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Representations on Sustainability Appraisal - Second Interim SA Report Appraising Options for the Provision of Strategic Distribution Growth (Feb 2016) - Q1. Do you have any comments to make on the Second Interim Sustainability Appraisal Report - Appraising Options for Strategic Distribution growth (Feb 2016)?

Representation ID: 5334

COMMENT IDI Gazeley represented by Now Planning (Ms Nora Galley)

Summary:

Representation sets out comments on the Second Interim Sustainability Appraisal Report (ISA2) key issues are summarised below. Further detail is provided in respect of each point in the full representation.

Errors of approach

* ISA2 not published alongside HDC's Options Consultation Paper in September 2015, to enable the public to make informed representation based on both. Publication and consultation on ISA2 is a clear intention to make up for the omission of ISA1. HDC is obliged to ensure that the draft local plan consultation is extended to allow it to include representations based on ISA2.

* ISA2 is focussed on projects rather than strategic options. Planning applications used as proxies for the strategic options are actual projects, not strategic options, and an approach which is not wholly compatible with the requirements of the SEA Directive.

* ISA2 is selective in the use of project specific ES evidence, misunderstands keys parts of that evidence and makes serious errors of fact.


Errors of Fact & Omission
An account of errors of fact and omission is provided, summarised below:

1) Incorrect use of the SDSS forecasts (in particular the 107 ha need for non-rail connected land) as a precise quantum and upper limit and as a matter of fact when that figure is heavily dependent on working assumptions and should be used in broad terms and with caution. Specific points made on SDSS on forecast methodology:

- "Replacement demand" assumption of 70% doesn't account for trend towards larger units, concentration in the best locations or the loss of industrial land to other uses
- Assumes Leicestershire will supply 25.9% (static) share of the region's future floor-space stock throughout forecast period
- Assumes 58% of the forecast need to be rail-connected.
- Makes further assumptions to derive a gross and then net land need.

2) Incorrect use of SDSS advice on a sequential approach, and site selection:
- Existing supply doesn't meet SDSS recommended sequential approach to site selection, none are extensions to existing sites
- Insufficient consideration of proper application, i.e. first preference to extensions to existing sites cannot reasonably be construed as a broad locational criterion. Plainly favours Options A and C.
- further work, in the form of a Site Selection Task Panel, not done or underway

3) Errors in the descriptions of each Option. Descriptions have to be consistent with the planning applications, because each option is measured for its contribution to 107ha, and ISA2 aims to advise HDC on development management for the applications. Identified errors & corrections in descriptions provided, summarised below (further detail of full representation):

Option A
- Operational area is 22ha (not 37ha)
- Site is for DHL and does not allow for further expansion of Magna Park, no rationale for adding land or treating site as an option (has planning consent)
- Site does not account for 40% of need (even if 107ha were a precise figure)
- Site accords 'completely' (not broadly adheres) to SDSS recommended site selection approach & criteria

Option B
- Site does not adhere to SDSS advice on site selection. Not an extension to an existing site (only in proximity to), and does not make use of Magna Park's existing infrastructure or management.

Option C
- planning application on which Option C is modelled is for just 83.5 ha of distribution land (not 232ha), of which 22ha is accounted for by Option A. Options C adds 61.5ha to the operational area of Option A.
- would account for 78% (of 107ha) and not "significantly exceed" SDSS requirement
- description fails to recognise range of other uses delivered; green infrastructure (48ha Country Park, 22ha meadow, 33ha structural landscape with public access - 105ha in total), Logistics Institute of Technology (D1 use - 3,700m2) with campus / playing field, Innovation Centre (B1 uses - 2325m2), Company expansion (B1 use - 7,000m2), and Estate Office incl. Local Heritage Centre (300m2). All are relevant considerations for the SA.
- Ought to acknowledge 7ha parcel that includes; a no-low emission road-based Railfreight Shuttle, HGV park and Driver Training Centre.

4) Errors in alternative growth & distribution options.
- ISA2 takes view that Option C amounts to over-supply (making it an unreasonable alternative in SEA terms) but assesses it anyway
- ISA2 considers combination B+C to be still more unreasonable, but assesses anyway
- Uses incorrect distribution land areas (& makes no reference to floor-space quanta), on which Option C is assumed to be an unreasonable alternative. Corrections provided:
o Sum of A+B =110ha (not 125ha) or 379,553m2, in land area terms only 3% more than 107ha, or in floor-space terms 89% of that requirement (at 40% density)
o Sum of B+C (which includes Option A)= 171.5ha (88ha +83.5ha) not 320ha, in land area terms 60% over the 107ha, or in floor-space terms 65% of that requirement (at 40% density)
o Increment of Option C over combination A+B is just 21.2% in land terms (88ha +63.5ha =151.5ha, not 125ha) or just 12.5% in floor-space terms (427,200m2 not 379,553m2)
o As Option A is now permitted the relevant comparison is between Option B and the additional increment of warehousing that Option C adds
The conclusion ISA2 reaches (that the adverse effect of Option C on its own would be considerable greater than the combination A+B) as a result of these errors (para 5.3.18) is incorrect. It also follows that ISA 2 is not justified in concluding that a combination of options A+B does not lead to any further effects, and it is therefore not justified in terms of key finding 5 (para 5.4).

- Statements to explain why Option C would not be a reasonable alternative for policy making (alone or in combination with Option B) are wrong in respect of; exceeding 107ha requirement, no un-met need in neighbouring authorities, limiting geographic choice. Extra reasons cited;
o Magna Park is on the boundary of the East and West Midlands underscoring why 107ha should not be treated as a precise figure
o HDC does not need to be made aware of un-met need by other neighbouring authorities, NPPF para 179 obliges HDC to meet need arising in its area unless it cannot. ISA explains needs arises because of the planning applications, as well as the future need of the industry (i.e. need de facto arises in HDC area)
o SDSS does not seek "geographic choice" because it wants a spread of sites, its objects are to supply market- facing sites that increase concentration / take-up in the South Midlands and accommodate increasing warehouse sizes.
o ISA2 fails to understand that clustered provision is more sustainable (environmentally, socially and economically) than dispersed provision of single or small sites. Concentration can reduce the sectors environmental footprint.

5) Error in claiming that the objects of sustainable development would be compromised if 107ha is exceeded, ISA2 is wrong to claim that Option C, on its own or in combination, would have adverse impacts (i.e. distort the function of the property market, or compromise the ability of the logistics sector to meet its land needs in optimal locations) on competing sites as this has no foundation in evidence or policy.
- ISA2 provides no information on intended supply by other LPA's.
- The East Midlands overall requirement is for a further 5,570,000m2 of distribution floor-space by 2031 (according to SDSS). Located on the edge of the East / West Midlands Option C, or combination B+C contribute just a small proportion to this wider requirement.
- HDC is obliged to understand and meet the needs of industry in its area (NPPF para 179), limiting provision is not justified and (with 3 planning applications) would not meet the stated needs of business
- Any competition from Magna Park would be dispersed across the whole of the Golden Triangle (not confined to Leicestershire), to assert otherwise is to fail to understand the geography and market economics of the sector
- LLEP designates Magna Park as 1 of its "areas of transformation for the future", NPPF para 180 requires HDC to work collaboratively with LLEP
- SDSS advocates a geographical spread to provide market-facing choice not to limit supply, where the market clearly wants it, in order to achieve what LPA's together might consider an 'equitable' distribution
- Magna Park returns benefits to the industry (& in turn the environment) that make its premium management charge worthwhile, compared to other sites.
- ISA2 omits to acknowledge that Option C includes a railfreight shuttle designed to increase rail freight take-up at DIRFT
- Government policy does not limit competition in land supply. National Policy Statement on national Networks does not, in promoting an increase in SRI's, seek to limit delivery of road-only sites
- The views of other LPA's, in terms of the effect of over-provision, are accepted without supporting evidence and in respect of DIRFT III are misplaced (as DIRFT III is part of the existing and proposed supply, and only more sustainable where occupiers use rail).

6) Error in the use of SHMA forecasts to assess / conclude that options A+B and Option C would impact adversely on planned housing supply, reasons summarised as:
- SDSS and SHMA forecasts use different methods, for different purposes and for different geographies. Thus inappropriate to use HMA estimates of the need for jobs, which are closely related to projected housing need & based on population, until tested / found sound through examination. FOAN is always a minimum not a ceiling.
- The economic case for Magna Park (ES Chapter 5) is misunderstood by ISA2, it sets out that impacts affect the 16 local authority / SHMA areas that best align to Magna Parks 45 mins labour market catchment and that employment / housing needs are fully taken account of with the resulting conclusion that neither Option A, Option C or Option C+B will have significant adverse effect on housing supply or the labour market.
- No. of jobs projected to be created by each option or combination of options, represents a tiny share of the projected labour force growth in these 16 local authority / SHMA areas and would be dispersed across them.
- A proportion of jobs will be taken by people who already live in the labour market area, at present 18-20% of Magna Park employees live in a postcode area which wholly or partly lies in a Harborough District ward. Heads of Terms for the S106 for Option A and C includes appointment of a local employment co-ordinator to increase that share.
- Harborough has a very open labour market, and the creation of more jobs could reduce the level of out-commuting.

7) Errors and Unfounded Conclusions in the Assessment and Key Findings (Section 4):
The detailed appraisal in Section 4 is inaccurate and appears to be a comparison between the 3 projects rather than a proper high level appraisal of the strategic options for a plan. Selective use of ES evidence is problematic. A detailed list of the most problematic points is provided (in full representation) and summarised below;

Natural Environment:
- Loss of agricultural land is principle concern, but none of it (options A, B, C) is 'best and most versatile' protected by the planning system.
- Assessment draws selectively on the ESs for the applications and fails to pick up on proposals for green infrastructure, mitigation, and their potential positive effects on biodiversity.

Health & Wellbeing:
- Skills training and education are omitted from the objectives. ISA2 omits to acknowledge the proposed Logistics Institute of Technology included in Option C. ES for Options A and C contain detailed plans for reducing reliance on private car travel. Population projections relevant to the sector are not cited, and current labour market surplus is not understood. Strong case for more jobs to reduce out-commuting.
- Option C could place pressure on bus services, and also increase the commercial rationale for a significant increase in bus services (starting with improvements associated with Option A).
- Scoring: Recreation & Open Space -Option C merits 2 green ticks, Communities - Option C merits 3 green ticks, Accessibility - Option C should score better than Option B (2 red crosses not merited).

Resilience to Climate Change:
- ES evidence (relied upon for other parts of the assessment) means an uncertain red score for Option C is inexplicable, as no development in Flood Zone 1 and surface water mitigation measures proposed.

Housing & Economy:
- Assessment is flawed, due to errors in the descriptions / size of the options in relation to the 107ha SDSS forecast. Summary / overall score for Option C ("mixed effects") is unfounded and contrasts with the assessment of other options where ISA2 concludes Combination A+B ("similar effects to option B alone") and Combination B+C ("similar effects to Option C").
- Reference to the negative implications of the loss of least valuable agricultural land grades (3b/4), is difficult to follow.
- All options to a greater or lesser extent support NPPF para 28 (support sustainable growth of all types in rural areas), Option C does so better that A,B, or A+B (once the correct relationship to SDSS forecast is understood)
- Assessment incorrectly concludes that Option C and combination B+C would have an impact on housing in the HMA (or any other HMA) without any evidence to contradict (the Economic Case for Magna Park) evidence when; the 45min drive-time catchment would likely spread any additional housing demand over 16 local authority areas, the high level of out-commuting for work by Harborough residents, and that labour market forecasts (Economic Case for Magna Park) take account of the SHMA's for all 16 area in the 45 min catchment.
- Wide geographic footprint and dispersed nature of the industry is not understood by the assessment.
- Assessment fails to have regard to the wide labour market catchment of the sector or to the job creation targets of all 4 LEP in that catchment, each of which targets logistics because of its high growth and their areas competitive advantage for its efficient operation.
- The job count for Options C (5,300 jobs) and Option B (3,500 jobs) together represent only 7% of the current surplus labour in the 16 local authority areas / 45 min drive-time catchment of Magna Park, less if forecast labour market growth is taken into account.
- No basis or evidential support for ISA2 concluding that growth at Magna Park, which is growth that could take place across the East Midlands, would have a significant impact on any one HMA. ISA2 confuses the assessment by seeking to compare job need forecasts with the differently derived SDSS forecast of the need for additional distribution space.
- Job count of Option A is incorrectly stated and should be amended to 1230 FTE and 296 construction jobs.
- The EIA (Economic Case for Magna Park and Chapter 5 of the ES) takes account of the potential significant impacts on housing, but ISA2 ignores this evidence, and makes arbitrary judgements which are prejudicial to the proper assessment of Option C.
- It would be unreasonable to expect housing supply in Harborough to be in balance with the job creation of developments of strategic importance, which are optimally located. Optimally located means more productive and therefore more competitive.

Resource Use:
- No reference to Railfreight Shuttle proposal (Option C).
- Greenhouse Gas emissions, Option C scoring 2 red crosses compared to option B (neutral) is unfounded.

8) ISA2 Conclusions (Effects on Harborough / Broader Implications) & Key Findings
A number of issues are raised, these are summarised as (further detail in full representation);

- Stated potential for synergistic effects of the combinations assessed (A+B and B+C) is questioned and is considered incidental. Inexplicably there is no reference to the synergistic effects of options A and C with the existing Magna Park, which are significantly beneficial for the economy, environment and for employees (ref. Economic Case for Magna Park). Existing Magna Park with a large extension (co-ordinated under single management) creates a synergy, by increasing the likelihood that bus services will be commercially feasible.
- ISA2 para 5.2.9 claim, as to the need to revisit all the SHMA's (housing need), is unfounded. If there is a need it would arise because the SHMA's have taken inadequate account of the growth potential of the logistics sector (and its economic geography and labour market).
- Evidence from the "pro-forma" referred to in para 5.3.5 is not provided, nor is it assessed against the supply accounted by the SDSS (Part B report).
- Para 5.3.10 is wholly un-evidenced. EIA data includes a cumulative impact assessment (Option B +C) which finds there are no significantly adverse environmental impacts that would provide grounds for refusing the two proposals in combination.
- The claim that competition would be bad is not substantiated (Para. 5.3.15-5.3.16). The market requires choice and is particularly sensitive to location / appropriateness of units, developers will not deliver development for which demand is unlikely. SDSS advice on a sequential approach to site selection is to ensure that supply is optimally located and market-facing.
- The notion of a strategic land use as a locally arising need is misconceived (Para. 5.3.17). Magna Park exists and there are planning applications before HDC, it already draws on a large labour market area and so would any extension proposals. If HDC wants to reduce the openness of its labour market, it would have to take a policy-led approach to increase the number of jobs in the district.
- Option C on its own provides for 12.6% (47,647m2) more distribution space that Option B, therefore it is incorrect for ISA2 (para. 5.3.18) to assert that any negative implications for combination A+B would be "much less than for Option C".
- No basis provided for concluding that combination B+C would have overall implications that are likely negative because of competition, over-supply and housing. No regard had to evidence, including cumulative impact, submitted with Option C.

9) Key Findings
Conclusions provided are flawed for the reasons summarised below;
- ISA2 provides no evidence to demonstrate that Option A+B is better than Option C on its own.
- Reliance on the 107ha figure is indefensible, and ISA2 does not demonstrate that the B+C combination is not sustainable.
- ISA2's notion of a balanced approach is also indefensible on the evidence cited
- The preference for Option B is misplaced and misunderstands the evidence, if Option C is the most sequentially suitable location in terms of the SDSS it could be made to comply with the forecasts which ISA2 relies upon.
- ISA2 has not tested whether there are other options (which could be variations of the options considered) which would better meet the objectives which ISA2 purports to use to test the project specific schemes.

Representation concludes that:
1. ISA2 may not be a compliant report for the purposes of the SEA Directive 2001/42/EC.
2. Proposed alternatives are not properly assessed, either as strategic options or in terms of what they properly represent, in terms of comparing their likely impact with each other.
3. The basis on which ISA2 has been undertaken requires significant and objective re-consideration, or risks impairing the soundness of the plan.
4. given the unusual approach of adopting EIA specific material for SEA purposes, ISA2 could be regarded as legally flawed and open the plan up to challenge
Consequence of ISA2 unusual approach, together with miss-description of the options plus the evidential errors is that the principal ISA2 conclusion, that Options A+B would seem more reasonable (in contrast to Option C) and thus would appear to have the support of ISA2, is deeply flawed. It is also difficult not to infer that the combination of these factors does not amount to an exercise designed to justify a pre-determined outcome that finds against Option C.

Representation ID: 5330

COMMENT Environment Agency (Mr Nick Wakefield)

Summary:

In line with the National Planning Policy Framework, all new development should be steered away from areas of flood risk.
We have submitted our formal comments to the planning applications associated with Option A, B and C (summarised as separate representations) and we have no further comment to make at this stage.

Representation ID: 5328

COMMENT Environment Agency (Mr Nick Wakefield)

Summary:

In line with the National Planning Policy Framework, all new development should be steered away from areas of flood risk. We have submitted our formal comments to the planning applications associated with Option A, B and C and we have no further comment to make at this stage.

Representation ID: 5327

COMMENT Prologis UK Ltd. represented by Nathaniel Lichfield & Partners (Mr. Sean Gilbreth)

Summary:

An additional site (Prologis Park, Leicester) is proposed for strategic distribution development, as part of an emerging proposal for the development of a replacement motorway service station at a new Junction 20A on the M1 motorway.

Site for the logistics park extends to 65ha, would provide 378,000m2 of B2 /B8 floor-space and could deliver over 6,000 high quality jobs. Site includes land in both Harborough and Blaby districts.

Supporting documents (submitted with representation) detail site advantages, summarised as;
* Strategic highway location (with proposed new M1 junction)
* Proximity to Leicester, could assist in addressing congestion issues of M1 Junction 21
* Within convenient reach of a large resident working population
* Help meet distribution development needs of Leicester and Leicestershire up to 2031
* Accessible by means other than the private car
* Would allow direct HGV access to UK strategic highway network
* Outside of any flood zone (except small parcel to E of Whetstone Brook)
* No on-site heritage policy protection
* 4kms from nearest policy protect ecological site
* Within an area where large scale development exists & can be accommodated in landscape
* Not within an Air Quality Management Area

The M1 Junction 21 is a heavily congested section of motorway, which cannot be improved due to impracticalities with gaining road width and capacity at the roundabout. Junction 20, 11 miles away doesn't offer any potential for relieving traffic pressure. A new junction would:
* Provide alternative access to Leicester
* Reduce turning movements and traffic volume at junction 21
* Provide a direct link into Blaby bypass / the A class road network
* Allow relocation of Leicester Forest East Motorway Service Area (to betterment of prevailing road conditions)
* Create more appropriate base traffic flows enabling Highways England to introduce the "managed motorway" system

Delivery of proposed M1 junction 20a via the Development Consent Order (DCO) process as a Nationally Significant Infrastructure Project ('NSIP'), could also apply to warehouse element via an opt-in DCO.

Site not subject of representation at Options Consultation Paper stage, or via Calls for Sites, as junction 20a scheme not sufficiently progressed.

An indication of how Prologis Park Leicester (suggested Option D) and a hypothetical Option E (107ha in 2 locations beyond Magna Park and across Leicester and Leicestershire area) could contribute to the principles of sustainable development is provided in supporting documentation. For comparison it uses an identical appraisal process to the Second Interim SA Report.
The initial appraisal of Options D and E states that they give rise to less adverse effects on the principles of sustainable development and therefore comprise reasonable alternatives that should be considered as part of the process of identifying the most appropriate locations for strategic distribution floor-space within Leicestershire.

Representation ID: 5326

COMMENT Prologis UK Ltd. represented by Nathaniel Lichfield & Partners (Mr. Sean Gilbreth)

Summary:

Detailed comments made in respect of Report (ISA2) are summarised as;

Consideration of 'Reasonable Alternatives'
 SA doesn't assess other schemes discussed in the LP Options Consultation Paper (Sept. 2015), and is restricted to an SA of 3 planning applications.
 Guidance of PPG on what comprises a reasonable alternative has not been followed, and the SA has not considered all reasonable alternatives and assessed them in the same level of detail.
 The SA should have properly identified possible alternatives, rather than quickly dismiss possible sites without reference to the SA Framework. Para 2.1.4 refers to "a number of other sites" that may also have been put forward but doesn't identify or assess them. Appraisal of these against the SA Framework should have been undertaken.
 Arguments made in Section 2.3 for 'alternatives discarded', are neither valid nor robust. The rejection of sites before this stage on the basis of criteria outside of the SA Framework undermines any conclusions that could be reached from the SA process.
 A complete assessment of the ability of all possible options should be carried out with reference to the SA Framework and no policy decisions should be made until such time that this appraisal has taken place. The sites to be appraised must be drawn up comprehensively and with regard to the guidance provided at Section 4 of the SDSS which makes specific recommendations regarding the establishment of a task force to ensure proper long term strategic and collaborative planning across Leicestershire and proper discussion and identification of the most suitable sites to be brought forward. All sites identified from the sieving process must be considered to be 'reasonable alternatives' and should be subject to the same detailed appraisal to inform proper spatial planning in Leicestershire.

Failing the Duty to Co-operate Test
 The development of strategic distribution floor-space of the nature envisaged by the SDSS comprises the type of infrastructure specified in para 4a of Part 33A of the Localism Act. For the Council to meet the Duty to Co-operate test, it must engage with the authorities surrounding Harborough to establish the most appropriate means by which to take forward the recommendation of the SDSS.
 ISA2 provides limited information on any engagement. Pro-forma is referred to but no record of responses and how these have fed into the SA and planning process is provided. Harborough has failed to demonstrate how it has complied with the Duty to Co-operate. It must be concluded that meaningful liaison on a strategic level has not taken place, and any policy decisions taken by HDC arising from ISA2 must bring into question whether the Local Plan is sound

Incorrect Application of Reason for SA
 Second Interim SA has been prepared, not to identify how reasonable alternatives in the provision of strategic distribution floor-space contribute to sustainable development, but rather to assess and provide a basis on which the Council may base decisions on the three applications for sites on the edge of Magna Park. The flaws in the methodology used and the assumptions that have been made mean that any decision taken which uses the conclusions of the Second Interim SA as a basis would be flawed and could affect proper planning in the area.
 SA has no role in justifying decisions to be made in respect of planning applications. This is particularly the case when such decisions must be considered to be premature ahead of the examination and, ultimately, adoption of clear strategic policies in respect of the delivery of distribution floor-space within Leicestershire.
 PPG provides guidance on the circumstances in which it may be justifiable to refuse planning permission on the grounds of prematurity. Both circumstances are met in terms of the provision of strategic distribution, namely in respect of the scale of development that is required to meet needs and in respect of the current stage of the Harborough Local Plan.

Interpretation of Evidence (on which SA is based)
 Consistent with the conclusions of the SDSS, a key element is to deliver development across the Leicester & Leicestershire area rather than concentrate development in one area.
 Second Interim SA report has incorrectly interpreted or referred to the recommendations of the SDSS in 2 key areas; the process of collaborative planning (incl. site identification / analysis) for the sector, and the importance of offering a geographical spread of commercially attractive sites. It does not recommend the independent and isolated identification of sites by local authorities which, it must be concluded, would harm proper plan making in the area and would threaten the objectives of sustainable development.
 Floor-space quoted is inaccurate with reference to Table 3.1 of the SDSS which specifies a shortfall of 50ha for rail served floor-space by 2031 with 115ha by 2036. For non-rail served floor-space, Table 3.1 specifies a shortfall of 107ha by 2031 and 153ha by 2036.
 Rapidly changing economic circumstances in respect of UK strategic distribution floor-space mean that there is an urgent need to update the SDSS in 2016 to reflect the very significant demand for floor-space in the Leicestershire area. Evidence indicates that the floor-space in the SDSS may be out of date already and there is already a need for further areas to be identified in the area to meet needs.

Relationship of SA to Harborough Local Plan
 Clear conflict between the statements made in paragraph 1.1.8 and 1.1.10. If the findings from the Second Interim Report are being used in the process of policy making then the document must be concluded to form part of the formal SA process. If that is the case, then the failure of the document to properly appraise all reasonable alternatives, to provide clear recommendations and any mitigation and to explain how the process will inform the plan making process is clearly contrary to the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 and the SEA Directive. If not part of the formal process of SA, then policy choices and decision making in respect of the delivery of strategic distribution floor-space should not take place until full and proper SA has occurred to ensure that any decisions made have full regard the legislative requirements of the SA process.

Our review of the Second Interim SA report has highlighted a number of significant flaws that must give rise to questions regarding the soundness of the appraisal process. Notwithstanding this, it is considered that these matters are capable of being addressed through a limited focussed examination of the key points relevant to this sector. However this should only occur once proper strategic analysis of this issue has taken place to find the most appropriate locations for the delivery of the requirements for the Leicestershire area as a whole and a robust analysis of the relationship of any sites to the principles of sustainable development has taken place.

We consider that the weight of evidence presented by this document indicates that further consideration needs to be given to ensuring that the delivery of strategic distribution floor-space is subject to proper strategic investigation before any policy choices or further decisions are made. Further SA will be required once the process has taken place.

Representation ID: 5322

COMMENT Historic England (Mrs Emilie Carr)

Summary:

A strategic study of capacity and needs looking at distribution issues across the county, should help to frame thinking on options.

Sites around Magna Park should be subject to assessment of the impact upon designated and undesignated heritage assets, and their settings, to enable safe evidenced based decisions. Recommended studies will assist you, in relation to the NPPF and Statute, to apply the required great weight to the conservation of Designated Heritage Assets (in their settings) and remains of demonstrably equivalent importance to Scheduled Ancient Monuments and in having special regard to the desirability of preserving the special historic and architectural interest of Listed Buildings and their settings and the character of Conservation Areas.

We recommend that your authority address in detail the issues raised and follow closely the advice of LCC Development Control Archaeologicals and Historic Buildings Officer, in considering options in line with you emerging stratgey for expansion at Magna Park and local and national planning policy and guidance.

In taking a strategic approach to options for expansion at Magna Park, your authority should give great weight to the conservation of the Scheduled Ancient Monument and consider whether there is clear and convincing justification, specifically for Option C, as required for any harm or loss to a designated heritage asset under NPPF para 132.


Representation ID: 5318

COMMENT Mr W Carlton

Summary:

Summary of issues raised in representation;

Appraisal of options A, B and C has been driven solely by current planning applications, all aimed at huge expansion in the area of Magna Park.

Little reference to any other nearby non-rail sites, despite the requirement of the NPPF to take account of cross boundary locations (e.g. Rugby Gateway, developments near Ibstock). Both these areas have a greater need for the provision of large numbers of jobs than here, where unemployment is low.

Not all 107ha for non-rail connected sites needs to be in this particular area, many other possible locations.

Planning authority should revert to its original intention of no further expansion in the area of Magna Park.

Promise of thousands of additional jobs, of which 82% will draw in labour from beyond the district, is in itself unsustainable. This will result in additional HGV traffic and huge volumes of commuters, 96% of whom will travel by car to work a 24/7 shirt pattern.

Magna Park is confined by a local road system already inadequate to handle the volume of traffic generated. Options proposed are evidence of unsustainable planning in direct contradiction of the NPPF.

The scale of development is completely inappropriate.

Commercial development is desirable, but it needs to be smaller scale, close to public transport routes and offer higher value-added jobs with skills training for the long term. This would have the added benefit of encouraging those with valuable skills to work closer to home, offsetting the presnt outflow to other employment centres.

By concentrating on space-consuming warehouses,the planning authority is demostrating a lack of will, competance and power to plan strategically for the longer term.


Representation ID: 5317

COMMENT MR Michael Wilcox

Summary:

Following concerns expressed about the consultation;

1. No clear evidence of proactive planning and HDC setting out a planning policy, as all the options are developer led and only focus on Lutterworth / Magna Park and not elsewhere within the district. HDC is merely responding to developer applications.
2. HDC has already decided to set aside provisions (in Core Strategy) limiting expansion at Magna Park, so consultation is meaningless as you have decided to allow expansion
3. Option A already approved
4. Overwhelming local opposition to all 3 (planning) applications, which is simply being ignored. Whats the point of consultation when response ignored
5. AECOM also work for the Highways England, so their participation in this evaluation is not nuetral and may well be biased.
Seriously concerned that HDC has ignored local opinion and current planning policy, and that consultation is a tick box exercise.

Representation ID: 5316

COMMENT Mr Malcolm Stringer

Summary:

Further comments are made raising the following issues;
- Not all 107ha needs to be found in the Magna Park area
- If all options accepted, the cumulative effects would be providing land well in excess of any percieved need.
- Full account should be taken of the consenting of East Midlands Gateway and the proposal for a Rail Freight interchange on the M69 at Hinckley. The latter ticks all the boxes for modal transport.
- in the best interests of ensuring an even opportunity to all locations in the HMA, need is tailored to availability of land adjoining deprived communities
- The appraisal overstates the benefits arising from the creation of jobs with Option C (political rhetoric not good planning). Little need for jobs in local area.Bringing in jobs increases competition for labour locally and places strain on infrastructure and the environment.
- Further development will place strain on the availability of housing, unless its accepted that the Travel to Work Area (TTWA) for logistics extends into deprived areas an hours drive away. Public transport is non existent to Magna Park. More sensible to put the development where jobs area needed.
- provision of country park (Option C) is given too great a weight. It will be smaller than the open land, network of walks/bridleways and wildlife habitat that currently exists, and alongside huge warehouses and only available on foot to a limited number of people who already have access to the countryside. It seems that there will be no positive impact from providing a country park where better amenities already exist.
- a Technology College is of dubious merit given the demographic changes taking place and the recent opening of the Whittle Studio in Lutterworth. A College is also proposed at DIRFT 111. Where will all the students come from and how will they get there?
- The proposals will soak up the availability of land and deprive other locations of the opportunity to provide employment where it is needed in closer proximity.No proper consultation within the duty to cooperate has been undertaken with adjoining authorities to assess the full impact of these proposals on any that they may have in the pipeline.

Representation ID: 5314

COMMENT Mr Malcolm Stringer

Summary:

Page 16 (Amenity/ Wellbeing - Sensitivity of Receptors). Authors are misdirected on properties affected by Option C. Cross in Hand Farmhouse, Liberty's Hotel and Moorbarns Farm are some considerable distance from Option C whereas Bittesby Stables, Orchard Lodge, Bittesby Coach House and White House Farm would be immediately juxta position to the northern edge of the option C area. Bittesby Stables would be within 100 metres of the nearest building and 175 metres from the proposed new roundabout on the A5.

Page 17 (Ammenity / Wellbeing - Likelyhood of Effects) comments in respect of noise (option C) cannot be appropriate to Cross in Hand Farmhouse, Libertys Hotel and Moorbarns Farm given the overbearing physical, visual and operational proximity of Option C to Bittesby Stables, Orchard Lodge, Bittesby Coach House and White House Farm. Facts should be correctly established before effects considered.

Representation ID: 5312

COMMENT Mrs Lynn Stringer

Summary:

The report is completely wrong regarding the properties which will be adversely affected by noise, light pollution and air quality management. Together with the overall impact in respect of option C. Cross in Hand Farmhouse, Liberty's Hotel, Moorbarns Farm are nowhere near Option C. Whereas, Bittesby Stables, Orchard Lodge, Bittesby Coach House would be immediately next door. The impact on these properties would be profound.

Further comments are made raising the following issues;
- Not all 107ha needs to be found in the Magna Park area
- If all options accepted, the cumulative effects would be providing land well in excess of any percieved need.
- Full account should be taken of the consenting of East Midlands Gateway and the proposal for a Rail Freight interchange on the M69 at Hinckley. The latter ticks all the boxes for modal transport.
- in the best interests of ensuring an even opportunity to all locations in the HMA, need is tailored to availability of land adjoining deprived communities
- The appraisal overstates the benefits arising from the creation of jobs with Option C (political rhetoric not good planning).Little need for jobs in local area.Bringing in jobs increases competition for labour locally and places strain on infrastructure and the environment.
- Further development will place strain on the availability of housing, unless its accepted that the Travel to Work Area (TTWA) for logistics extends into deprived areas an hours drive away. Public transport is non existent to Magna Park. More sensible to put the development where jobs area needed.
- provision of country park (Option C) is given too great a weight. It will be smaller than the open land, network of walks/bridleways and wildlife habitat that currently exists, and alongside huge warehouses and only available on foot to a limited number of people who already have access to the countryside. It seems that there will be no positive impact from providing a country park where better amenities already exist.
- a Technology College is of dubious merit given the demographic changes taking place and the recent opening of the Whittle Studio in Lutterworth. A College is also proposed at DIRFT 111. Where will all the students come from and how will they get there?
- The proposals will soak up the availability of land and deprive other locations of the opportunity to provide employment where it is needed in closer proximity.No proper consultation within the duty to cooperate has been undertaken with adjoining authorities to assess the full impact of these proposals on any that they may have in the pipeline.

Representation ID: 5308

COMMENT Ms Kerry-Anne Browne

Summary:

As a resident of Pailton (Warks) the following concerns are raised with regard Magna Park (existing) and any potential / future extension;
- the continual inconvenience & nuisance the heavy traffic flow of HGV's, and/or motor vehicles, and/or motorbikes, and/or buses, which travel through Pailton in order to access the Magna Park
- the huge volume and high frequency of traffic (HGV's, cars, motorbikes, buses) travelling at excessive speeds through Pailton (optimum period 05:00 to 22:00)
- degeneration of the road surfaces through Pailton due to voluminous & frequent, heavy traffic
- dangers to personal safety & hazzardous road conditions caused by the volume / speed of traffic
- danger to pedestrians (particularly the elderly, children, bus users) using pavements in Pailton due to nature / volume / speed of traffic.

It is blatantly obvious that any additional and/or further expansion to the Magna Park Development would intensify & exacerbate & already altogether intolerable & unacceptable traffic-circumstance within Pailton which significantly impacts upon the quality of life and jeopardises the personal safety of Pailton Residents.

Representation ID: 5305

COMMENT Mrs June Whiting

Summary:

Leicestershire need identified as 107ha, Option A already permitted (upto 37ha)- why does the rest need to be at Magna Park, it should be spread elsewhere.

If Option A and Option B go ahead it will result in over-provision, increasing the need for labour in an area that has little or no unemeployment. Concern expressed about ensuing rise in in-commuting resulting in; traffic problems, road safety issues, air pollution.

Why should local villages be made to suffer anymore, Magna Park is Big Enough.

Representation ID: 5304

COMMENT Oadby and Wigston Borough Council (Mr Ed Morgan)

Summary:

No comment

Representation ID: 5303

COMMENT Mrs Janet Ellerker

Summary:

Local roads are congested and producing harmful pollution, and the situation is sure to deteriorate once the reconfigured Catthorpe interchange is completed, thus obliging drivers to use the A426 to travel between the motorways.

To consider doubling the size of Magna Park and so adding even more heavy traffic is appalling.
Concern expressed regarding;
- covering even more farm land in tarmac
- loss of open country, which also counteracts the adverse effects of pollution and absorbs water which mitgates flooding. Flooding in Swift and Avon Valley should not be excacerbated.

Representation ID: 5302

COMMENT Highways England (Ms Emma Stewart)

Summary:

Highways England's principal interest is safeguarding the operation of the M1 and A5.
Main interest in the SA relates to the "Accessibility" criteria. Noted that all options and combinations score between 'Minor negative' and 'Major negative', with the exception of Option A (no significant effects). Whilst we considers that these scores reflect the relatively poor accessibility of the Magna Park area by public transport, it is not evident how they have been derived.
SA contains limited specific evidence regarding accessibility (except statements on page 16).Highways England would question the term "reasonable" in terms of public transport access and considers that, whilst the other comments may appear reasonable, the scoring associated with accessibility should be supported by some evidence in order to ensure that the scorings provided in the SA are robust.
Reference should be made to the potential for commuter traffic to also have sustainability effects. Evidence on this, increased HGV & car traffic and its effects should be available from transport assessments that have undertaken for the sites.

Representation ID: 5301

COMMENT Hallam Land Management represented by Gary Stephens

Summary:

Hallam Land Management Limited (HLM) have an interest in land adjoining the M1 Junction 20 (forming part of the proposed SDA at Lutterworth East. Land (c.3ha)put forward to the Council through SHLAA/ELA call for sites request in 2015 as a strategic distribution site for c. 12,000 sq.m of warehousing.
SA Report dismissed the land as an alternative option at para 2.35. HLM disagree with the comments made;
- location adjacent to M1 is considered more attractive ( in highway, ammenity terms) given direct access to M1, therefore fewer vehicle movements on the local road network.
- size small in comparison to Options A-C, and would provide a complimentary role to development elsewhere. However, size does not mean it is less attractive or deliverable.
Opportunity should not be disregard by the SA.

Representation ID: 5300

COMMENT Mrs Gill Read

Summary:

Representation makes a number of points summarised as;
- not clear how to make comments via website
- consultation process is just a box ticking exercise
- consultation documents are too lengthy, not in plain English, nor comprehensible to the layman

Further comments made about planning in relation to Market Harborough.

Representation ID: 5299

COMMENT Framptons (Ms Louise Steele)

Summary:

Noted that paragraph 1.1.10 of the report ".....this interim SA Report does not constitute an 'SA Report' as defined by the SEA Regulations (i.e. the SA Report that should be prepared and consulted upon alongside the draft Local Plan at Regulation 19 stage of the Planning Regulations)....."

We reserve our right to make comments on the SA in the future, particularly as the Council has announced (Press release 8/3/16) that the db symmetry application (ref. 15/00865/OUT), and the IDI Gazeley application (ref. 15/01531/OUT), that the Council has decided toconsider these applications together at one committee meeting.

Representation ID: 5298

COMMENT Equality And Human Rights Commission (Local Planning Liaison

Summary:

Local, parish and town councils and other public authorities have obligations under the Public Sector Equality Duty (PSED) in the Equality Act 2010 to consider the effect of their policies and decisions on people sharing particular protected characteristics. The PSED is an on-going legal requirement and must be complied with as part of the planning process. In essence, you must consider the potential for planning proposals to have an impact on equality for different groups of people. To assist, you refer to our technical guidance.

Representation ID: 5294

COMMENT Daventry District Council (Mr Joseph Qureshi)

Summary:

The approach taken in assessing the different options is supported.

Representation ID: 5287

COMMENT Anglian Water Services Ltd (Mr Stewart Patience)

Summary:

No comment.

Representation ID: 5285

COMMENT Cllr Rosita Page

Summary:

Following points made in comment;
- Properties affected by Option C include; Bittesby Stables, Orchard Lodge, Bittesby Coach House, White House Farm.
- Viability and implementation of Options A and C is limited by the developer not being in possession of Emmanual Cottages.
- Negative impacts on the well-being of residents nearby, in Lutterworth and surrounding villages has not been given enough attention.
- 107ha is identified as needed in Leicester & Leicestershire, not all needs to be found in Harborough.
- Cumulative effect of all options (A, B and C) is well in excess of need and totally unaceeptable
- Account should be taken of other logistics parks (e.g.East Midlands Gateway, proposed Rail Freight Interchange M69 Hinckley)- over provision will lead to long term wider negative economic effects.
- Allocate sites where jobs needed (not in low unemployment area)
- SA overstates benefits of job creation for Option C, approval of DHL application provides enough jobs
- SA understates disadvantages i.e. strain on infrastructure, environment
- Public transport cannot be taken into account as its virtually non-existent to this location,not sustainable due to different shift patterns / annualised hours
- Provision of Country Park is given too much weight - will be smaller than existing open land / network of paths / wildlife habitat, development will restrict access. No positive benefit.
- Development will add to loss of agricultural land and open countryside
- Provision of a Technology College is not sustainable, not needed (one at DIRFT)and not accessible by sustainable modes of transport
- Proposals will deprive other locations of the opportunity to provide employment, where it is in greater need.
- No proper consultation has taken place to establish need and assess the full impact of the proposed options within the Duty to Co-operate, as reflected in the comments of adjoining authorities.

Representation ID: 5284

COMMENT Northampton Borough Council (Ms Noreen Banks)

Summary:

We have no comments to make on the second interim report appraising options for the provision of strategic distribution growth.

Representation ID: 5281

COMMENT Mrs Donna Hunt

Summary:

As a Harborough resident I am disappointed to see HDC hiring such established companies to make such significant decisions appear so simple and meaningless.
Dumbing-down these massive applications down to tick-boxes based on little policy or technical evidence with a lack of transparent information is very worrying.
I can only hope and urge that councillors do not make decisions based on documents like these.

Representation ID: 5280

COMMENT Now Planning (Ms Nora Galley) represented by Now Planning (Ms Nora Galley)

Summary:

The representation is on behalf of IDI Gazeley. The representation provides an account of the errors of approach, fact and omission which explain our view that ISA2 is deeply flawed. It is our view, therefore, that ISA2 will require significant and objective reconsideration of the basis on which the exercise has been undertaken and be scrutinised to ensure it is not at risk of being seen as an attempt to justify an existing conclusion. As it stands, our view is that ISA2 poses a risk to the soundness of the local plan and may also be legally flawed.

Individual points explained in detailed representation (attached).

Representation ID: 5274

COMMENT Melissa Gillbee

Summary:

Condensing all the required road distribution allocation to Magna Park is wrong and not needed.

No reference to safety on the highways is given or considered in the consultation yet Leicestershire is the 6th most dangerous county of road fatalities.

Employment is not needed in the area and benefits to housing and economy totally over-weighted. Social workers in the area hard to find because people are working at Magna Park instead! This was not considered in report.

Representation ID: 5265

COMMENT Mr A Adcock

Summary:

- There is a flaw in the assessment as Option C includes land allocation for option A which has already been consented. The report therefore overstates impacts of Option C. What needs to be compared is what is additional to what has already been consented.

-There is little transparency or evidence of cross-authority consideration. Warwickshire in particular has been understated and the management of A5 / A426 south to M6 has not been evaluated adequately.

- Cotesbach as a whole is underrepresented in the report given its proximity to Option B and the significant impacts identified in the application.

Representation ID: 5261

COMMENT Mr Michael Stanhope

Summary:

Objection:
Magna Park does not directly access the motorway network, with the result that the very large volume of vehicles accessing the distribution centre is already causing congestion on the local road network, and adding to the noise and vehicle emissions pollution in the area. Therefore the proposed further expansion of logistics facilities along the A5 between the A426/A5 roundabout and the M69 will greatly aggravate the problem.

The proposals being put forward will replace large areas of farmland with industrial development with negative effects on the environment and the local population.

Representation ID: 5258

COMMENT Edmund Hunt

Summary:

1) Assessment appears very "finger in air" and high level, making broad interpretations. I see no evidence how measures were based against planning policy or technical guidelines.

2) There's a major risk of over-supply when all other distribution developments taken into account and there is no consideration of Warwickshire allocations. This is not given adequate weight in the report (only mentioned in 5.3.9)

3) Option A should be removed all-together as consent has been granted. Option C should be reduced by the relevant land allocation of Option A to make comparison apples for apples. See attached for more.

Representation ID: 5254

COMMENT Prologis UK Ltd. represented by Nathaniel Lichfield & Partners (Mr. Sean Gilbreth)

Summary:

Representations are submitted on behalf of Prologis UK Ltd. A detailed report is provided that raises concerns regarding the approach adopted within the SA, given its failure to consider alternative development scenarios beyond those promoted at Magna Park; a lack of collaboration with neighbouring authorities; and a role more in keeping with advising development control decisions rather than properly informing the Local Plan preparation.

The representations present and assess alternative development options and include a second report detailing proposals for a strategic distribution development at a new junction (20A) of the M1 motorway.

Content of supporting documents has been summarised in 2 seperate representations.

Representation ID: 5251

COMMENT Mr Graham Logan

Summary:

Consulting on Option A is utterly pointless as HDC has already approved this plan on 28th January even though it contravenes HDC's current Local Plan.
The 3 options taken together provide 232 hectares more than Leicestershire's quota of 107 hectares for warehouse provision.
Unemployment in this area is very low (under 0.5%) and the appraisal overstates the need for jobs locally. The result would be increased inward commuting and if these plans were approved significantly more HGVs, more pollution, traffic congestion & RTAs. Leicestershire is already the 6th worst county in England for road fatalities!
No one living here wants these monstrous plans.

Representation ID: 5249

COMMENT Mrs Claudia Terry

Summary:

As Option A has been given approval agaisnst strong local opposition, there is no reasonable argument for any further expansion of Magna Park. Buiding is ongoing at the existing site and there is large expansion a few miles down the road at DIRFT .
Unemployment in the area is low, The inevitable additrional trafic will further intensify the conjestion and air pollution. The roads are not fit for this kind of development.
We should not be carving up precious aggricultural land for warehousing and distribution.

Representation ID: 5246

COMMENT Mr Neil Terry

Summary:

The Report needs to take into account the level of objections which were raised to Option A at the recent public meeting.
As there is scope for addltinal expansion on the existing site, (an example of this is taking place at this time) there is no need for extra land.
The proposals being added to the first Option A exceed the recent land area studies and do not reasonably take into account the road conjestion.

Representation ID: 5243

COMMENT Mr Colin Hancock

Summary:

If all the the planning applications are approved, the area of land
used would exceed the requirement for the area. Perhaps, the excess could be used elsewhere in the region where unemployment is higher. This would help in the reduction of pollution, and traffic problems in the Lutterworth and surrounding areas. Planning applications of a similar type already approved will cater for land required in Leics. The road conditions in the area are already dire, potholes etc. Surrounding villlages are also suffering disruption with vehicles travelling to Magna Park.

Representation ID: 5239

COMMENT Mr Brian Fowler

Summary:

It is my understanding that a need has been identified for 107 hectares of land to be made available for development. BUT it is not necessary for all of this land to be added to the overspill of Magna Park

Representation ID: 5238

COMMENT Mr Stephen Henthorne

Summary:

Please see the accompanying letter which outlines my comments on this report.

Representation ID: 5237

COMMENT Simon Silvester

Summary:

The appraisal overstates the benefits that would arise from the creation of jobs. There is little need for jobs in the local area (unemployment is about 0.5%) and bringing in jobs increases and competition for labour locally plus the disadvantages of the development because of the increase in traffic, pollution etc.
The country park would be smaller than the open land, network of walks/bridleways and wildlife habitat that currently exists. It would be alongside huge warehouses, so there will be a negative impact from providing a country park where better amenities already exist.

Representation ID: 5233

COMMENT Mrs Clare Robinson

Summary:

1. The 107 hectares identified as needed in Leicestershire do not all need to be found in the Magna Park area.

2. If all three options are accepted this would lead to a provision of 357 hectares well in excess of the stated need.
3. The provision of the country park is given great weight. However, the country park would be smaller than the open land, network of walks/bridleways and wildlife habitat that currently exists.
4. The local roads cannot cope with the increase in traffic.

Representation ID: 5232

COMMENT Mr Scott Munton

Summary:

The inaccuracies to properties on page 16 under the heading Health and Wellbeing/ Nature of Effects and Sensitivity of Receptors.
All three options are not required as this would be an overprovision of the required 107 hectares required in Leicestershire.
Country Park
Low employment in Lutterworth development should be encouraged where jobs are needed (NPPF).

Representation ID: 5228

COMMENT uk oak doors (Mr edward lines)

Summary:

Bad idea
- not thought through
-dosen't make any business sense, or at best many smaller business will be forced to leave in order to simply get the staff
-temporary contract model of these warehouses makes for large seasonal wage fluctuations that smaller business need to bear all year round
- no accomodation
- lutterworth needs general upskilling of the population rather than a higher proportion of wasehouse and distribution employment

Representation ID: 5224

COMMENT Mr David Burton

Summary:

As Option A has already been given permission at Magna Park, no further development should be considered there as to do so would increase provision significantly beyond the maximum of 107 hectares. Other areas, where there is a genuine need for local jobs, should provide any additional capacity required beyond that available under Option A. This would reduce commuter journeys and will be much better for the environment than allowing even more growth at Magna Park.

The scoring system is flawed. The country park offered under C, which will be surrounded by massively intrusive warehousing, will NOT enhance the current landscape.

Representation ID: 5223

COMMENT Mr Scott Munton

Summary:

The inaccuracies to properties on page 16 under the heading Health and Wellbeing/ Nature of Effects and Sensitivity of Receptors.
All three options are not required as this would be an overprovision of the required 107 hectares required in Leicestershire.
Country Park not comparable to existing countryside.
Low employment in Lutterworth development should be encouraged where jobs are needed (NPPF).

Representation ID: 5216

COMMENT Ms Kerry-Anne Browne

Summary:

107 ha Leicestershire need doesn't all need to be found in Magna Park area
If all 3 options are ok-ed 357 ha = total; such is above the stated need
If options A & B are ok-ed an overprovision of land is likely; 125 ha opposed to the stated need of 107 ha
The benefits of new job creation are Over The Top(OTT)
There's no need for new jobs in the Magna Park area (unemployment is circa 0.5%); new job creation increases competition & disadvantages local villages because of the increase in traffic, pollution & noise.
Existing walk bridleways wildlife & open views will suffer negatively by warehouses

Representation ID: 5215

COMMENT Suzanne Hayto

Summary:

The report claims there will be provision of a country park. Does no-one see the irony of creating a country park after standing by watching the destruction of hectares and hectares of a 'natural' county park which contains wildlife and fauna the likes of which takes decades to try and recreate. This is so wrong.

Representation ID: 5209

COMMENT Mr john Blower

Summary:

Magna Park is too big already. If we need more warehousing provision in Leicestershire there must be other areas more suitable. Noise pollution, light pollution and atmospheric pollution increases are totally unacceptable if the expansions are given the go ahead. We need our local Council to protect people living in the area against such applications.

Representation ID: 5207

COMMENT Maureen Perkins

Summary:

15/00865/OUT & 15/01531/OUT
The further unnecessary development of the area around Magna Park is not required. The increased volume of heavy traffic and workers vehicles will magnify the exhaust pollution, noise pollution already being suffered by local residents. There is no unemployment in this area. The loss of farm land, animal habitats etc destroyed all for what? An expansion that is not wanted or needed as Magna Park is big enough already. It will cause us to be grid locked in our own town. No green spaces, more flooding and total misery. HDC DON'T listen to the residents and are dictatorial.

Representation ID: 5205

COMMENT mr christopher dodd

Summary:

The proposal is in breach of HDCs previous commitment not to allow further expansion of the site and is in itself far too big and will have a number of impacts on the local surroundiings, roads, villages and people.

Representation ID: 5200

COMMENT Mr Neil Ridley

Summary:

No account of other logistics and distribution park developments close to the area have been considered. The option presented provide significantly more space that the report states is required. The impact of traffic, noise etc are not fully considered. An option of no further expansion at Magna Park has not been fully considered.

Representation ID: 5196

COMMENT Mrs Helen Heath

Summary:

Why is Option A included when it has already been given permission?
There is no need to find all of the 107 hectares in Leicestershire at Magna Park itself.
Options A and B together make 357 hectares, well over the number of hectares required.
Lutterworth and its surrounding areas has little need for further job creation.
The provision of a country park would fall well short of the open land and its pathways and wildlife that we currently have.
I am sure that there are other areas where there are employment needs that would benefit from developments like Magna Park.

Representation ID: 5192

COMMENT Mrs Karen Farnsworth

Summary:

The surrounding road network cannot cope with the traffic as it is. Hazardous and congested conditions on the roads will arise. There are enough warehousing units in Crick and Rugby, this will exceed the hectares stated.
More damage to the surrounding landscape, wildlife, heritage sites. Increased light pollution, noise, pollution with fumes affecting the local area will escalate, pollution is already at excessive and dangerous levels. Employment in warehousing is not needed this will encourage more traffic by employees, travelling on shift work, together with the increase of lorries at all hours. The lay-bys are already full of lorries parking.

Representation ID: 5183

COMMENT Mrs Shiela Carlton

Summary:

Despite acknowledging that option A (planning application 15/00919 already approved) plus option B, total 125 hectares of distribution land, exceeding the need for 107 h identified by the LSDSS, with option C considerably in excess of that, the report pre-emptively maintains all 3 options as viable. There is no need however, for any further such development in this rural area of S Leics, while other non-rail acessible sites already exist eg. Rugby Gateway, Ibstock, where there is greater need for the level and scale of jobs to be offered, while HDC area has a low unemployment rate (less than 0.2%).

Representation ID: 5176

COMMENT SHAWELL Parish Meeting (Mr Frank Fisher)

Summary:

There is considerable local elector objection to ANY further increase to warehouse/distribution development at Magna Park. Such development will necessarily involve increased HGV and commuting traffic and to unhealthy traffic polution. All to the detriment of local reidents. It was a travesty of democracy and localism for the Planning Committee to over turn the established Core Strategy when approving Planning Application 15/00919/FUL in January 2016.

Representation ID: 5160

COMMENT Ian Lewis

Summary:

Magna Park is Big Enough no further expansion is required.
Ian Lewis

Representation ID: 5159

COMMENT Mr John Branston

Summary:

The existing countryside of fields, hedgerows and wildlife that is better than that proposed Country Park and does not have a negative on the environment.

The local area has low unemployment; bringing in jobs will therefore increases traffic and air pollution, is already a local problem.

The 107 hectares identified is for all Leicestershire and not just for the Magna Park area.

All three options in the plan would lead to an over provision of land.

Options A + B are an overprovision of land, 125 hectares

Both Options B and C would be gross overprovision

Representation ID: 5158

COMMENT J Bradley

Summary:

Leicestershires requirement to provide 107 hectares does not all need to be found in the Magna Park area.
This appraisal overstates the benefits that would arise from the creation of jobs. There is little need for jobs in the local area and bringing in jobs increases and competition for labour with local businesses plus the disadvantages of increase in traffic & pollution etc. Agreeing to accept all three options will deprive other locations of the opportunity to provide employment where it would be welcomed.

Representation ID: 5157

COMMENT Mrs Ann Branston

Summary:

We already have a much better Country Park in the existing countryside of fields, hedgerows and wildlife that is better than that proposed and does not have a negative impact on the environment..

There is low unemployment in the local area and bringing in jobs increases traffic & air pollution, already a local problem.

The 107 hectares identified is for Leicestershire as a whole not for the Magna Park area.

All three options in the plan would lead to an overprovision of land

Options A + B are an overprovision of land, - 125 hectares

Options B + C would be gross overprovision.

Representation ID: 5156

COMMENT Mrs Kathleen Rowell

Summary:

The identified need of 107 hectares does not need to found at Magna Park look at other existing proposals in Leicestershire already decided or awaiting decision, we do not have to have all the misery!
If both B and C go ahead there will be over provision of warehousing.
The jobs created are not needed locally and again will bring great misery to the locality in respect of traffic, pollution. Jobs should be created where there is a need.
There will be wholesale destruction of countryside and wildlife habitat, which will not be improved by these proposals

Representation ID: 5155

COMMENT Mr michael Wood

Summary:

I object to all proposals to expand magna park. Traffic, light and noise pollution will all increase and will have long lasting impacts on the local villages and towns.

Representation ID: 5135

COMMENT LUTTERWORTH TOWN COUNCIL Parish Council (Andrew Ellis)

Summary:

Lutterworth Town Council is strongly of the opinion that a strategic overview is required as the appraisal options currently underplay the impact of traffic on Lutterworth and the surrounding villages. There are claims within the report as to the scale and volume of traffic that are not substantiated. A decision concerning these options should be determined at a higher level due to the large scales of development involved.
There is not any discussion of road improvements with Options B or C and their impact on Lutterworth and the surrounding villages.

Representation ID: 5131

COMMENT Dr Paul Dimmer

Summary:

In general the report under-estimates the negative effects while over-estimating the positive effects.
Loss of 170 ha of agricultural land is not considered sufficient to merit a cross.
Access to the countryside exists and the rights of way are fine - as recently reported to the Ramblers Association Big Pathwatch. These footpaths are walked regularly by both organised and ad-hoc walkers. Surrounding these areas with warehouses would be to the detriment of such activity. In fact it would cease. A so-called "country park" would be no substitute. Option C Landscape & Recreation and Open Space should both be negative.

Representation ID: 5121

COMMENT Mr Boguslaw Siwecki

Summary:

There is too much development in the area as a whole and there is still ample space being marketed in several "Parks" including Magna Park. Employment is needed in other parts of the country not more empty warehouses here. the provision of the country park is going to give the local community less than it has at the moment and is a contrived substitute for the natural beauty we already enjoy.
Magna Park does not need to be expanded and when option A already has been given permission why is it included in this consultation. "ALL A SHAMBLES" again

Representation ID: 5120

COMMENT Mr Shane Blower

Summary:

I am very concerned about the implications of increased traffic, both HGV and commuting vehicles through Pailton, We already have problems with current heavy goods vehicles trying to negotiate chicanes and bad corners within the village.

Representation ID: 5119

COMMENT Mr Antony Osborne

Summary:

The report continues to fail to realise that it sits on a border with Warwickshire. The scale of development is so big this is a Warks/Leics & wider issue - not just Harborough. It is understandable that Magna exists because of the adjacency to M1, M6, M69 & A5. But even these strategic highways have a capacity limit. Already 5-6 mile tail backs occure on B roads when accidents occur on major roads. Unless the major roads are expanded and proper controls placed on B roads, health & wellbeing will be destroyed. The report underestimates the impact.

Representation ID: 5115

COMMENT Mrs Jaqueline Strong

Summary:

The three options together provide 232 hectares more than Leicestershire's quota of 107 hectares warehouse provision.
Unemployment in area is low, (c,0.5%). The appraisal overstates the need for jobs locally.
Surely there is a need to povide jobs elsewhere in the county where needed.
This would mean inward commuting in vehicles and, if planning permission given, an increase in HGV with associated pollution, traffic hazards, litter, noise and an erosion of village life.
The country park looks like a sop to environmentalists. We already have one. The proposed addition would be surrounded by warehouses - hardly a country park!

Representation ID: 5114

COMMENT Dr I.D. v.d. Ploeg

Summary:

1. 107 hectares identified as needed in Leicestershire do not all need to be found in the Magna Park area.
2. All options together lead to 357 hectares, in excess of need.
3. A&B lead to overprovision of land.
4.No need for jobs (unemployment 0.5%) and causes increased traffic pollution.
5.The country park would be smaller than land, network of walks and habitat that exists. The country park would be alongside warehouses.There will be a negative impact instead.
6.Options B and C would soak up the availability of land and deprive other locations of the opportunity to provide employment where it is needed.

Representation ID: 5110

COMMENT Mr David Chapman

Summary:

1. The 107 hectares identified as needed in Leicestershire do not all need to be found in the Magna Park area.
2. If all three options are accepted this would lead to a provision of 357 hectares that is well in excess of the stated need.
3. If options A & B were accepted this would also lead to an overprovision of land, 125 hectares as compared to the stated need of 107 hectares.

Representation ID: 5109

COMMENT Mrs Julie King

Summary:

Planning has already been approved for Option A even though it is contrary to the current plan. This report leans heavily towards options B & C which would obviously be the most beneficial for the Council's coffers but which would be extremely detrimental to the health and wellbeing of the residents of the wider local area. Planning was approved for Option A despite fierce opposition from local residents with extremely valid objections. What is the point of asking for local opinion if the Council is not going to listen to those opinions and put the welfare of its residents first?

Representation ID: 5102

COMMENT BROUGHTON ASTLEY Parish Council (Debbie Barber)

Summary:

Broughton Astley Parish Council has no comments to submit, subject to ratification by the Parish Council, at the meeting to be held on Thursday 17 March 2016.

Representation ID: 5098

COMMENT MR Michael Wilcox

Summary:

You are consulting on option A which you have already appoved so it is pointless.
Additionally you are using AECOM as consultant who is working for Highways England who has already approved all options so their advice is not neutral and is probably biased

Representation ID: 5097

COMMENT Mr Sam Weller

Summary:

The Sustainability Appraisal is based on the false premise that 107 ha of new land for strategic distribution at non-rail served sites needs to be provided, and Magna Park is the best place for this. Under "Health and Wellbeing" it overemphasises the benefits of job creation and minimises the detrimental effects on Air Quality, Accessibility, and Amenity. The benefits are virtually nil, and the costs to health from poor air quality and deaths and injuries from road accidents and congestion mean that this area should not be subject to any further development.

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