Harborough Local Plan 2011-2031, Proposed Submission

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.

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.

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.

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.

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.

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.

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.