Harborough Local Plan 2011-2031, Proposed Submission

We wish to register our objection to Policy BE1 as it is not effective or justified when considered against reasonable alternatives. Specifically, we object to the following:

1. the lack of sufficient options/ alternatives for the delivery of employment land in Lutterworth during the early stages of the Plan;
2. the absence of suitable allocations for the provision of B1 office use.

It is noted that only two sites in Lutterworth have been allocated to provide the 26 hectares of additional employment land required during the Plan period. The majority of the 26 hectares is proposed to be provided as part of the 'East of Lutterworth Strategic Development Area (SDA)' which the Council acknowledges will be delivered "over an extended time period" (Local Plan, para 15.2.27). Whilst the Council have indicated that 'Land to the south of Lutterworth Road/ Coventry Road will ' " ...provide new employment land for Lutterworth prior to the provision to be made as part of the East of Lutterworth SDA" (Local Plan, para 15.4.1), it is our view that the policy is too limited in terms of options for delivery,
particularly in the early stages of the Plan period. Specifically, Policy BE1 is overly reliant on the delivery of employment development from sites which form part of the SDA. It is clear from the Strategic Employment Land Availability Assessment (SELAA) that wider improvements to the highway network are required to facilitate the delivery of employment land from the SDA (a timeframe of 6-10 years is indicated in the SELAA). However, should there be delays in the delivery of employment land associated with this site, there would be a significant impact on employment delivery in Lutterworth. This has the potential to undermine the Council's spatial strategy and stifle the sustainable growth of the settlement. As such, Policy BE1 is currently unsound. Additional land should be allocated to provide a greater level of certainty that adequate employment land will be delivered in Lutterworth in the short to medium term.

In addition to Policy BE1's lack of sufficient options/ alternatives for employment delivery in Lutterworth during the early phases of the Plan, it is our view that the policy is currently deficient in terms of the range of employment types to be delivered. As mentioned previously, the policy relies on just two site to deliver the 26 hectares of employment land required in Lutterworth during the Plan period. It is noted that half of the employment land allocated (13 hectares) comprises B8 storage and distribution uses, with the remainder split between B1 office/ light industrial and B2 general industrial uses. Given the size and location of the allocated sites (particularly the SDA), it is considered unlikely that smaller scale office and retail uses (i.e. those uses most suited to town centre locations/ compatible with existing residential uses) will be delivered. As such, we consider Policy BE1 to be ineffective and, as such, unsound. It is our view that additional land close to the town centre should be allocated to ensure the delivery of a greater range of employment types (including smaller scale B1 office use). The allocation of additional employment land for B1 office use would contribute positively to the Local Plan's effectiveness by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth in accordance with national policy (NPPF, para 7 - emphasis ours).

We wish to register our objection to Policy GI4. Specifically, we object to the designation of a parcel of land to the west of Rugby Road, Lutterworth as a 'Local Green Space ' (as shown on Inset Map: 64 (Lutterworth, Bitteswell and Magna Park).

In order to assess the validity of the proposed designation of land to the west of Rugby Road, Lutterworth (as part of a wider parcel of proposed Local Green Space), an 'Outline Landscape and Visual Appraisal' has been undertaken. The full report is appended to this letter of representation. In summary, the report concludes that there is very little weight that can be attached to landscape and visual matters that would support the designation of the area as a Local Green Space when considered against the criteria of paragraph 77 of the NPPF.

The designation of land to the west of Rugby Road, Lutterworth is not justified and, as such, Policy GI4 is unsound.

Policy RT1 - Provision of new retail uses

We wish to register our objection to Policy RT1 as it is not effective or justified when considered against reasonable alternatives. Specifically, we object to the following:
1. the lack of sufficient options/ alternatives for the delivery of retail development in Lutterworth during the Plan period;
2. the absence of allocations for retail development in close proximity to the Lutterworth town centre.
It is noted that only one site in Lutterworth has been allocated for retail development during the Plan period (the 'East of Lutterworth Strategic Development Area' (SDA)). Of the 1,000sq m (gross) of convenience floorspace required in Lutterworth during the Plan period, 100% of this is proposed to be delivered as part of the SDA.
In terms of convenience floorspace, Table B.18 of the Proposed Submission Local Plan indicates that 400sq m (gross) will be developed in Lutterworth to the period to 2021. Between 2021 and 2026, it is predicated that 300sq m (gross) of convenience floorspace will be delivered, with the same amount of floorspace (300sq m (gross)) predicted for delivery between 2026 and 2031. Given that 100% of the convenience floorspace is proposed to be delivered by the SDA, any delays in the site's delivery would have significant implications for the provision of convenience retail development in Lutterworth. The current strategy does not provide sufficient flexibility or allow the Plan to adapt to changing circumstances. As such, it is currently unsound.
In our view, additional land should be allocated for retail development close to the existing town centre. This would support the vitality of the existing town centre and facilitate the logical expansion of the current retail offer in a sustainable location close to existing residential areas and bus routes. The proximity of existing markets, as well as the strategic highway network (including M1 motorway), would be commercially attractive and, as such, retail sites in this location would be highly deliverable.
In addition to the above, it is considered that there is qualitative need for a better choice of food shopping outlets to meet the requirements of Lutterworth and its catchment area, commensurate with the towns status in the District's shopping hierarchy. The adopted Core Strategy DPD identifies Lutterworth as a Key Centre within the spatial strategy (Policy CS1), on a par with Broughton Astley. However, in the retail hierarchy, set out at Policy CS6, Lutterworth is designated as a Town Centre, at the same level as Market Harborough and above Broughton Astley, which is classed as a second tier, District Centre. In terms of current food store provision, Market Harborough has a wide choice of supermarkets available to meet the needs of the local bulk food shopper, including two operators in the rapidly expanding and very popular deep discount food sector (ALDI and Lidl). Broughton Astley has recently benefitted from the opening of a discount food store operated by ALDI, which is proving to be very popular and has helped that settlement to become more self-contained in terms of meeting its own food shopping needs.
Lutterworth, on the other hand, while offering two mainstream supermarkets capable of meeting most bulk food shopping needs, fails to provide a sufficiently wide choice of food retail provision for a town of its standing in the shopping hierarchy. In particular, the town does not offer its residents the benefits of a discount food store, which would materially enhance the range and quality of convenience goods available, to local people, particularly to those on tight budgets.

Omission site - Land to the west of Rugby Road. Lutterworth

As part of this Local Plan consultation we wish to put forward 'Land to the west of Rugby Road, Lutterworth' as a proposed allocation for B1 office/ retail uses. The site is located adjacent to the southernmost built-up part of Lutterworth, with residential dwellings sited immediately to the north of the site. Existing commercial uses (including a hotel, restaurant and offices) lie to the east of the site across Rugby Road. To the south, the site is bounded by the A4303 Lutterworth Road. Open fields/ countryside lie to the west . See 'Site Location Plan' attached. The existing use of the site is grazing / pasture land.
The site is well located in relation to Lutterworth, a 'Key Centre' as defined in the emerging Local Plan. The Local Plan makes clear that Lutterworth is an appropriate location for 'significant' housing and employment development due to its location, accessibility and level of services (Local Plan, para 15.1.4). The allocation of the site for development, therefore, accords with the thrust of the Council's spatial strategy. Lutterworth's central location and access to major routes within the 'Golden Triangle' further adds to its attractiveness for employment-based development.
The site is located in very close proximity to Lutterworth Town Centre (less than 200m from the Town Centre Boundary as indicated on the Proposals Map). It is therefore a logical and sustainable location for additional office and retail provision. The siting of employment opportunities near to where people live is promoted in the NPPF to encourage more sustainable commuting patterns and reduce reliance on the private car. The site is located within easy walking distance of the town centre and is close to existing bus routes, encouraging sustainable travel.

The site is well located in respect of the local and strategic highway network (including the M1 motorway). These factors contribute to the commercial attractiveness of the site which will ensure viability and , ultimately, deliverability. The site has no ownership constraints and should be considered available for development.
The River Swift is located adjacent to the sites northern boundary. Whilst approximately half of the site is located within Flood Zone 2 and 3, it is considered that this would not preclude the remainder of the site being developed for viable and commercially attractive B1 office/ retail uses. Commercial uses are classed as 'less vulnerable' in the Flood Risk Vulnerability Classification. The site lies within the SSSI Impact Risk Zone for Misterton Marshes. However, given the distance of the site from the SSSI and the intervening features, it is not considered to represent a major constraint to development. The site is located in close proximity to the Lutterworth Conservation Area. However, there are no listed buildings or designated heritage assets in the immediate vicinity. In light of this, it is considered that there is the potential for a proposal to be designed that would not result in an unacceptable heritage impact.
In accordance with NPPF paragraph 182, Local Plans should be positively prepared, justified, effective and consistent with national policy. In terms of the allocation of sites, Local Plans should " allocate sites to promote development and flexible use of land" (NPPF, para 157). Given the highly sustainable and commercially attractive location of the site, it is our view that 'land to the west of Rugby Road' should be allocated for employment/ retail use in the Local Plan.

The allocation of the site would supplement the District's existing employment/ retail land supply and provide the Plan with greater flexibility in accordance with national policy. It is noted that a high proportion of the employment and retail development planned for Lutterworth is to be delivered as part of the Strategic Development Area (SDA). The Local Plan acknowledges that the SDA will be delivered "over an extended time period" (Local Plan, para 15.2 . 7). If there are delays in the delivery of employment and retail on this site, the proposed allocation site could augment supply in the short to medium term. The allocation of the site is justified when considered against reasonable alternatives and would improve the effectiveness of the Plan by ensuring the timely delivery of employment and retail uses.
The allocation of the site could also provide greater choice in terms of the employment types delivered during the Plan period . Given the location of the site (i.e. close to the town centre and existing residential uses), the site would be well suited to smaller scale B1 office uses and retail as opposed to larger scale employment uses (i.e. B8 storage and distribution) which may be suitable elsewhere. The allocation of the site would contribute positively to the Local Plan ' s effectiveness by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth in accordance with national policy (NPPF, para 7 - emphasis ours).
In addition to the above, it is considered that there is a strong case for allocating the site for food retail purposes. That case is based on meeting a qualitative need for a better choice of food shopping outlets capable of meeting bulk food shopping requirements of Lutterworth and its catchment area, commensurate with the towns status in the District's shopping hierarchy. The adopted Core Strategy DPD identifies Lutterworth as a Key Centre within the spatial strategy (Policy CS1), on a par with Broughton Astley. However, in the retail hierarchy, set out at Policy CS6, Lutterworth is designated as a Town Centre, at the same level as Market Harborough and above Broughton Astley, which is classed as a second tier, District Centre.

In terms of current food store provision, Market Harborough has a wide choice of supermarkets available to meet the needs of the local bulk food shopper, including two operators in the rapidly expanding and very popular deep discount food sector (ALDI and Lidl). Broughton Astley has recently benefitted from the opening of a discount food store operated by ALDI, which is proving to be very popular and has helped that settlement to become more self­ contained in terms of meeting its own food shopping needs.
Lutterworth, on the other hand, while offering two mainstream supermarkets capable of meeting most bulk food shopping needs, fails to provide a sufficiently wide choice of food retail provision for a town of its standing in the shopping hierarchy. In particular, the town does not offer its residents the benefits of a discount food store, which would materially enhance the range and quality of convenience goods available, to local people, particularly to those on tight budgets.

The proposed allocation site on land west of Rugby Road represents an ideal opportunity to meet this qualitative need through the plan led system. The site is well related to the Town Centre and is accessible by a choice of modes of transport. There are no opportunities to meet the need through sequentially preferable sites due to the highly constrained nature of the own centre and lack of available, suitable land.

Omission site - Land to the west of Rugby Road. Lutterworth

As part of this Local Plan consultation we wish to put forward 'Land to the west of Rugby Road, Lutterworth' as a proposed allocation for B1 office/ retail uses. The site is located adjacent to the southernmost built-up part of Lutterworth, with residential dwellings sited immediately to the north of the site. Existing commercial uses (including a hotel, restaurant and offices) lie to the east of the site across Rugby Road. To the south, the site is bounded by the A4303 Lutterworth Road. Open fields/ countryside lie to the west . See 'Site Location Plan' attached. The existing use of the site is grazing / pasture land.
The site is well located in relation to Lutterworth, a 'Key Centre' as defined in the emerging Local Plan. The Local Plan makes clear that Lutterworth is an appropriate location for 'significant' housing and employment development due to its location, accessibility and level of services (Local Plan, para 15.1.4). The allocation of the site for development, therefore, accords with the thrust of the Council's spatial strategy. Lutterworth's central location and access to major routes within the 'Golden Triangle' further adds to its attractiveness for employment-based development.
The site is located in very close proximity to Lutterworth Town Centre (less than 200m from the Town Centre Boundary as indicated on the Proposals Map). It is therefore a logical and sustainable location for additional office and retail provision. The siting of employment opportunities near to where people live is promoted in the NPPF to encourage more sustainable commuting patterns and reduce reliance on the private car. The site is located within easy walking distance of the town centre and is close to existing bus routes, encouraging sustainable travel.

The site is well located in respect of the local and strategic highway network (including the M1 motorway). These factors contribute to the commercial attractiveness of the site which will ensure viability and , ultimately, deliverability. The site has no ownership constraints and should be considered available for development.
The River Swift is located adjacent to the sites northern boundary. Whilst approximately half of the site is located within Flood Zone 2 and 3, it is considered that this would not preclude the remainder of the site being developed for viable and commercially attractive B1 office/ retail uses. Commercial uses are classed as 'less vulnerable' in the Flood Risk Vulnerability Classification. The site lies within the SSSI Impact Risk Zone for Misterton Marshes. However, given the distance of the site from the SSSI and the intervening features, it is not considered to represent a major constraint to development. The site is located in close proximity to the Lutterworth Conservation Area. However, there are no listed buildings or designated heritage assets in the immediate vicinity. In light of this, it is considered that there is the potential for a proposal to be designed that would not result in an unacceptable heritage impact.
In accordance with NPPF paragraph 182, Local Plans should be positively prepared, justified, effective and consistent with national policy. In terms of the allocation of sites, Local Plans should " allocate sites to promote development and flexible use of land" (NPPF, para 157). Given the highly sustainable and commercially attractive location of the site, it is our view that 'land to the west of Rugby Road' should be allocated for employment/ retail use in the Local Plan.

The allocation of the site would supplement the District's existing employment/ retail land supply and provide the Plan with greater flexibility in accordance with national policy. It is noted that a high proportion of the employment and retail development planned for Lutterworth is to be delivered as part of the Strategic Development Area (SDA). The Local Plan acknowledges that the SDA will be delivered "over an extended time period" (Local Plan, para 15.2 . 7). If there are delays in the delivery of employment and retail on this site, the proposed allocation site could augment supply in the short to medium term. The allocation of the site is justified when considered against reasonable alternatives and would improve the effectiveness of the Plan by ensuring the timely delivery of employment and retail uses.
The allocation of the site could also provide greater choice in terms of the employment types delivered during the Plan period . Given the location of the site (i.e. close to the town centre and existing residential uses), the site would be well suited to smaller scale B1 office uses and retail as opposed to larger scale employment uses (i.e. B8 storage and distribution) which may be suitable elsewhere. The allocation of the site would contribute positively to the Local Plan ' s effectiveness by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth in accordance with national policy (NPPF, para 7 - emphasis ours).
In addition to the above, it is considered that there is a strong case for allocating the site for food retail purposes. That case is based on meeting a qualitative need for a better choice of food shopping outlets capable of meeting bulk food shopping requirements of Lutterworth and its catchment area, commensurate with the towns status in the District's shopping hierarchy. The adopted Core Strategy DPD identifies Lutterworth as a Key Centre within the spatial strategy (Policy CS1), on a par with Broughton Astley. However, in the retail hierarchy, set out at Policy CS6, Lutterworth is designated as a Town Centre, at the same level as Market Harborough and above Broughton Astley, which is classed as a second tier, District Centre.

In terms of current food store provision, Market Harborough has a wide choice of supermarkets available to meet the needs of the local bulk food shopper, including two operators in the rapidly expanding and very popular deep discount food sector (ALDI and Lidl). Broughton Astley has recently benefitted from the opening of a discount food store operated by ALDI, which is proving to be very popular and has helped that settlement to become more self­ contained in terms of meeting its own food shopping needs.
Lutterworth, on the other hand, while offering two mainstream supermarkets capable of meeting most bulk food shopping needs, fails to provide a sufficiently wide choice of food retail provision for a town of its standing in the shopping hierarchy. In particular, the town does not offer its residents the benefits of a discount food store, which would materially enhance the range and quality of convenience goods available, to local people, particularly to those on tight budgets.

The proposed allocation site on land west of Rugby Road represents an ideal opportunity to meet this qualitative need through the plan led system. The site is well related to the Town Centre and is accessible by a choice of modes of transport. There are no opportunities to meet the need through sequentially preferable sites due to the highly constrained nature of the own centre and lack of available, suitable land.