6.1.4 TO 6.1.7 explanation

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Object

Harborough Local Plan 2011-2031, Proposed Submission

Representation ID: 7275

Received: 17/11/2017

Respondent: Prologis UK Ltd.

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Reasons summarised as:
- does not provide a clear and comprehensive approach as para 6.1.7 / Table B.10 excludes strategic distribution
- Table B.11 Sources of Employment Land Supply needs to be updated to accurately reflect the position (i.e. planning consent 15/00919/FUL)
- unclear whether the plan meets objectively assessed employment need because the Council has not provided all the evidence to justify that the approach to general new business development combined with strategic B8 development is justified.
- overall employment land requirement not robustly justified. Further work needed to justify that this amount is appropriate and deliverable.

Full text:

4.0 Policy BE1 Provision of new business development
4.1 Policy BE1 provides for a supply of employment land in accordance with the settlement hierarchy and strategic aims of Policy SS1 The spatial strategy. Policy BE1 states that in addition to the delivery of existing commitments, a minimum of 59 hectares for office B1 (a) and (b), industrial B1(c) and B2, and non-strategic storage and distribution B8 will be focussed on development at Market Harborough and Lutterworth (particularly within the SDAs) as the District's main economic centres, and at Rural Centres all of which are well located, served by infrastructure and are accessible by sustainable modes of travel.

Consideration of Policy
4.2 Prologis UK Limited and RRSLP object to the Council's approach to the identification of employment land because it does not provide a clear and comprehensive approach. The Reasoned Justification (para.6.17 and Table B.10) identifies gross need for B Class employment land in Harborough District, excluding strategic distribution (B8 use in units over 9,000sq.m. gross floor-space), as a minimum of 51 hectares between 2011 and 2031 (HEDNA, Table 83). Prologis and RRSLP note that in line with the comments made in relation to Policy SS1, the Sources of Employment Land Supply (hectares) needs to be updated to accurately reflect the position. It is unclear why the Council has decided to exclude strategic B8 floorspace from the table when the approach to ensuring sufficient employment land needs to demonstrate that a comprehensive approach has been taken.

Tests of Soundness
4.3 Prologis and RRSLP considers that Policy BE1 fails to meet the following tests of soundness because it is not:
1. Positively Prepared: It is unclear whether the plan meets objectively assessed employment needs because the Council has not provided all the evidence to justify that that their approach to general new business development combined with strategic B8 development is justified. Whilst the Council state evidence is contained within the Leicester and Leicestershire Housing and Economic Development Need Assessment (HEDNA), SELAA, HDC Existing Employment Area Review (EEAR), L&LSDSS and L&L SDSS Update we do not consider that their approach to the amount of employment development is justified. We have made comments on the duty to cooperate above and do not seek to repeat them here.
2. It is not justified: The Council has not robustly justified its overall employment land requirements. Further work needs to be undertaken in order to justify that this amount of development is appropriate and deliverable.

Recommended Change
4.4 In order to address the conflicts identified above and ensure that Policy BE1 is sound, it is requested that the Council:
1. Provide a table setting out a clear strategy for all employment land needs for the period 2011-2031. This should include office (B1), industrial (B2), general distribution (B8) and strategic distribution (B8) so there is a clear hierarchy of need.