Harborough Local Plan 2011-2031, Proposed Submission

In justifying policy BE2 the Proposed Submission relies heavily on the LLEP MDS Strategic Distribution Sector Study 2014, updated in 2016, and the HEDNA report 2017. The LLEP reports forecast the need for additional (i.e. new build) for both rail linked and non-rail linked warehousing/distribution space in Leicestershire. The high estimate forecast (later called a minimum) is for 320k. sq. m. of non-rail linked space by 2021, 435k. sq.m. by 2026 and 607k. sq.m. by 2031. Para. 6.3.1 of the Proposed Submission states "This policy [permitting 700,000 sq. m] contributes towards meeting the requirement .... to 2031." In fact, it does not just contribute to the requirement but exceeds the figure for the entire LLEP area by about 100k sq. m. In doing so it also ignores the fact that since 2014 local authorities have continued to approve, in outline or full, a number of large ( > 9,000 sq.m.) warehousing/ distribution centres. The Sustainability Appraisal prepared by AECOM (August 2017 in the print version, September 2017 in the on-line version) in time for the adoption by the Council of the draft states that "Completions and commitments in the district and across the HMA are sufficient to meet minimum need without selecting a site for allocation," (para18.5.1). Many of these are currently advertised or under construction. The proposed 700,000 sq.m. will lead to a potentially significant and unsustainable over-supply of warehousing in Leicestershire, offering largely low skilled and low paid jobs and heavy in-commuting into areas such as Harborough where unemployment is extremely low and where house prices are the highest in the county. Conclusion: The policy fails to meet the test of soundness. It is not positively prepared in that it far exceeds objectively assessed development needs and ignores new build warehousing at Rugby Gateway, less than 6 miles from Magna Park at junction 1 of the M6. It is not justified in that it has not considered reasonable alternatives. It is not effective in that required road improvements to the A5 are outside the council's (and even Leicestershire County Council's) remit, that essential improvement to the A426 between the M6 and A5 are another county's responsibility, and that there is no plan foreither of these to be deliverable within the plan's timeframe, and is inconsistent with government policy on sustainability and rail-linked strategic distribution.

This policy (H2) should be more specific. 75% affordable or socially rented is too vague and could be 15% socially rented and 60% 'affordable' 10% + 65% or other. If policy B2 goes through there will be a demand for socially rented housing in Lutterworth East SDA as wages on Magna Park are low and will no doubt remain so, making it impossible to buy. Also many employees are temporary or on zero hours contracts, making mortgages unavailable.

I feel that the figure of 10 is too high. Harborough DC has in recent times been requiring an affordable element in smaller developments than this. We need more mixed housing, not developments of up to 10 dwellings affordable only to a few.

House prices in Harborough are the highest in the county, especially in villages such as our own. This policy will help attract or retain households on lower incomes and help maintain or develop a mixed community.

Please see our comments on SS1, the Spatial Strategy, 2c.Strategic storage and distribution

This sentence is written to favour two outline applications pending since 2015. It conflicts with the council's existing Core Strategy (2011), which ruled out any expansion of Magna Park because there were '"more suitable sites elsewhere". The submission doesn't now deny that there are more suitable sites elsewhere or claim that Magna Park is now the only suitable site, and ignores developments in the county which have already met forecast need to 2031.
The Sustainability Appraisal prepared by AECOM, (print version dated August 2017, on-line version dated September 2017) in time for the adoption by the Council of the draft, states that "Completions and commitments in the district and across the HMA are sufficient to meet minimum need without selecting a site for allocation." The plan ignores the approximately 175,000 sq.m at Rugby Gateway adjoining junction 1 of the M5, about 6 miles from Magna Park.
and the 180,000 sq.m. included in Rugby's draft local plan submitted for examination in July 2017. It is as if Harborough District were an independent island state!

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

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

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

While there would be employment opportunities for local residents if the proposal to double the size of Magna Park were to go ahead, take-up would be very limited, as unemployment in the Lutterworth area is very low and in the district it is the 2nd lowest in the county (see HEDNA final report, January 2017). It would not significantly reduce out-commuting of people holding skilled jobs as there are relatively few such jobs in warehousing. Uptake of jobs would be largely by people commuting longer distances to Magna Park from areas with higher unemployment and lower house prices (see HEDNA report above), but as unemployment continues to fall, recruitment of warehousing staff may be a problem. Anecdotally, employment agencies locally tell us it already is. Jobs should be created, as far as possible, where the unemployed are, rather than encourage large numbers to commute (overwhelmingly by private car as public transport is so inadequate) with resulting congestion and pollution. This part of the plan too fails the test of soundness as the strategy is not the most effective strategy to achieve the council's aim to reduce out-commuting

see comment on previous section

The objective here is unattainable in the foreseeable future. The A5 is already heavily congested. Although developer-funded dualling of a few hundred metres of the A5 and minor works at roundabouts are promised in connection with approval already given to 15/00919/FUL, Highways England have no plans to widen the A5 in the affected area during the lifetime of this Plan.

The A426 between Junction 1 of the M6 and the A5 at the Gibbet roundabout is also severely congested at peak times, with tailbacks often reaching close to the M6. There are no known plans to improve it, whether through public funds or developer funding.

This part of the plan is not sound. It is not effective in that required road improvements to the A5 are outside the council's (and even Leicestershire County Council's) remit and that essential improvement to the A426 between the M6 and A5 are another county's responsibility. There are no known plans to improve matters. There is therefore no guarantee that the objective can be delivered.