Harborough Local Plan 2011-2031, Proposed Submission

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Object

Harborough Local Plan 2011-2031, Proposed Submission

SP3: Meeting regional and national demand for strategic distribution (logistics) development.

Representation ID: 7271

Received: 17/11/2017

Respondent: Prologis UK Ltd.

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

HDC has not fully met the Duty to Cooperate when identifying a strategic extension to Magna Park, reasons stated as:
- proposed scale would have significant cross boundary implications including for; Leicester & Leicestershire, Northamptonshire, Nottinghamshire, Derbyshire and the W.Midlands, therefore the Duty to cooperate & evidence base requires such cross-boundary consideration
- scale proposed (in ha)not justified by the evidence cited (L&LSDSS, HEDNA)
- not clear in demonstrating or assessing vacant floorspace at Magna Park or the likelihood and impact of probable redevelopment (given age of buildings)
- concentrating proposed scale of development in this part of Harborough will have serious implications for the delivery of sustainable economic development in the rest of Leicestershire.
- proximity and scale of development will impact on the delivery of DIRFT III, and Daventry's ability to deliver their employment / GVA aspirations
- HDC has not given due consideration to concerns raised by Daventry DC, that an assessment be prepared to demonstrate that the level of employment planned for Magna Park is justified
- criterion BE2.2b demonstrates acceptance of concern, to consider in context of plan-making. HDC consideration of such assessment as disproportionate / non-conclusive (as per DtoC statement)undermines its inclusion.

Object

Harborough Local Plan 2011-2031, Proposed Submission

SS1 clause 2c. Strategic storage and distribution

Representation ID: 7274

Received: 17/11/2017

Respondent: Prologis UK Ltd.

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object for the following reasons:
- amount of employment land quoted in SS1.2c does not reflect an up to date position (no Ref. to planning consent 15/00919/FUL)
- it fails to clearly set out the scale and distribution of new employment development, including strategic B8, as a total minimum or maximum amount
- not based on a strategy which seeks to meet objectively assessed development and infrastructure requirements
- doesn't robustly justify the amount, more than double the requirement, for road-based strategic B8 development
- approach conflicts with strategic aims of NPPF, to reduce carbon emissions, and the National Networks Policy Statement (NPS) which prioritises distribution & warehousing sites served by rail.

Object

Harborough Local Plan 2011-2031, Proposed Submission

6.1.4 TO 6.1.7 explanation

Representation ID: 7275

Received: 17/11/2017

Respondent: Prologis UK Ltd.

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Reasons summarised as:
- does not provide a clear and comprehensive approach as para 6.1.7 / Table B.10 excludes strategic distribution
- Table B.11 Sources of Employment Land Supply needs to be updated to accurately reflect the position (i.e. planning consent 15/00919/FUL)
- unclear whether the plan meets objectively assessed employment need because the Council has not provided all the evidence to justify that the approach to general new business development combined with strategic B8 development is justified.
- overall employment land requirement not robustly justified. Further work needed to justify that this amount is appropriate and deliverable.

Object

Harborough Local Plan 2011-2031, Proposed Submission

BE2 clause 2

Representation ID: 7276

Received: 17/11/2017

Respondent: Prologis UK Ltd.

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Reasons for objection are summarised as:
- the Council has not taken full account of evidence in the L&LSDSS, particularly that a geographical spread of sites is offered, this scale of development in 1 location is not justified
- the implications of directing a substantial amount of growth to Magna Park go beyond the defined FEMA / HMA and have not been robustly considered
- agreement has not been reached within the Leicestershire Planning Authorities, County Council, LEP that Magna Park is the correct location for this scale of development
- the policy has the potential to; impact negatively on the operation of the country's leading SFRI (DIRFT), deter investment & implementation of the DCO approved NSIP project (DIRFT III)and impact negatively on the delivery of national planning policy
- the policy has the potential to undermine modal-shift and the associated on-going educational process
- its highly likely that development at Magna Park will displace demand for units at DIRFT III (non-rail and rail served schemes do not compete on a level playing field) and have implications on labour availability
- the evidence, including the Sustainability Appraisal,is based on pre-determined assumptions to justify approval of planning applications for Magna Park and any alternatives have not been robustly considered
- the MP Employment Growth Sensitivity Study does not justify the scale of allocation at Magna Park, it provides evidence justifying additional housing needed to support growth
- the U-Turn from current Core Strategy policy CS7 is not fully justified by the evidence
- preparation of policy has not taken account of necessary cross-boundary discussions with neighbouring authorities (WNJPU, DDC)

In summary the policy fails to meet the tests of soundness because it:
1. has not take account of cross-boundary discussions with neighbouring authorities,
2. has not justified the amount of strategic B8 needed in Harborough, or that Magna Park is the most reasonable location out of all alternatives.
3. conflicts with the overall aims of the NPPF and NNNPS, to reduce carbon emissions and prioritise sites served by rail.

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