Item 4 Appendix 2

North Joint Core Strategy 2011-2031

Emerging Draft for Consultation

JPU response to representations regarding Policy 14: Airfield Area of Opportunity

January 2013

North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

1.0 Introduction

1.1 Policy 14 of the Emerging Draft Joint Core Strategy (JCS) provides scope to consider, as an exception to the overall strategy of urban-focussed growth, the opportunity to deliver an exemplar new village at Deenethorpe Airfield, to the north of the A427 between Upper and Weldon. The policy approach was a response to strong support from Council (ENC) for the principal of creating a sustainable new village, following dialogue and presentations with the site promoter, which emphasised the unique opportunity that this site provides.

1.2 Draft Policy 14 is an enabling approach and does not represent the site being allocated in the JCS. The potential housing had not been included in ENC’s housing requirements in Policy 28. The proposal will be considered as an opportunity to deliver sustainable development in addition to the strategy (which remains one of urban concentration) and housing requirements set out elsewhere in the JCS. Any development will therefore be in addition to continued organic growth in the villages (where supported locally) and the development strategies for Oundle and Thrapston set out in the adopted Rural North, Oundle and Thrapston Plan. Policy 14 will set out specific principles to ensure that if the scheme is brought forward it will deliver a range of benefits and achieve exceptional sustainability standards.

1.3 A number of representations were received regarding the emerging JCS proposals for Deenethorpe Airfield. These cover three broad themes:

• The relationship of Policy 14 to the overall Vision/ Outcomes/ spatial strategy within the JCS Review; • Wider impacts of the new village proposals; • Robustness/ soundness of Policy 14.

1.4 The initial responses of the Joint Planning Unit (JPU) are set out below.

2.0 The relationship of Policy 14 to the overall Vision/ Outcomes/ spatial strategy

2.1 The following concerns have been raised:

• There is no clear explanation/ rationale as to how Policy 14 relates to the overall (urban focused) spatial strategy; • There are no unique criteria within Policy 14 – this could relate to any development; • Additional development would be better directed to established urban areas (e.g. / Oundle) or Principal Villages with an existing range of services and facilities;

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North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

• Whether Deenethorpe Airfield could, justifiably, be described as a “sustainable” location; • A need for clarity as to whether Deenethorpe Airfield will contribute to the strategic opportunity/ delivery targets (policies 28/ 29), or whether the proposal is in addition to these targets; • Focusing of further growth upon extensions to existing urban areas represents a more sustainable option; • Strong objections from & Deenethorpe and Weldon Parish Councils; • Concern from infrastructure providers (set out in more detail in Section 3).

2.2 Deene Estates, the site promoter, has made representations in support of Policy 14, including its relationship to the overall Vision and Outcomes of the emerging JCS review. Deene Estates argues that:

• Policy 14 would act as an “enabling” policy, in accordance with NPPF; • Deenethorpe Airfield provides an opportunity to deliver homes jobs and services in the rural area; • Deenethorpe Airfield provides an opportunity to deliver new strategic green infrastructure, through working closely with key stakeholders, e.g. Environment Agency, Forestry Commission, Rockingham Forest for Life; • Substantial progress has been made regarding masterplanning, delivery strategy, funding and developing exemplar standards, e.g. through setting up “Area of Opportunity Steering Committee” (AOSC).

2.3 JPU analysis and response – Policy 14 (including its specific reference to Deenethorpe Airfield) must be considered in relation to the overall vision for North Northamptonshire and there are a number of elements of that do not support the proposal. Equally, however, it may certainly be argued that the development of an exemplar new village at Deenethorpe Airfield would, in principle, accord with many aspects of the Draft Vision and Outcomes; in particular:

• “…showpiece for modern living and well managed sustainable development…” • “…exemplar for construction based innovation and the delivery of low carbon growth. Its high quality environment and prosperous economy will ensure it has a stronger profile…” • “…Rockingham Forest will be re-invigorated through major new tree planting, providing carbon storage and a focus for tourism, recreation and sustainable wood fuel production…” • “…network of accessible natural green spaces forming the urban gateway [from Corby] to the wider Rockingham Forest”

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North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

2.4 Through the emerging draft consultation, the promoters of the site have presented the case for Deenethorpe Airfield 1 as:

• “…part of a balanced portfolio of sites the Airfield proposition is prospectively able to provide homes, jobs and services in an important rural area, help to support transport choice and higher order services in nearby towns and to relieve pressure on existing settlements where appropriate ” • “…an excellent opportunity, for example, to introduce strategic green infrastructure as the framework for a new village – as well as the single, historic land ownership of the Deene Estate to safeguard highest standards, exercise longer term control and facilitate delivery ”

2.5 It is considered that this latest material does not go far enough in identifying how the proposal would be an exemplar of sustainable rural development, with the exceptional standards of design, sustainability and management referred to in previous material. The site promoters are seeking to address these issues and the Joint Committee will be updated on any further material that is received.

2.6 A key issue is how the proposal will relate to the spatial strategy of the JCS and the respective visions for Corby Borough and East Northamptonshire Councils. These focus upon growth in and around the existing urban areas, rather than the creation of an entirely new village in the rural area, albeit within 5-10km of Corby. The respective visions for both Councils set a priority for regenerating the existing urban areas. Many objectors have raised similar concerns; i.e. that the concentration of new development in and around the established urban areas represents a more sustainable approach and that Policy 14 (as currently drafted) is at odds with these visions.

2.7 If the development of Deenethorpe Airfield was intended to form an intrinsic part of the spatial strategy and targets for job creation and/ or housing delivery (policies 23 and 28 respectively), these concerns may raise significant issues. However, as set out above, the supporting text (yet to be finalised) will emphasise that Deenethorpe Airfield is not intended to form part of the strategic opportunities (policies 23 and 28) and if proposals come forward which meet unique and exacting requirements, the development will, instead, deliver over and above these targets. If Policy 14 is retained within the JCS, greater clarity will be required in the supporting text to explain the background to Policy 14.

2.8 It is accepted that the development of a new exemplar village at Deenethorpe Airfield could provide a significant contribution to delivering many of the key aspects of the overall vision for North Northamptonshire. These include the provision of new strategic green infrastructure, significant new tree planting and zero carbon development. It may be argued that the National Planning Policy Framework (NPPF) enhances the case for the proposal, in that: “ The supply of

1 http://www.nnjpu.org.uk/docs/101-110.pdf 4

North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities ” (paragraph 52). The NPPF itself could, therefore, be seen to provide a policy “hook” for Policy 14 and the development of a new village.

2.9 The Government has recently expressed renewed support for the concept of garden cities and suburbs. The Town and Country Planning Association (TCPA), has identified a number of key principles for the development of Garden Cities 2, many of which would be relevant to smaller scale developments. These include:

• Community ownership of land and long term stewardship of assets • High quality imaginative design including homes with gardens • Mixed tenure homes which are affordable for ordinary people • A strong local jobs offer with a variety of employment opportunities within the garden city and easy commuting distance of homes • Generous green space linked to the wider countryside • Access to strong local cultural, recreational and shopping facilities • Integrated and accessible transport systems • Local food sourcing, including allotments.

2.10 The TCPA also argues that new settlements provide the opportunity and the economies of scale to truly fulfill the ambitions of sustainable development by delivering multiple benefits including social housing, zero carbon design, sustainable transport and local food sourcing. New communities also offer a powerful prospect to put in place new governance structures that put people at the heart of developing new communities and owning community assets.

2.11 It is considered that, if Policy 14 is retained, it (and/ or its supporting text) should embrace all of the TCPA’s principles for Garden Cities, in order to ensure that it would enable the delivery of a genuinely sustainable exemplar new settlement that will contribute positively to delivering the vision for North Northamptonshire. There is clearly an issue of scale in translating these principals to a village scale development (see section 3 below). Further information on deliverability of the proposals is required to demonstrate how the development concept including the proposed infrastructure and quality standards can be achieved.

3.0 Wider impacts of the new village proposals

3.1 A number of representations have identified the possible negative impacts of the development of a new village at Deenethorpe Airfield. These raise the following issues:

2 http://www.tcpa.org.uk/pages/garden-cities.html 5

North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

• Proximity to Corby – impact upon existing services and facilities (Corby Borough Council) • Reliance upon travelling by private car to Corby, Oundle or Stamford (the nearest established service centres) for main services and facilities • To function effectively the new village would require a high level of new infrastructure, including access to surrounding urban centres • Impact upon A43/ A427 – unsuited as major access roads to an additional development of this size • Cumulative impacts of Deenethorpe Airfield village proposal and other developments north east of Corby (Priors Hall/ Weldon Park) upon surrounding road network • Traffic impacts of new development on nearby villages, e.g. Benefield, Deenethorpe and Weldon • Development would entail significant new infrastructure, including new access/ links to surrounding urban centres • The need to support transport choice re providing access to higher order services in nearby towns (i.e. Corby)

3.2 JPU analysis and response – Concerns about the wider impact of the Deenethorpe Airfield proposal are directly linked to the issue as to whether such a proposal (1,000-1,250 dwellings, associated rural businesses and green infrastructure) represents a truly “sustainable” development. These matters relate to the scale of development proposed and the probable reliance upon car transport to access “higher level” services in the nearby urban centres.

3.3 National planning policy reflects these concerns. The Eco-towns supplement to Planning Policy Statement 1 (July 2009) 3 remains in force. Eco-towns policy EN2.2(a) proposes a minimum threshold for 5000 homes. Policy ET2.2(a) states that: “ Planning on this scale allows the development to exploit a number of opportunities and benefits as set out in the Government’s objectives for eco- towns ”. The Eco-towns supplement therefore recognises that economies of scale are likely to be necessary in order to deliver a genuinely “sustainable” development.

3.4 The Eco-towns supplement may be regarded as providing further detailed guidance in support of the NPPF (paragraph 52) reference to Garden Cities. Given the concerns expressed in a number of representations regarding the wider traffic impact, it is considered that Eco-towns supplement Policy ET11 provides an appropriate set of standards on which locally distinctive standards for Deenethorpe Airfield could be based. Policy ET11 defines a wide range of transport standards, notably:

• “…homes should be within 10 minutes’ walk of (a) frequent public transport and (b) neighbourhood services ” (Policy ET11.1)

3 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7773/pps-ecotowns.pdf 6

North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

• “…design will enable at least 50 per cent of trips originating in eco-towns to be made by non-car means, with the potential for this to increase over time to at least 60 per cent ” (Policy ET11.2(a)) • “good design principles, drawing from Manual for Streets, Building for Life and community travel planning principles ” (Policy ET11.2(b)) • Travel plans to demonstrate “how transport choice messages, infrastructure and services will be provided from ‘day one’ of residential occupation ” (Policy ET11.2(c)) and “how the carbon impact of transport in the eco-town will be monitored…” (Policy ET11.2(d)) • For eco-towns close to higher order settlements: “…ensuring that key connections around the eco-town do not become congested as a result of the development, for example by extending some aspects of the travel plan beyond the immediate boundaries of the town…” and “ significantly more ambitious targets for modal share than…50 per cent (increasing to 60 per cent over time) ” (Policy ET11.3) • “…designed in a way that supports children walking or cycling to school safely and easily. There should be a maximum walking distance of 800m from homes to the nearest school for children aged under 11…” (Policy ET11.5)

3.5 Policy 14 should ensure that any development satisfies the highest possible standards of design and sustainability and that the site promoters must demonstrate that the proposal is viable and can deliver the promised infrastructure. In this respect, it is accepted the criteria in draft Policy 14 are too generic and could be applicable to many other large scale developments such as SUEs. To emphasise that Deenethorpe is a unique opportunity, Policy 14 should be made more exacting and locally distinctive. This could be achieved by reflecting the principles and standards set out in the eco-towns supplement, recognising that targets need to be locally appropriate and realistic about travel choices based on discussions with the Highway Authority. The site promoters have specifically suggested that criterion a) of Policy 14 should make more direct reference the key issue of energy efficiency and potential for renewable energy. This is supported.

4.0 Robustness/ soundness of Policy 14

4.1 A number of representations have raised concerns regarding the overall soundness of Policy 14, particularly whether it is justified (i.e. is the most appropriate strategy, when considered against the reasonable alternatives) and whether it is consistent with national policy (NPPF). Specific comments regarding the broader robustness of Policy 14 and its general approach (e.g. specific reference to Deenethorpe Airfield) are as follows:

• Other alternative “areas of opportunity”/ options ought to be identified • Deenethorpe Airfield is not a “unique” site/ location • Appropriate evidence is necessary to substantiate the proposal

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North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

• The Policy needs to comprehensively consider the range of previously developed sites across North Northamptonshire

4.2 JPU analysis and response – All comments regarding the overall robustness and soundness can be linked to the Sustainability Appraisal; i.e. whether Policy 14, as set out in the emerging draft JCS, could be justified as being the most sustainable option.

4.3 The matter of whether Policy 14 represents the most sustainable approach has been systematically assessed through the Interim Sustainability Appraisal/ Strategic Environmental Assessment (August 2012) 4. Four options were considered through the Sustainability Appraisal (SA). This concluded that: “ Any new village is likely to have adverse effects in relation to the sustainability objectives, due to their very nature. Sticking with the proposed strategy is considered to be the most favourable option in sustainability terms. However if a new village is required and appropriate then further works should be done on assessing alternatives and its justification ” (paragraph 5.5.38).

4.4 Significantly, therefore, the SA raises questions regarding Policy 14 in its current form. In order to address these concerns, it is essential that sufficient evidence and justification is made public in order to present the case for Policy 14 and/ or Deenethorpe Airfield and which clearly sets out the sustainability benefits of the proposal.

4.5 As previously discussed, it is considered essential that should Policy 14 be retained within the JCS, it is clear in the supporting text that the proposal is a unique opportunity rather than new villages being part of the spatial strategy, in which case the JPU would need to have assessed all alternative locations.

5.0 Ways forward in respect of Policy 14 and/ or Deenethorpe Airfield

5.1 The representations regarding Policy 14 and the conclusions of the Interim SA report both raise questions about whether Policy 14 is “sound” and should be included within the submission JCS review. Having considered these responses, and based on the analysis within this report it is considered that there are Three possible ways forward:

1. Continue with Policy 14 albeit supported by additional evidence base and justification to make the policy more locally distinctive. 2. Remove Policy 14 from the JCS review; 3. Introduction of an alternative Policy 14, which makes provision for the development of an exemplar new village to be brought forward at

4 http://www.nnjpu.org.uk/docs/Interim%20Sustainability%20Appraisal%20Report%20August%202012.p df 8

North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

Deenethorpe airfield through a Neighbourhood Plan, working closely with Deene and Deenethorpe Parish Council. 4. A more general policy that makes provision for the development of new settlements.

5.2 It should be understood that in none of these scenarios is Deenethorpe Airfield relied upon as delivering the targets within the JCS. As set out in this paper, and in the previous consideration of how to take forward this issue, such an approach would, effectively, require the allocation of land at Deenethorpe Airfield. This approach would be extremely difficult to justify, especially given the Interim SA, which has already indicated that the development of a new village would not be the most favourable option in sustainability terms. Each of the alternative options is considered below.

Option 1: Continue with Policy 14 :

5.3 The JPU view is that the enabling approach proposed by Policy 14 does not pose potential problems with the soundness of the JCS because:

a) It does not seek to allocate Deenethorpe for development but indicates that it is an opportunity to be explored, subject to criteria to be met. This approach is considered to be in line with the positive approach to opportunities for growth identified in the NPPF; and

b) The potential housing and employment provision arising from this proposal are not included in the JCS minimum requirements. If a proposal satisfied Policy 14, it could come forward in addition to the sites developed in line with the urban-focused spatial strategy. In this way, Policy 14 is ‘insulated’ from the rest of the plan, ensuring that any soundness issue with the approach to Deenethorpe it does not impact on the whole plan.

5.4 It will be important that the criteria within Policy 14 are made more exacting and locally distinctive, based on the unique elements of the Deenethorpe proposal. It is considered that this would alleviate concerns that have been raised that the policy was generic and could be applicable to other locations within North Northamptonshire. From initial discussions with the site promoter this would be their preferred option.

Option 2: Remove Policy 14 from the JCS review:

5.5 This would remove a contentious issue from the JCS, potentially smoothing the progress of the plan. However, it would not provide the policy ‘hook’ that ENC wishes to see in the plan and would remove the opportunity to set out clear and exacting standards for any development.

5.6 From the point of view of Deene Estates, the removal of Policy 14 from the JCS review would represent a setback in respect of bringing the Deenethorpe Airfield scheme forward. They could pursue a planning application, which would

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North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

need to be considered as a departure from the development plan (CSS and RNOT plan) without any recognition/ support from the emerging JCS.

Option 3: Introduction of an alternative Policy 14, which makes provision for the development of an exemplar new village to be brought forward through a Neighbourhood Plan:

5.7 The introduction of Neighbourhood Planning through the 2011 Localism Act represents a potential opportunity for the promotion of a new exemplar village, which sits outside the overall emerging spatial development strategy for the JCS Review. The NPPF (paragraphs 183-185) sets out the function and role of Neighbourhood planning:

• Direct power for communities to develop a shared vision for their neighbourhood and deliver the sustainable development they need • Ambition of the neighbourhood should be aligned with the strategic needs and priorities of the wider local area • Neighbourhood plans must be in general conformity with the strategic policies of the Local Plan • Outside strategic elements, Neighbourhood plans will be able to shape and direct sustainable development in their area

5.8 There may be some challenges in presenting an argument that, in pursuing the Deenethorpe Airfield proposal through a Neighbourhood plan, that this is in conformity with the strategic policies of the Local Plan, as there would be no policy hook on which the Neighbourhood Plan could based, and subsequently the proposal would be contrary to the urban focused spatial strategy. Furthermore, given objections that have been raised it is unlikely that the proposal would be supported through this process.

Option 4: A general policy making provision for the development of new settlements:

5.9 This option was previously considered by the Joint Planning Committee during the development of the Emerging Plan. It is considered that a more general policy that could be applicable to the whole of North Northamptonshire would be extremely difficult to justify, and raise the soundness issues that have been discussed in section 4 of this paper. Extensive further work would be required to justify why new settlements were a reasonable option within the context of an urban focussed spatial strategy. Furthermore, a more general policy could increase development pressure for such proposals, a concern that Kettering Borough Council has raised in relation to Policy 14.

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North Northamptonshire Joint Core Strategy 2011-2031 January 2013 JPU response to representations regarding Policy 14: Deenethorpe Airfield Area of Opportunity

6. Conclusions

6.1 This paper has considered the range of issues identified through the representations received during the consultation upon the emerging draft JCS. The representations reveal a range of views and opinion and, in themselves, provide a valuable evidence base for progressing the JCS review to submission.

6.2 Four possible approaches have been considered. Option 1 (progressing with Policy 14) would require significant supporting evidence and further criteria (similar to the current national PPS1 supplement Eco-towns standards) in order to support such a scheme and emphasise that is unique within a North Northamptonshire context. Option 2 would significantly reduce the prospect of such a scheme being brought forward, while Option 3 would require the promoters to work closely with Deene and Deenethorpe Parish Council (the statutory body) in order to bring the scheme forward but would face significant challenges, notably conformity with the spatial strategy in the absence of a policy hook, and it is considered that Option 4 would not address the concerns raised in representations in relation to soundness/ wider impact.

6.3 The approach to Deenethorpe has been extensively considered by the Joint Planning Committee and through this report. It is considered that Option 1 retaining Deenethorpe within the Plan is the preferable option. However, it will be important that Policy 14 is made more exacting and locally distinctive and that it is clear that the any development at Deenethorpe is in addition to the spatial strategy and targets within the JCS.

6.4 The retention of the Policy is reliant on the site promoter providing further information to illustrate why the proposal remains a unique long term opportunity and to clearly demonstrate the viability of the scheme at its proposed scale with the required standards and infrastructure. Further work should also be undertaken to address the concerns raised by infrastructure providers, local parish councils and Corby Borough Council. Given current local opposition to the proposal expressed through consultation responses, it will be important for the promoters to demonstrate effective community engagement in developing the proposals further.

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