BE2 2b.

There is no rail link to Magna park. Dirft at Crick has the rail link and that is already being expanded. We will have too much warehousing in the area.

There is a large and growing SRFI a few miles down the A5 at DIRFT. Another is being mooted by dbSymmetry a few miles north of Magna Park, alongside the Leicester-Nuneaton railway line (part of the line beween Felixstowe Docks and the West Coast Main Line. East Midlands Gateway is another SRFI currently under construction in the region. Non-rail linked strategic distribution centres are cheaper to build and if lower costs are passed on to client companies, this risks undermining the viability of rail-linked interchanges.

This plan does not accord with the emphasis contained in the National Policy Statement for National Networks (NPS), issued after the NPPF, which contains strong support for SRFIs, viz: "The Government .... believes it is important to facilitate the development of the intermodal rail freight industry. The transfer of freight from road to rail has an important part to play in a low carbon economy and in helping to address climate change." (Paragaph 2.53)

In this respect, too, the draft plan fails to meet the test of soundness. It is inconsistent with achieving sustainable development, it is not the most appropriate strategy, when considered against the reasonable alternatives, it fails in this respect, too, to demonstrate that it is based on effective joint working on cross-boundary strategic priorities and is inconsistent with national policies

I am concerned that the draft Local Plan has the potential to undermine environmentally less damaging strategic rail-served interchanges, such as DIRFT, 9 miles down the A5, which is currently being expanded, and East Midlands Gateway, currently under construction. Harborough Council will also be well aware of plans being developed for a SRFI at Stoney Stanton within the county in neighbouring Hinckley District. A 74,976 sq.m. project (non-strategic) approved at Ashby de la Zouch (North-west Leicestershire District) has been advertised for the last two years, for which the developers IDI Gazeley, who seek to expand Magna Park, have, it would appear, yet to find tenants. The Local Plan ignores the government's National Policy Statement for National Networks (NPS), which postdates the NPPF.

The lower cost of building non rail-served sites will be passed down to the occupiers and thus favour these sites over the more expensive rail-served projects.

Not Justified - what evidence is within the supporting information to demonstrate that Magna Park expansion will not have an adverse impact on further SRFIs? Prologis at DIRFT III had already objected to 15/01531/OUT on grounds of market saturation risk

There is no rail freight facility in the immediate vicinity therefore an increase in road traffic/decrease in rail freight would be inevitable should this extension be permitted.

I oppose the objective because I do not think it realistic.. Building SRFIs is an expensive business, while building a non-rail-served centre along an existing trunk road or motorway junction is cheaper. Lower construction costs of the latter can be passed on to the occupiers of the warehouses, thus making them more competitive and undermining the environmentally less damaging SRFIs. The nearest SRFI to Magna Park is DIRFT, only 9 miles away via the A5. DIRFT is currently undergoing expansion. To approve expansion at Magna Park on the scale envisaged in the draft Plan could put the success of further lettings at DIRFT in jeopardy. (Please note, I have no connection with DIRFT whatsoever). Another approved SRFI in the LLEP study area is the East Midlands Gateway, on which work is already underway. A 75,000 sq.m. rail-served non-strategic centre at Ashby de la Zouch has had consent and has been advertised for the last two years (during which time two applications for expansion totalling 700,000 sq. m. at Magna Park have been waiting for approval) without any takers. Are potential clients waiting for a cheaper option to come on stream soon?

Non-rail-linked centres place more pressure on the road infrastructure (in this case the A5 and A426 in particular, both in terms of congestion and damage, and cause more pollution.

Policy BE2 is in conflict with the National Policy Statement on National Networks (NPS), 2014.

Daventry district council have indicated that excessive over development and over supply of distribution space in the area, (magna park or other distribution sites) will have an adverse effect commercial viability at DIRFT and DIRFT 2 distribution centre which has the governments preferred SRFI rail served distribution. and is located also joining the motorway for HGV Movements.

There is a large SFRI site a few miles southbound along the A5, DIRFT. There is no evidence provided that demonstrates the Magna Park allocation will not have an adverse impact on further SRFIs, particularly DIRFT. One of the outstanding applications, 15/01531/OUT (IDI Gazeley), has been objected to by Prologis III at DIRFT on grounds of market saturation risk. It should also be noted that the National Policy Statement for National Networks (NPS) strongly supports SRFIs. There are no rail freight assets at Magna Park, there is a large SFRI very close by and a new one planned around the M69/A5 junction, therefore, the proposed policy conflicts with paragraph 31 of the National Planning Policy Framework (NPPF):

31. Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development, including large scale facilities such as rail freight interchanges, roadside facilities for motorists or transport investment necessary to support strategies for the growth of ports, airports or other major generators of travel demand in their areas. The primary function of roadside facilities for motorists should be to support the safety and welfare of the road user.

There is a large SFRI site a few miles southbound along the A5, DIRFT. There is no evidence provided that demonstrates the Magna Park allocation will not have an adverse impact on further SRFIs, particularly DIRFT. One of the outstanding applications, 15/01531/OUT (IDI Gazeley), has been objected to by Prologis III at DIRFT on grounds of market saturation risk. It should also be noted that the National Policy Statement for National Networks (NPS) strongly supports SRFIs. There are no rail freight assets at Magna Park, there is a large SFRI very close by and a new one planned around the M69/A5 junction, therefore, the proposed policy conflicts with paragraph 31 of the National Planning Policy Framework (NPPF):

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.