Harborough Local Plan 2011-2031, Proposed Submission

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Harborough Local Plan 2011-2031, Proposed Submission

BE2 1c.

Representation ID: 7266

Received: 17/11/2017

Respondent: Tritax Symmetry

Agent: Framptons

Representation Summary:

The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a)ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Full text:

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2b.

Representation ID: 7267

Received: 17/11/2017

Respondent: Tritax Symmetry

Agent: Framptons

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

May be difficult for a developer to demonstrate, because:
- proving a negative would be onerous, especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Planning system doesn't exist to prevent competition.
- a developer has to address other potential SRFIs which may be at various stages in the planning process and may not secure a grant of planning permission.
- reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an extensive analysis of potential impact.
Purpose of this Criterion would be clarified if reworded, see change to Plan.

Full text:

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.

Support

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2d.

Representation ID: 7268

Received: 17/11/2017

Respondent: Tritax Symmetry

Agent: Framptons

Representation Summary:

I believe some wording has been omitted from this Criterion to give effective meaning. I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

Full text:

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.

Support

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2e.

Representation ID: 7269

Received: 17/11/2017

Respondent: Tritax Symmetry

Agent: Framptons

Representation Summary:

'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions' (see Change to Plan)

Full text:

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.

Support

Harborough Local Plan 2011-2031, Proposed Submission

BE2 2f.

Representation ID: 7270

Received: 17/11/2017

Respondent: Tritax Symmetry

Agent: Framptons

Representation Summary:

A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

Full text:

Harborough District Council: Harborough Local Plan Proposed submission
Lutterworth, db symmetry

Introduction

1 These representations accept the soundness of the Local Plan in the context of Policy BE2 Strategic Distribution.

2 It is however considered that the development management process would be assisted by some clarification to the wording of the following criteria. Such amendments do not alter the underlying purpose of the Criterion, but are considered to assist developers and the public in the operation of the policy when relevant planning applications are submitted for determination.

Criterion 1 a:

3 The allocation is to make provision for strategic scale storage and distribution uses. Criterion 1a) ensures that unit sizes are not less than 9,000 m2. On this basis it seems to me that Criterion c) could be simplified to state:

'The primary use of the premises will be within Class B8. Other uses should be ancillary in function or be relevant associated uses, for example a lorry park driver facilities.'

Criterion 2 b:

4 While the underlying objective of this Criterion maybe understood it may be difficult for a developer to demonstrate 'no adverse impact on the viability and deliverability of existing or further SRFIs.' My comments are as follows. Firstly the planning system does not exist to prevent competition. A developer would be faced in having to prove a negative, which would be an onerous task especially if a competing developer claimed that consent would impact upon ability and deliverability of another site. Secondly the Criterion as presently worded appears to suggest that a developer has to address other potential SRFIs which may be at various stages in the planning process and may indeed not secure a grant of planning permission. The reference to SRFIs 'serving' other neighbouring authorities and Leicestershire could result in an underlying extensive analysis of potential impact.

5 It is submitted that the purpose of this Criterion would be clarified on the basis of it is worded as follows:

'Support or at least no substantial impact upon the delivery of committed SRFIs located within Leicestershire and the neighbouring authorities.'

Criterion 2 d:

6 I believe some wording has been omitted from this Criterion to give effective meaning.

7 I suggest adding the words 'to travel other than by private car' after 'Harborough District'.

'include measures to enable an increase in the proportion of the workforce commuting from locations within Harborough District to travel other than by private car'

Criterion 2 e:

8 'Congestion' is not a term that is defined. It seems that the criterion would be more effective with the use of the word 'conditions'.

'not lead to severe traffic conditions anywhere on the nearby strategic and local road network, particularly the A5, whether within Harborough District or outside'

Criterion 2 f:

9 A landscape impact is an environmental impact. As such the criterion could be simplified to read.

'Ensure that 24 hour operations do not have an unacceptable impact upon the environment, and the amenity of local communities.'

10 I trust that these comments are considered helpful.

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