Misterton with Walcote Parish Council – response to Harborough Local Plan

Walcote Parish Council wishes to make the following representations concerning the Harborough Local Plan. Parish Council is concerned that the consultation process has not been used to inform a number of policies proposed in the Harborough Local plan. This does not encourage participation, as the public has had no opportunity to express its views concerning these policies and indeed it seems that some new policies are entirely at odds with the opinions expressed in the earlier consultation.

Policy BE1bii – the allocation of 13 hectares of land for storage and distribution to the south of the A4304 Misterton with Walcote Parish Council OBJECTS to this allocation for the following reasons:  The plan has not demonstrated a need for this development (paragraph 15.2.11). In the consultation document, the land was proposed for a Motorway Service Area (to which the Parish Council also objected) – there is no information provided to justify this reallocation.  The allocation of land to the south of the A4304 opens land further to the south to development pressure as there is no natural or landscape barrier distinguishing the allocated site from its surroundings. Therefore it is not in accordance with policy GD8d.  The allocation has not been tested through consultation as it differs fundamentally from the proposals in Harborough’s consultation document.  Land to the south of the A4304 is grade 2 agricultural land, a limited resource and comparatively scarce within . In its Strategic Housing Land Availability Assessment 2014, development was discouraged on land quality 1, 2 and 3a. Thus the Parish Council contends that development on this site is contrary Harborough District Council’s own selection criteria and is contrary to policy GI5.3  Access to the site is likely to cause excessive traffic congestion despite, or possibly because of, the access arrangements proposed. Access will be via a traffic light controlled junction. A similar access is planned for the strategic allocation to the north of the A4304 (Lutterworth East) and traffic lights are also proposed for junction

20 of the M1 and the A4304 with the A426. The total distance between the eastern most part of the site and the A426 is 0.73 miles (1175m approx.). In this distance it is proposed to install four new sets of traffic lights. Furthermore, the A426 roundabout and the M1 junction will also need to accommodate traffic generated by development at Magna Park. All four junctions will also process any extra traffic generated by development at Airfield, new traffic from Lutterworth East residential development and traffic removed from Lutterworth town centre approximately (24% - 34% 15.2.19) in addition to existing traffic using the A4304.

Policy BE2 – Land for Strategic Distribution at Magna Park Misterton with Walcote Parish Council OBJECTS to this allocation for the following reasons:  The allocation has not been tested through consultation as it differs fundamentally from the proposals in Harborough’s consultation document.  The allocation is contrary to Key Objective 3 as it will not provide employment ‘for Harborough’s higher skilled residents’.  The allocation is excessive. The plan provides no evidence of the need for an allocation of this size which has been labelled as ‘political’ by Harborough’s own councillors at the meeting on 18th September.  The allocation is contrary to Objective 2 (p17) and Policy BE2.2.c as it will not ‘create new jobs that meet local employment needs’ or ‘increase employment opportunities for local residents’. This is because in the whole of Harborough District there were only 1200 people registered unemployment from April 2016 – March 2017 (https://www.nomisweb.co.uk/reports/lmp/la/1946157143/report.a spx#tabempunemp) a rate of 2.6%, well below 4.2% for the and 4.7% nationally.  Already 75% of the Magna Park workforce comes from outside the district. There is insufficient unmet employment need to reduce this figure, thus commuting will increase substantially. Magna Park Growth Sensitivity Survey concludes the allocation of 700 000m² of extra warehousing will generate 9689 extra jobs. Of these, the best case scenario sees 6488 commuting from outside Harborough District, whilst changing the assumptions used will see 7962 extra commuters from beyond district boundaries. Even if the workforce is hired in accordance with policy BE2.2.d, there will still be a substantial increase in commuting. We also question Harborough Council’s ability to ensure compliance with this policy or to take

action if it is breached. Does the Council have the powers to influence employment decisions?  Along with allocations of housing land in policy L1, employment land in policy BE1.bii and intensification of use in policy BE4.1.f Misterton with Walcote Council is concerned that congestion is inevitable, particularly around junction 20 on the M1, contrary to policy BE2.2.e

Policy L1 – East of Lutterworth Strategic Development Area Whilst Misterton with Walcote Parish Council appreciates the advantages of allocating substantial parcels of land for housing allowing the economic provision of infrastructure, it wishes to raise concerns about certain aspects of the allocation of land to the east of Lutterworth.  Whilst the size of the allocation to 2031 is now reduced to 1500 dwellings, the ultimate size of the development to 2036 remains 2750, 750 more than was in the original consultation document.  The Parish Council is concerned that delaying the completion of the spine road until 1250 house have been constructed (2029 approximately) will be contrary to policy IN1.1 as the infrastructure provision will not be in place until a substantial proportion of the site has already been developed.  The proposal will be contrary to Key Issue 8 and policy IN2.g as delayed provision of the spine road will have an adverse impact on the Air Quality Management area in Lutterworth town centre.  The Parish Council notes that the main road through the development site between the A426 north of Lutterworth and the A4304 to the east of Lutterworth is described as a spine road (policyL1.3.m) rather than the Lutterworth Eastern by-pass, the provision of which was the prime factor on which previous support for the development was based. The access via a traffic light controlled junction is likely to discourage drivers from using the spine road, the design standard of which is lower than previously detailed.  Paragraph 15.2.16 suggests the road will facilitate only ‘some relief to through traffic within Lutterworth town centre’ and is concerned that ‘currently unforeseen circumstances’ might further delay or down grade the quality of the spine road.  Misterton with Walcote Parish Council SUPPORTS the policy L1.5 to minimise the number of heavy vehicles passing through Lutterworth town centre.  Misterton with Walcote Parish Council SUPPORTS the policies L1.3.jiii and L1.3.u which aims to protect greenspaces, woodland

and the Misterton Marshes SSSI within the site. Although paragraph 15.2.25 promises that Harborough District Council will consider a detailed ecological assessment of the site, Misterton with Walcote Parish Council considers it imperative such survey be completed before any development is begun on the site.  The Parish Council is concerned that land proposed for development lies within the floodplain of the , an area frequently subject to flooding. Consequently, poorly designed development may impede the flow of the stream, causing problems within our parish.  In addition, we urge careful consideration be given to the siting of development in relation to St Leonard’s Church Misterton, a grade 2* building.

Misterton with Walcote Council is concerned that the Plan has no overall strategic view of transport issues throughout the District, including the intergration of traffic generated by different policies. We are concerned that the cumulative effect of these allocations may have unforeseen consequences for the road network which have not been addressed.