Planning Application Reference No: DA/2015/1140

10th March 2016

After debating the above application, its supportive documentation, and considering the subsequent amendments following the project presentation to DTC by a DRA representative on 18th February, we, the Committee of the Drayton Residents Association, wish to formally register our continued objection to the establishment of the proposed industrial development associated with the above Planning application in respect of the land stretching between the roundabouts located at Browns Rd and Royal Oak Way South adjacent to A45 Leamington Way, Daventry.

Our opposition to the Planning Application is based on the following factors;

1) Locating industrial operations closer to dense, established residential developments and a local school.

2) The potential for increased levels of noise, light and air pollution associated with industrial and warehousing operations.

3) The application is speculative, without a declared end user, the nature of industrialisation is unspecific and the hours of operation are unknown. Consequently the impact on the local community cannot be properly assessed.

4) The loss of a pleasant green rural corridor along Daventry’s principal western approach and the timescale involved in the creation of an effective green screen following the removal of established trees and bushes.

5) Disruption of A45 traffic flows by the establishment of a vehicle access route into and out of the development.

6) The impact on the local community relating to noise, air pollution and traffic impedance associated with the initial installation of the site; demolition and clearance operations, the laying of foundations, continuous deliveries of building materials and the construction of the buildings and yards.

7) The destruction of the established path from Drayton which provides access to Kentle Wood, Staverton, Braunston and beyond.

8) Possible disruption to established natural habitat of indigenous wildlife.

In terms of footprint, the project will be the most extensive industrialisation adjacent to dense housing in Daventry over the last 50 years. It is contrary to the established ethos that industry should be unobtrusive, set back and that there should be a pleasantly landscaped, natural ‘green barrier’ of land between industrial operations and communities in the locality. Currently, noise levels are relatively low and not intrusive, light pollution is not an issue and there are some pleasant and unobstructed rural views. The whole ambience, though, will be adversely and permanently impacted by the establishment of elevated visible warehousing and the introduction of industrial operations along the length and width of a pleasant and well maintained green corridor.

1 A consequence of siting industrial operations closer to established residential housing is the adverse effect on the community that the potential increases in the levels of noise, air and light pollution will bring. The prevailing winds over the vicinity are westerly (WSW to be exact) and the incidence of gales is becoming more frequent. On such occasions, events on the sports field in Browns Rd are audible and the unpleasant emission of odours by the Earthworms IVC facility off Browns Rd has been a constant source of annoyance amongst residents of the Grange Estate and Drayton. The DRA acknowledges and respects the highly professional approach that the developers and architects have demonstrated in their attempts to contain noise and light spill in terms of building layout, design and selection of construction materials but, following unit handover to clients, the potential for noise associated with the industrial and particularly outside yard operations risks being a real issue unless best practice conditions are built into leasing agreements and duly enforced.

Other than the installation and development of 3 industrial/warehouse units, it appears that the uses of the proposed site, hours of opening, its proposed resident machinery, the very nature of the industrial operations to be carried out and the employer have yet to be determined. One or all of the units could remain empty until the leases are taken up. There is even the possibility that the units could be leased by 3 different employers each with their own specific working practices and different hours of business. The noise assessment for the site conducted by Resound Activities recommended the installation of very tall acoustic fencing and, additionally, noise barriers around the on-site car parks to assist sound proofing – these measures have been sensibly integrated into the project by the developers. However the study expressed that reliance must be placed on the employers to adopt and enforce specific codes of practice within their operations to comply with an acceptable level of noise emissions. The recommendations contained in the document RA00372 (Noise Assessment) sections 5.10 and 5.11 are particularly relevant. If DDC approve the Application, DRA request that, given the current unknowns and noise risks, a 24/7 carte blanche operation is not granted and that the workday is restricted to 12 continuous hours during weekdays (06.00 – 18.00) with further restrictions at weekends.

The rural impact of driving or walking the principal route from the west (which is one of the few remaining pleasant approaches into our market town) will be lost forever. The grassy, landscaped, well maintained extensive rolling green verges will be stripped of many of their mature trees and bushes and instead the access will initially be punctuated by elevated, intrusive and extensive industrial buildings fronted by a sections of 6m high (20ft) and 2.5m high (8ft) acoustic sound barriers. Although extensive planting and landscaping is proposed in the application, it could be many years before their screening benefits are realised. The developers have addressed our concerns in their amended project submission by selectively replacing exterior building cladding with glass and by the introduction of larger and more mature trees. Perhaps additional trees could be planted in the gaps on the Thames Rd side of the carriageway as the new buildings will be visible from adjacent and elevated Grange properties facing north. If DDC approve the Application, DRA request that a long term view is applied to the choice of trees and bushes to be planted. Their placement and density of planting should be planned sympathetically and scientifically wherever possible in order to provide a dense canopy throughout all of the seasons, to quickly restore screening and to re-establish the pleasant approach from the west. It is further requested that assigning the responsibility for the ongoing development and maintenance of the landscaping is seriously considered.

Within the Proposal is a planned access road off Leamington Way into the industrial development. This tangent could have an adverse impact on the traffic flows along the route. The carriageway is 2 only single but busy at all times as it serves the eastern exit of the town bypass and is the main approach from the west for traffic heading towards DIRFT, the M1, M6 and A14. Although a ‘left turn only’ has been authorised, the natural traffic flow could be disrupted as it bunches up behind HGV’s (in particular) and lighter vehicles as they slow down and brake to enter the proposed development. Exiting vehicles will similarly have an impact as they slowly merge into the traffic stream. Traffic levels at the roundabouts at both ends of the development may increase as vehicles perform u turns to compensate for the left turn only access to and from the plant. The incidence of vehicle collision along the stretch has been low, possibly because traffic is free flowing and unrestricted. A Toucan crossing has now been integrated into the project. Although this will facilitate access to the plant for pedestrians and cyclists needing to cross Leamington Way from the Grange side of the road, it may also further impact traffic flows. The baseline used to project vehicle flows along Leamington Way, however, has not accounted for the recent developments in the vicinity notably (a) reduced hours of opening and restricted days of operation of the Browns Rd recycling facility which is already causing pinch points in the area and (b) NCC approval to establish a bio mass renewable energy generation plant and waste water treatment works on the Earthworms site also in Browns Rd. The latter development will involve 30 additional daily deliveries to the site via HGV and tankers. Additionally, the possible introduction in 2018 of 3-weekly black bin collections across Daventry district could increase the frequency of householders’ journeys to the recycling centre to use landfill skips.

If the Application is approved the residents of Drayton and the Grange will have to endure noise and dust emissions throughout the day associated with the demolition, clearance and construction phases of the project. The timescale from start to completion of the works is unclear but what we are sure of is that there will be dust when the weather is dry, mud when it’s wet and there will be continuous audible noise from JCB’s, earth moving equipment and HGV’s delivering to the site. There are many retired residents living in Drayton who enjoy the peace and tranquillity of sitting in their garden, relaxing and enjoying the sounds associated with rural life – noise and dust emissions associated with the proximity of the building site will be intrusive. We expect that the controls expressed in the Kairus Air Quality Assessment (document AQ051353 section 7 Mitigation) to be engaged and enforced in order to limit the unavoidable disruptive impact on local households.

The proposed siting of the development will obstruct the route which provides resident’s access to paths to Kentle Wood, Staverton, Braunston and beyond. This route is popular and well used by dog walkers and country walking enthusiasts. It’s not clear whether it is an official right of way but it has provided a custom and practice route over the last 50 years with perhaps, some tacit agreement from Fords, and it has been documented on pre 1960 O.S. maps of the local area (Ref appendix 1). The project introduces the provision for a 2m wide footpath (now amended to 3m to include a cycle way) along the verge of Leamington Way extending between Royal Oak Way South and Browns Rd. This will allow the Kentle Wood approach to be re-joined but users, however, will find the route an unpleasant 600m of walking against the sustained flows of oncoming traffic. Would it be feasible to consider an access path to Kentle Wood along the north facing boundary of the proposed site behind the units?

On the 30736 Design and Access statement, page 22 subsection 8.0 refers to an existing badger sett located in the SW corner of the site which may be retained and protected or closed depending upon its proximity to the proposed development. In the Ecology Report (AEL1074) sections 2.21, 3.3 and 3.8 contain redactions of text and photographs relating to badgers. It is unclear therefore what effect the proposed development will have on local badger habitat.

3 Finally, Way if the Application is approved, could DDC through a Section 106 agreement achieve a lighting and refurbishment upgrade to the 3 established subways which provide access under Leamington to Drayton, Thames Rd and Royal Oak Way South? After all, these will be the principle routes avoiding the road crossing for local cyclists and pedestrians employed at the development.

We trust that the DRA objection to the above Planning Proposal is considered and treated with respect and understanding. It will be appreciated if you would please acknowledge receipt of our objection by return.

Dr Virginia Hayden

Chair, Drayton Residents Association Drayton Manor Cottage Orchard Street Daventry NN11 9EU .