Harborough Local Plan 2011-2031, Proposed Submission

A development of this size far exceeds the forecasted need for non-rail served warehousing and distribution space for the entire Leicester & Leicestershire Enterprise Partnership (LLEP) area for 2031. In addition, no consideration appears to have been given to planning consents given by councils in Leicestershire since 2014 or consented sites currently under construction, which combined, amount to a minimum of 577,000 sq. m. Further development of 700,000 sq. m potentially contributes to a huge over-supply of non-rail served warehousing and distribution space in the local area, it does not allow spread across the LLEP area. This potentially leads to a huge influx of workers from further afield exacerbating local congestion and traffic issues, further over-loading local villages with additional commuter traffic and conflicting with available housing in the area.

The allocation of 700,000 sq. m. is fundamentally different from previous consultation documents, this figure has not been tested through consultation. There are two outstanding planning applications for warehousing in this area totalling 700,000 sq. m. These statements underpin the view of the Parish Council that the allocation of 700,000 sq. m. is not a strategic allocation, it is an allocation to accommodate approval of the two outstanding planning applications for warehousing in this area. In HDC's existing Core Strategy (2011) Policy CS7h clearly states 'Protect Magna Park's unique role as a strategic distribution centre (B8 uses / Min unit size 10,000m2) of national significance and an exemplar of environmental performance. No further phase of development or large scale expansion of the site, beyond the existing development footprint (to be defined in the Allocations DPD) will be supported'. One of the explanations provided for this statement is that 'there are more suitable locations and sites (both rail and non rail-linked) than Magna Park within the region and sub-region to meet forecast need for strategic distribution to 2026'. The Local Plan does not deny that there are more suitable sites elsewhere, neither does it claim that Magna Park is now the only suitable site.

The allocation of 700,000 sq. m. is fundamentally different from previous consultation documents, this figure has not been tested through consultation. There are two outstanding planning applications for warehousing in this area totalling 700,000 sq. m. These statements underpin the view of the Parish Council that the allocation of 700,000 sq. m. is not a strategic allocation, it is an allocation to accommodate approval of the two outstanding planning applications for warehousing in this area. In HDC's existing Core Strategy (2011) Policy CS7h clearly states 'Protect Magna Park's unique role as a strategic distribution centre (B8 uses / Min unit size 10,000m2) of national significance and an exemplar of environmental performance. No further phase of development or large scale expansion of the site, beyond the existing development footprint (to be defined in the Allocations DPD) will be supported'. One of the explanations provided for this statement is that 'there are more suitable locations and sites (both rail and non rail-linked) than Magna Park within the region and sub-region to meet forecast need for strategic distribution to 2026'. The Local Plan does not deny that there are more suitable sites elsewhere, neither does it claim that Magna Park is now the only suitable site.

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

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

Clearly an allocation of this size would lead to a vast number of employment opportunities. However, unemployment in the area is very low, the majority of the workforce required for an allocation of this size would have to be recruited from outside the district. Supporting documents for the IDI Gazeley application, 15/01531/OUT, state that 74% of the employment opportunities will be for 'essential/basic jobs'. Key Issue 3 of the Local Plan highlights that there is a requirement for more opportunities for 'higher skilled residents' in the district. Objective 2 of the Local Plan states: 'Contribute to reducing the need for out-commuting and thereby help to increase the sustainability and self-containment of communities, while encouraging the development of a vibrant, diverse and sustainable business community'. Out-commuting of people within the district holding skilled jobs would not be significantly reduced as, previously highlighted, 74% of the opportunities are for essential/basic jobs, the people filling these roles will commute from areas where unemployment is higher and house prices are lower.

There is no evidence to support this point. 81% of the existing Magna Park workforce commute from outside Harborough District postcodes. The Magna Park Growth Sensitivity Survey concludes the allocation of 700,00 sq. m. of extra warehousing would generate 9689 extra jobs. In the whole of the Harborough District there were only 1400 people registered as unemployed from July 2016 - June 2017 (Nomis Official Labour Market Statistics). Unemployment in the Harborough District for this period was 3% well below 4.3% for the East Midlands and 4.6% nationally. The majority of the workforce required would have to commute from outside the district. Public transport in the area is inadequate and anyone commuting into the area would most likely have to use a private vehicle. This will impact on congestion and pollution, particularly in the surrounding villages who are already used as 'rat-runs' around the clock due to shift patterns.

The Midlands Connect Strategy 2017 - 2030 highlights the inadequacy of the A5, this strategy does not envisage any major upgrading of the A5 in the Magna Park area prior to the end date of the strategy in 2030, one year before the end date of the proposed submission version of the HDC Local Plan. When the additional HGV volume and commuter traffic from the proposed policy are factored in, the current A5 layout become inoperable. Surrounding villages are already suffering from increased traffic volume when being used as a 'rat-run' to avoid A5 congestion and HGVs using 'short-cuts'. In addition to the increased traffic flow through surrounding villages the inadequacy of the A5 will also impact on business efficiency and the ability of the workforce to commute effectively at the current and proposed expansion Magna Park sites. UPC also contests that the definition of 'severe' is subjective, the various traffic assessments commissioned use different definitions of severe. It should be noted that public transport options in the immediate vicinity of Magna Park are limited and private car is the most convenient way for employees to travel to work.

The original Magna Park site was built on a former RAF aerodrome which could be considered as a brownfield site. The two outstanding planning applications for the proposed Magna Park expansion area are for land which is currently agricultural land. This conflicts with paragraphs 111 and 112 of the National Planning Policy Framework (NPPF):
111. Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.
112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.
The proposed submission of the Harborough Local Plan 2011 to 2031 does not consider whether there are any brownfield sites which could be used in preference to the agricultural land currently proposed.

The visual and light pollution impact of a Magna Park expansion would be detrimental to Ullesthorpe. Since the creation of Magna Park in 1988 Ullesthorpe has suffered from extensive visual and light intrusion. Tree screening measures are still highly ineffective meaning that overnight light pollution is highly invasive and disruptive, the aspirations of policy BE2 would further exacerbate these issues for residents in the parish of Ullesthorpe.

Policy GD6 of the proposed Local Plan suggests an Area of Separation should be implemented between Bitteswell/Lutterworth/Magna Park, to maintain separation of both Lutterworth and Bitteswell from Magna Park. There is no mention in the proposed Local Plan of maintaining an Area of Separation between Magna Park and Ullesthorpe who are equally at risk.

Implementation of Policy BE2 would certainly have an unacceptable environmental, community and landscape impact on the immediate and wider surrounding area.

Policy BE2 conflicts with the statement 'the district will have a diverse and thriving economy', by allowing such a large expansion in one sector which is low paid and low skilled the opposite effect will be achieved. In the District, there are approximately 45,000 working people, the creation of c.10,000 new jobs would represent a gross over-supply. If the vision is to achieve a more diverse economy why is HDC not following the Leicester and Leicestershire Enterprise Partnership (LLEP) strategy which aims to encourage a broad range of business development, HDC have signed up to this strategy.

An allocation of the size in Policy BE2 would lead to a vast number of employment opportunities. Uemployment in the area is very low, the majority of the workforce required for an allocation of this size would have to be recruited from outside the district. Key Issue 3 of the Local Plan highlights that there is a requirement for more opportunities for 'higher skilled residents' in the district. 74% of the opportunities are for essential/basic jobs, the people filling these roles will commute from areas where unemployment is higher and house prices are lower.