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Consultation Starts


Hello All,

Right, where are we now? Following on from the Inspector's Hearing on 10th October, Harborough District Council (HDC) have revised the proposed 2011 - 2031 Local Plan using a "Schedule of Main Modifications" based on the comments and directives made by the Inspector. What we should see now is a plan which complies with everything that the Inspector wanted to see, and should therefore be considered legally "sound". However, in order to ensure that everybody can air their views on whether or not they agree with the amendments, we are now in a period of public consultation.

This document compares the comments and directives issued by Mr Jonathan Bore, Planning Inspector, at the Examination Hearing on October 10th 2018, with the Schedule of Main Modifications to the Harborough Local Plan issued on 15th January 2019.

Please note, any views that are expressed within the body of this document are MINE. While I am a Town Councillor, the Town Council has yet to meet to discuss these changes, and therefore has not at this stage formed an official position. A meeting is scheduled, and the Town Council will form that position. I am writing this article because this is an important issue, and the residents of Lutterworth need to know as soon as possible where we are, and that we are now in a time limited period of public consultation. The Town Council know that this article is being written.

The publishing of the Schedule of Main Modifications indicated the commencement of the period of public consultation, which officially runs from 12 noon on Tuesday 15th January 2019 to 12 noon on Tuesday 26th February 2019. The consultation is limited to the Schedule of Main Modifications and associated consultation documents, and is not an opportunity to re-open consultation on items within the local plan that are not covered within these documents.

There is no standard format for the presentation of comments of objection or support, and all such representations should be submitted:

by email to localplan@harborough.gov.uk,

or by post to

Strategic and Local Planning Team

Harborough District Council

Adam and Eve Street

Market Harborough

LE16 7AG

So, if you are interested in this subject, and I assume that as you are reading this page you are, please read and consider what is printed below.

  • Think about what it says

  • Think about how Lutterworth will look, feel and work during the development and afterwards.

  • Think about what Leicestershire County Council is proposing for Lutterworth

  • Think about what you want for the town

  • Consider whether on balance it's a good thing or not

  • Consider some of the detailed points - do they work for you or can you see problems?

Once you have done that, decide whether or not you want to support, object, or just comment on the proposals. If you do, and you have EVERY RIGHT to do so, choose one of the options above (email or letter) and state your case. Remember, all responses will be read and must be considered, so if you can, state WHY you support or object to a point. Don't be shy, don't worry what people will think - if you have a view and can say why you take that view, then get that view out there - it is as valid as anybody else's!

However, please remember that if you want to comment, you MUST do so BEFORE MID DAY ON TUESDAY 26TH FEBRUARY 2019. Comments received after this point will not be considered.

The full version of the Schedule of Main Modifications can be found at the following address:

https://www.harborough.gov.uk/local-plan-examination​

Hopefully, what you read later on in this article will be clear. However, it may not be, and you will not be the only person to have questions or not understand a certain point. I am more than happy to answer any questions that you may have - just contact me via the email link at the bottom of the web site and I will do my best to help.

So, before we get in to the detail, a brief explanation. The Local Plan is made up of Policies, each of which has a number and relates to a particular area of development within the Local Plan. The Policy that relates to Lutterworth East is called Policy L1. Another Policy that you will read about is Policy BE2 - this relates to Strategic Distribution, and put simply is the Policy that deals with the expansion of Magna Park and the development of Glebe Farm as another distribution location.

This document will primarily concentrate on Policy L1, relating to the East of Lutterworth Strategic Development Area, however reference will also be made to Policy BE2 and other areas of the proposed local plan as and when they impact the proposals. The document will address the following points:

  1. What comments / instructions were made by the Inspector at the October Hearing?

  2. How has the Schedule of Main Modifications (SMM) addressed those points within the Policy?

  3. What other points of note are raised within the Schedule of Main Modifications?

So, here we go....

The Inspector clearly stated that the new development must be seen as being an extension of Lutterworth, and not a stand-alone community.

  1. SMM point 3, and point 15.2.1 of the Explanation (Extract) (EE) address this point. It states that “The masterplan will guide the creation of a high quality sustainable urban extension to Lutterworth and an attractive environment for living, working and recreation”.

  2. Clearly, at this stage, we have not seen the masterplan (remember the plans that were on view at the Library as September?) that has been created as a result of the SMM, and hopefully the Town Council will have sight of this during the meeting with LCC and the Planners on Tuesday 22nd January. As soon as it is available I will publish it on this site. The most recent masterplan that we have seen suggests a plan that clearly creates a separate development, indeed the new development itself is split in to three separate areas, each with a “village” name. Therefore, we should be expecting to see a much improved masterplan.

The Inspector stated that the M1, the Spine Road, and the proposed employment areas must not act as barriers which effectively divide the new entirety of Lutterworth in to two separate halves.

  1. SMM point 3 states that “(the masterplan) will address and overcome the issue of common severance resulting from the presence of the M1, to create a sustainable urban extension which is permeable and well connected to Lutterworth via legible walking and cycling routes with good natural surveillance”. This is also supported by EE point 15.2.4.

  2. Subject to the presentation of the revised masterplan, there are a number of points here.

  3. Firstly, it is clear that the M1 cannot be diverted, so we would expect the plan to demonstrate clear and usable crossings

  4. The Spine Road, however, is part of the new development and its very nature will be that, like the M1, it is a line of division. While the promoter will no doubt claim that the solutions for the M1 will also serve as solutions for the Spine Road, there is an argument that the Spine Road does not have to be built between the old and new Lutterworth. The routing could take it around the new development, from the planned exit point on the A426 to a point on the A4304 slightly further east than the current proposed junction. This would still enable it to serve the new development in terms of access, however it would also serve as the much yearned for by-pass to Lutterworth, without diverting traffic through the new development which the current proposal will inevitably do.

  5. The Inspectors comments also refer to the employment areas as points of severance. At the hearing on October 10th, Marrons presented a plan which moved the employment areas to the north of the residential development. In the SMM, under “Housing” on page 58, point f), in referring to the class B1 and B2 business use, has had the phrase “…on land between the Spine Road and the M1”removed, so we should expect to see a masterplan that reflects this, with the employment areas being moved north of the development.

  6. Finally, and we may as well address this point now, we need to remember that this is a hybrid development. Leicestershire County Council (LCC) will be developing the road network and will be selling off the residential developments to other developers. Therefore, LCC have a vested interest in keeping the highway development as simple and as cheap as possible, and therefore not necessarily in the interests of current and future residents.

The Inspector questioned the proposed closure of the Gilmorton Road, as he stated that it was clearly the most direct connection between Lutterworth and the new development, and was the easiest way of crossing the M1.

  1. On page 60, as part of the Explanation (Extract), point n) from the original draft has been removed, along with the phrase “…following completion of the spine road, conversion of the Gilmorton Road crossing over the M1 for use by public transport, cyclists, pedestrians, and emergency vehicles only”.

  2. It will be interesting to see whether Marrons follow this point and change the proposed use of Gilmorton Road.

  3. If so, there could be an argument that vehicular use of this route will improve links to the new development that would otherwise have to be satisfied by the Spine Road. If this could be successfully argued, this could lend weight to the justification of moving the Spine Road to the northern and eastern perimeter of the new development, and allow it to become a by-pass.

  4. We would of course have to consider the potential impact to the centre of Lutterworth in terms of traffic, however if it allows for a by-pass the net impact should only result in reduced traffic volumes.

The Inspector stated that pedestrian and cycle ways through green spaces must be highly visible and overlooked by buildings. Pathways must not be bordered by hedges.

  1. On page 60, under Highways and Transportation, point o) provides for “…a network of legible, direct, safe and attractive routes, which will all be well lit, surfaced, with good natural surveillance and provide connections to Lutterworth town centre, the local centre and employment uses within the SDA, and to existing cycle routes, bridleways and footpaths…”.

Having reviewed the masterplan on October 10th, the Inspector suggested that Marrons take the plan away and start again.

  1. We have seen a revision dated 16th October 2018, where there were very minor adjustments, however nothing that could be described as “starting again”!

  2. Close review of the masterplan that will be produced as a result of the SMM will be essential.

The Inspector stated that the masterplan should be of the best design, should incorporate key design principles, and should meet the requirements of the task.

  1. Clearly, we need to see the revised masterplan in order to answer this point.

The Inspector required that the plan provided for a sustainable and integrated community

  1. Point 15.2.4 states that “The SDA will create a sustainable urban extension to Lutterworth, essentially mirroring the existing town to the west of the M1, with new development to the east of the M1. The SDA is expected to be sustainable at the neighbourhood level and to provide for the day to day needs of its residents,…”

The Inspector stated that, as part of the development, HGV traffic running through Lutterworth is removed or significantly reduced.

  1. Point 6 of the Explanation (Extract) on page 62, along with 15.2.6 on page 64 deal with this point. Point 6 states that “Following completion of the spine road, in partnership with County Highways Authority and the SDA promoters, the Council will develop traffic management measures that remove or minimise the passage of heavy goods vehicles through the centre of Lutterworth, as part of the implementation of an effective air quality mitigation strategy for the Air Quality Management Area in Lutterworth town centre”.

  2. However, the key point for us here is the phrase “Following the completion of the spine road..”. This effectively means that all action and planning will be retrospective. In order for there to be any likelihood of the spine road assisting the relief of Lutterworth town centre, it needs to be designed for the purpose. There is nothing in the revised policy that stipulates this requirement, and therefore this clause very much resembles the idea of “jam tomorrow”. Dealing with the problem after the completion of all necessary infrastructure suggests that in reality the problem will not be dealt with, and the creation of the spine road is far enough in the future for this to be kicked in to the long grass. Clearly, at the very least, we need a specific commitment that the spine road (regardless of final location) is built to deal with the projected HGV traffic flows relating to 2031 and beyond. Further, we need clarification on what the “traffic management measures”will be. There is an infinitely high probability that the planners at Marrons, the lead figures within the promoter, the staff of the County Highways Authority and the planning department at HDC will all have changed by the time that the traffic management measures are to be considered. Given that effective measures could be determined now, and implemented at the appropriate time, there is no reason whatsoever that specific plans can’t be prescribed within the local plan, so that the residents of Lutterworth have a high degree of certainty as to what will happen, and the effectiveness of the plan. Leaving this point in limbo is unacceptable.

  3. In point m), on page 60, we are told that the spine road will be constructed before 1,250 dwellings are complete. However, in point a) on page 58, we are told that the number of houses required to meet the housing requirement by 2031 is 1,260. Therefore, the rocket scientists amongst us will have worked out that the spine road does not need to be completed much before 2031. In effect, there is therefore no plan to provide any relief to Lutterworth town centre for at least 12 years from now.

  4. Further, in 15.2.6 on page 64, we are told that the spine road is predicted to “remove some of the through traffic currently travelling through the centre of Lutterworth”. Not that it will be designed to remove HGV traffic, but that it will remove some of the through traffic.

  5. However, it then goes on to say that the “…southern part of the spine road, and not Gilmorton Road, should be used as the main means of accessing the site, both for residents and construction traffic, until such time as the link across the motorway to the north is in place”. So, this means that there must be some form of prevention in place to stop the Gilmorton Road being used. As we saw earlier, the requirement to close the Gilmorton Road to through traffic has been removed, although this doesn’t stop it happening. So, if it is closed, in order to prevent it being used as an access to the new development as per the policy, what the policy is now saying is that the only access to Gilmorton for Lutterworth residents is via the current M1 crossing, and then down the new southern spine road to the new junction with the Gilmorton Road. This will have the effect of pushing even more traffic through Lutterworth from the traffic lights by the library through to the Whittle roundabout, and onwards across the M1. This will hardly improve air quality, or the level of traffic congestion.

  6. The answer to all of the above is the creation of a road that circumnavigates the new development, adjoining the A426 north of Lutterworth, and adjoining the A4304 to the east of the M1 junction. This road, effectively a by-pass to the entire Lutterworth development (old and new) will ensure that both developments are protected from through traffic, and should be built at the commencement of the project, thus bringing greatest access and greatest benefit in the shortest possible timescale.

The Inspector required that the proposed cycle ways linked up with existing cycle routes.

  1. Under Highways and Transportation, on page 60, point o) states that new and existing cycle ways must connect.

It was highlighted at the Hearing by Lutterworth Town Councillor David Gair that all new cycle ways and pedestrian routes terminated at the A426, with no proposed safe access to the rest of Lutterworth. The Inspector acknowledged the point, and required that the policy must be changed in order to resolve this issue

  1. In point 5, on page 62, there is the following comment. “Appropriate traffic management and public realm improvements in Lutterworth Town centre to facilitate the movement of pedestrians and cyclists, particularly across Leicester Road, will be agreed and provided for through the planning application and accompanying agreements”.

  2. This is clearly of concern, as it is leaving the provision of safe passage across the Leicester Road to the planning process, rather than stipulating the requirement as part of policy.

  3. The population of Lutterworth will have no advance knowledge of what this will mean prior to development commencing

  4. There is no reason why this could not be a prescribed requirement of the masterplan, rather than leaving it to discussions as part of the planning process.

  5. There is an argument that the existing nature of the A426 also provides a separating line between old and new developments, and the significant reduction in traffic flow afforded by a by-pass would serve to reduce this line of separation

The Inspector required that the Highways Department must demonstrate how vehicles would be managed away from the A426 and on to the Spine Road.

  1. Within the SMM, there is no requirement for the Highways Department to demonstrate vehicle management, and this needs to be corrected.

  2. Clearly the obvious method is the de-classifying of the A426 to a B road, and the enforcement of a 7.5 tonne weight limit (other than for access).

  3. This is going to receive strong opposition as it will mean the requirement of a by-pass, which is something that the promoter does not want to entertain

The original policy provided for the replacement of the Leisure Centre. The Inspector stated very clearly that as this was the centre of Lutterworth both geographically and socially, the replacement of the Leisure Centre must be removed from the policy.

  1. Under Community Facilities point k), on page 60, the SMM states that the policy will “…safeguard land for a potential new leisure centre to serve Lutterworth”.

  2. While the word “replacement” has been removed, this does not necessarily change the meaning of the original wording. Any “new” leisure centre could still be a replacement, as the closure of the existing leisure centre is not specifically prevented by the policy.

  3. The Inspector stated that any change to the existing Leisure Centre should be outside of the policy, and should only occur as a result of community planning and consultation.

  4. The wording of point k) needs to change to reflect this.

We now move on to other points of note within the SMM, that are not necessarily directly linked with comments made by the Inspector, but are worthy of consideration.

Housing – point a), page 58. Of the 2,750 dwellings proposed, the number required to satisfy the housing demand by 2031 has been down rated from 1,500 to 1,260

  1. This will mean that the remaining 1,490 houses (54%) are required for post 2031 demand.

  2. This suggests that the timescale for this development could easily run from the indicated 15 years to closer to 25 years.

Business and Employment – point e), page 58. The land to the south of the A4304 (ie next to Junction 20) is now to be classified as B8 Distribution, with the words “non-strategic” removed from the policy.

  1. This means that it will now be classified in exactly the same way as land at Magna Park and the proposed Glebe Farm developments

  2. In policy BE2, a limit of 700,000 square metres was recently placed on the scale of development of B8 use within the 2011 – 2031 Local Plan. In theory, therefore, the land south of the A4304 should only be developed for B8 use if it comprises part of the 700,000 sqm.

  3. Analysis of the SMM for Policy BE2 reveals the following. In point 2 on page 23, the policy states that “An additional development of up to 700,000 sqm for non rail-serviced strategic storage and distribution (Class B8) use will be provided in the District. Additional development should form an extension of, or be on a site adjoining, Magna Park in the following locations: a) 380,000 sqm already committed on two sites…..b) 320,000 sqm on land North and West of Magna Park…”. Therefore, the policy puts a cap on development of B8 at 700,000 sqm, and then states where that 700,000 sqm will be located. These locations are clearly shown on the map provided within the SMM.

  4. Clearly, neither of these locations is the land south of the A4304.

  5. Equally clearly, the narrative relating to the land south of the A4304 and its proposed use for B8 Storage and Distribution is incompatible with policy BE2 and needs to be shown as such. The land is high quality agricultural land (a point that has now been removed from Policy L1 in the SMM – see EE 15.2.13 on page 65). The issue here for the promoter is that they have declared that the use of this land for B8 classification is effectively a cash cow – the original Policy L1 stated that even though there is no justification of need for warehousing at this location, and even though the land is high quality agricultural land, it will generate money which will pay for the changes to the M1 roundabout, and this is considered justification enough for it to be incorporated in the policy.

  6. In the SMM for policy BE2, in point 6.3.98 on page 28, we are told that “The limit on the amount of development to be permitted in the District balances the strategic distribution floorspace with the capacity of the housing provision. Development above this amount would impact upon the distribution of housing in the wider area.” Therefore, there should be no extension to the 700,000 sqm already provided for.

  7. We need to focus on this and have the provision of B8 removed from Policy L1 – we do not need more warehousing, and the warehousing that we have needs to be concentrated around Magna Park.

Community Facilities

  1. Point g), page 58, tells us that of the two, two form Primary Schools, at least a one form entry must be complete and open by the September beforethe completion of 300 dwellings. This is a welcome change to the previous iteration which suggested that additional schooling would only be available after the completion of 300 houses. However, there is a qualification to the statement, in that the policy goes on to say that the opening schedule may be delayed to a later date based on the policy of the LEA. This point is clarified in EE 15.2.15 on page 65, as it points to below predicted pupil numbers as the trigger for a later date.

  2. In point i) we discover that the deadline for the provision of the neighbourhood centre has moved from “…before the completion of 700 dwellings…”to ..”in accordance with a phasing plan to be agreed with the Local Authority…”. Again, the plan is now becoming less predictable in terms of what will be done and when. Further, we now learn that the facilities quoted as being part of the development are now a list from which “…some or all…” will be provided. So, there may not be an additional Doctor’s Surgery, Community Hall etc…

  3. Finally, in point j), we learn that the provision of greenways are for walking and cycling – the inclusion of horse riding has been removed.

Highways and Transportation

  1. In point o) on page 60, it is confirmed that a minimum of 5 crossings must exist between the two developments, providing dedicated walking and cycling connections in to Lutterworth across the M1. Remember, Gilmorton Road is no longer required to be closed as part of the policy, so this may not form part of the “dedicated” walking and cycling routes.

  2. In 15.2.20, on page 65, we learn of the fate of the various junctions. Probably the most locally sensitive junction, the Whittle Roundabout, will no longer succumb to replacement with a traffic light controlled crossroads junction, but will be an“upgraded roundabout”. Other junction changes are compatible with the type of road network that is being proposed, with the Bill Crane Way / A426 junction being of note as it is proposed to put traffic lights there, along with a pedestrian crossing.

  3. Finally, in 15.2.24, we have an explanation relating to the Air Quality Management Area. “Lutterworth town centre is one of just two Air Quality Management Areas (AQMA) in the District. This is primarily as a consequence of the volume of traffic including HGV's using the A426. Development of the site provides the potential to deliver an eastern relief road for the town which can deliver significant environmental benefits to the town centre, as well as improving the health and well-being of residents. The policy requires noise and air quality mitigation measures for proposed dwellings adjoining the M1, and no moderate or worse adverse impact upon air quality within the Lutterworth Air Quality Management Area. A moderate adverse impact is defined by Land-Use Planning & Development Control: Planning For Air Quality May 2015 b(v1.1) EPUK & IAQM (or a successor document). Following completion of the spine road, traffic management measures and public realm improvements will be developed to remove or minimize the passage of HGVs through the centre of Lutterworth and to facilitate the movement of pedestrians and cyclists between the SDA, town centre and key facilities within Lutterworth.”

  4. This explanation clearly allows for the “eastern relief road” which is clearly supposed to relieve the town centre. This puts the protestations to the contrary of Simon Lawrence and LCC to bed once and for all. We need to use this clause as a spring board to push for the by-pass.

  5. We should challenge the comment that allows for “…no moderate or worse adverse impact upon air quality within the Lutterworth AQMA...”. We need this development to actively improve the quality through its planning and policy.

Consultation

  1. Given that this has been a point of contention with the developer and the planners, it is interesting that the SMM for Policy L1 provides quite clearly for the consultation process. In the Explanation (Extract), point 15.2.2 provides for the following:

  2. “In order that the SDA is developed in a way that complements and enhances the town and does not become an unwelcome accretion, it should be in accordance with a masterplan that is produced with the full engagement of the existing community of Lutterworth and which has the support of the population through a consultation process as part of either a Supplementary Planning Document, a Neighbourhood Plan or a planning application.“

Well, hopefully that wasn't too dry, that you could understand what changes were being made to the plan, and where this puts us. If you have any questions, please get in touch and I'll do my best to answer. DO NOT take the view that a question that you have is trivial, daft, makes you look stupid, or is in any way not worth asking. There is no such thing as a bad question, so if you need an answer to anything related to the above, ask and I'll do my best to answer.

That then leaves the question -

"Are you going to make a comment of objection or support using either the email address or the postal address given at the beginning of this article?"

Remember - this is your time to express your views. It doesn't happen often, and it won't last for long. You have until mid day on Tuesday February 26th 2019. If you aren't bothered, then OK. If you have a view point, I would encourage you to express it - if you do, you can never look back and and regret that you didn't make your views known, regardless of the final outcome.

As and when we see what the proposed masterplan is, I'll let you know. If the Town Council plan to arrange any public meetings or exhibitions relating to the Lutterworth East Development, I will also let you know.

As usual, any queries, please give me a shout !

Regards

Richard


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