Harborough Local Plan 2011-2031, Proposed Submission

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Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2f.

Representation ID: 5587

Received: 31/10/2017

Respondent: Ashby Parva Parish Meeting

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Traffic and light pollution are already a problem in the area. BE2 would double this. The proposed developments would be highly intrusive to some communities

Valuable agricultural land would be built on, thus reducing the UK's capacity to grow food at a time of rapid population growth. There has been no consideration of alternative brown field sites and no off-setting of loss of agricultural land against any gain.

Full text:

Magna Park as it exists today aready has profound effects on the environment and on the quality of life in the surrounding area. More than twenty years after Magna Park phases 1 and 2 were built, screening with trees is still ineffective, except from very close by, along the A5 boundary. Despite mitigation measures taken, light pollution is extensive. BE2, which would double the existing size of Magna Pak, would make this worse. Unregulated employee traffic rushes through rural roads, lanes and villages, especially at shift changeover times. Employer travel plans for staff are purely advisory and unenforceable. The private car is the most convenient way of getting to work door-to-door. The B4207 (formerly the A407) is not part of the Magna Park HGV routing plan and villages along it already suffer vibration and damage to houses caued by HGVs. Peak traffic, much of it HGVs, along single carriageway sections of the A5, such as at Wibtoft just north of Magna Park present a real danger and accidents are common.

Policy BE2 is written specifically with the 2 pending applications in mind. It emerged in its final form specifying 700k sq.m. only after three-way discussions between the council and the 2 developers, after dbSymmetry withdrew their judicial review application against the approval given to 15/00919/FUL (the DHL warehouse) and after each developer undertook not to oppose the other's application (see letter from dbSymmetry's planning consultants, Framptons, to the council dated 10 May 2017 - a highly significant letter). If BE2 is approved, the two applications will require 327 hectares of what is currently agricultural land, both productive arable and pasture. This will diminish the UK's capacity to grow food at a time when the population is forecast to grow rapidly (and world demand is also growing due to population growth and the effects of climate change). BE2 conflicts with paragraphs 111 and 112 of the NPPF. The Submission Plan does not consider whether there are brown field sites which could be used in preference productive farm land. The existing Magna Park was built on a former RAF aerodrome which could be considered a brown field site, but any expansion would be outside it.

The Secretary of State at DEFRA has warned (23 October 2017) of much of the UK's arable soil losing its fertility within the next 30-40 years because of intensive farming, but such farming will increase if more and more land is taken up by warehousing.

Visually, expansion of Magna Park would be highly intrusive, especially to communities such as Ullesthorpe. MOre than twenty years after Magna Park phases 1 and 2 were built, screening with trees is still ineffective, except from very close by along its boundary with the A5. Despite mitigation measures taken at the time, light pollution is extensive. BE2, which would double the existing size of Magna Park, would make this worse.

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 1b.

Representation ID: 6807

Received: 16/11/2017

Respondent: Ashby Parva Parish Meeting

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Allow some flexibility in activity on a predominantly B8 site.

Full text:

This paragraph prevents diversification of industrial sites. If Harborough needs to attract more industry, it is not more warehousing and logistics, of which there is a disproportionate amount compared to other economic activity. Rather, it needs high value skilled productive employment if it is to reduce the outflow from the district of persons in work, as is the aim of the plan. There has been an empty site on the existing Magna Park for a long time. If it had been available to build an industrial unit it could have been in productive activity by now. A maximum percentage for B1(b) and B1(c) site activity to be permitted would allow for a flexible response to local demand and lessen the tendency to a 'monoculture' of B8.

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 clause 2

Representation ID: 6817

Received: 16/11/2017

Respondent: Ashby Parva Parish Meeting

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

700,000 sq. m., taken together with other development in the area, takes us far beyond forecast need.

Full text:

Forecast need of additional non rail=linked warehousing and distribution space in Leicester and Leicestershire (the area covered by the LLEP Strategic Distribution Sector Studies, 2014 and 2016) for 2031 has already been, or is close to being met. The high estimate forecast (later called a minimum) is for 320k. square metres of non rail-served space by 2021, 435k. sq.m. by 2026, 607k.sq.m. by 2031 and 792k. sq.m. by 2036. 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 almost 100K sq.m.

Across the LLEP area many strategic distribution schemes (i.e. 9,000+ sq.m) have been approved in outline or in full, or are being speculatively built or are ready and vacant. The same is true of an area such as Rugby which immediately borders on to the A5 alongside Magna Park. The draft local plan treats Harborough District as if it were not part of a wider area.

Over-provision for warehousing and logistics space in the area seems inevitable and a sound plan is needed to avoid this.

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2b.

Representation ID: 6861

Received: 16/11/2017

Respondent: Ashby Parva Parish Meeting

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Cheaper non-rail-linked strategic distribution centres are likely to undermine the viability of nearby existing and future SRFIs because of lower construction costs, and are more environmentally damaging. Policy BE2 is in conflict with the NPS

Full text:

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

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

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

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