Settlements and Countryside Local Plan (Part 2) for Daventry District Statement of Compliance with Duty to Cooperate (PSD10) December 2018

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Contents

Page

1. Introduction to the Duty to Cooperate 3

2. The Settlements and Countryside Local Plan (Part 2) Duty to Cooperate 6

3. Summary of Main Duty to Cooperate Matters 7

4. Additional Duty to Cooperate matters related to plans of neighbouring 8 authorities Appendix 1 – Duty to Cooperate by Statutory Organisation / Neighbouring 15 Council in respect of the Daventry District Settlements and Countryside Part 2 Local Plan

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1. Introduction to the Duty to Cooperate 1.1 This document forms part of the technical evidence base that informs the Part 2 Settlements and Countryside Local Plan. It supersedes the Duty to Cooperate Background Paper which was produced for the Proposed Submission stage of plan making. It sets out the Council’s approach to compliance with the Duty to Cooperate in the production of the Plan and identifies how the outcomes of this cooperation have influenced the Strategy up until the point of Submission. It also sets cooperation in the wider context of ongoing relationships and delivery partnerships between local authorities and other key cross-boundary agencies.

1.2 The Duty to Cooperate was introduced by the Localism Act 2011 in the wake of the abolition of the regional and sub-regional tiers of planning. It places a duty on local planning authorities to engage constructively, actively and on an ongoing basis to maximise the effectiveness of Local Plan preparation in the context of strategic cross boundary matters. The Local Planning Regulations 2012 (Part 2: Duty to Cooperate) prescribes which bodies are subject to the Act.

1.3 In addition to demonstrating that the plan has been prepared in accordance with the duty to cooperate, local authorities must demonstrate how joint working has influenced policy outcomes within the plan in order for the plan to be found sound at examination.

1.4 Paragraph 178 of the 2012 NPPF states that public bodies have a duty to cooperate on planning issues which cross administrative boundaries, particularly those relating to strategic priorities. This is required to ensure that strategic priorities which cross local boundaries are properly co- ordinated and clearly reflected in individual Local Plans.

1.5 The National Planning Policy Guidance (NPPG) was launched in March 2014. It states that Local Planning Authorities must demonstrate how they have complied with the duty. If a Local Planning Authority cannot demonstrate that it has complied with the duty then the local plan will not be able to proceed further in examination.

1.6 The NPPG expands on the extent to which Local Planning Authorities should cooperate. The duty to cooperate is not a ‘duty to agree’, but must demonstrate that planning authorities have made every effort to seek necessary agreements and cooperation over strategic planning matters prior to submitting the plan for examination.

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1.7 Should another authority or organisation subject to the duty, not cooperate on strategic cross-boundary issues, it must be demonstrated with comprehensive and robust evidence that efforts have been made to cooperate and any outcomes achieved.

1.8 Where Local Planning Authorities are at different stages of local plan preparation, the NPPG advises that the respective Local Planning Authorities should try to enter into formal agreements, demonstrating their long-term commitment to a jointly agreed strategy on cross boundary matters. The key element is that there is sufficient certainty through the agreements that an effective strategy will be in place for strategic matters when the plans are adopted.

1.9 The Localism Act 2011 states that the duty-to-cooperate:

 Relates to a ‘strategic matter’ defined as sustainable development or use of land that has or would have a significant impact on at least two local planning areas or on a planning matter that falls within the remit of a county council  Requires that councils and public bodies ‘engage constructively, actively and on an ongoing basis’ in the preparation of development plan documents, and

 Requires councils to consider joint approaches to plan-making.

1.10 The planning authorities to which the duty most directly applies in the case of Daventry District Council are identified below:

 South Northamptonshire Council

 Northampton Borough Council

 Northamptonshire County Council

 Wellingborough Borough Council

 Kettering Borough Council

 Stratford-upon-Avon District Council

 Harborough District Council

 Rugby Borough Council

1.11 The statutory bodies identified in Part 2 of the Town & County Planning (Local Planning) (England) regulations 2012 (as amended) include:

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• The Environment Agency • Historic England • Natural England • The Mayor of London • The Civil Aviation Authority • The Homes and Communities Agency • Clinical Commissioning Groups • Office for Rail Regulation • Transport for London • Highways England • Marine Management Organisation. • Local Enterprise Partnerships

1.12 Recent changes to the plan making system in the summer of 2018 through the revised NPPF introduced the requirement to produce statements of common ground. A statement of common ground is a written record of the progress made by plan-making authorities during the process of planning for strategic matters across local authority boundaries. It documents where cooperation is and is not happening, and is a way of demonstrating at examination that plans are deliverable over the plan period, and based on effective joint working. The statement of common ground is also evidence that the duty to cooperate has been complied with. For this Local Plan, a small number of Statements of Common Ground are being prepared with different statutory bodies, explained further in section 3.

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2. The Settlements and Countryside Local Plan (Part 2) Duty to Cooperate 2.1 The Settlements and Countryside Local Plan follows on from the adoption of the West Northamptonshire Joint Core Strategy (WNJCS) in December 2014. Building on the WNJCS, it is being prepared to help further guide planning decisions in the area and, once adopted, will form part of the Development Plan for the District with the WNJCS and made neighbourhood development plans.

2.2 The duty to cooperate has not just been an ongoing process since the launch of the Settlements and Countryside Local Plan, but a continuation of that which was undertaken for the WNJCS where a number of the key strategic issues were addressed. This has ensured efficient and productive dialogue with neighbouring authorities as well as other statutory bodies. Meetings have been held with statutory bodies and neighbouring authorities from early 2016 through to submission in late 2018 (and indeed will continue beyond then) . These are often informal in nature and used to ensure the process of ongoing dialogue between planning authorities. Typically this dialogue relates to strategic and/or cross-boundary matters concerning each authority’s evolving development plan. This Paper will restrict itself therefore to those issues that concern the Daventry District Settlements and Countryside (Part 2) Local Plan.

2.3 The Duty to Cooperate process has involved regular meetings at officer level with neighbouring authorities as well as the joint commissioning of work and studies, such as the Strategic Flood Risk Assessment and the Open Space Study.

2.4 DDC has also sought to actively engage with other statutory duty to cooperate bodies, including Historic England, Environment Agency and Anglian Water to ensure that all relevant issues were considered during the local plan process. A summary of this engagement is set out in Table 1 and detailed fully in Appendix 1.

2.5 Throughout the Duty to Cooperate process, some issues have been identified by both neighbouring authorities and statutory bodies. DDC has sought to engage constructively to understand the issues and worked proactively to ensure the issues have been addressed. This process, the discussions held and studies undertaken, have all contributed and have helped to inform the strategy and policies set out within the Settlements and Countryside Local Plan.

2.6 There are a small number of outstanding issues relating to soundness that have not been resolved as there are still a limited number of outstanding objections from Historic England and South Northants Council. However neither of these objections

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are on the basis of a lack of cooperation and the evidence contained within this Statement clearly identifies that in all cases, DDC has engaged actively with our relevant bodies and is confident that the legal requirement to ‘engage constructively, actively and on an on-going basis’ has been met.

3. Summary of Main Duty to Cooperate Matters related to the Settlements and Countryside Part 2 Local Plan 3.1 The West Northamptonshire Joint Core Strategy (WNJCS) has been prepared at a sub-regional level to provide an overall framework in which more detailed plans will be drawn up and decisions made across Northampton, Daventry and South Northamptonshire. This means that a number of strategic duty to cooperate issues, in particular the level and over-arching distribution of housing and employment, were agreed through the production of that Plan.

3.2 Notwithstanding the Part 1 Local Plan a key requirement for the Part 2 plan is to ensure delivery of development, which requires a range of discussions with the wider stakeholder group and comprising inter alia flooding, water infrastructure, highways, schools, etc.

3.3 A summary of duty to cooperate matters concerning the Daventry Part 2 Local Plan is set out below, this also identifies whether issues are resolved or ongoing and require continued dialogue. The full schedule in Appendix 1 sets out in detail any issues for the Part 2 Local Plan, where possible how they have been resolved in the Part 2 Local Plan and further actions as the plan progresses. It is important to note that none of the statutory bodies or any adjoining authority have objected to the proposed submission Part 2 Local Plan on the grounds that Daventry District Council has failed to meet the Duty to Cooperate.

3.4 As set out below, the issue of most significance relates to delivery of the housing requirements for the Northampton Related Development Area. This is explained in more detail in the sections in Appendix 1 for Northampton Borough and South Northamptonshire and the NRDA background paper. However to summarise, currently it is the Council’s position that there are sufficient sites to meet the needs of the Borough and the NRDA but these are taking longer to come forward than was anticipated in the WNJCS when it was adopted in 2014. In respect of the Boroughs needs it has been confirmed through a sites consultation carried out in Autumn 2017. With regard the Sustainable Urban Extensions that form the basis of the NRDA requirement in Daventry District, the level of progress is explained in more detail in

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the Housing Implementation Strategy1. Whilst slower than anticipated, they are progressing (all have reached planning application stage as a minimum, with completions occurring on some sites) and it is important to note that the monitoring provisions in the WNJCS have not yet been triggered through under-supply.

3.5 Therefore as the SUE’s are progressing it is important to ensure that additional growth does not undermine and harm their delivery. The Council remains committed to helping to ensure that Northampton’s needs can be met however this should be in a plan-led manner and only where it cannot be accommodated within the NRDA. This position is reflected in policy SP1 of the Part 2 Local Plan. Any review of the NRDA boundary will be carried out through a review of the Part 1 plan and a review of the WNJCS is currently underway which is the appropriate mechanism for addressing the issue of a shortfall in delivery in the NRDA.

3.6 The position in respect of the NRDA is also set out in the NRDA background paper and a Statement of Common Ground is being prepared with South Northamptonshire Council and Northampton Borough Council to reflect this.

3.7 Further Statements related to the soundness of the plan may be produced in respect of the following;

 Northamptonshire County Council in relation to highways and education at the Daventry South West (HO1) allocation;

 Historic England in relation to Daventry South East (EC9).

3.8 Whilst the Duty to Cooperate is deemed to end in relation to the production of a local plan once it is submitted for Examination, Daventry District Council considers that it is in fact a continuous process that will carry on past this point, as allocations within the plan are brought forward and policies are implemented. The Council is fully committed to continued engagement with neighbouring authorities and other Duty to Cooperate bodies as planning applications are prepared, submitted and determined to ensure all commitments are honoured and to ensure the delivery of sustainable development and growth that benefits residents, communities and businesses both within and beyond Daventry District.

1 Daventry Housing Implementation Strategy available from; https://www.daventrydc.gov.uk/living/planning- policy/five-year-housing-land-supply/

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4. Additional cross-boundary matters related to plans of neighbouring authorities

4.1 Throughout this process, further dialogue relating to strategic and/or cross- boundary matters with each neighbouring authority’s evolving development plan has taken place. Principally this has been with Rugby Borough Council and Harborough District Council where specific cross-boundary issues have been identified. Whilst they do not have a bearing on the Part 2 Local Plan and have not been raised by the respective authority as doing so they are covered below for completeness.

Rugby Local Plan

4.2 With regard to the Rugby Local Plan, Daventry District Council has an outstanding objection to the Rugby Local Plan regarding a potential new settlement near to Daventry District. Mitigation of the impact of the allocation involved highways improvements at junctions within Daventry District that may require reference in Daventry District Part 2 Local Plan. The Rugby Local Plan has progressed through examination and the planning inspector has indicated in initial findings that this allocation will be deleted from the Rugby Local Plan. Rugby Borough Council consulted on main modifications to the plan in September 2018 which included the deletion of the new settlement allocation. This was supported by Daventry District Council confirming that this modification addresses our previous objections. The final inspector’s report has not yet been issued.

Harborough Local Plan

4.3 With regard to the Harborough Local Plan, the plan includes a criteria based policy that allows for 700,000 sqm of strategic distribution at Magna Park, a logistics park at Lutterworth. A sensitivity study produced to assess the impact of different growth scenarios on housing identifies the need for a minimal amount of additional housing in Daventry District (6 dwellings per annum) if the highest growth scenario (700,000 sqm) is taken forward. The amount of floorspace to be provided is currently being explored through the examination of the plan and DDC has raised concerns about the potential impact of the quantum of floorspace on the implementation of proposals for DIRFT 3 (Policy E4 of the WNJCS). These concerns were articulated by DDC officers at the Harborough Local Plan examination hearings and the inspector requested that further work was undertaken as the original, criteria based approach was not satisfactory.

4.4 This work has been completed and reported that an additional 700,000 sqm of strategic distributuion at Magna Park would only have a moderate impact on the implementation of the WNJCS. This is now proposed to be an allocation in the Local Plan subject to approval by Harborough Council at its meeting in December 2018. 9

Dialogue is continuing and further consultation on possible modification will need to be undertaken (additional hearing sessions may also take place) however 6 dwellings per annum is not considered to be strategic, and would not be needed until a significant amount of the floorspace was built out and occupied which is likely to be towards the end of the Part 2 Local plan period (beyond 2029). Consequently this issue is not discussed in more detail in Appendix 1.

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Table 1: Summary of Duty to Cooperate Issues in Respect of the Daventry part 2 Local Plan

Duty to Cooperate Issue in Respect of the Daventry Part 2 Local Plan Resolved or Ongoing Body

ANGLIAN WATER Water Cycle Study update to demonstrate that Resolved preferred development sites can be brought forward with appropriate infrastructure investment

ENVIRONMENT SFRA (Part 1) completed at West Northants level to Resolved - SFRA completed with no outstanding AGENCY establish that preferred development sites can be issues for Part 2 plan brought forward

HARBOROUGH DC Gypsies & Travellers sites Resolved

HISTORIC Objection raised in respect of potential housing Resolved- land to the north of the A45 not being ENGLAND allocation at Daventry South East pursued as a housing allocation

Concern raised regarding Daventry South East Gateway Ongoing - Heritage impact assessment has been as an employment allocation undertaken for all proposed allocations including Daventry South East Gateway. The HIA concluded that the site can be developed with appropriate mitigation against the impact on the Burnt Walls and Borough Hill Scheduled Monuments and non- designated assets. At Reg 19 stage, Historic England maintained its objection to the allocation.

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Further dialogue is ongoing to seek to resolve this issue which could include a Statement of Common Ground.

NATURAL No issues identified at present – HRA screening opinion Resolved - HRA Screening Opinion received at ENGLAND sought at proposed submission stage. proposed submission consultation

KETTERING BC Potential provision of sites for Gypsies, Travellers and Dialogue to continue in respect of Emergency Travelling Showpeople- Daventry has no residual need Stopping Place location which is likely to come for Gypsy and Traveller Pitches however need for 1 forward outside of the Local Plan. In respect of the Emergency Stopping Place and 6 Traveller Showpeople issue related to need, additional commentary was Plots. KBC have received planning applications for sites included in the supporting text to confirm that from residents of Daventry District and therefore have each case is judged on its merits despite the need challenged the evidence that states there is no residual being met. DDC have shared examples of schemes need. permitted recently that have demonstrated this approach. KBC have not subsequently objected to the Part 2 plan at proposed submission stage therefore this issue is considered to be resolved.

NORTHAMPTON The ability for the NRDA requirements to be met. Ongoing however a Statement of Common Ground BC Northampton Borough has identified sufficient sites to is being prepared to reflect the agreement that this meet Borough needs (18,870) however delivery of issue is a matter for the review of the WNJCS Part 1 SUE’s that form NRDA slower than anticipated but are Plan. progressing.

NORTHAMPTON Range of issues connected with County Council Ongoing however further dialogue took place has SHIRE CC infrastructure, notably the implications of Part 2 Plan seeking to resolve the issue in relation to the

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growth on the highways network and schools provision highway network related to policy HO1 which was constructive. Following this no formal comments were made on the submission version of the plan. Further dialogue taking place regarding the education contributions required which will be reflected in the Infrastructure Delivery Schedule.

NORTH The identification of Green Wedges should not Resolved as per their representation (PS067) which NORTHAMPTON prejudice the assessment of all options in considering set out that they considered the revisions to ENV3 SHIRE JOINT PLANNING AND the longer term growth of Northampton and will need and the supporting text addressed their previous DELIVERY UNIT to be justified through the Examination process. concerns about the designation pre-determining decisions about the future growth of Northampton.

RUGBY BC Subject to Lodge Farm not being included as an allocation in the Rugby Local Plan there are no issues in No issues respect of the Settlements and Countryside Local Plan

SOUTH Object to the extent of the green wedge designation to Ongoing - The concerns related to the Green NORTHANTS the north of Northampton however this is not on the Wedge designation relate to soundness of the plan grounds of the Duty to Cooperate. A Statement of Common Ground is being prepared The ability for the NRDA requirements to be met. to reflect the agreement that the issue of meetings Northampton Borough has identified sufficient sites to Northampton’s housing need is a matter for the meet Borough needs (18,870) however delivery of review of the WNJCS Part 1 Plan. SUE’s that form NRDA slower than anticipated but are

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progressing.

STRATFORD-U- No issues No issues AVON DC

WELLINGBOROUG No issues in respect of the Settlements and Countryside No issues

H BC Local Plan however further dialogue required when review of the WNJCS takes place relating to exploring options for helping to accommodate Northampton’s housing need.

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Appendix 1: Duty to Cooperate by Statutory Organisation / Neighbouring Council in respect of the Daventry District Settlements and Countryside Part 2 Local Plan

Anglian Water

How cooperation Meeting: 27th January 2017 (combined to consider the evidence base required for the Part 2 plan in relation to the has taken place SFRA)

28th November 2017 Receipt of completed Water Cycle study work

Meeting: 20th March 2018 (Presentation on Water Resource Management Plan and Water Recycling Long Term Plan given at Northamptonshire Policy Officers group)

Emails: 16th May 2018 (to clarify amendments required to the plan)

Overview of Assessment needed to establish available capacity of existing water and water recycling infrastructure regarding issues potential Local Plan allocations

Additional wording required in some allocation policies to include reference to assessments and mitigation relating to water and water recycling infrastructure

How have issues Assessment completed and mitigation included in relevant policies. been addressed?

Outstanding None at Present action required

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Environment Agency

How cooperation Meeting: 27th January 2017 (combined meeting to consider the evidence base required for the Part 2 plan in relation to has taken place the SFRA)

Meeting: 27th March 2017(combined meeting to agree to jointly commission NCC to update Level 1 SFRA for all West Northamptonshire area)

Meeting: 4 May 2017 (SFRA work inception meeting)

Relevant Issues Water Cycle Study / River Basin Catchment Management

Update to water cycle study needed to reflect proposed location and implications of development across West Northamptonshire and, more specifically, Daventry. EA has requirement regarding river basin catchment management, which can be captured through the WNJCS

SFRA Sequential Testing

SFRA Level 1 required for West Northants, including Daventry DC

River Nene NIA

River Nene Nature Improvement Area: formal reference in policy required

How have issues Completed Water Cycle Study update (Anglian Water assessment 2017) been addressed? Completion of SFRA Level 1: (November 2017)

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Inclusion of reference to the River Nene NIA within Part 2 Plan policy ENV4.

Outstanding None at present action required

Harborough District Council

How cooperation Meeting: 17 February 2016 has taken place Meeting: 21 April 2017

Meeting: 17 May 2017

Meeting: 2 August 2017

Email: January 2018 Confirmation from HDC with summary of DDC representation to Local Plan

Examination Hearings: 3rd October 2018

Email: November 2018 regarding scope of further work to assess impact of possible Magna Park allocation

Issues identified Gypsies & Travellers: Each authority to keep the other informed of respective Calls for Sites in respect of accommodating gypsies, travellers and travelling showpeople. Each local plan will need to consider how best to provide additional Gypsy and Traveller provision.

How have issues Harborough stated at the 2 August 2017 meeting that supply for its own community was likely to be met via an application to extend an existing plot. Therefore no issue identified for the Daventry District Settlements and 17

been addressed? Countryside Local Plan Part 2.

Outstanding None at present action required

Historic England

How cooperation Email/telephone: 17th January 2017 (DDC approached Historic England to request involvement in the emerging draft has taken place plan, specifically in relation to Daventry South East, Burnt Walls and Borough Hill)

Letter: 1st February (Historic England set out objection to Daventry South East site which at the time was proposed for residential)

Meeting: 1st March (To discuss Historic England objection)

Workshop: 25 April 2017 (Led by Design Review Panel, Opun and included all stakeholders relevant to the Daventry South East residential allocation)

Letter: 4th May (Received from Historic England emphasising that the proposed allocation would result in substantial harm to the Scheduled Monuments)

Letter: 14th September (Received from Historic England responding to a question asked about view corridors between the Scheduled Monuments. They advised that the connection shouldn’t be restricted to narrow view corridors but rather as part of the wider landscape.)

Email: 3rd October 2018 (in response to Proposed Submission consultation Historic England continue to object to Daventry South East site)

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Meeting: 27th November 2018 (DDC approached Historic England to request a meeting to discuss their objection)

Issues Identified Housing- Daventry South East

Historic England raised an objection to potential for residential development on land to the north and south of the A45 citing impacts on the setting of Borough Hill and Burnt Walls Scheduled Monuments and the relationships between them.

Employment – Daventry South East

Historic England has an outstanding objection relating to the soundness of the plan to development on land adjacent to Burnt Walls (North of the A45) identifying concerns about the impact on the setting of Burnt Walls Scheduled monument. They have suggested removing part of the allocation.

Burnt Walls and Borough Hill Scheduled Monuments

Consider inclusion of a policy to ensure these historic assets are protected and enhanced.

How have issues Housing- Daventry South East been addressed? Council are not pursuing residential development on land to the north of the A45.

Employment – Daventry South East

A heritage impact assessment was undertaken for the site following the emerging draft consultation. Mitigation was referred to in the policy which was subject to consultation at proposed submission stage.

Burnt Walls and Borough Hill Scheduled Monuments

Specific policy included in the Part 2 Local Plan

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Outstanding Historic England have maintained objection to Proposed Submission plan – dialogue ongoing to seek to resolve this action required issue including possibly through a statement of common ground.

Kettering Borough Council

How cooperation Meeting: 12 February 2016 (General meeting to discuss cross boundary issues) has taken place Meeting: 16 June 2017 (General meeting to discuss cross boundary issues)

21st February 2018 – Meeting regarding KBC objection

Further dialogue taking place through following forums;

Northamptonshire Policy Officers – last date 26th September 2017

SEMLEP Planners Forum – 12th April 2018

Issues Identified Gypsies & Travellers

Potential provision of sites for Gypsies, Travellers and Travelling Showpeople- Daventry has no residual need for Gypsy and Traveller Pitches however need for 1 Emergency Stopping Place and 6 Traveller Showpeople Plots.

Kettering BC are concerned that the methodology adopted in this study, and the assumptions relied upon, have the strong potential of under-estimating need for residential pitches in Daventry District. They give an example where they are currently determining a planning application for an additional 2 pitches at a gypsy and traveller site at Broughton, near Kettering from an applicant who currently lives on a site in Daventry District, and he needs extra pitches through new household formation as his children become more independent.

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Furthermore they refer to an application for 3 mobiles homes that is pending at Golden Stables in Daventry District. This would suggest there is further need emanating from Daventry District. Therefore concern that assumptions made concluding the need for 1 residential pitch in period to 2029 is flawed and should be properly addressed through policy considerations.

Whilst there is no outstanding need for residential pitches this does not preclude further proposals coming forward for residential pitches through Development management. However it is considered this position could be further clarified in the supporting text to the policy to confirm that applications would be treated on a case-by-case basis but that additional residential pitches will need to be justified.

How have issues Amend supporting text to the policy to confirm that applications would be treated on a case-by-case basis but been addressed? additional residential pitches will need to be justified. No objection from Kettering BC to Proposed Submission version of Part 2 Local Plan.

Outstanding Nothing at Present action required

Natural England

How cooperation Emails: May 2017 has taken place

Issues Identified HRA screening opinion sought at proposed submission stage.

How have issues HRA Screening opinion received with no objection. been addressed?

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Outstanding None required action required

Northampton Borough Council

How cooperation Meeting: 27th January 2017 (combined meeting to consider the evidence base required for the Part 2 plan in relation to has taken place the SFRA)

Meeting: 27th March 2017 (follow up combined meeting to agree to jointly commission NCC to update Level 1 SFRA for all West Northamptonshire area)

Meeting: October 2017 (combined meeting with South Northants Council)

Meeting: 23rd July 2018 (combined meeting with South Northants Council)

Further dialogue taking place through following forums;

West Northamptonshire Planning and Housing – 21st September 2017; 7th February 2018; 25th April 2018, 4th July 2018

West Northamptonshire Policy Managers – 15th September 2017; 14th March 2018 (NRDA issue specifically discussed); 16th May 2018, 11th July 2018

West Northamptonshire Transport Officers – 11th October 2017; 7th December 2017; 8th February 2018; 19th April 2018, 14th June 2018,

West Northamptonshire Monitoring Group – 30th April 2018, 9th July 2018

Northamptonshire Policy officers Meeting – 26th September 2017; 14th March 2018 ; 28th September 2018

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SEMLEP Planners Forum – 12th April 2018; 1st November 2018

Issues identified NRDA Housing Land Supply

- NBC sites consultation confirms that there is capacity to meet Northampton Boroughs needs as set out in the WNJCS but difficulties with rate of delivery. NRDA sites progressing in Daventry District but at rate considerably slower than envisaged in the WNJCS

- No 5-year housing land supply for the NRDA at present

- Plan needs to make reference to helping to meet Northampton’s needs where this cannot be accommodated within the NRDA. However such development should be plan-led and not undermine the WNJCS spatial strategy.

How have issues Policy SP1 includes following reference under criterion B; been addressed? B. Assisting with the delivery of plan-led development to meet Northampton’s needs where it is identified that this cannot be accommodated within the Northampton Related Development Area

A Housing Delivery Manager post has been created to accelerate this delivery of housing in the NRDA and will work with NBC, SNC and DDC. When appointed, the person will lead on the preparation and implementation of a Housing Delivery Plan for the area.

Any review of the NRDA boundary will be carried out through a review of the Part 1 plan and a review of the WNJCS is currently underway. A Local Development Scheme for this work was adopted by each of the partner authorities in October 2018.

Outstanding Statement of Common Ground is being prepared to reflect the agreement that this issue is a matter for the review of

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action required the WNJCS Part 1 Plan.

Northamptonshire County Council

How cooperation Meeting: 23 August 2016 (with Highways) has taken place Meeting: 27th January 2017 (with Highways to discuss allocations and transport modelling)

Meeting: 27th January 2017 (meeting to consider the evidence base required for the Part 2 plan in relation to the SFRA- attended by Lead Local Flood Authority officers)

Meeting: 27th March 2017(follow up combined meeting to agree to jointly commission NCC to update Levelt 1 SFRA for all West Northamptonshire area-attended by Lead Local Flood Authority officers)

Meeting: 14th December 2017 (Education)

Workshop: 24th April 2017 (Led by Design Review Panel, Opun and included all stakeholders relevant to the Daventry South East residential allocation attended by NCC Public Transport)

Meeting: 17th May 2018 (Specific discussion with highways about Daventry South West allocation)

Other meeting forums;

West Northamptonshire Transport Officers – 11th October 2017; 7th December 2017; 8th February 2018; 19th April 2018, 14th June 2018, 16th August 2018, 12th October 2018, 6th December 2018

Northamptonshire Policy officers Meeting –26th September 2017; 14th March 2018; 28th September 2018

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Issues identified: Daventry South West

Transport NCC Highways had previously raised concerns about the acceptability of a direct access from the A45 onto the site through engagement in the OPUN review workshop. Need to establish if suitable access arrangement can be achieved

from the A45 (Stefen Way) to the satisfaction of NCC as Highways Authority.

Gypsies, Travellers and Travelling Showpeople

Need to provide for 1 Emergency stopping place

Other Matters

Transport Assessments of all allocations in the Part 2 Local Plan

Northampton Northern Orbital Route– a relief road to the north of Northampton situated in Daventry District. Various options have been consulted on and a route has yet to be finalised. Part 2 Local plan needs to make reference to project although route is yet to be confirmed.

Issues identified: Residential allocations need to refer to provision of necessary contributions to education.

Education Daventry South West allocation (1100 dwellings) needs to make provision for land for a 2 form entry primary school

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How have issues Daventry South West been addressed? Initial modelling has confirmed that access can be achieved from the A45 (Stefen Way) and NCC Highways are satisfied Transport this can be achieved. Further dialogue has taken place on this matter following the representation by NCC to the Part 2 Local Plan at emerging draft stage that stated ‘no rationale is presented as to why the principal junction is proposed on the A45, which currently forms part of the Department for Transport’s Indicative Major Road Network’. The representation also raised further concerns about pedestrian connectivity as they considered an at-level crossing across the 60mph route to be unsafe and also did not consider that public transport could be routed through the development. Further dialogue has taken place which has sought to address this issue. No formal objection has been received to the Proposed Submission plan on this issue.

Gypsies, Travellers and Travelling Showpeople

Maintain dialogue. Provision for 1 Emergency stopping place will come forward outside of the Local Plan.

Other Matters

Transport Modelling of all allocations in the Part 2 Local Plan were carried out in advance of Proposed Submission consultation

Northampton Northern Orbital. Part 2 Local plan makes reference to project although route is yet to be confirmed so cannot refer to its safeguarding.

How have issues Housing allocations refer to necessary contributions to education and Daventry South West requires provision of land been addressed? for a 2 form of entry primary school

Education

Outstanding Ongoing dialogue is taking place to establish agreed costs for education infrastructure in the Infrastructure Delivery

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action required Schedule.

North Northamptonshire Joint Planning and Delivery Unit

How cooperation Further dialogue taking place through following forums: has taken place Northamptonshire Policy Officers – 26th September 2017; 14th March 2018; 28th September 2018

SEMLEP Planners Forum – 12th April 2018; 1st November 2018

Issues identified The identification of Green Wedges should not prejudice the assessment of all options in considering the longer term growth of Northampton and will need to be justified through the Examination process. Consider amendment to green wedge policy to acknowledge the longer term growth of Northampton in the review of the WNJCS.

How have issues Proposed submission plan included amendments to Green Wedge policy with specific reference to the designation not been addressed? pre-determining future decision making for further growth of Northampton that may arise through a review of the Part 1 Plan.

Outstanding Maintain ongoing dialogue however no outstanding issues in respect of the Part 2 Plan as demonstrated by their action required representation (PS067)

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Rugby Borough Council

How cooperation Meeting: 5 May 2017 has taken place Meeting: 31 May 2017

Examination Hearings: 25th January 2018; 31st January 2018; 26th April 2018 – Participated in Rugby Local Plan examination hearings

31st August 2018: Response submitted to main modifications confirming support for the modification to remove Lodge Farm allocation

Issues identified No issues subject to Lodge Farm no longer being allocated in the Rugby Local Plan as per main modifications to Rugby Local plan.

How have issues N/A subject to the above. been addressed?

Further Action Maintain ongoing dialogue to ensure latest position is taken into account.

South Northamptonshire Council

How cooperation Meeting: 27th January 2017 (combined meeting to consider the evidence base required for the Part 2 plan in relation has taken place to the SFRA)

Meeting: 27th March 2017(follow up combined meeting to agree to jointly commission NCC to update Level 1 SFRA for all West Northamptonshire area)

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Meeting: October 2017 – (combined meeting with Northampton Borough Council)

Meeting: 23rd July 2018 (combined meeting with Northampton Borough Council)

Further dialogue taking place through following forums;

West Northamptonshire Planning and Housing – 21st September 2017; 25th April 2018

West Northamptonshire Policy Managers – 15th September 2017; 15th November 2017; 17th January 2018; 8th February 2018; 14th March 2018 (NRDA issue specifically discussed); 16th May 2018, 13th September 2018

West Northamptonshire Transport Officers – 11th October 2017; 7th December 2017; 19th April 2018 14th June 2018, 16th August 2018, 12th October 2018, 6th December 2018

West Northamptonshire Monitoring Group – 30th April 2018; 24th September 2018

Northamptonshire Policy officers Meeting – 26th September 2017; 14th March 2018; 28th September 2018

Issues identified NBC sites consultation (Autumn 2017) confirms that capacity to meet Northampton Boroughs needs as set out in the WNJCS but difficulties with meeting Northampton Related Development Area (NRDA) requirement. NRDA sites progressing in Daventry District but at rate considerably slower than envisaged in the WNJCS as set out in the Housing Implementation Strategy.

Plan needs to make reference to helping to meet Northampton’s Needs where this cannot be accommodated within the NRDA. However such development should be plan-led and not undermine the WNJCS spatial strategy.

South Northants Council made a formal objection to the emerging draft plan consultation and considered there had been a failure to meet the duty to cooperate with regard to housing delivery within the NRDA. DDC urged to consider inclusion of a criteria-based policy as per South Northants., this is explored in the NRDA Background paper.

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Regarding the Green Wedge South Northants consider the designation to mean the plan had not been positively prepared and could be considered unsound

How have issues As set out in the NRDA Background paper a criteria based policy not considered appropriate and would undermine been addressed? plan-led system. However Policy SP1 includes following reference under criterion B;

B. Assisting with the delivery of plan-led development to meet Northampton’s needs where it is identified that this cannot be accommodated within the Northampton Related Development Area

The objection to the Green Wedge was maintained at the Proposed Submission stage, but only in respect of soundness and not related to the Duty to Cooperate.

Outstanding action Maintain ongoing dialogue to seek to resolve these issues however a Local Development Scheme for the review of required the WNJCS was adopted by each of the partner authorities in October 2018.

Statement of Common Ground is being prepared to reflect the agreement that the issue of meetings Northamptons housing need is a matter for the review of the WNJCS Part 1 Plan.

Stratford-upon-Avon District Council

How cooperation Meeting: 26 January 2016 has taken place

Issues identified No issues requiring further joint work

How have issues N/A been addressed?

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Outstanding action Maintain ongoing dialogue however there are no outstanding issues. required

Borough Council of Wellingborough

How cooperation Meeting: 14 January 2016 has taken place Meeting: 20 April 2017

Other meeting forums;

Northamptonshire Policy Officers Meeting – last date 26th September 2017

West Northamptonshire Transport Officers – 11th October 2017; 7th December 2017

Issues identified Discussions about how to address Northampton’s housing needs at review stage of WNJCS require involvement of BCW.

How have issues Not a matter for the Part 2 Local Plan. been addressed?

Outstanding action Maintain ongoing dialogue however there are no outstanding issues for the Part 2 Local Plan. required

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