities. Given the above, delivering the identified need will require continual long-term strategic and collaborative planning across the county of Leicestershire, and potentially with authorities in neighbouring areas outside the county" (p.25). It is clear from the Duty to Co-operate Statement that there is still work to do to confirm agreement within the Leicestershire planning authorities, the County Council and Leicestershire LEP that Magna Park is the correct location for this scale of development. It is also clear from the evidence that requirement should be spread to more than one location.
Implications on Nationally Significant Infrastructure Project (NSIP) and rail-based fright distribution
5.6. Prologis UK Limited and RRSLP objects to Policy BE2 on the basis that the policy promotes the potential release of a significant road-based distribution development in proximity to an approved Nationally Significant Infrastructure Project (NSIP), which seeks to deliver the government's agenda of rail-based fright distribution. Policy BE2 therefore has the potential to impact negatively on the delivery of national planning policy.
5.7. Given that the DIRFT III Site is situated just beyond the boundary of the Functioning Economic Market Area (FEMA) the effects of proposed extension to Magna Park on DIRFT III are not considered to be robustly sufficient. Whilst Prologis and RRSLP welcomes the policy criteria 2 (b) which places a requirement on the applicant to demonstrate "no adverse impact on the viability and deliverability of existing or further Strategic Rail Freight Interchanges (SRFIs) within or serving neighbouring authorities and Leicestershire". It is highly likely that Magna Park will displace demand for units at DIRFT III as well as have implications on the availability of employees to work on the DIRFT III Site and other consented sites in the locality. Indeed, the Logistics & Distribution Sector Growth Action Plan Final Report notes that LLEP Business Survey 2015 found that just under 40% of logistics and distribution sector companies had undertaken recruitment activity in the past 12 months, with 18% reporting difficulties in filling vacancies in the Leicester and Leicestershire LEP Area. The Action Plan notes that issues are concentrated on two job roles - vehicle drivers accounting for 73% of all hard to fill vacancies and warehouse operatives a further 15% [para 2.2.3]. It is noted that whilst the Magna Park Employment Growth Sensitivity Study identifies that it has sought to consider where the additional workforce might come from. This is invariably a complex issue, influenced by accessibility, transport links, demographics and housing provision. The Study starting point has been to consider existing commuting patterns to Magna Park.
5.8. Prologis and RRSLP urge the Council to fully consider the implications of allocating this scale of extension to Magna Park, given that potential occupiers who may well currently be considering rail-based options for their distribution networks, will be provided with a road-based alternative. Whilst those occupiers who have invested in rail are beginning to see the benefits of such a modal switch, it remains an on-going educational process, to the extent that providing an alternative road-based option has the potential to undermine this process. Clearly, such an alternative could well deter the on-going investment at the DIRFT, to the detriment not only to its operation as the Country's leading SRFI, but also the implementation of the DCO-approved expansion scheme issued by the Secretary of State. Equally, the sustainable transport benefits of this project, delivered through an increase in rail-based distribution traffic that were pivotal to the success of the application, will be placed at risk.
5.9. There is a further implication of allowing non-rail related distribution development close to DIRFT III or any Rail Freight Interchange due to the relatively lower cost of bringing forward non-rail based development (without the added financial burden of securing rail linkages and the associated infrastructure). Typically, because they do not carry the same level of infrastructure costs, non-rail developments can secure a competitive advantage in terms of rent and accommodation costs they are able to offer thus do not compete on a level playing field with rail-linked schemes. This is likely to then have the effect that occupiers gravitate to the non-rail-linked schemes and hence the government's objective of securing a movement of freight by rail is prejudiced.
5.10. Prologis and RRSLP draw your attention to the Report on the Examination into the West Northampton Joint Core Strategy Local Plan (December 2012) in relation to the proposed expansion of J16 of the M1 for strategic B8 employment uses where the Inspector found that "given the potential alternative sites available near, including the recent approval of a major extension of 345 ha to DIRFT for rail linked freight, there is no overriding local need for a major new strategic employment allocation on a greenfield site in the open countryside". Furthermore the Inspector, acknowledged that the development of "very large B8 uses, might well provide direct competition to DIRFT to the detriment of the delivery of both, potentially also discouraging the increased transfer of freight to rail" [Appendix 2].
5.11. The Council will also be aware of the decision by South Northamptonshire Council when granting planning permission for Class B2, B8 and ancillary B1, provision of a 2ha lorry park and associated infrastructure on land at Junction 16 of the M1 that they sought to not conflict with operations at the DIRFT III Site [LPA ref: S/2016/0400/EIA]. The Condition states: "that any building exceeding 40,000sqm in gross internal area shall only be occupied and operated by an existing Northampton based employer". The Reason states: "To ensure that units exceeding 40,000sqm that are not occupied and operated by existing Northampton based employers are directed towards DIRFT, to comply with the requirements of Policy E8, criterion e) of the West Northamptonshire Joint Core Strategy".
5.12. RRSLP and Prologis note that DIRFT III to J.16 M1 (Midway Park) is 11.4 miles according to AA route planner and is of greater distance than DIRFT III to Magna Park. Magna Park to DIRFT III (Danes Way) to Parkway Magna Park is a lesser distance at only 9.5 miles. Given that an Inspector had concerns with the impact of Junction 16 of the M1 on DIRFT it is highly likely that Magna Park would have a greater influence. Whilst RRSLP and Prologis acknowledge that it is right for the Council to define an area of assessment, it is clear that the implications on DIRFT III go beyond the defined FEHMA.

Predetermined Evidence
5.13. Prologis and RRSLP considers that the evidence to justify the extension to Magna Park is based on pre-determined assumptions to justify the approval of the planning applications to extend the Magna Park Site1. There are various references through the Council's evidence which demonstrate such an approach.
5.14. The Harborough Local Plan Sustainability Appraisal (SA), also points towards predetermined evidence, and states that given the presence of three live planning applications. The SA notes that it was considered useful to base the options on the broad growth and distribution being proposed in the planning applications either individually or in combinations with one another. This resulted in five alternatives being appraised as follows:
1. Option A - 37 ha (100,844sq.m.) of growth corresponding with the location of planning application 15/00919/FUL.
2. Option B - 88ha ( 278,209sq.m.) of growth corresponding with the location of planning application 15/00865/OUT.
3. Option C - 232ha (432,425sq.m.) of growth corresponding with the location of planning application 15/01531/OUT.
4. Combination of A+B - (125 ha / 379,053sq.m. of growth).
5. Combination of B+C - (320 / 710,634sq.m. ha of growth).
5.15. This approach is fundamentally flawed. There is no evidence to justify the strategic allocation at Magna Park. The Council has not robustly considered any alternatives despite the L&LSDSS Update requiring two locations.
5.16. The Magna Park Employment Growth Sensitivity Study (2017) does not justify the scale of the allocation proposed at Magna Park. It is clear that this assessment work has been modelled to support the assessment of the planning applications at Magna Park1. The report essentially provides evidence justifying additional housing needed to support the growth of Magna Park.
5.17. Prologis and RRSLP are surprised by the policy U- Turn that the Council has taken to extending Magna Park because they inherently conflict with the District's current Core Strategy Policy CS7(h): "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."
5.18. Furthermore, the Harborough District Council Core Strategy DPD Inspector's Report (November 2011) indicated that the future expansion of Magna Park is not required noting at [para 109 - para114] its links to the Daventry International Rail Freight Terminal (DIRFT) some 15km away, stating that Magna Park itself has no rail connection.
5.19. While now revoked, the East Midlands Regional Plan (RS) did not identify Magna Park as a preference for strategic distribution. The RS established a clear priority for sites which can be served by rail freight and can operate as intermodal terminals.
5.20. It has not been demonstrated why the Council has suddenly gone from no further expansion to Magna Park to now promoting substantial expansion to it. RRSLP and Prologis consider that it is in response to the applications submitted at Magna Park. The reasons for such a change are not fully justified by evidence.
Tests of Soundness
5.21. Prologis UK Limited and RRSLP consider that Policy BE2 fails to meet the following tests of soundness because:
1. Positively Prepared: The preparation of the policy has not take account of necessary cross-boundary discussions with neighbouring authorities (West Northamptonshire Joint Planning Unit and Daventry District Council) in relation to the quantum of strategic distribution development and, importantly, the location of such development - recognising that commercial demand for strategic distribution development does not adhere to local government administrative boundaries.
2. Justified: The Council has not robustly justified the amount of strategic B8 development needed within Harborough or that Magna Park is the most reasonable location out of all alternatives..
3. Effective: The policy is not effective as it not based on effective cross boundary planning but is based on predetermined evidence used to justify the approval of planning applications at the Magna Park Site.
4. Consistent with National Policy: The Plan should enable the delivery of sustainable development in accordance with the polices in the Framework. The proposals at Magna Park conflict with the overall strategic aims of the Framework which seeks to reduce carbon emissions through promoting sustainable transport modes, and the National Networks National Policy Statement ('NNNPS') which prioritises distribution and warehousing sites served by rail.

Recommended Change
5.22. In order to address the conflicts identified above and ensure that BE2 is sound, it is requested that Harborough Council:
1. Undertakes further consultation with neighbouring authorities as it is clear that the duty to cooperate has not been fulfilled with regards to the justification of the extension to Magna Park. It is clear from comments made by Daventry and North West Leicestershire that they are not convinced that Policy BE2 is effective or justified. Harborough Council has failed to justify delivering such a substantial extension to Magna Park and have not secured agreement with all the relevant authorities. Until this work is done Prologis and RRSLP consider that the plan is unsound and should not proceed.
2. Provides evidence justifying why it is appropriate for the Council to extend Magna Park and justify why it is appropriate for the District to allocate more than double the requirement for non-rail served sites required in Leicestershire as well as delivering in excess of the gross land requirement for strategic B8 development for Leicester and Leicestershire by 2031 in one location.
3. Provides evidence that the Council has robustly fulfilled its duty to cooperate with regards to meeting the concerns of Daventry and North West Leicestershire in terms of allocating in excess of the identified need for the whole of Leicester and Leicestershire in one location.

This proposal fails to be legally compliant as it doesn't meet objectively assessed employment needs. There are already empty warehouses at Magna Park that aren't leased, despite 2 outstanding planning applications. There are also empty warehouses on new developments within 10 miles down the A5 and on the edge of Rugby. It is therefore, obvious the claim that there is a glut of employers needing this is blatantly untrue!
Unemployment in Harborough District and Lutterworth are very low and there are existing recruitment issues. This means any employees would come from outside there area, creating traffic congestion, pollution, dangers for the local community with no benefits and damage to the local environment. For these reasons the plan is neither justified nor effective.

It is also not consistent with National Policy as the preference of that is for such sites to have access to rail freight. There are existing sites with such access and another planned on the M69 where such expansion would be more appropriate and where such employment may actually be positive.
The inadequency of the A5 has been recognized (Midlands Connect Strategy 2017-30), with no plans to deal with this. Local road junctions are already dangerous and for residents considered a no-go.

The roundabout between Brookfield Way and the "Bypass" does not have a clear line of sight to the right making this incredibly dangerous. This situation would be dramatically worsened by the expansion. This issue has been raised with Harborough District and the County Council, but nothing has been done.

The added traffic to the M1 would also increase already bad levels of congestion and pollution on roads in Lutterworth due to prevention of traffic flow (Lutterworth already has some of the worse pollution levels in the country for a settlement our size!).

If this plan is allowed to happen the health and safety of local residents will be sacrificed.

- Dramatic increase in freight traffic on all roads in the area. The A5 and on minor roads.
- The increase in traffic will mean an equal increase in air pollution.
- There will be a dramatic loss of wildlife habitat.
- Light pollution will blight the surrounding area.
- There has been extensive objection to the proposal, therefore, the Policy is not sound as there is now a total lack of democracy in it being put forward.
- The proposal does not follow due to process and the evidence presented to support it is bias.
- Despite the major increase in inbound and outbound freight traffic there is no commitment to a rail head.
- The expansion taking place at DIRFT, just down the A5, which does have a rail head, is better placed to take any perceived increase in logistics.
- There is virtually no unemployment in Lutterworth and thus the majority of all new employment envisaged will mean in bound commuting.

Harborough Local Plan 2011-2031: Proposed Submission Representation
17 November 2017


1. Gazeley UK Ltd are the developer of Magna Park - Harborough District's single largest employer and the focus of Policy BE2 in the Proposed Submission Local Plan (PSLP). Gazeley are also the applicant for an extension to Magna Park to provide a further 419,800 sq m of strategic distribution floorspace together with a range of ancillary uses, including an Innovation Centre, Logistics Institute of Technology and Railfreight Shuttle and Terminal. The ancillary uses are aimed both at creating the efficiencies of the logistics cluster that Magna Park stands to become and at capturing the benefits that would follow for the industry, its employees, local communities and the environment. Almost uniquely in the sector, Magna Park is proactively managed by Gazeley. That fact, coupled with the concentration at Magna Park of blue chip logistics businesses, generates the opportunities that Gazeley's extension proposals would realise.

2. Gazeley welcome and support Harborough's PSLP. The PSLP provides a welcome strategic platform for achieving the ambitions for Magna Park, and in particular for ensuring that Harborough's economy, communities and environment gain accordingly.

3. This representation sets out the basis for Gazeley's support for the PSLP, together with suggested amendments to Policies GD3, HE1 and BE2.2. The change to GD3 is needed to make it consistent with BE2.2; the change to HE1 is needed to bring the policy into line with NPPF 132-135; and the changes to BE2 are suggested to strengthen the policy's expectation that large scale distribution development around Magna Park should create a valuable logistics industry cluster that will benefit local communities as well as the economy and in all other ways constitute sustainable development as defined by NPPF 15-149.

The PSLP policies Gazeley particularly welcome

4. Gazeley particularly welcome the following policies for the reasons explained.

* SS1 The Spatial Strategy and the accompanying written statement, because of:

i. the recognition of the significant role the district plays in the strategic distribution sector because of its competitive advantages (strategic infrastructure, land, labour and cluster efficiencies)

ii. the recognition of Magna Park's role in the significance of the sector for the district, county and region

iii. the recognition that with more employment in the district, there is a chance that out- commuting for work could reduce (no chance otherwise) - and in that context note the wide range of occupations in strategic distribution and the sector's a good match with the district's skill set;

iv. the consistency with the Strategic Economic Plan for the Leicester and Leicestershire Local Enterprise Partnership (LLEP) and with the Midlands Engine for Growth strategy;

v. the use made of the extensive evidence base commissioned by LLEP, the Leicestershire authorities and HDC on the strategic distribution sector; and

vi. the acknowledgement that the evidence is a projected need for a minimum quantum of 608,000 sq m in the county to 2031, provided in market-facing locations, offering development plots of a scale and with the flexibility required to meet the increasing size needs of the sector, with sequential approach to site selection starting with a first preference for extensions to existing sites.

* CC1 - Mitigating Climate Change, because of the obligations CC1 places on major developments to provide and use renewable energy, minimise resource consumption and reduce carbon emissions.

Policy not sound as drafted: Policy GD3 Development in the Countryside

5. Policy GD3 is not sound as drafted, but solely because it fails to account for Policy BE2.2, the delivery of which will require development in the countryside for a use which Policy GD3 precludes.

6. Policy BE2.2 is not accompanied by a site allocation, but requires the development of land in the countryside to deliver the up to 700,000 sq m of strategic distribution floorspace that BE2.2 locates next to Magna Park. Therefore, as drafted, GD3 is neither positively prepared nor effective.

7. To make GD3 sound, we suggest simply adding a new criterion 'j.' to refer to BE2.2, and to renumber the remaining criteria in GD3 as follows: criterion j., and renumber the remaining criteria as follows:

8. Should a site or sites ultimately be allocated for Policy BE2.2, then the change to Policy GD3 would clearly not be necessary.

Policy BE2 Strategic Distribution: sound but would benefit from setting a higher bar for what would constitute sustainable development

9. Gazeley welcome policy BE2 and its criteria-based approach, and in particular the recognition of the particular merits of the Magna Park location in meeting the needs of a growing and dynamic logistics sector for which Harborough has compelling competitive advantages.

10. Nonetheless - and with regard to the sheer scale of development that is promoted by BE2, the concentration of an additional 700,000 sq m of strategic distribution space on land that extends or adjoins Magna Park and the concerns of local communities (voiced since the first planning permissions were granted for Magna Park) - Gazeley take the view that the policy is less ambitious than it should be. Magna Park itself is already unique: its existing size (some 772,000 sq m of large B8 units); its occupation solely by blue chip companies; its dominance by national distribution centres; and the high share of the site given to landscape, habitat and woodland (Gazeley planted over a million trees to create the publicly accessible Magna Wood). Magna Park is also in the open countryside but close not just to the strategic highway network but to a small town and many smaller rural villages. These factors, together with the prospect of a further 700,000 sq m of large B8 units, combine to present a singular opportunity for Harborough - not just to meet the floorspace needs of the logistics sector in an optimal location, but in doing so also to optimise the economic efficiencies for the competitive growth of the industry by promoting Magna Park as the centre of a logistics cluster and, at the same time, setting a new bar for socially responsible and environmentally sustainable logistics development.

11. The key challenges to the logistics industry's competitive growth are, alongside securing an adequate supply of optimally located land, its image, the availability of suitably skilled and qualified labour, and its environmental footprint. These are all closely related: the ability of the industry to grow productively as well as sustainably is fundamentally dependent on attracting and providing people with the skills needed to drive up innovation in the sector, reduce the costs of the supply chain, improve its value to end users and minimise its environmental effects. The sector's ability to do this is, in turn, fundamental to the performance of UK plc, including environmentally.

12. These considerations create the opportunity for policy BE2 to drive and support the singular opportunity to build on the standing and scale of the existing Magna Park and to both drive and capture the benefits of the logistics cluster that BE2 is capable of creating. A cluster is a group of similar and related firms in a defined geographic area that shares common markets, technologies, worker skill needs, and which are linked by buyer-seller relationships. Clusters are drivers of economic efficiencies, innovation and productivity resulting from competition and inter- trading between firms and the further efficiencies entailed in resources, factor inputs, labour skills and markets.

13. The logistics industry has particular features of its operation that makes it particularly well-placed to secure the economic benefits of clustering. One feature of this is pure geography. There are a limited number of optimal locations with supporting infrastructure from which logistics operators can most efficiently fulfil demand. Magna Park is one. But there are also particular operational advantages for logistics from cluster activity. Moving between large centres of freight activity rather than highly dispersed centres lowers transportation costs and almost certainly creates greater reliability as well. In any competitive cluster environment these costs savings get passed on to the logistics operator's customers and hence lower costs across the economy as a whole.

14. Logistics clusters also tend to encourage value-added activities such as product differentiation, repair and servicing - and increasingly, amongst the more innovative, also various forms of 'trialling' of new systems of supply change management and other forms of R&D and its application. Long and complex manufacturing supply chains, for example, mean that firms often have to respond quickly to changing technologies, fashions and consumer tastes to stay relevant to the market. The closer and later this can be done to point of delivery to market, the greater the competitive edge for the selling firm. Logistics clusters provide the ideal base to perform such value added functions. Thus the notion, particularly in the Golden Triangle, that the National Distribution Centres that tend to dominate the occupier base, 'only' do stock-holding and distribution is incorrect, and increasingly so.

15. The other merit of the scale of development promoted by BE2 is the cost savings achievable in the development process itself. For example, shared infrastructure means the costs of providing it are lower per unit of occupation. The margins achieved can be diverted to less commercial, but nonetheless needed and valued services to the cluster are greater. Gazeley, for example, is capturing those margins to promote, as part of its application to extend Magna Park:

* a Logistics Institute of Technology (LIT) in partnership with Aston University and North Warwickshire and South Leicestershire to address the industry's rising needs for more skilled, better qualified labour and for the kinds of applied research innovations needed to continue to drive the industry's sustainable, competitive, growth;

* an 'innovation centre' to supply easy-in, easy-out small business space to encourage new firms to start up and grow on the back of the out-sourcing opportunities the Park provides and the output of the applied research functions;

* a Driver Training Centre to address the shortage of skilled and professional HGV drivers;

* a railfreight shuttle - using low or no carbon fuelled traction units - to provide and 'on- demand' service to nearby DIRFT and on-site container storage, to overcome these hurdles to the take-up of railfreight by Magna Park's largely road-based distribution firms;

* an HGV park, fuelling station and vehicle wash;

* a 70 ha country park and meadow supported by public car parks, public lavatories and shared use of the innovation centre's café - targeted on local communities but also occupiers' employees;

* the dual use of the LIT's campus facilities, including playing fields, with the community and again with Magna Park employees;

* a Local Heritage Centre to exhibit and explain the history of the site's habitation in its landscape and the economic forces that have shaped both, with focuses that include parts of the Key Stages 1 (heritage) and 2 (climate change) curriculum; and

* the re-use of a non-designated heritage asset on the site as a conferencing centre and marketing suite.

16. The value that the logistics cluster is able to return to the economy, environment and local communities is very significantly increased by the addition of these complementary uses. Yet the market - in the absence of the kinds of margins that large scale schemes create - could not and would not be able to deliver these wider uses. Though these uses deliver public benefits in line with policy, constraints on the public finances make it unlikely that funding for such uses will be forthcoming for the foreseeable future.

17. Their delivery at Magna Park is made possible for Gazeley by the sheer scale of the extension scheme, the existing concentration at Magna Park of blue chip logistics businesses to provide an initial customer base for these complementary uses and by Gazeley's proactive engagement with partner bodies for their delivery. The commercial return for Gazeley is achieved by the competitive advantages gained from attracting the industry's best and most socially responsible occupiers.

18. Finally - and again in recognition of how firmly Magna Park is already embedded in the community which hosts it - Gazeley convene and chair a 'Community Liaison Group' which meets quarterly to listen and respond to the concerns of local parish councils and residents groups, operates a community fund of £20,000 per year which awards project funds on a competitive basis to local schools, community groups and charities and hosts annually a family fun day at Magna Park open to the wider community as well as the Park's employees.

19. With all of this in mind, Gazeley suggest the amendments and additions to policy BE2 that are set out below. We also request that a site allocation(s) be made (which if done would obviate the change requested to policy GD3). The certainty of a site allocation(s) would, in Gazeley's view, greatly assist the industry and local communities.

20. The amendments proposed to policy BE2.1 acknowledge the cluster benefits of the concentrating logistics businesses around Magna Park and the consequences for the growth of related but ancillary activities that support or are spun out of the cluster; and the amendments to BE2.2 aim to take advantage of the scale of the development(s) to benefit the community and local environment as well as the wider economy. While it is appreciated that additional criteria are covered by development management policies in other parts of the Proposed Submission Local Plan, these are generic. The scale and nature of the BE2 development and its concentration at Magna Park merits in Gazeley's view a more specific set of criteria.
BE2.1 As drafted)

BE2.1a (As drafted)

BE2.1b. any new building or the change of use of an existing building is only for Class B8, ancillary uses to Class B8 only, or for a use for which a location as part of the Magna Park logistics cluster is necessary and beneficial

BE2.1c. the proposal for any non-strategic storage and distribution use is small-scale, proportionate in scale and function to Magna Park's strategic storage and distribution use and ancillary to the use of individual plots

BE2.2 Additional development of up to 700,000 sq.m. for non rail-served strategic storage and distribution (Class B8) use will be permitted where it would:
BE2.2a form an extension of, or be on a site adjoining, Magna Park;
BE2.2b support or at least have no adverse impact on the viability and deliverability of existing or further Strategic Rail Freight Interchanges (SFRIs) within or serving neighbouring authorities and Leicestershire;
BE2.2c increase employment opportunities for local residents, including training and apprenticeships;
BE2.2d include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District;
BE2.2e not lead to severe traffic congestion anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside; and
BE2.2f ensure 24 hour operations do not have an unacceptable environmental, community or landscape impact
BE2.2e: mitigate significant adverse impacts on the not lead to severe traffic congestion anywhere on the nearby strategic and local road network to achieve nil detriment or better particularly the A5, whether within Harborough District or outside;
BE2.2f include measures to encourage car-sharing, cycling and sustainable alternatives to private car use;
BE2.2g include measures for regular community liaison;
BE2.2h include measures for publicly accessible green infrastructure;
BE2.2i optimise the bio-diversity of the site and its capacity to sequester greenhouse gases;
BE2.2j make use of optimal technologies for the construction of buildings and their operation to reduce resource consumption and optimise the use of renewable energy sources;
BE2.2k achieve the highest practicable environmental standards for buildings;
BE2.2l adopt a design approach to the buildings, materials and lighting to minimise the visibility of the buildings during the day and at night time;





BE2.2m site buildings and service infrastructure to respect the character of the landscape;
BE2.2n site gatehouses, yards and HGV circulation routes so that visual intrusion and noise beyond the site is minimised; and
BE2.2o mitigate landscape and visual impacts using, in particular, tree planting and other species that will optimise carbon sequestration.

More heavy traffic, more pollution, definite loss of wildlife due to habitat loss.

NO THANK YOU - ENOUGH IS ENOUGH

Further development at Magna Park would increase the level of pollution and traffic level more and diminish the quality of life of the local population. The threat to wildlife in the area would be catastrophic

700,000 sq mtrs. 10,000 jobs equates to one job per 70sq mtrs. The local chip shop employ more people per sq mtr.
The company Semi-Lab next to the Magna park site employs many more people per sq mtr and if probably the largest employer per sq mtr in and around Lutterworth and no roads had to be built, altered or widened. All the roads around Magna Park, particularly the A5, are covered in rubber (skid marks) the closer you get to Magna Park suggest some very "dodgy" driving and can only get worse. To lose so much countryside under concrete and tarmac is stupid and irresponsible. Magna Park has had a warehouse standing empty (186,695 sq ft) since it was built! Where then is the demand for more?

Magna Park is already a huge complex which has increased traffic flow in the Lutterworth area. The expansion of Magna Park would bring more jobs, but these positions are most likely to be filled by people commuting from the Leicester city fringes, which will increase traffic. There is virtually no unemployment in the Lutterworth area.
Extra huge warehouses will have an adverse effect on the viability of the area. Likely to lead to excessive traffic congestion on the A5 and M1 junction link.
700,000 sq mtrs of new warehousing is excessive and some of this allocated space could be used to provide a medium size housing estate, suitable for existing Magna Park workers, may workers at Magna Park would therefore no have to travel across Lutterworth town to commute to work, if there was a housing estate in this area.

Extra huge warehouses will have an adverse effect on the viability of the area. Likely to lead to excessive traffic congestion on the A5 and M1 junction link.
700,000 sq mtrs of new warehousing is excessive and some of this allocated space could be used to provide a medium size housing estate, suitable for existing Magna Park workers, many workers at Magna Park would therefore not have to travel across Lutterworth town to commute to work if there was a housing estate in this area.

The Plan includes 700,000 square meters expansion at Magna Park. Given the impact this will have on air quality and traffic congestion in the Lutterworth area, this is totally unacceptable.

I object to a further expansion of Magna Park which does not comply with the Local Plan for the area.
* 100,000 sq mtr has already been granted.
* The current proposal for 700,000 sq mtr would allow the approval of a further 2 outstanding applications for expansion of the site. Why is there a need for further expansion when there is another planned around the M69/A5 junction with a rail link.
Why increase the commuter traffic of low paid workers from outside the area when unemployment in Harborough and particularly Lutterworth is as low as 2%

I do not feel the proposal to expand Magna Park by 700,000m2 is sound for the reasons below:
The local plan should "contribute significantly to wider sub-regional requirements for road based strategic distribution business space" but in this instance there is no evidence that there is a need for this amount of this type of development in this one place. There is already a large amount of warehousing along the A5 corridor, much of it linked to a rail head and it would seem to offer a broader range to the potential employment opportunities to allow other areas of Leicestershire to pick up a larger part of the development allocation.

The proposal matches planning applications which have already been submitted. These applications were contra to the previous local plan, which felt Magna Park had expanded sufficiently. This proposal now seems as if it is only included to take advantage of an arising opportunity and not because it is a rationally thought through scheme and offering the best solution for the area.

Further the local plan should "reduce the dependence of Harborough's residents on commuting and increasing wage rates by providing a breadth of employment opportunities" but in this instance most of the employment opportunities provided by the proposed warehouses are low skilled and low paid. Unemployment figures in Harborough District are low and the majority of current employees at Magna Park are commuting in from outside the area. There is no need, within the district, for yet more jobs of this nature.

I am deeply concerned about any development which increases traffic on this part of the A5, a road already identified in the Midlands Connect Strategy 2017-2030 as inadequate, with no accompanying proposals for upgrading. More commuters and more warehousing will mean more HGVs and more commuting cars, putting pressure on smooth traffic flow, increased accident risk, poor air quality and noise pollution, which will bring no benefits to local residents. Local groups have produced plentiful evidence showing that further development at Magna Park will bring no benefit and will adversely affect the local area and its residents but HDC has refused
to take any account of this evidence and has persisted in pushing forward these proposals. They are currently planning to consider the 2 relevant development applications before this Local Plan has been approved or even considered by the Inspector, which seems to demonstrate a complete lack of will to give consideration to valid representations or due process.

Not positively prepared:
* The proposal is not strategic or aimed at meeting the District's employment needs, but opportunistic, as the sum of two planning applications, is used as evidence, that this amount of land ( 700,000 sq metres ) is needed here for more warehousing.
* Using this proposed amount of land for more warehousing exceeds the LLEP SDS, 2017 findings for the demand of non- rail warehousing across all of Leicestershire. It ignores the study's recommendation that the shortfall in warehousing should be spread across the county, and has the likelihood of creating an oversupply of warehousing.

Not Justified
* LLEP SDS, 2016 advocates that meeting the demand for more warehousing should be spread across Leicestershire, with Harborough District contributing. As Magna Park has now been granted an extra 100,000sq m warehousing, then allowing more, would rob other areas in the county of employment opportunities.
* LLEEP SDS, 2016 recommends that new warehouses are sited close to areas of employment need , and deem sites unsuitable , if they have an unlikelihood of filling job vacancies . Magna Park is unsuitable, as currently it is struggling to recruit workers, as there is under 2% unemployment , ( The Office for National Statistics 2017), in the district, (especially the Lutterworth area), and competition from other distribution centres , ( like DIRFT, and Rugby Gateway ) in the vicinity.
* The proposed 10,000 job will not meet the plan's aim of increasing the breadth of employment alternative , as warehouses generate a narrow range of job types, with the majority being warehouse operative jobs. These are temporary, low-paid, and unskilled. Consequently, there will be a massive glut of these , and little scope for higher and intermediate - skilled people.
* The proposal contradicts the plan's aims of meeting local employment needs. The plan declares that Harborough has one of the highest skills profile, and wants to encourage a well- educated workforce, therefore it should make provision for well- paid , skilled work, like technology and engineering, not support the creation of 10,000 more warehouse jobs, that in many cases will mismatch people's skills.
* As Magna Park already has job vacancies and most employees commute from outside the District, then providing many more of the same job types , in this area of exceptionally low unemployment, will not achieve the plan's aim of reducing out - commuting. For this to be met, the District needs to provide a variety of employment to match people's different abilities.
* Vastly increasing the number of jobs at Magna Park will greatly increase in- commuting, which together with the increased number of HGV's , will greatly exacerbate the congestion and and delays on strategic and local roads , so hinder employees and the fluency of business.

Not Justified:
* LLEP SDS, 2016 advocates that meeting the demand for more warehousing should be spread across Leicestershire, with Harborough District contributing. As Magna Park has now been granted an extra 100,000sq m warehousing, then allowing more, would rob other areas in the county of employment opportunities.
* LLEEP SDS, 2016 recommends that new warehouses are sited close to areas of employment need , and deem sites unsuitable , if they have an unlikelihood of filling job vacancies . Magna Park is unsuitable, as currently it is struggling to recruit workers, as there is under 2% unemployment , ( The Office for National Statistics 2017), in the district, (especially the Lutterworth area), and competition from other distribution centres , ( like DIRFT, and Rugby Gateway ) in the vicinity.
* The proposed 10,000 job will not meet the plan's aim of increasing the breadth of employment alternative , as warehouses generate a narrow range of job types, with the majority being warehouse operative jobs. These are temporary, low-paid, and unskilled. Consequently, there will be a massive glut of these , and little scope for higher and intermediate - skilled people.
* The proposal contradicts the plan's aims of meeting local employment needs. The plan declares that Harborough has one of the highest skills profile, and wants to encourage a well- educated workforce, therefore it should make provision for well- paid , skilled work, like technology and engineering, not support the creation of 10,000 more warehouse jobs, that in many cases will mismatch people's skills.
* As Magna Park already has job vacancies and most employees commute from outside the District, then providing many more of the same job types , in this area of exceptionally low unemployment, will not achieve the plan's aim of reducing out - commuting. For this to be met, the District needs to provide a variety of employment to match people's different abilities.
* Vastly increasing the number of jobs at Magna Park will greatly increase in- commuting, which together with the increased number of HGV's , will greatly exacerbate the congestion and delays on strategic and local roads , so hinder employees and the fluency of business.

Not effective:
* Leicester and Leicestershire Strategic Growth Plan HEDNA (2017) recognises that since the study 's start in 2011, new developments, or local authorities earmarking land for warehousing, will have continually reduced the need for warehouses. Since the latest report Magna Park has been granted an extra 100, 000 square metres, and several miles from Magna Park, millions of square metres of warehousing land has been agreed during the last 2 years, so an additional 700,000 sq m at Magna Park will create a huge oversupply of warehouse land .
* Green space separation zones are proposed between Magna Park and Bitteswell and Lutterworth, but none are indicated between Magna Park and Cotesbach and Ullesthorpe

Inconsistent with NPPF:
* The NPFF is encouraging warehousing at rail-served sites. Magna Park has no rail head, but close to it are warehouses that do, and another is planned around M69/ A5 junction.
* Disregards NPPF objectives to take into account the cumulative impacts on air quality in an air quality management area. Since 2001, Lutterworth has been an air quality management area, as its nitrogen dioxide levels are exceedingly high, primarily from the huge volume of traffic generated by the 24 hour operation of Magna Park. (2013 Lutterworth AQMAAP for HDC. ) Air Quality Action Plans have aimed to reduce these levels, but to no avail, so they still exceed air quality objectives ( 2017 Annual Air Quality Status Report.) Massively expanding Magna Park will generate enormous amounts of extra traffic that will exacerbate Lutterworth's air pollution.

I consider this sham democracy. The 700,000 sq mtr is the exact measurement of two planning applications to be considered in November 2017. If the applications are approved, then the 700,000 sq mtr in the Local Plan will be used up before its confirmation. This pointless and also makes the Consultation pointless as a decision will be made before our views are heard. 100,000 sq mtr has already been approved so that only leaves 600,000sq mtr. The 700,000 sq mtr stated is an error and overstates the Harborough District Council's own perceived need.
Key Issue 3 states that the Local Plan should be contributing significantly to the wider sub-regional land requirements for road based strategic distribution business space.
I believe the proposal is opportunistic, does not meet local employment needs & is not strategic but income drive.
There are research reports that suggest that demand for non rail warehousing across Leicestershire is less than the 700,000 sq mtr quoted in the plan. By not spreading the need across the county, Lutterworth will suffer an over supply of warehousing.

Harborough District Council was advised by Consultants that its choice of the level of development at Magna Park would be a political decision. Placing such a large amount of warehousing around Magna Park would deprive other parts of the county of this employment opportunity but also encourage those living in other parts of the county to drive to Magna Park, thereby adding to the pollution around Lutterworth that already fails the pollution levels.
Since the research reports for the plan were commissioned 100,000sq mtr has already been approved. Also, in the last couple of years, since these reports a million square meters of warehousing have been approved within a few miles of Magna Park. It could be argued that this area already has an over supply of warehouse land being developed.
Key Issue 3 also states "reducing dependence of Harborough's residents on commuting and increase wage rates by providing a breadth of employment alternatives, including more opportunities for Harborough's higher skilled residents..."
The District has very low employment rate indeed. This is particularly so in the Lutterworth area where the 700,000 sq mtrs is proposed. Magna Park employers already have great difficulty recruiting. This is being exacerbated by DIRFT which is way ahead on its development, Rugby & East Midlands amongst others. These developments are recruiting out of the same small pot of suitably qualified individuals.
The majority of current employees at Magna Park commute into the area. Due to the negligible unemployment in the area, in-commuting would be increased excessively. The local major and minor roads are already overcrowded and come to standstill if there is an accident on M1, M6 or M69 as all traffic is sent along the A5. If the movement of people after Brexit is reduced it is difficult to see how these additional employees will be recruited. Many current employees are from other countries within Europe. Already many are returning home where earnings have increased or moving to other EU countries. This probably because many jobs at Magna Park are low wage or zero hours - referred by local recruitment companies as flexible hour contracts.
10,000 plus extra jobs at Magna Park will increase in-commuting and not reduce out-commuting as claimed. If the jobs were relevant to the out-commuting people of Harborough & more importantly Lutterworth (and vice versa) then the out-commuting would already have been reduced materially.
The NPPF states that the preference is for warehouse/distribution sites to be placed on railheads. Magna Park is not a railhead. There are already other railhead warehouse/distribution sites nearby and another planned near the M69/A5 junction.
Midlands Connect Strategy 2017-2030 already recognizes the inadequacy of the A5. The strategy does not include any major upgrading of the A5 around Magna Park before the end of this period - 2030. The many extra HGV's, other distribution vehicles and 10,000 in-commuting employees will add to the already overcrowded roads. This will lead to even more congestion and pollution. The congestion will cause delay to all, an increase in rat-running through small villages with narrow roads. All this will impact on businesses & employees beyond those at Magna Park. The local economy will suffer rather than improve.

- Dramatic increase in freight traffic on all roads in the area. The a5 and on minor roads.
- The increase in traffic will mean an equal increase in air pollution.
- There will be a dramatic loss of wildlife habitat.
- Light pollution will blight the surrounding area.
- There has been extensive objection to the proposal therefore the policy is not sound as there is now a total lack of democracy in it being put forward.
- The proposal does not follow due to process and the evidence presented to support it is bias.
- Despite the major increase in inbound and outbound freight traffic there is no commitment to a rail head.
- The expansion taking place at DIRFT, just down the A5, which does has a rail head, is better placed to take any perceived increase in logistics.
- There is virtually no unemployment in Lutterworth and thus the majority of all new employment envisaged will mean in bound commuting.

My concerns with the plan start with its title. It cannot be retrospectively applied to year 2011. By the time it is adopted we could well be in year 2019 if not 2020. 2011 is already 6 years past. Events have overtaken it.

Secondly there is a complete imbalance in the proposals. It would appear that a line has been drawn across the district following the route of the A6 road and all "hard landscaping" development proposals concentrated to the west of this road with the consequential loss of agricultural land particularly in the southwest corner in the Lutterworth area and very little to the east of this road. Times change, circumstances alter; the plan leaves little room to accommodate such events.

Policy H6
Consistent with the above observation of imbalance, all the existing and proposed traveller sites apart the site at Keyham are concentrated around the Lutterworth and Market Harborough areas. Another site between Ullesthorpe and the Claybrookes is not needed nor is it desirable. Additional provision should be made in the eastern half of the district where at present there is a shortage.

Policy BE2 (Magna Park)
It is noted that the plan allows for the expansion of Magna Park subject to certain criteria, one of which is the effect of traffic flows on the local roads and A5. The area around Magna Park does not have an unemployment problem consequently any expansion will create commuter traffic to and from the site as well as increase the flows of HGVs servicing the site. The plan should state emphatically that no expansion of the Magna Park be entertained until, i. there is an unemployment crisis in the Lutterworth district and ii. The A5 trunk road is majorly improved along its whole length from the M1 to the M42 with a dual carriageway and safety improvements at all its junctions with the minor roads with which it interconnects.

My major concern relates to incremental traffic flows and movements relating to the industrial and residential developments in the south and west of Lutterworth.

Your reference to the 'Golden Triangle' raises significant issues on the pre and post development road infrastructure surrounding Lutterworth. Notwithstanding the intent to build an eastern by pass around Lutterworth which will support both heavy inter-regional traffic flows on a north-south trajectory of the town but also encompass residential developments and related traffic flows in the area, It is my firm belief that there are critical infrastructural faults with existing routes (A4303, A426, and the A5). These routes are already very congested as they connect with main routes from and to the M6 (especially to and from the North). The development of Magna Park and DIRFT (together with the latter's new town devleopment) will further increase the strain on A4303, A426 and A5 which in their present state are not fit for purpose.
The loss of access to M6 north is an important traffic generator within this 'Bermuda Triangle' with regional and local industrial traffic now forces much more flows on to the A426 and A5 with poorly developed connections to M6. Before the new A14/M6/M1 junction at Catthorpe was completed, there was an alternative direct link from the M1 South to M6 North - this was severed in 2015. The infrastructure is poor and mainly single carriageway between DIRFT, Magna Park and
the M69 creating further problems.

A related point is that these key roads (A426, A4303, A5) are in the front line when there are problems on the M1 and M6 in the area (M1 junction 19-20, A14-M6 junction 1-2) which again has major negative effects on traffic around Lutterworth.

In my opinion, the developments planned should not go-ahead without the infrastructural problems of the A426, A4303 and A5 being solved.

I have been a resident in the area since 1982 and have seen at first hand the infrastructural effects of developments in the area.

Severe increase in freight traffic on all roads in the area, the A5 and on minor roads. Increased traffic means equal increase in air pollution. Any increased pollution will blight surrounding areas. There has and will continue to be extensive objection to the proposal. Therefore the Policy is not sound as there is now a total lack of democracy in it being put forward. Proposal does not follow due process and the evidence presented to support it is bias. The expansion taking place at DIRFT, just down the A5 which does have railhead is better placed to take any increase in logistics.

The landowners of Whetstone Pastures, duly object to the failure of the Council to recognise the potential to:

* Identify land within Whetstone Pastures as a future logistics park; and more over
* Recognise the ability of land within Whetstone Pastures to deliver a new Garden Village as part of a large strategic allocation extending over the administrative boundaries of both Blaby and Harborough.

2 On this basis objections are duly made insofar as SS1 - The Spatial Strategy is not 'sound' insofar as it is not:

* Positively Prepared as it fails to meet objectively assessed development needs and infrastructure requirements, including, where they arise, potentially making an appropriate contribution towards meeting unmet requirements from neighbouring authorities;
* Justified in that the plan is not based on the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
* Effective in that the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy as the plan does not enable the delivery of sustainable development in accordance with the policies in the NPPF.

3 With regard to SS1 it is submitted the following strategic priorities of the Local Plan (pp. 9) are not fully met:

* SP1: Meeting the housing and employment needs of the Leicester and Leicestershire housing and economic market areas;
* SP2: Assisting other local authorities to meet their unmet housing need; and
* SP3: Meeting regional and national demand for strategic distribution (logistics) development.

4 This is predicated on the basis that:

* Policy H1 - fails to make provision for sufficient new housing for the Plan period;
* Policy BE1 - fails to make provision for sufficient new business development for the Plan period; and
* Policy BE2 - fails to identify land at Whetstone Pastures as a potential logistics park.

5 Policies H1, BE1 and BE2 are effectively drafted on the basis of Harborough meeting its own objectively assessed needs. Accordingly, the draft Plan fails to recognise the wider needs of its neighbours as established in January 2017 when the Leicester and Leicestershire Authorities (including Harborough and Blaby) and LLEP jointly published its HEDNA which identifies the future quantity of housing and employment land needed in Leicester and Leicestershire up to 2031 and 2036.

6 The HEDNA has identified an Objectively Assessed Need for 117,900 dwellings between 2011 and 2036 across Leicester and Leicestershire. The need for larger more strategic warehousing and distribution units across Leicestershire is set out in the Leicester and Leicestershire Strategic Distribution Study 2015 (updated in 2017).

7 Leicester City Council has indicated that there will be unmet housing need within the City. A letter from Leicester City Council to all the other local planning authorities in the HMA dated 13th February 2017 stated that;

"the scale of the need [OAN] set out in the HEDNA is of such magnitude that it is concluded that there will be an unmet need arising in the city'. An additional letter sent on the same day to the Planning Inspector for the examination of the North West Leicestershire Local Plan set out 'our formal declaration of unmet housing need arising in the city."

8 In addition to setting out the future housing and employment requirement the document recognises that there is a need for all authorities within the Leicester and Leicestershire Housing Market Area to work collaboratively to account for the distribution of any identified unmet need.

9 On the basis of the foregoing local authorities have a statutory Duty to Cooperate over such matters and to identify how any such needs would be met. A Memorandum of Understanding (MoU) is currently being prepared by the 9 local authorities within the HMA (including Harborough). This document will identify how any unmet housing needs will be accommodated and will be signed by each authority as a binding agreement.

10 Given that the unmet needs of Leicester City Council should be addressed within the period of the Harborough emerging Local Plan the landowners are very concerned that there is no flexibility within the Plan to demonstrate how Harborough will accommodate unmet need through policies H1, BE1 and BE2 to meet this need.

Harborough DC - New Local Plan Options

11 The Council will be aware of representations made to Harborough DC - New Local Plan Options document (2015) by Nathaniel Lichfield & Partners (NLP) on behalf of Prologis UK Limited (Prologis). The representations principally related to proposals for a new logistics park on land between junctions 20 and 21 of the M1.

12 In broad terms the landholding related to an area in excess of 185 ha to the east and west of the proposed new M1 junction 20a (Whetstone Pastures Estate). The land is located to the south east of Cosby and west of Willoughby Waterleys. The Estate straddles the administrative boundaries of both Harborough and Blaby.

13 At the time of the submission the landowners and Prologis were promoting:
A new motorway Junction 20a on the M1 to relieve congestion at Junction 21 and to help remove an obstacle to further economic development;
* A new motorway service area to replace the existing Leicester Forest East motorway service area allowing for the managed motorway programme to be introduced; and
* A new 370,000 sq m logistics park on approximately 80 ha next to the proposed Junction 20a that would deliver over 6,000 high quality jobs in a wide range of roles.

14 Representations were duly made and recorded as follows:

* New Local Plan Options (September 2015), (rep. ID 2680 / 4242); and
* 'Sustainability Appraisal - Second Interim Report Appraising Options for Strategic Distribution Growth (February 2016) (rep ID 5327 / 5326 and 5245).

15 The representations were endorsed by the landowners in a follow up written submission lodged by Strutt & Parker on the 28th June 2016.

A New Garden Village

16 Since these submissions Blaby District Council, with the support of Leicestershire County Council and the Leicester and Leicestershire Local Enterprise Partnership (LLEP), made a submission in response to the Department for Communities and Local Government (DCLG) and Home and Communities Agency's (HCA) invitation for Garden Village proposals in July 2016.

17 The proposed Garden Village would be focused around a new M1 junction at 20a. The total site area would extend to approximately 400 hectares and would include the 185 hectares previously identified for the logistics park. Whilst the majority of the site falls within the administrative boundary of Blaby some 15% of the southern part of the landholding lies in Harborough. Please see attached map for more detail.

18 Whilst the bid was not successful the HCA in their individual letter of response went on to encourage the continued pursuit of the Garden Village idea:

"The HCA is responsible for delivering the Garden Villages Programme for the DCLG and we recognise the potential of your proposal. We would like to have a conversation with you around how we can best support you in progressing your Garden Village ambitions. There is scope for us to offer support from our planning Team ATLAS, from delivery specialists in our teams and in HCA's Land Team. We hope to open another round of Garden Village Funding in 2017/2018 and offer guidance in preparing applications."

19 Blaby District Council are continuing to work with the landowners to deliver a shared vision for the Garden Village proposals.

20 The proposals are at an early stage. However, the Local Authority and landowners have a shared goal to develop the ideas into fully-fledged proposals over the next 12-24 months. In broad terms it is envisaged that the Garden Village would offer a unique opportunity to deliver truly sustainable strategic growth; comprising of a new community, large scale employment opportunities and considerable benefits for the surrounding highways network. Specifically the plans would ensure:

* The delivery of a new M1 Junction (J20a):
* Approximately 280,000 sqm employment and logistics park; and
* In excess of 3,500 homes.

It is envisaged that this sustainable new community would deliver facilities including schools, healthcare and sports, and green and blue infrastructure, new local shops and other community facilities, all set within an attractive landscaped network of streets and parks. All this on a site located approximately 5km from the major commercial hub of Leicester City Centre.

Harborough Local Plan 2011-2031: Submission
14 February 2018: Follow-up Representation by Gazeley

This Representation and Objection:
Gazeley, the owner of Magna Park, submitted its representation on Harborough District Council's (the Council) Proposed Submission Local Plan on 17 November 2017, the deadline for representations.
Though broadly supportive of the Plan, Gazeley requested a minor change to GD3 to make it consistent with BE2 and more substantial changes to strengthen BE2, including a request that BE2 be made sound by the inclusion of site allocations on the Policies Map. The Council has proposed the minor change to GD3, but is proposing no substantial changes to BE2.
Gazeley, therefore, while supporting the principle of BE2, objects to the absence of site allocations in the Policies Map.
BE2 seeks up to 700,000 sq m of strategic distribution floorspace where it will form an extension of, or be on a site adjoining, Magna Park but makes no site allocations. The Council reasons that none is needed because the policy is 'criteria based' and there are also precedents for the approach elsewhere in the Submission Plan. Gazeley, however, disagree and object on the basis that BE2 is unsound as drafted because it is incapable of delivery and therefore is not effective.
For the Local Plan to be sound - positively prepared in response to the strategy for meeting the evidenced need and effective in being deliverable over the plan period - the site allocations for BE2 are essential.
Gazeley's Rationale for a Late Objection
Gazeley has submitted two planning applications to extend Magna Park, both EIA developments. The first, for 100,944 sq m strategic distribution space on a 56 ha site to the north west of and adjoining Magna Park was permitted in October 2016 (the First Application). The second (the Second Application) was refused following a call-in by the council of the decision of the council's planning committee to grant planning permission on 23 November, shortly after the deadline for the representations on the proposed submission plan.
The Second Application was in two parcels, both of which - as sought by BE2 - extend Magna Park: the Zone 1 parcel was for 232 ha in total (including the site of the permitted 56 ha scheme forms part) to add a further 318,956 sq m of strategic distribution floorspace plus a Logistics Institute of Technology (4,300 sq m plus playing fields), Innovation Centre (2,325 sq m), HQ for a local high tech firm (7,000 sq m), Local Heritage Centre, 70 ha Country Park and a further 33 ha of green infrastructure, SUDS etc; and the Zone 2 parcel was for a 7 ha site (which also extends Magna Park and benefits from an existing consent) for an HGV park, driver training centre and road-based railfreight shuttle and terminal to serve Magna Park's firms who already account for 16% of all trips into and out of the Daventry International Railfreight terminal.
As of 17 November, Gazeley had received the officers' report to planning committee on the Second Application, and it recommended that planning permission be granted. No professional officer in the Council or for a statutory consultee objected to the scheme, the Council's officers' considered the balance of economic, social and environmental benefits to outweigh the limited residual harm that remained, in no case significant.
Another planning application, by db symmetry for 279,708 sq m of strategic distribution space on a site opposite to Magna Park, was also considered by the 23 November 2017 planning application, and it too benefited from a recommendation to approve and it too was granted. However, the db


symmetry planning application was not called in for redetermination by the Council. The issue of the planning permission for the db symmetry application is subject to confirmation from the Secretary of State as to whether he will call-in the application for his determination and completion of the S106 agreement.
Gazeley did not object to the absence of site allocations for BE2 in time for the 17 November 2017 date for representations, but requested that they be made. At that point, given the officers' report's recommendation to grant planning permission for both the Second Application and the db symmetry application, the expectation was that the resolution to grant the two permissions on 23 November 2017 would give effect to Gazeley's request.
While the Second Application satisfied the location, quantum and criteria provisions of policy BE2, BE2 itself could have little weight in the planning determination, although the evidence base for BE2 carried very significant weight as it continues to do. Extensions to existing sites in areas of opportunity (of which Lutterworth is one) are the first preference in the evidence base for meeting the needs of the logistics industry in the county for a minimum of 608,000 sq m of additional road-based strategic distribution floorspace; and the grant of the First Application established the acceptability of the principle of the principle of extending Magna Park to contribute to that need, notwithstanding the conflict with Core Strategy CS7h which precludes such expansion.
It is difficult to see how BE2 could be implemented in the absence of allowing for the remainder of the need to be met on Gazeley's Second Application site. There are no other options that would extend or adjoin Magna Park and come close to the BE2 quantum. The green wedge adjoining the eastern boundary of Magna Park is safeguarded by the Submission Plan, although part of the green wedge was granted planning permission on appeal for 250 dwellings on lad adjoining the Lutterworth boundary (APP/F2415/W/16/3151978).
It is also the case that Magna Park sits within the countryside, and thus any expansion scheme capable of meeting the quantitative need promoted by BE2 - in the large scale distribution units the industry requires - could not but have significant landscape and other environmental effects that would require suitable and effective mitigation.
Finally, it is also the case that the SA for the Submission Plan (September 2017, Section 19, pages 166-170) assessed seven candidate strategic distribution sites, of which two cover the sites of the First and Second Applications and a third the db symmetry application, and did so in the context of a preference, all SA objectives considered, for the 'high growth' (700,000 sq m) scenario that BE2 promotes. The SA's assessment focused on the 'baseline conditions' for each site, highlighting where development might be more likely to generate significant effects but also noting that the individual development schemes could propose measures to tackle potential constraints and opportunities.
The SA concluded that there was little to distinguish between the sites at the high level at which the appraisal was conducted but that 'the ability to secure enhancements, highways access and transport modelling [would] need to be taken into consideration alongside the SA findings'. The SA also went on to conclude that the high growth (up to 700,000 sq m) scenario with focus on Magna Park was preferred (see Appendix G), but that BE2 should adopt a criteria-based approach 'to avoid prejudicing the treatment of pending applications, and the emerging Strategic Growth Plan for the HMA.'
In fact, of course, neither consideration is a reasonable basis for precluding site allocations. The SA has no role in development management, and the Strategic Growth Plan, now published, simply acknowledges the need for additional land for strategic distribution in the county and notes that Government's Midlands Engine Strategy (2017) includes what it calls the 'Magna Park Distribution Centre' as an economic growth area.


If BE2, most particularly the quantum of floorspace to be located where it will extend or adjoin Magna Park, is to be an effective policy, then BE2 also needs to be capable of implementation. As it stands, it is not and as a consequence BE2 is not sound in the terms of NPPF 182 bullet 3. It stands to reason that site allocations would resolve this soundness hurdle. SA Table 19.2 also provides an adequate basis for selecting those sites from the alternatives considered.
Gazeley therefore suggest that the better performing of the Table 19.2 sites, having regard to the BE2 quantum and location requirements and the need for consistency with the other policies of the Submission Local Plan (e.g., are not sited within the GD6 green wedge that adjoins Magna Park on the east), should be allocated. These are sites E/012OC/15 (First Application), E/010OC/15 (Second Application) and E/009OC/15 (db symmetry application).
As with any site allocation in a Local Plan, subsequent planning applications can be assessed in the usual way following due process. In this case, BE2 already establishes the principle that up to 700,000 sq m of additional strategic distribution floorspace should be accommodated on land that extends or adjoins Magna Park. The SA rejects a lower growth option for strategic distribution for the reasons it explains. Allocations, as Gazeley propose, would make BE2 sound, and would in no way predetermine planning applications that seek to develop the allocated sites. Instead, BE2 would do the job of it that the NPPF requires: providing a sound basis, and the certainty needed, for the market to respond to the opportunities otherwise positively promoted by BE2 to supply the industry with the floorspace it needs in an optimal location in line with the BE2 evidence base.