Statement of Consultation Addendum July 2015 2. Focused Changes
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Statement of Consultation Addendum July 2015 1.1 The North Northamptonshire Joint Core Strategy (JCS) review has incorporated a number stages of consultation. The Town and County Planning (Local Planning) (England) Regulations 2012 (“the Local Plan Regulations”) require at Regulation 22 (c) the Local Planning Authority to include amongst the documents it submits a statement setting out: i. which bodies and persons were invited to make representations under Regulation 18; ii. how those bodies and persons were invited to make such representations; iii. a summary of the main issues raised by those representations; and iv. how those main issues have been addressed in the Development Plan Document (DPD) (the JCS). v. if representations were made pursuant to regulation 20, the number of representations made and a summary of the main issues raised in those representations, and vi. if no representations were made in regulation 20, that no such representations were made. 1.2 This addendum has been produced following the consultation on Focused Changes to the Pre-Submission Plan. It should be read alongside the January 2015 Statement of Consultation1 (which accompanied the Pre-Submission (Publication JCS) and set out in detail the consultation that had been undertaken in the development of the JCS, and how the issues identified informed the development of the Pre-Submission JCS), and June 2015 Update2, (which provided an overview of representations made to the Pre- Submission JCS (at Regulation 20)). 1.3 This document provides an update on the main issues arising from the Focused Changes consultation. It only provides an overview of main issues and consequently does not refer to all of the representations made to the Focused Changes. These can be viewed on the JPU web site. It also corrects an error to Appendix 1 (list of respondents to the Pre-Submission JCS) of the June 2015 Update, which omitted respondents 104-106. 2. Focused Changes 2.1 The Focused Changes were consulted on for six weeks between Monday 15th June and Monday 27th July 2015. Consultation was undertaken consistent with consultation on the Pre-Submission JCS and in accordance with the adopted Statement of Community Involvement. All documents were available on the JPU website and for inspection at libraries and main council offices. Statutory consultees and other consultees, on the JPU database were notified by email and all respondents to the 1 http://www.nnjpu.org.uk/docs/Final%20Statement%20of%20Consultation.pdf 2 http://www.nnjpu.org.uk/docs/Statement%20of%20Consultation%20Update%20June%202015.pdf Pre-Submission consultation were notified. The JPU also issued a press release on the consultation. 2.2 In relation to the inclusion of a new Policy 38 and supporting text relating to Rothwell North (FC 161), consultation was undertaken consistent with that previously undertaken in relation to other strategic sites. This included placing site notices in prominent locations close to the site, and notifying immediately adjacent properties. The JPU also notified Rothwell Town Council and provided them with 12 hard copies of the relevant extract of the JCS. 2.3 Responses were received from 39 organisations and individuals to the Focused Changes. All representations can be viewed on the JPU web site and a list of respondents is set out at Appendix 2. 3. Main Issues raised in representations to the Focused Changes 3.1 A number of respondents have supported the Focused Changes including NCC Highways, Highways England, the Environment Agency and Anglian Water. The main issues previously raised in the Pre-Submission consultation (set out in Section 4 of the June 2015 Statement of Consultation update and reported to the 4th June Joint Committee)3 remain the main concerns in representations. Where no Focused Changes were proposed in relation to previous representations, a number of respondents have re-stated previous objections, particularly in relation to Objectively Assessed Need and the distribution of development. However, a number of issues have been progressed and, in the opinion of the JPU, largely resolved through the Focused Changes consultation. These are set out below, alongside a summary of other main issues. For ease of reference, this summary is structured using the main issues previously identified. ISSUES RELATING TO DUTY TO COOPERATE i. Does the JCS satisfy the duty to cooperate in relation to planning for the longer term growth of Northampton? 3.2 In its consultation response to the Focused Changes, Northampton Borough Council (respondent No 028) advised that FC 4 would resolve their previous representation and has withdrawn it. Miller Homes (076) also support FC 4 as this will ensure that the JPU and adjoining authorities will work together collaboratively with West Northants, in order to consider needs and reasonable alternatives as any part of any future review of local plans. 3.3 The Home Builders Federation (056) considers that if Northampton is unable to meet its OAHN post 2029, and this unmet need may be required to be met in North Northants, it is necessary that any such arrangements arising under the Duty to Co- operate are addressed in formal agreements such as Memorandums of understanding and in local plan policies. The proposed text in FC 4 should be set out as a policy in the JCS. ii. Does the JCS satisfy the duty to cooperate in relation to the balance between jobs and labour force within the plan area and the implications of this for adjoining areas including Northampton and Bedford? 3http://cmis.northamptonshire.gov.uk/cmis5live/MeetingsCalendar/tabid/73/ctl/ViewMeetingPublic/mid/ 410/Meeting/2505/Committee/414/Default.aspx (Item 6) 3.4 In its consultation response to the Focused Changes, Bedford Borough Council (111) confirmed that Focused Changes 63 & 64 satisfy the Councils previous objection and the Council withdraws its previous objection. OTHER ISSUES RELATING TO LEGAL COMPLIANCE iii. Does the Sustainability Appraisal (SA) adequately consider reasonable alternatives? iv. Does the JCS adequately reflect the findings of the Habitat Regulations Assessment in relation to potential impacts on the Upper Nene Valley Gravel Pits Special Protection Area? 3.5 In its response to the Focused Changes consultation Natural England (NE) (045) is supportive of the Focused Changes and, subject to the inclusion of their changes recommended (refinements to FC 20, FC 21 and FC 26), consider the plan to be sound and legally compliant. NE set out that it is satisfied that the Addendum to the Habitats Regulations Assessment has responded to its previous feedback and that the HRA recommendations have been adequately addressed by the focused changes. It notes that several changes have been made to the HRA since the pre-submission version including aligning advice on issues such as construction noise and lighting with the content of the draft Upper Nene Valley Gravel Pits SPA Supplementary Planning Document. NE considers that all of the recommendations from the HRA have now been responded to by the Joint Core Strategy including the need for project level HRA to be specified within polices 19, 33 and 35. MAIN ISSUES RELATING TO SOUNDNESS v. Does the JCS meet the full objectively assessed need for housing in the Housing Market Area? 3.6 A number of developers and the HBF have re-stated their previous objections to the JCS that Policies 28 and 29 do not meet the full objectively assessed need (OAN) for housing in North Northamptonshire and that the Focused Changes have not addressed their previous concerns. Housing trajectory 3.7 In relation to FC 105 respondents including the HBF (056), Tata Steel (070) and Hallam Land Management (081) consider that the annualised housing trajectory requires deliverable sites in addition to the SUEs to be identified in the early years of the plan period so that a five year housing supply can be maintained. Jardin Smith (116) consider that the wording of paragraph 9.8 as amended lacks clarity. They question how planning for housing can be both “aspirational” and “realistic” at the same time. They consider that the wording suggests that housing delivery will be dependent on the number of completions across the plan period. Whilst this is true in practical terms, they consider that no reference is made as to how housing will be delivered in the event of under delivery. vi. Will the identified SUEs deliver the required amount of housing to ensure that North Northamptonshire delivers the full objectively assessed need for housing and is there sufficient contingency within the JCS? 3.8 Responses from the development industry re-state previous concerns that the JCS is over-reliant on SUEs. Catesby Estates (064) are of the view that the JCS approach could jeopardise housing supply across the JCS Plan period given approximately 7,200 of the 35,000 dwelling requirement is being proposed at SUEs which are yet to be committed, and in the case of Rushden East, not yet fully tested and therefore potentially unviable. This overall strategy also presents a risk to enabling employment growth and meeting affordable housing needs outside of the SUEs and Market Towns. Hallam Land (081) consider that there is a clear over reliance on the SUEs in the JCS with unrealistic assumptions about housing delivery at the SUEs, a view echoed by Jardin Smith (116). Gladman (090) question the JPU’s decision to rely on a development strategy that it considers has already proven to be ineffective at meeting North Northamptonshire’s housing needs. vii. Is the distribution of development the most appropriate when all reasonable alternatives are considered? viii. Does the JCS provide sufficient development in the rural area? 3.9 Linked to comments to the housing trajectory and the delivery of the SUEs, a number of respondents from the development industry re-state their previous objections that more housing development should be directed to the market towns and rural areas in order to meet needs where they arise and ensure that a 5 year housing supply is maintained.