Lutterworth East - Deadline for Comments
Just to remind you that, if you intend to make a comment on Lutterworth East, the official deadline is close of play tomorrow, Thursday 4th April. There is a suggestion that the ability to comment may be extended, but that hasn't been confirmed, and the 21 day consultation period ends tomorrow. Instructions on how to make a comment are included in my previous post.
For info, I have commented today, and my comment is repeated below.
"With reference to Planning Application number 19/00250/OUT, I wish to state the grounds for my objections as follows:
The single element of this entire proposal that has genuine merit is the provision of additional housing at a time when housing is in such short supply. The fact that, as part of the proposal, circa 1,000 houses will fall in to the category of “affordable”, and within that there will be “social” housing is particularly welcome. While I am not convinced that enough brown field sites are developed to help cover the housing need, I am also not of the view that those on the early steps of the housing ladder should be restricted to town or city centre accommodation, and denying them the opportunity to live in a rural or semi-rural location would manifestly NOT be the right thing to do. Therefore, as far as the provision of housing is concerned, I would support the plans.
Within the housing development, the Planning Application indicates the provision of a number of facilities, and this is where I start to have reservations. The Lutterworth Community have been working on the basis that these facilities willbe provided within the new development, however, we now understand that there is an option for “some” rather than “all” of these facilities to be created. We further understand that the provision of shops, a pub, a café etc, within the development, is contingent upon a retailer or operator wishing to take up the option to provide these facilities, in other words is dependent upon market demand. If no such operator is found, then these facilities will not be provided. This is not stated in any of the promotional material relating to the new development, and as a result the public are being misled. Similarly, the provision of an additional Doctors’ Practice – this will only happen if a medical practice is prepared to set up within the new development, and incur the rental costs of a new building, and see this as a viable business opportunity. If not, then this facility will not be provided. Again, this is not referred to in any of the promotional material, again the public is being misled, and the fact that the NHS have stated that they are applying for £1.1m of Section 106 funding to extend existing facilities in Lutterworth as a result of this development suggests that the promised Doctor’s surgery in Lutterworth East will not happen. What willhappen is that the medical requirements of the new population of Lutterworth East will have to be satisfied by existing, extended facilities, on Gilmorton Road. Remember, the proposal is to close Gilmorton Road to private traffic, so this will generate additional and longer journeys.
The Local Plan states that the development “…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…” I have highlighted the key words simply because, for the residents of Lutterworth, this is an absolute requirement. An exhibition which displayed the original version of the masterplan was held in September 2018, where according to LCC around 900 people attended, and views were expressed. I am aware that a key theme amongst these views was the impact of traffic and pollution on the existing Lutterworth town as a result of the new development, and a need for the proposed development to address these issues. Subsequently, after much pressure, a second “exhibition” was held on March 22nd 2019, which displayed a further version of the masterplan and which, to the eye of the public, showed no perceptible change from the first. I therefore have to question whether full engagement has taken place, and would certainly state that at this stage the proposed development does not have the support of the local population. There are many that hold the view that there is no point in objecting because they have been told that it is a “done deal”, however this does not indicate support. As far as I am aware, LCC have done nothing to measure the level of support, and therefore at this stage public support for the proposal cannot be confirmed.
At the Inspector’s Hearing in to the Local Plan on October 10th 2018, he made very strong points regarding the need for the “old” and “new” Lutterworth both to be seen as one and work as one. He recognised the issue of the M1 motorway as causing community severance, and said that although the M1 could not be moved, the new development MUST NOT create any further cause of severance. This is essential to the creation of a single settlement, and MUST be recognised and rigidly enforced when the masterplan is being debated. However, despite this, the Planning Application includes10 hectares of B1 and B2 business use, much of which is located towards the north of the development between proposed housing and the M1 and the existing Lutterworth development. The Inspector stated that such a business area MUST NOT sit alongside the M1, yet the planning application ignores this directive. Further, the “Spine Road” (which will be dealt with at length later) acts in its current guise to form another line of severance between the two communities. A solution to the location of the B1 and B2 business use area is possible, and is well within the capabilities of LCC to do, if they were so minded. The area could be relocated south of the A4304, on the piece of land that is currently allocated for B8 warehousing – warehousing that is the last thing that this area needs more of!
Local concern exists over the late provision of Primary schooling. The simple fact is that neither of the two existing Lutterworth primary schools have room to expand further, yet the planning application allows for nearly 300 dwellings to be built before the provision of further Primary places. Based on the Education Developer Contributions ratios, this would mean that 72 primary age children would be in the area, without primary schooling, before any places were provided. This is clearly unacceptable. If the promoter is serious about providing a sustainable development then the timescale for the provision of this schooling MUST be brought forward - the suggestion would be the September prior to the completion of the 100th house.
There is also extreme concern within the locality with the lack of clarity regarding further provision of secondary education facilities. The nearest High School to the new development, Lutterworth High, is already full and can take no further intake without significant redevelopment. While there is some space at Lutterworth College, we have recently had the news that the Frank Whittle Studio school is closing, so clearly demand that this currently absorbs will have to be taken by the college. Clarity is needed in terms of where and how the additional places would be provided, and the relevant schools informed.
However, while supporting the housing element, and offering concerns around the provision of facilities, I strongly object to the consequencesof the housing and wider development which are brought about by virtue of the fact that the plans focus entirely on the new development, and ignore the impacts on the existing development. There is an opportunity for this development to have a significantly positive impact on the locality, yet this opportunity is being ignored.
This is possibly the most objectionable part of the policy. We recently had policy BE2 voted through by HDC which allowed for a further 700,000 sq m of warehousing on land at or immediately adjacent to Magna Park, the effect of which provides a distribution area that is double the size of the original Magna Park area. There was strong opposition, but it was overruled. Policy BE2 states that this figure is the limit of additional warehousing in the district, and it is already allocated to specific sites. Therefore, to allow for a further 13 hectares of B8 warehousing within policy L1 is in direct contravention of the provisions within policy BE2. The Inspector has already said that the warehousing cannot be justified, and the very fact that in the Local Plan Explanations (Extract), point 15.2.13, HDC state that HEDNA 2017 does not identify a need for this quantity of B8 use, and that this part of the development is in fact a cash cow to fund the motorway junction development is disgusting. Not only is there not a need, there is no market - on the opposite side of the junction at “M1 Access” there is a 129,000 sq ft warehouse that is nearly two years old, has never been occupied, and cannot find an occupier now. Creation of more of the same will not generate funds, it will merely cost money and provide a white elephant. If funds are needed, then offer part of the site to Aldi as a replacement for their preferred lot next to the Whittle Roundabout. It will be better located for the new housing development, still convenient for Lutterworth, and will generate less traffic impact. The remainder of the site could be used for B1 and B2 use, as suggested above, thus removing part of the severance barrier.
We now start to address the main area of concern within the planning application, and that concerns Highways. When the idea of Lutterworth East was first discussed, it was with the intention that a by-pass would be provided with the result that through traffic would diminish, noise pollution would abate, and air pollution within the Lutterworth Air Quality Management Area would reduce. Over the years the concept of the “Eastern Relief Road” has diluted to something that is now known as a “Spine Road". At the Local Plan hearings, the Inspector directed that HDC must demonstrate in its policy, and that the developer must demonstrate within its masterplan, how it would reduce or remove the flow of HGVs through Lutterworth.
We have been told at various junctures that the Spine Road will absolutely not be designed to take HGV traffic, and then that it would be designed to do so and that all road signage would indicate that it was the correct route to take. It would appear that this is the position of the current application, in that it will be the directed route from the A426 southbound to the M1, and from the M1 northbound to Leicester for non-Motorway traffic. However, we need to remember what this means. Firstly, it might directthrough traffic along the Spine Road, but there is absolutely nothing to stop traffic from ignoring the directions and carrying on along the A426 as it always has. Secondly, this is not solving a problem – all it is doing is moving the problem from one part of Lutterworth to another, in this case the new development, as the Spine Road is designed to run throughthe new housing estate, not adjacent to it or around it.
The second part of the issue is the Spine Road itself. At the exhibition in March we were told that the Spine Road wold be designed to be the attractive route for vehicles to take, rather than using the A426. Well, let’s consider this. Even a cursory glance at the masterplan demonstrates that it certainly isn’t the shortest route to the motorway from the north of Lutterworth, so that won’t be the attraction. We know that there will be at least 3 roundabouts / junctions that the traffic will need to negotiate before getting to the Motorway, rather than the single Whittle roundabout on the existing route, so it won’t be the quickest. We know that it will take drivers through a large housing estate, with numerous side road junctions, so it certainly won’t be the route with the fewest potential traffic interventions. And finally, thanks to a Consultation response entitled “Desk Based Health Impact Statement”, we know that the recommendation is that the entire development should have a 20mph speed limit! The cumulative effect of the above points is not something that will attract HGV drivers away from the existing A426, and therefore there will be little or no reduction in traffic or congestion through Lutterworth Town Centre.
Further, there are concerns within Section 10 of the Transport Assessment. Firstly, the statement that “The SDA will result in initial increases in traffic in Lutterworth town centre of 10 – 17% in the peak hours”is probably something that most people will have missed (the documents associated with the Planning Application are not necessarily the first things that people choose to read…). The qualification that by 2036 the traffic flows are forecast to reduce by between 24% and 34% south of Gilmorton Road may sound good, but requires a further look. The data in table 10.1 actually shows that even with the Spine Road open, the am peak hour vehicle flows for HGV traffic in a southerly direction increaseby 28% - was this explained to residents at the recent meeting? While the forecast for a reduction in Light Goods Vehicles and Cars suggests that they are taking the Spine Road, the obvious conclusion is that the requirement to reduce HGVs in Lutterworth town centre is not being met. As far as northerly travel is concerned, this suggests that HGV traffic reduces, yet Light Goods Vehicles increase. So the question has to be asked – what is happening at the southern end of the Spine Road to attract HGVs, that is not happening at the northern end? Also, let look at the wider picture. These forecast figures show traffic reduction despite the creation of a large warehousing area which will increase HGV, LGV and car traffic, and the creation of two B1 and B2 business parks which will generate light goods vehicle and car traffic. If this traffic isn’t in Lutterworth town centre, then it must be on the Spine Road, surrounded by the residential areas which on the developers own admission will be the highest density on the new development. How can this be described as “doing the right thing”?
The “right thing”, surely, has to be to remove this traffic from the residential areas. This can be done in one of two ways.
Lutterworth, and the new development, CANbe by-passed with a little thought, creativity and the will to do it. I have already presented my suggestion to the HDC led East of Lutterworth SDA Community Partnership Group.
Creation of M1 Junction 20a at the motorway bridge just south of Countesthorpe (this is already in the proposals for the Whetstone Pastures development)
All southbound through traffic accesses the M1 there, rather than at Junction 20, and northbound through traffic exits there for areas south of Leicester. Lutterworth is therefore by-passed for through traffic.
Access to the new development from the A426 uses the Ullesthorpe Road, and the Spine Road is extended to meet it
Build a new roundabout on the A426 at the junction of Ullesthorpe Road and Cauldwell Lane, thus slowing traffic on the A426 at a known accident black spot, and allowing safe access and egress to the new development
This can be funded by removing the need for a new motorway bridge adjacent to the Gloster Road development, removes one of the proposed junctions near Gloster Road (Consultation responses suggest that the proximity of these two junctions is an accident hazard) and prevents the need for the Spine Road to be built alongside a recently built housing estate
A weight limit is put on the existing Leicester Road between George Street and the Whittle Roundabout. This prevents HGV’s ignoring the revised layout, while still allowing access to the industrial areas along the northern part of the A426
As a result, Lutterworth loses all Heavy Goods through traffic, and it is not diverted on to the Spine Road. Other through traffic reduces significantly due to the earlier availability of the M1. Air Quality improves substantially in existing Lutterworth, is not detrimentally affected in the new development, and the area becomes a desirable place to live. Through traffic has a quicker, more direct route, which in turn will reduce pollution generated per mile.
The Spine Road COULD be re-routed. Currently, it winds through the residential areas, but many may not be aware that there were 4 options available for routing, one of which took it along the side of the M1. This was rejected, not because of consideration for residents, but because to use this option would have meant sacrificing the business park to the south of the development, and north of the A4304 (Environmental Statement, Volume 1, Chapter 4 – “Reasonable Alternatives”). However, if the decision were changed, all traffic (motorway and Spine Road) would have been in the same immediate vicinity. Measures could be put in place to protect the new residential development from the area of traffic, severance would not increase as the M1 and Spine Road would be adjacent to each other, and the Spine Road could then be considered to be the “by-pass”, with re-designation as the A426. (see later point on Air Quality).
There is a fantastic opportunity here for the new development to provide a great place to live for new residents, and also to improve the conditions for existing residents, however with these plans the opportunity is being missed. It is difficult to believe that, with circa 4,000 additional cars associated with the new residential development, and additional cars, light goods and heavy goods vehicles associated with the proposed employment areas, that the Air Quality studies within the supporting documents for this application suggest that there would be no significant reduction in air quality, and indeed suggest that there may be an improvement! Of course, this completely flies in the face of the Consultation Response from Harborough District Council’s Contaminated Land and Air Quality Officer, who states as follows:
“In order to provide an air quality benefit to Lutterworth the A426 should be de-classified between the junction with the A4303 (Whittle Roundabout) and the point where the Spine Road joins the A426. The Spine Road should then be classified as the A426. A weight restriction should then be placed on a portion of the current A426 (Rugby Road, High Street and Market Street) between the junction with the A4303 (Whittle Roundabout) and the junction with George Street.”
This proposal from a department within Harborough District Council, combined with the re-routing of the Spine Road as suggested earlier, could offer a solution that may be acceptable to a large number of people, in the absence of a full by-pass. However, the preference should be for the suggested method of by-passing Lutterworth which will solve the issues in one go, albeit that this is a more difficult decision to make.
Be bold, take a risk. Take the through traffic out of Lutterworth, publicise what you are doing, be seen as a forward-thinking, leading District Council that takes action to make things better.
While this is not part of the Planning Application, comment has to be made as the application will potentially have a serious impact on the locality, especially in terms of Law and Order. Lutterworth has an increasing incidence of crime, and it is a well repeated suggestion that it is the proximity to the M1, affording an easy escape route, that attracts criminals from outside the area. Further development will not reduce this, it can only attract an increase. I have not seen any form of response from the Police in terms of potential S106 monies to address crime, other than their advice on development design, door and window locks etc. The proposals are for a number of facilities, community hub, Doctor’s surgery etc that have been dealt with above – how much more would it cost to provide facilities for permanent Policing, and given that LCC are forecasting annual revenues from the development to be in the multi millions of pounds, where is the commitment to redirect a small amount of that each year to provide for a permanent police presence in the wider Lutterworth? A figure of £500,000 per year (compared to the significant expected earnings from the development) would provide for a permanent, fully resourced, Police presence in the area. Lutterworth residents may then think that they are getting something back for what many believe they are losing."