055 Hallam Land Management

Dear Sir / Madam

NORTH NORTHAMPTONSHIRE JOINT CORE STRATEGY: REPRESENTATIONS TO THE CONSULTATION ON THE DRAFT INTERIM POLICY STATEMENT ON HOUSING REQUIREMENTS

These representations are submitted on behalf of Hallam Land Management (HLM) to the North Northamptonshire Joint Core Strategy Consultation on the Draft Interim Policy Statement on housing requirements for the North Northamptonshire Housing Market Area.

Background

HLM controls the land to the south east of Burton Latimer and are promoting this as a location for new housing. The site is located to the south of Higham Road, and is identified as a preferred option in the Kettering Site Specific Proposals Local Development Document Options Paper (2012).

The site has the potential to deliver in region of 200 dwellings to contribute towards the housing requirements for Burton Latimer, which is identified in the Core Spatial Strategy as one of three small market towns, providing secondary focus for growth outside of Kettering.

Draft Interim Policy Statement on Housing Requirements

General Approach

The following comments relate to the overall approach of the Draft Interim Policy Statement, the objective assessment of the need for housing for the North Northamptonshire Housing Market Area, and the calculation of the five-year supply for Kettering in the Interim Policy Statement.

HLM note that the purpose of the document is to provide an Interim Housing Policy Statement to enable the local planning authorities to take account of up to date evidence in maintaining a deliverable supply of land for housing development, in the intervening period before adoption of the emerging Joint Core Strategy. However, HLM have significant concerns with this approach to revise the housing requirement figures contained within an adopted Core Strategy through the introduction of an Interim Policy Statement on housing requirements.

In a recent appeal decision against Wellingborough Borough Council (ref: APP/H2835/A/12/2182431) for a housing development in Irchester, the Inspector considered that the housing requirement in the Draft Emerging JCS cannot yet carry significant weight, given the document is still at a very early stage, and

substantial outstanding objections to the housing figures in the Draft Emerging JCS remain. On this basis, the Inspector considered that the five-year land supply should be calculated on the requirements of the adopted Core Spatial Strategy.

In light of this decision, HLM question the overall approach of meeting housing requirements of the North Northamptonshire HMA through this Interim Policy Statement, and the amount of weight which can be attached to the document for the purposes of decision making.

In addition, HLM are concerned that the document proposes a reduction of the housing requirement figure independently without consideration of the implications on neighbouring authorities and compliance with the Duty to Cooperate.

HLM therefore consider that the housing requirement in the adopted Core Spatial Strategy should continue to form the basis of the five-year land supply.

Objectively Assessed Five Year Housing Requirement

Notwithstanding the above, HLM also has significant concerns with the calculation of objectively assessed needs, and resultant five-year housing land calculations in Part B of the consultation document.

The Draft Interim Policy Statement sets out an ‘Objectively Assessed Need for the Interim Statement’ figure of 17,832 dwellings over the period 2011-2021 (1,783 per annum). This figure is significantly lower than the housing requirement in the adopted Core Spatial Strategy (2,605 per annum), and the Draft Emerging JCS ‘Strategic Opportunity’ (2,025 per annum) figure.

It is noted that the ‘Objectively Assessed Need for the Interim Statement’ figure is derived from the latest CLG Household Interim Projections (2011-2021), and includes an allowance for the back-log of unmet housing need and a 3% allowance for vacant dwellings.

HLM consider that the Draft Interim Statement is overly reliant on the 2011 CLG Household Interim Projections to form the objectively assessed need in the HMA. These figures are trend based forecasts based on household data following a period of undersupply and suppressed household formation.

Notably the Draft Interim Statement recognises the limitations of the Household Interim Projections at paragraph A15, stating:

The CLG Household Projections are a key element of ‘objectively assessed needs’ (NPPF paragraph 159). They are most useful in considering requirements at the HMA level since, at a district level, they largely reflect recent levels of housing development (if a district has seen high levels of growth in the past 5 years then it is projected to see high growth in the future and, conversely, if housing development has been limited, the household projections will be lower).

This reliance on trend based forecasts does not represent ‘objectively assessed needs’ in line with the provisions of paragraph 47 and 159 of the NPPF. The Household Interim Projections do not fully reflect anticipated migration patterns, market demand and economic factors, including the need to align housing and employment strategies.

Whilst the Draft Interim Statement suggests that the Objectively Assessed Need for the Interim Statement’ figure aligns with the forecasted growth in jobs in the HMA, this is based on the lower trend based forecasts for the MKSM Economic Development Evidence Base, rather than the target of at least 28,500 jobs in the Draft Emerging JCS.

Paragraph 159 of the NPPF requires local planning authorities to have a clear understanding of housing needs in their areas through preparation of a Strategic Housing Market Assessment to assess their full housing needs. The Draft Interim Statement relies only on the 2011 Household Interim Projections, and disregards the Council’s existing evidence base, including more detailed local modelling (Edge Analytics 2011 & 2012) and the Strategic Housing Market Assessment (Housing Vision 2012).

On this basis, HLM consider that the ‘Objectively Assessed Need for the Interim Statement’ figure of 17,832 dwellings over the period 2011-2021 does not represent the full and objectively assessed needs for the HMA in line with the provisions of the NPPF.

The Five-year Housing Requirements and Assessments

The Draft Interim Policy Statement sets out the five-year housing requirements for each of the authorities in the HMA at Table 2. Notwithstanding the major concerns HLM has with the calculation of objectively assessed needs in the document, the approach to calculating the five-year requirements also has significant shortcomings.

Firstly, the identified shortfall in delivery (item ‘h’ in Table 2) considers only two years (2011-2013) of undersupply. It is unclear as to why only completions in the previous two years are considered, given that

the Core Spatial Strategy covers a period 2001-2021.

The latest Annual Monitoring Report for North Northamptonshire JPU (2013) reveals an overall shortfall against the Core Spatial Strategy requirement in the period 2001-2021, including a shortfall of 1,485 dwellings against the requirement for Kettering. The five-year housing requirements should be amended to reflect the historic shortfall against the Core Spatial Strategy requirement, rather than just the shortfall over the last two monitoring years.

Secondly, the five-year housing requirements are based on addressing the identified shortfall in delivery across the period to 2021 (the ‘Liverpool Approach’), rather than being addressed within the five year period (the ‘Sedgefield Approach’).

This approach runs counter to recent appeal decisions where Inspectors have almost universally favoured the Sedgefield approach of dealing with undersupply, and the recent draft NPPF Guidance which makes clear any historical undersupply should be addressed within the first five years. HLM therefore request that the five-year requirements are amended to reflect the full extent of the historic undersupply over the period 2001-2021, and this being addressed within the first five years.

In addition to this, the five-year land supply calculations do not allow any deduction for the non- implementation of existing planning consents. It is established practice for the Planning Inspectorate to apply a 10% reduction to sites with planning permission when calculating five-year land supply of deliverable sites in determining planning appeals.

Overall, the calculations of five-year housing land supply position in the Draft Interim Policy Statement need to be entirely reconsidered. The housing requirement in the adopted Core Spatial Strategy should continue to form the basis of the five-year land supply. In addition, the five-year requirements need to reflect the full extent of the historic undersupply over the period 2001-2021, reflect the need to address this shortfall within the first five years, and include an allowance for non-implementation of permissions.

On this basis, HLM consider that the five-year housing land supply for Kettering is in fact considerably lower than suggested in the Draft Interim Policy Statement.

We trust you find the above representations helpful and look forward to receiving confirmation that they have been considered. If you require any further information, then please do not hesitate to contact Karin Hartley at this office.

056 Trustees of FG Saxby No 4 Settlement

Appendix 3: Checklist for potential sites

Site Address Land to the south of Irchester between Wollaston Road and Farndish Road, and extending east beyond Farndish Road

Area (Hectares) 24 hectares (total)

What type of development is the site being put forward for eg. residential/employment/mixed use? If the site is being put forward for mixed use please specify. Residential

Please include a Ordnance Survey Plan that includes the following information: Land ownership details (clearly indicating any changes in land ownership) Type and location of any existing use(s) on the site and whether any of the existing use(s) would continue to operate from the site

If the site is located within or adjacent to a Conservation Areas or Listed Building please indicate this on a plan as this could influence the density/type/ cost of the building materials etc

Where would access be achieved from and are there any land ownership issues associated with the potential access?

Is the site adjacent to an adopted or unadopted road, ie. a private road that has not been adopted by the highway authority? Please provide details along with the width of the road

Details of the existing pedestrian footways from the site to the local facilities (shops, school etc) and any improvements that might be required

Location of the nearest gas/electricity and water supply to the site

The boundary of the site that is being put forward for development

Yes No Is the site is in multiple ownership? X If yes, please give details of ownership and the list all of the owners

The land is in single ownership of the Trustees of the F G Saxby No 4 Settlement

Yes No Is the site vacant? X Is the site occupied? X Is the site partly occupied? Please provide details of the existing use Agricultural use

Draft North Northamptonshire Interim Housing Policy Statement – August 2013

Yes - all Yes - No part If the site is considered to be suitable for development, would Flexibility depending on how all or part of the existing use remain in occupation? the site is brought forward

What would be the timetable for the existing use to cease? From October 2015

Yes No Are there any financial implications that you are aware of that may X influence whether the site would be available for development? If yes, please give details

Yes No Have any discussions already taken place with utilities companies? X

If yes, please provide copies of correspondence

Yes No Are there other restrictions on the site, eg. grazing licences or any X other requirements that you are aware of that would need to be satisfied to bring the site forward for development? If yes, please give details

Yes No Are you aware of any abnormal costs associated with bringing forward X this site for development, eg. contaminated land? If yes, please give details

If the site was considered for development by the local planning authority what would you consider to be the timeframe for bringing this site forward for development? 0-5 years 5-10 years 10-15 years 15-20 years Over 20 years X

Draft North Northamptonshire Interim Housing Policy Statement – August 2013

What assumptions have you made in your assessment for releasing this site for development in terms of financial contributions?

Dependent upon the appropriate Affordable housing scale of development required to Education contributions come forward on the sit Contributions towards play/open space

Yes No Is there any other information that has not been covered by the above X that the Local Planning Authority should be aware of?

If yes, please give details

Dear Sir / Madam

NORTH NORTHAMPTONSHIRE JOINT CORE STRATEGY: REPRESENTATIONS TO THE CONSULTATION ON THE DRAFT INTERIM POLICY STATEMENT ON HOUSING REQUIREMENTS

These representations are submitted on behalf of the Trustees of the F G Saxby No 4 Settlement (“the Trustees”) in respect of the North Northamptonshire Joint Core Strategy Consultation on the Draft Interim Policy Statement on housing requirements for the North Northamptonshire Housing Market Area.

The Trustees own the land to the south of Irchester between Wollaston Road and Farndish Road and extends eastwards beyond Farndish Road.

Draft Interim Policy Statement on Housing Requirements

The representations relate to the following questions raised in the consultation document:

1. The objective assessment of the need for housing for the North Northamptonshire Housing Market Area in Part A of the Draft Interim Policy Statement, and the calculation of the five-year supply for

East Northamptonshire in Part B of the document; 2. The Land south of Irchester is available as an additional site for development which could deliver housing in the period 2014-2019.

The Trustees note that the purpose of the document is to provide an Interim Housing Policy Statement to enable the local planning authorities to take account of up to date evidence in maintaining a deliverable supply of land for housing development, in the intervening period before adoption of the emerging Joint Core Strategy. However, The Trustees have significant concerns with this approach, including the calculation of objectively assessed needs, and resultant five-year housing land calculations in Part B of the consultation document.

Question (a): Do you agree with the approach taken to calculating an objectively assessed, five year housing requirement as set out in Part A of this statement? If not, please outline your proposed approach and the evidence on which it is based.

Objectively Assessed Need

housing requirement in the adopted Core Spatial Strategy (2,605 per annum), and the Draft Emerging JCS ‘Strategic Opportunity’ (2,025 per annum) figure.

The Trustees consider that the Draft Interim Statement is overly reliant on the 2011 CLG Household Interim Projections to form the objectively assessed need in the HMA. These figures are trend based forecasts based on household data following a period of undersupply and suppressed household formation.

Notably the Draft Interim Statement recognises the limitations of the Household Interim Projections at paragraph A15, stating:

The Draft Emerging JCS ‘Strategic Opportunity’ housing requirement figure (2,025 per annum) was based on this more detailed modelling of a ‘migration-led recalibrated’ scenario, and it is unclear as to why this has not been used in the Draft Interim Statement.

On this basis, the Trustees consider that the ‘Objectively Assessed Need for the Interim Statement’ figure of 17,832 dwellings over the period 2011-2021 does not represent the full and objectively assessed needs for the HMA in line with the provisions of the NPPF.

Notwithstanding the above, in a recent appeal decision against Wellingborough Borough Council (ref: APP/H2835/A/12/2182431) for a housing development at the north of Irchester, the Inspector considered that the housing requirement in the Draft Emerging JCS cannot yet carry significant weight, given the document is still at a very early stage, and substantial outstanding objections to the housing figures in the Draft Emerging JCS remain. On this basis, the Inspector considered that the five-year land supply should

be calculated on the requirements of the adopted Core Spatial Strategy, concluding that Wellingborough could demonstrate only 1.3 years supply.

In light of this decision, the Trustees question the overall approach of meeting housing requirements of the North Northamptonshire HMA through this Interim Policy Statement, and the amount of weight which can be attached to the document for the purposes of decision making. It is considered inappropriate to revise the housing requirement figures contained within an adopted Core Strategy through the introduction of an Interim Policy Statement.

The Trustees therefore consider that the housing requirement in the adopted Core Spatial Strategy should continue to form the basis of the five-year land supply.

The Five-year Housing Requirements and Assessments

The Draft Interim Policy Statement sets out the five-year housing requirements for each of the authorities in the HMA at Table 2. Notwithstanding the major concerns the Trustees have with the calculation of objectively assessed needs in the document, the approach to calculating the five-year requirements also has significant shortcomings.

The latest Annual Monitoring Report for North Northamptonshire JPU (2013) reveals an overall shortfall against the Core Spatial Strategy requirement in the period 2001-2021, including a shortfall of 3,795 dwellings against the requirement for Wellingborough. The five-year housing requirements should be amended to reflect the historic shortfall against the Core Spatial Strategy requirement, rather than just the shortfall over the last two monitoring years.

The Trustees therefore request that the five-year requirements are amended to reflect the full extent of the historic undersupply over the period 2001-2021, and this being addressed within the first five years.

On this basis, The Trustees consider that the five-year housing land supply for Wellingborough is in fact considerably lower than suggested in the Draft Interim Policy Statement.

Question (d): Wellingborough BC cannot currently identify a 5 year Housing Land Supply against the requirements set out in Part A. In addition to speeding up delivery on sites identified in Part B and Appendix 2, what additional sites are available for immediate development and, provided in line with the adopted Core Spatial Strategy, could deliver housing in the period 2014-19?

The land south of Irchester is available as an additional location for development which could deliver housing in the period 2014-2019, in line with the adopted Core Spatial Strategy. All of the land is within the ownership of the Trustees, and therefore there are no landownership constraints to delivery. In addition, the sites could be accessed directly from Farndish Road. We enclose a completed form from Appendix 3 of the Draft Interim Policy Statement and site location plan for consideration.

It is recognised that the whole of the land south of Irchester may not be required in the short to medium term. However, the land is put forward on a flexible basis, with potential for one or more parcels to contribute to the housing shortfall within the first five years. This could form an initial phase of a wider development of the land south of Irchester, or a modest extension to the village as a discrete development, subject to the long term housing requirements and supply of sites in the borough.

The area to the south of Irchester is the most suitable location for development at this settlement. It avoids growth that would result in the expansion of the settlement such that gaps between Irchester and the larger urban areas of Wellingborough and Rushden are reduced. This enables Irchester to retain its own identity and prevents coalescence with the larger neighbouring settlements. The land to the south of Irchester is also an area which is not subject to long views given the natural topography of the land which gradually slopes upwards away from the settlement towards a ridgeline south of the sites.

Development of land to the south of Irchester would be in line with the adopted Core Spatial Strategy, relating to the broad location and distribution of development. Whilst Policy 10 of the Core Spatial Strategy seeks to direct most of the district’s development to Wellingborough town, and the two SUEs, the policy also makes provision for 1,210 dwellings of the district’s overall requirement to be in the rural area, including Irchester.

Irchester has a good range of services, including a school, shops, doctor’s surgery, library and employment, and therefore represents a sustainable location for development. On this basis, it is considered that the location accords with the Core Spatial Strategy Policy 1 requirement that development in the rural area should be focussed on the villages that perform the role of a sustainable local service centre. Whilst the land to the south of Irchester is outside of the settlement boundary, it is located adjacent to the built-up area, and within close proximity to facilities in the centre of the village.

Summary

The Trustees have significant concerns with Interim Housing Policy Statement, and consider that the housing requirement in the adopted Core Spatial Strategy should continue to form the basis of the five-year land supply.

Notwithstanding this, the calculations of five-year housing land supply position in the Draft Interim Policy Statement need to be entirely reconsidered. The five-year requirements need to reflect the full extent of the historic undersupply over the period 2001-2021, reflect the need to address this shortfall within the first five years, and include an allowance for non-implementation of permissions.

The Land south of Irchester is identified in response to the consultation as an additional site available for development which could deliver housing in the period 2014-2019.

Yours faithfully

Turley Associates

057 Pegasus Group

058 Barwood Land and Estates Ltd

By post and email b

Dear Sirs

Consultation on Interim Housing Policy Statement, Statement of Community Involvement and elements of the emerging Joint Core Strategy Review Representations by Barwood Land & Estates Ltd.

On behalf of our client, Barwood Land & Estates Ltd. (“Barwood Land”), we would like to provide comments on the following documents:

- Consultation on Strategic Housing and Employment Sites (August 2013) - Urban Structure Study (August 2013) - Draft Interim Policy Statement on housing requirements in the North Northamptonshire Housing Market Area (August 2013)

Barwood Land is an active developer within the North Northants area, but has a particular interest in the East Northants town of Raunds, where it has two extant planning permissions:

“Northdale End” (NNJPU Site No. 88), which comprises

- 1,859m2 (20,000sq.ft) of flexible, small scale office/light industrial starter units; - 68 bed care home and 19 close care apartments - 140m2 of community facilities; - the establishment of a regeneration fund to support the regeneration of the town centre through measures such as improvements to shop fronts; - site-specific and Raunds-wide flood relief and attenuation measures; - 310 dwellings (including provision of affordable housing); - conversion and restoration of the historic Northdale Farm buildings to provide the focal point of a new public square; - major areas of multi-functional green infrastructure including parkland, children’s play areas, informal open space, allotments, community orchards and meadows delivering recreational and ecological benefits; - further ecological benefits through improved management, retention and strengthening of hedgerows, enhancement of the existing Brook through the site and the creation of new wetlands and green wedges; - public transport enhancements including the extension of the X46 bus route; - provision of new and enhanced footways and cycleways both within the site and between the site and the heart of Raunds; and

Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East.

a - significant financial contributions towards social infrastructure including health, schools and libraries.

“West End” (NNJPU Site No. 55), which comprises:

- 18,581 m2 of flexible B1/B2/B8 employment floorspace; - 230 dwellings (including provision of affordable housing); - the continuation and strengthening of a regeneration fund to support the regeneration of the town centre through measures such as improvements to shop fronts; - further areas of multi-functional green infrastructure delivering recreational and ecological benefits and including the same categories of open space provided within Northdale End; - further public transport enhancements; - provision of additional new and enhanced footways and cycleways both within the site and between the site and the heart of Raunds; and - additional significant financial contributions towards social infrastructure including health, schools and libraries.

The Northdale End and West End schemes have been master planned so that they are capable of being developed independently of one another, but also as part of a wider Sustainable Urban Extension (SUE) in conjunction with additional land that Barwood Land has an interest in known as “Middle End” (NNJPU Site No. 94). Barwood Land wishes to ensure that Middle End (as the remaining component of the SUE) remains underpinned by the JCS.

This letter introduces and encloses separate representations on each of the three documents listed above. For the avoidance of doubt, we do not have any comments on the Statement of Community Involvement.

These representations should be read in conjunction with our previous representations on behalf of Barwood Land made at previous stages in the preparation of the Joint Core Strategy Review. We should be grateful if you would keep us apprised of further progress on the preparation of the JCS.

In the meantime, please do not hesitate to contact me if you require any further information or clarification.

Encs: 1. Representations on Strategic Housing and Employment Sites 2. Representations on Urban Structure Study 3. Representations on Interim Housing Policy Statement

Page 2

Draft In ter im Policy Statement on Hou sing Requirements in the North Northam pton shi re Hou sing Market Area (Augu st 2013)

Re prese ntat ion s by Barwood Land & Estates Ltd.

Introduction and Context

1. Barwood Land & Estates Ltd. (“Barwood Land”) has engaged consistently with the Joint Core

Strategy Review preparation process and has commented specifically on previous consultations

on the housing targets for the North Northamptonshire area.

2. The National Planning Policy Framework (NPPF) expands on the Government’s growth agenda

in a planning context. It sets out a presumption in favour of sustainable development that

includes providing the supply of housing required to meet the needs of present and future

generations and widening the choice of high quality homes.

The Duty to Co-operate

3. For plan making, the presumption in favour of sustainable development means that Local Plans

should meet the full objectively assessed housing needs of the housing market area. The

interim statement has, in our view, misinterpreted this to mean that the emerging JCS for North

Northamptonshire should only meet the local needs of its geographic area. This is not the case.

4. Within the Core Planning Principles set out in paragraph 17 of the NPPF, the first Core Principle

seeks to ensure that planning should be genuinely plan-led; empowering local people to shape

their surroundings. However, the context for this plan-led system is that:

“Plans should be kept up-to-date and be based on joint working and co-operation to address

larger than local issues.”

5. This theme of co-operation is developed further in the advice on plan-making in paragraph 157

of the NPPF which advises that:

“Crucially, Local Plans should…be based on co-operation with neighbouring authorities, public,

voluntary and private sector organisations.”

6. In other words the abolition of the Regional Spatial Strategy (RSS) does not mean that local

planning authorities can retreat from their wider strategic responsibilities behind their district

boundaries. They must co-operate with neighbouring authorities to ensure that development

requirements that have a wider than district implication are properly accommodated.

7. Furthermore, the duty to co-operate is a legal requirement. Section 33A of the Planning and

Compulsory Purchase Act 2004, imposes a duty on local planning authorities to cooperate with

councils and other bodies to address strategic cross-boundary issues when preparing Local

Plans. Section 33A is a new provision which was introduced by S.110 of the Localism Act 2011

and came into force on 15 November 2011.

8. The duty to co-operate is a key issue in the preparation of a Local Plan and it is a requirement

to which inspectors are attaching increasing weight. Failure to meet either the statutory

requirement to co-operate or the NPPF duty to co-operate is likely to render a Local Plan

unsound.

9. In the context of the North Northamptonshire Local Plan, the duty to co-operate is particularly

significant because the adopted Core Strategy figure of 52,100 for the period 2001 to 2021 was

clearly based on the area accommodating housing growth from elsewhere.

10. Therefore any decision to abandon this housing requirement in favour of a lower target will, by

implication, have an impact on local planning authorities elsewhere. The implications of this

decision should therefore be considered in conjunction with the authorities directly affected and

the strategy arising from those discussions should be subject to independent examination.

There is no evidence that any such consultation with other local planning authorities outside the

NNJPU has taken place and on this (fundamental) point alone, the Draft Interim Policy

statement on housing requirements fails and cannot be used as a basis for decision making.

11. In terms of the content of the Interim Statement itself, the basis appears to be a misguided view

(set out in paragraph A4) that the housing targets set out in the adopted Core Strategy are

undeliverable:

i. given market conditions;

ii. the changed national planning policy context; and

iii. are out of date in view of the revocation of the RSS and new evidence in the latest

household projections.

12. Dealing with each point in turn.

i. Market conditions

13. The reasoning here is that sticking with the Core Strategy requirement will require more new

homes to be built in the ten years from 2011-21 than were built in the preceding 20 years. The

Core Strategy requirement is 52,100 units between 2001 and 2021 or 2,605 units per annum.

However, figure 1 in the Interim Statement shows that from 2001 to 2007/08, housing

completions grew steadily from approximately 1,500 units per annum to over 2,100 units per

annum and the trajectory was on an upward trend. It is hardly surprising that completions have

fallen back to around 1,200 since 2008 in the context of the worst economic recession in living

memory.

14. The NNJPU has assumed that this depressed level of completions is the new norm – a view

that is completely at odds with the NPPF encouragement to local authorities to “boost

significantly” the supply of housing within the immediate 5 year period.

15. It is equally valid to take an entirely opposing interpretation from Figure 1 which is that the

upward trajectory of housing completions to 2008 suggests that with a reasonably positive

planning context and favourable economic conditions, it is entirely likely that something

approaching the Core Strategy requirement can be achieved.

ii. Changed National Planning Context

16. As discussed above, the NNJPU seems to interpret the guidance in the NPPF to “…objectively

assessed needs…” to mean that each local planning authority is only required to accommodate

only their own housing requirement. However, as explained above, the NPPF and statute

require that in assessing housing requirements and other development requirements, proper

account need to be taken of the implications of this on adjoining authorities.

iii. Revocation of the RSS and latest Household Projections

17. As discussed above, the revocation of the RSS does not automatically render its household

requirement figures invalid. It could equally be argued that the NPPF requirement to “…boost

significantly…” the supply of housing gives new credence to the Core Strategy Housing

Requirement. Furthermore the most recent 2011 based household projections for North

Northamptonshire differ little from the 2008 based projections (see table below). What has

changed in the 2011 projection is the distribution of the future housing requirement. However

the 2011 projections include the last five years of a deep recession and they cannot therefore

properly reflect the potential of each area to accommodate increased rates of growth. For

example, the potential of the Barwood Land sites at Raunds could increase households in East

Northamptonshire above the rate predicted in the 2011 projections.

2011 Projections 2008 projections

Total Total change in Average Percentage change in Average Percentage HHs 2011 HHs 2021 HHs Change change in HHs 2011 HHs 2021 HHs Change change in (000s) (000s) (000s) (000s) households (000s) (000s) (000s) (000s) househ olds

Corby 25 29 4 0 14 23 26 2 0 9

East Northamptonshire 36 39 4 0 11 36 42 5 1 15

Wellingborough 32 35 3 0 10 33 37 4 0 12

Kettering 40 45 5 1 13 40 46 6 1 15

Totals 133 149 16 2 47 133 150 17 2 50

18. The NNJPU takes as its starting point the 2011 projection of a 16,000 increase in households

between 2011 and 2021. However, sensitivity testing carried out by Edge Analytics in their

2011 Population and Household Paper considered the impact of potential underestimation of in-

migration and found that, adjusting for this, the potential increase in households could be

20,774.

19. What these differing assessments highlight is the need for this issue to be properly considered

through independent examination so that the correct housing requirement can be identified

having regard to all the available evidence.

20. Barwood Land therefore reiterates the point made in its previous representations that in

lowering housing trajectories to reflect current build rates, the JPU may inadvertently be

restricting the delivery of new housing through artificially low targets as the market inevitably

begins to recover. Moreover, such an approach is unreasonable on those developers who have

incurred cost in bringing forward land to meet the Core Strategy requirement and will also fail to

positively boost the supply of much needed housing in the process. This failure is directly

contrary to the Government’s often stated aim to boost this supply and to take every associated

opportunity to do so.

Conclusions

21. In summary, the Interim Policy Statement on housing requirements is contrary to the core policy

principles of the NPPF. It plans not to succeed and is completely at odds with the

Government’s agenda for growth and the NPPF key objective of boosting significantly the

supply of housing now. It makes unsubstantiated claims that the Core Strategy housing targets

cannot be delivered.

22. With regard to the 5 year supply calculations we see little point in commenting as they are

based on a dramatically reduced housing requirement that departs radically from adopted

housing requirements without any justification. It is clear that none of the authorities can

demonstrate a five year housing supply on the basis of the adopted Core Strategy housing

requirement.

23. The five year land supply calculations have no credence as they are based on artificially low

housing requirements and inflated estimates of supply.

24. In this context, Barwood Land cannot support any move away from the Core Strategy

requirement either in terms of housing numbers or the timescales for their delivery. Against the

Government’s restated intention to boost significantly new housing (partly supported by the New

Homes Bonus and Help to Buy), allowing local authorities the ability to artificially distort their five

year housing land supply will further weaken the ability of the development industry to meet the

demand for new housing.

25. Barwood Land therefore believes that no adjusting of housing targets should be effected before

the Core Strategy has been properly reviewed and tested through an independent and thorough

examination in accordance with the provisions of the NPPF and the duty to co-operate set out in

statute.

063 Harborough District Council

North Northamptonshire Joint Planning Unit Consultation Documents, October 2013 Interim Housing Policy Statement

Harborough District Council Officer Level Comments The need for the Interim Housing Policy Statement is clearly set out within the paper itself. Given the significant changes in housing market conditions since the adoption of the Core Strategy in 2008 and the East Midlands Regional Plan in 2009, together with changes in national policy and the revocation of the Regional Plan, the paper appears to be a pragmatic approach to dealing with 5 year housing land supply issues prior to the adoption of the replacement Joint Core Strategy. The proposal to continue with an urban-focused strategy, which identifies specific delivery opportunities through sustainable urban extensions is supported by Harborough District Council. Such an approach will serve to ensure that the necessary infrastructure required to support such development can be more readily delivered, thus lessening the potential for impact upon transport and other infrastructure within Harborough District. As part of the neighbouring Leicester and Leicestershire Housing Market Area, Harborough District Council clearly has an interest in the way in which the objectively assessed housing needs of North Northamptonshire are calculated and planned for. It is understood that the previous high levels of planned housing growth (as set out in the Regional Plan and Core Strategy) reflected a nationally planned re-distribution of future housing growth through the Milton Keynes and South Midlands Strategy. Given changing market conditions, the revocation of the Regional Plan and changes to national planning policy, it is understood that re-consideration of planned housing growth levels would be required. However, Harborough District Council has some concerns and queries about the methodology used to calculate the objectively assessed housing need within North Northamptonshire and the resulting figures, as set out in the Interim Housing Policy Statement. The date of the Statement suggests that the latest advice, contained within the National Planning Policy Guidance was not taken into account in calculating objectively assessed housing need. As such, it is suggested that a Strategic Housing Market Assessment (SHMA) should be carried out to take account of this latest guidance, to ensure that the resultant figure may be robustly defended at Examination. The specific queries / concerns are as follows: 1. 2011-based CLG Household Projections should be used as the starting point for objectively assessing housing need. However, from the brief description of the methodology, it is unclear the extent to which these projections have informed the assessment. As such, it is vital that the assessment is re-done to ensure adequate account is taken of the CLG 2011-based Household Projections;

2. The Statement explains that information from Councils’ housing registers indicate a backlog of unmet need for 1,700 homes. However, it is unclear from the description of the methodology whether future (as well as unmet past and present) affordable housing needs have been identified and factored into the objectively assessed need. Again, in line with the NPPG, this is a significant part of assessing future housing needs and should be carried out in line with the NPPG and NPPF, to ensure the final objectively assessed housing need is an accurate reflection of all future need;

3. The comparison between the objectively assessed housing need and historic delivery rates at para A21 and Figure 4 is potentially misleading. The chart seeks to demonstrate that future housing growth based on the objectively assessed need for 17,832 over the ten years to 2021 would demonstrate a significant boost to housing delivery required by NPPF when compared with previous rates of growth of an average of 15,200 per decade during 1991-2011. However, given the much lower rates of delivery during the first decade (1991 – 2001) and the significant passage of time and change in policy at the national, regional and local levels during this time, the inclusion of the 1991-2001 period in the comparison seems to be unjustified. A more useful comparison would be the average annual delivery rate from 2001-11 with the planned delivery rate from 20011-2021. NPPG guidance that previous rates of under performance should not be used to constrain objectively assessed need should be applied.

The Leicester and Leicestershire Strategic Housing Market Assessment is expected to commence shortly and report during Spring 2014. Harborough District Council wishes to reserve the right to add further observations on the North Northamptonshire objectively assed housing needs (as set out within the Statement) during the preparation and reporting of the Leicester and Leicestershire SHMA.

066 The Boughton Estate and Buccleuch Property

Document 1 - Revised Site Development Principles – Kettering North (Tracked Changes)

This doc ument sets out th e site develo pment pri nci ple s pro posed by th e Joi nt Pla nning Un it for th e develo pment of la nd at Ke tteri ng Nor th . In resp ons e to qu est io n D of th e ‘Consultatio n on Strategic Ho using and Employ ment Site’ doc ument , a number of al teratio ns are sugge st ed by The Est ate. These are incl uded as tracked change s with in th is doc ument . Doc ument 2 sets out th e revi sed site develo pment pri nci ple s, incorpora ting th e tracked change s set out with in th is doc ument .

E. Kettering North

4.32 Site descriptio n

The site is located on the no rth side of Kette ring. The A43 forms the southe rn extent of the allocated land whil st the no rthe rn boundary is de fined by woodland. North Kettering Busine ss Park is located di rectly to the west and is acce ss ed from the A6003 Kette ring to Co rby Road. The eastern bounda ry is de fined by a hedge beyond which lies Boughton Park. Kette ring North occupies an area of reclaimed qua rry land characte rised by grass land and woodland.

4.33 Proposed la nd us es and scale of development

Kette ring North total s approximately 88ha 75ha and provide s a majo r opportunity to exte nd the existin g Kette ring Busine ss Park, providing a high quality development which will include the provi sion of 45ha 40ha of land scaped pa rcels land for a mix of B1 (bu sine ss) , B2 (general indu strial ) and small scale B8 (di stribution ) uses together with up to 3 ha of land for lei sure development. Propo sal s will inco rpo rate exten sive woodland planting to further enhance the development and will provide for the exten sion of a ci rcula r walk to be implemented as part o f the p roposals for the Kette ring Bu sine ss Park.

4.34 Key objectives

The development should delive r:

• employment and training oppo rtunities which help to build a mo re dive rs e, dynamic and self-reliant economy;

• imp rovement s to the road net work made nece ssary by the development;

• opp or tunitie s for non-car ba sed travel th rough the provi sion of public transpo rt which is comme rcially sustainable in the long te rm; improved walking and cycli ng

connection s with the existing urban area; and on-site provi sion of ancillary facilitie s to serve the development;

• acce ss ible green in frastructu re which enhance s not only access to the count ryside but al so biodive rsity ass et s and recreational oppo rtunities;

• high quality land scape treatment to supplement the quality of the development; mitigate the impact on he ritage ass et s; enhance the setting of Boughton Hou se Registe red Park and Boughton Hou se; and en sure that the development is sati sf acto rily ass imilated into t he surr ounding count ryside;

• lo w carbon growth th rough the attainment of high standards of energy and water efficiency; renewable energy pr ovi sion; sustainable con struction; and recycling; and

• floo d mitigation mea sures.

4.35 Key const rai nts

The A43, which is a single carriage way with a 60mph speed limit and high traff ic flo ws , forms a signi ficant barrier to pedestrian s and cycli sts. To the south of thi s road there is an area of woodland which furthe r isolate s separates the site fr om the urban area of Kette ring. Whil st the re are public footpath link s into the residential area ac ross the woodland the routes may be perceived as isolated and intimidating. The adjoining Kettering North Busine ss Park is cu rrently served by exi sting bu s route s and opportunitie s to develop the se in order to serve the development mu st will be inve stigated. An ove rall strategy will therefore need to be ag reed and implemented to delive r a development that is well-connected to North Kette ring Busine ss Park, the to wn cent re and residential areas to the south of the A43 by sustainable means.

Follo wing the opening of the Co rby Link Road and its de signation as the prio rity route to Co rby and Stam ford, this section of the A43 will expe rience lo wer traffic flo ws and be do wng raded. Not with standing this, ho weve r, enhancement s to the highway net work within the vicinity of the site will be requi red whe re this is nece ss ary to mitigate the impact of the development. The A14 Kette ring Bypass Improvement (junction s 7 to 9) will add ress press ures on the mainline carriage way and slip roads but doe s not include material change s to the A14 junction s themselve s. The development may cont ribute to traffic queues on the app roaches to Junction 6 and 7 and this will require further ass ess ment and modelling, including the con side ration of any cumulative impacts from othe r employment and residential development in no rth Kette ring and south Corby. is, ho wever, likely to inc rea se traffic queues on the app roache s to junction 7 and thi s will requi re furthe r inve stigation, including con sideration of the cumulative im pact of Kette ring North and the Corby West urban exten sion.

Whil st the site is screened fr om the A43, the road represent s a potential sou rce of noi se pollution . tThe need for attenuation mea sures will the refore need to be inve stigated and, where nece ssary, agreed and implemented taking account of the occupation and use at the detailed stage, as well as the scheme layout.

Much of the woodland on the site and di rectly to the no rth is de signated as a Local Wildlife Site and forms an impo rtant featu re in the land scape. The woodland should be maintained and enhanced and should inco rpo rate areas of ne w planting. Other potentially impo rtant habitats and featu res include hedge rows and trees, areas of semi-imp roved grass land and dry ditches. Measures mu st be taken to safeguard and enhance the land scape, wildlife and rec reational value of the se ass et s whe re it i s app ropriate to do so.

In addition, the re i s a slight po ss ibility that great crested ne wts may utilise the site. An area o f wet flu sh located o ff-site but adjacent to the ea ste rn bounda ry at the no rthe rn end o f the site i s owned by the promote r and its value as a wetland habitat could the refore be enhanced, if app ropriate.

There is an up wards slope from the eastern boundary into the site. Thi s create s long di stance vie ws of the grade 1 listed Boughton Hou se and pa rts of the ass ociated registered park and garden along the Broad Walk Avenue (a tree-lined avenue which is a key featu re of Boughton Hou se Registe red Park) to the east. The re are al so glimp sed vie ws fr om the villages of Weekley and Warkton which both include a con servation area and a numbe r of li sted buildings. It will be vital to maintain the setting of the se asset s and detailed con sideration will the refore need to be given to the location and height of development and land scape structu re as pa rt of the maste rplan

To the east of the site sits the Grade 1 Listed Park and Garden of Boughton Hou se with long vie ws fr om the valley belo w along the Broad Walk Avenue (a tree lined avenue which is a key featu re of Boughton Hou se Registe red Park) to wards the site. The re are al so glimp sed vie ws fr om the villages of Weekley and Wa rkton which both include a conservation area and a numbe r of li sted buildings. It will be vital to maintain the setting of these ass et s and detailed con sideration will the refore need to be given to the location and height of development and land scape structu re as part of the maste rplan

The detailed app roach to the planting of ne w woodland and ne w avenues ha s been explo red with Engli sh Heritage and exciting oppo rtunities have been identi fied to mitigate the se impacts in ass ociation with the po sitioning and height of the development

4.36 Key infra st ructu re require ments

requi red prio r to the submi ss ion of any planning application in order to take account of the mo st up to date in formation on in frastructu re needs.

Key in frastructu re requi red to delive r the development will include the follo wing:

• structu ral land scaping and the pr ovi sion o f green infr astructu re;

• pedestrian/cycleway routes and public transpo rt p rovi sion;

• highway measures whe re nece ss ary to mitigate the impact of the development on the surrounding highway network;

• the exten sion of the ci rcula r walk planned as part of the development of the adjoining North Kette ring Busine ss Park;

• sustainable drainage system s to manage surf ace wate r;

• potable wate r, foul water, electricity and ga s supply networks; and

• othe r in frastructu re a s detailed in the Infr astructu re Delivery Plan.

• In addition, highway mitigation mea sures may be necess ary follo wing furthe r inve stigation into the likely im pact on the capacity of the A14 at junction 7.

4.37 Place sh aping re quire ments

Acce ss: The site could be immediately acce ss ed from the A6003 via the existing Kette ring Busine ss Park. As the site is develope d and pha sed it would benefit from an additional acce ss point fr om the A43 at a location central to the scheme. The site would, however, bene fit from an additional access point off the A43.

Key strategic link s to the surr ounding area : In order to encou rage a modal shi ft away from the car it will be ess ential to enhance connectivity with Kette ring. Completion of the Co rby Link Road will reduce traffic flo ws on the A43 to the south of Kette ring North and offer oppo rtunitie s to enhance cross ing condition s. In addition, the woodland area di rectly south of the A43 is in the owne rs hip of the site promote r and the oppo rtunity mu st the refore be taken to provide clear and safe cross ing facilitie s for pede strian s and cycli sts and improvement s to the existing link s th rough to the residential area to the south. In orde r to help reduce speed s, the oppo rtunity to provide built fronta ges to the A43 should be explo red. It is con sidered that a combination of the ne w acce ss junction and the vi sual presence of the development will help provide a calmed yet flo wing traffic solution.

St rategic land scaping and green infrastructu re: High quality strategic land scaping and green in fr astructu re mu st enhance the cha racter of the development and en sure that it is integrated into the surr ounding count ryside. The existing woodland areas and othe r impo rtant featu res and habitat s mu st be retained and enhanced, whe re app rop riate. Woodland creation and hedgerow planting will be requi red to create a green, access ible co rrido r which will pe rmeate the development; provide link s to the count ryside; act as a wildlife co rridor; include area s of formal and in formal recreation; inco rpo rate footpath s, cycleways and sustainable drainage in fr astructu re; and c reate link s towards Kette ring.

Heritage Ass et s: The Broad Walk Av enue (referr ed to above) frame s long di stance views from Boughton Hou se and the Registe red Park towards the ho rizon and the hedge row which forms the easte rn bounda ry of the development site. The views must be maintained, continuing the sen se of openness and the impress ion of a ‘vie w to in finity’. Propo sals should screen the development whil st avoiding the appea rance of overly den se woodland along the easte rn bou nda ry of the site. Histo rically an avenue c ross ed the Broad Walk Avenue at a right angle and the development provide s an impo rtant oppo rtunity to re-establi sh the line of this lo st tree-lined avenue along the ea ste rn edge of the site with strip s of grassed land eithe r side. Thi s app roach could al so mitigate any vi sual impact o f the development on the he ritage a ss et s at Weekley and Warkton. West of the lo st co rrido r a sub stantial area of woodland could furthe r serve to sepa rate ne w development from the sen sitive easte rn edge of the site wit h a grass ride extending westwards across this woodland area, continuing the long di stance vie ws along the Broad Walk Avenue with furthe r screening bet ween the edge of the avenue and propo sed development to the west.

Built fo rm: The woodland setting of the site should provide in spiration for the development of contem porary, innovative buildings. Example s might include the use of timbe r, green wall s and green roo fs. It will be ess ential to unde rtake a tree survey and en sure that the location of the se key ass et s is fully taken into account Iin de signing the site layout. Capitali sing on the vie ws of the land scape fr om within the buildings will provide a furthe r oppo rtunity to c reate an excellent place.

The location of services and facilities: The planning pe rmi ss ion for the adjoining North Kette ring Busine ss Park include s pro vi sion for mino r retail development togethe r with a hotel, pub/ restau rant and a health and fitne ss centre. The propo sal s for North Kette ring mu st the refore provide for convenient and safe route s for pedestrian s and cyclists to access the se facilitie s.

Renewable energy : The oppo rtunity to provide combined heat and po wer using the neighbouring estate woodland s should be fully explo red as pa rt of a strtategystrategy to minimise carbon emi ss ion s.

Delivery: Pr opo sal s will need to be in accordance with a detailed, agreed ma ste rplan which include s a pha sing scheme in order to en sure the delive ry of all of the in fr astructur e requi rement s.

4.38 Policy

La nd at Kett ering North , as defined on th e Policy Ma p, is alloca ted primarily for employ ment uses. The site will provi de for a wide ra nge of opp ortun itie s incl uding a minimum of 40 ha of B1 (business) , B2 (general indust ry) and small scale B8 (st orage and dist ri bution) toge ther with app roxi mately 3ha of lei sure (D 2) related develo pment . Develo pment must be compatible with a detaile d masterpla n for th e whole of th e site agree d with th e local plann ing auth ori ty.

Proposal s must incl ude:

a) ve hic ular acce ss at safe and co nve nie nt locatio ns alo ng th e A6003 (via th e exi st ing Ke ttering Bus iness Park) and A43 ;

b) infra st ructu re requ ired to mitiga te th e imp ac t of th e develo pment on th e su rro unding hig hway netw or k;

c) an integrated tra nspor t netw or k th at is foc us ed on wal king, cycli ng and excellent pub lic transpor t and provi des st ro ng, co nve nie nt , per mea ble and safe ro ut es th at co nn ect Kettering North to th e adjoi ning North Ketteri ng Bus iness Park, th e town cent re, areas to th e south of th e A43 and to th e neighbouri ng co unt ryside;

d) hig h qu ality la nds ca ping wh ich mitiga tes th e impact ca us ed by th e develo pment on th e setting of heritage ass ets to th e ea st and south-east and enhances th e setting of Bo ughton Hous e Regi st ered Park and Boughton Ho use;

e) a netw or k of hig h quality la ndsca ping and gree n inf ra st ructu re whic h integrates th e develo pment into th e co unt ryside and enh ances its character and its ecological and recrea tional value; and

f) oth er infra st ructu re re qu irements as set out in th e North North ampt onshire Infra st ructu re Delivery Pla n.

g) pro posal s must comply with all oth er releva nt policie s in th e Core Stra tegy and be pla nn ed and imple ment ed in a co mprehens ive way th at is li nked to th e delivery of key infra st ructu re.

Document 2 - Revised Site Development Principles – Kettering North (Including Tracked Changes)

E. Kettering North

4.32 Site descript io n

The site is located on the no rth side of Kette ring. The A43 forms the southe rn extent of the allocated land whil st the no rthe rn boundary is de fined by woodland. North Kettering Busine ss Park is located di rectly to the west and is acce ss ed from the A6003 Kettering to Co rby Road. The eastern bounda ry is de fined by a hedge beyond which lie s Boughton Park. Kette ring North occupies an area of reclaimed qua rry land characte rised by grass land and woodland.

4.33 Proposed la nd us es and scale of develo pment

Kette ring North total s app roximately 88ha and provide s a majo r oppo rtunity to extend the existing Kette ring Business Park, providing a high quality development which will include the provi sion of 45ha of land scaped parcels for a mix of B1 (bu sine ss) , B2 (general indu strial ) and small scale B8 (di stribution ) uses together with up to 3 ha of land for lei sur e development. Propo sal s will inco rpo rate exten sive woodland planting to furthe r enhance the development and will provide for the exten sion of a ci rcular walk to be implemented as pa rt of the propo sals for the Kettering Busine ss Park.

4.34 Key objectives

The development should delive r:

• employment and training oppo rtunities which help to build a mo re dive rs e, dynamic and self-reliant economy;

• imp rovement s to the road net work made nece ssary by the development;

• opp or tunitie s for non-car ba sed travel th rough the provi sion of public transpo rt which is comme rcially sustainable in the long te rm; improved walking and cycli ng connection s with the existing urban area; and on-site provi sion of ancillary facilitie s to serve the development;

• acce ss ible green in frastructu re which enhance s not only access to the count ryside but al so biodive rsity ass et s and recreational oppo rtunities;

• high quality land scape treatment to supplement the quality of the development; mitigate the impact on he ritage ass et s; enhance the setting of Boughton Hou se

Registe red Park and Boughton Hou se; and en sure that the development is sati sf acto rily ass imilated into the surr ounding count ryside;

• lo w carbon growth th rough the attainment of high standards of ene rgy and wate r efficiency; renewable energy pr ovi sion; sustainable con struction; and recycling; and

• floo d mitigation mea sures.

4.35 Key const rai nts

The A43, which is a single carriage way with a 60mph speed limit and high traff ic flo ws , cu rrently forms a signi ficant ba rr ie r to pedestrian s and cycli sts. To the south of thi s road there is an area of woodland which separate s the site from the urban area of Kette ring. Whilst the re are public footpath links into the residential area ac ross the woodland the route s may be pe rceived as isolated and intimidating. The adjoining Kette ring North Busine ss Park is cu rrently served by existing bu s routes and opportunitie s to develop the se in order to serve the development will be investigated. An overall strategy will the refore need to be agreed and implemented to deliver a development that is well-connected to North Kette ring Bu sine ss Park, the to wn cent re and residential a reas to the south o f the A43 by sustainable means.

Follo wing the opening of the Co rby Link Road and its de signation as the prio rity route to Co rby and Stam ford, this section of the A43 will expe rience lo wer traffic flo ws and be do wng raded. Not with standing this, ho weve r, enhancement s to the highway net work within the vicinity of the site will be requi red whe re this is nece ss ary to mitigate the impact of the development. The A14 Kette ring Bypass Improvement (junction s 7 to 9) will add ress press ures on the mainline carriage way and slip roads but doe s not include material change s to the A14 junction s themselve s. The development may cont ribute to traffic queues on the app roaches to Junction 6 and 7 and this will requi re furthe r ass ess ment and modelling, including the con side ration o f any cumulative impact s fr om othe r employment and residential development in no rth Kette ring and south Co rby.

Whil st the site is screened fr om the A43, the road represent s a potential sou rce of noi se pollution. The need for attenuation measures will the refore need to be inve stigated and, where necess ary, agreed taking account of the occupation and use at the detailed stage, as well a s, the scheme layout.

Much of the woodland on the site and di rectly to the no rth is de signated as a Local Wildlife Site and forms an important featu re in the land scape. The woodland should be maintained and enhanced and should inco rpo rate areas of ne w planting. Other potentially impo rtant habitats and featu res include hedge rows and trees, areas of semi-imp roved grass land and dry ditches. Measures mu st be taken to safegua rd and enhance the land scape, wildlife and rec reational value of the se ass et s whe re it i s app ropriate to do so.

To the east of the site sits the Gr ade 1 Listed Park and Garden of Boughton Hou se with lo ng vie ws fr om the valley belo w along the Broad Walk Avenue (a tree lined avenue which is a key featu re of Boughton Hou se Registe red Park) to wards the site. The re are al so glimp sed vie ws fr om the villages of Weekley and Warkton which both include a conservation area and a numbe r of li sted buildings. It will be vital to maintain the setting of these ass et s and detailed con sideration will the refore need to be given to the location and height of development and land scape structu re a s pa rt o f the maste rplan

The detailed app roach to the planting of ne w woodland and ne w avenues ha s been explo red with Engli sh Heritage and exciting oppo rtunities have been identi fied to mitigate the se impacts in a ss ociation with the po sitioning and height o f the development

4.36 Key infra st ructu re require ments

Development of the scale propo sed will requi re a range of in fr astructu re. Relevant providers and stakeholders have broadly indicated how and when the se facilitie s might be required and thi s in formation is set out in the Infr astructu re Delive ry Plan. Further discu ss ions will be requi red prio r to the submi ss ion of any planning application in order to take account of the mo st up to date in formation on in frastructu re needs.

Key in frastructu re requi red to delive r the development will include the follo wing:

• structu ral land scaping and the pr ovi sion o f green infr astructu re;

• pedestrian/cycleway routes and public transpo rt p rovi sion;

• highway measures whe re nece ss ary to mitigate the impact of the development on the surrounding highway network;

• the exten sion of the ci rcula r walk planned as part of the development of the adjoining North Kette ring Busine ss Park;

• sustainable drainage system s to manage surf ace wate r;

• potable wate r, foul water, electricity and ga s supply networks; and

• othe r in frastructu re as detailed in the Infr astructu re Delive ry Plan.

• In addition, highway mitigation mea sures may be necess ary follo wing furthe r inve stigation into the likely im pact on the capacity of the A14 at junction 7.

4.37 Place sh aping re quire ments

Acce ss: The site could be immediately acce ss ed from the A6003 via the existing Kette ring Busine ss Park. As the site is develope d and pha sed it would benefit from an additional access point fr om the A43 at a location cent ral to the scheme.

Key strategic link s to the surr ounding area : In order to encou rage a modal shi ft away from the car it will be ess ential to enhance connectivity with Kette ring. Completion of the Corby Link Road will reduce traffic flo ws on the A43 to the south of Kette ring North and offer oppo rtunitie s to enhance cross ing condition s. In addition, the woodland area di rectly south of the A43 is in the owners hip of the site promote r and the oppo rtunity mu st the refore be taken to provide clear and safe cross ing facilitie s for pede strian s and cycli sts and imp rovement s to the existing link s th rough to the residential area to the south. In orde r to help reduce speed s, the oppo rtunity to provide built fronta ges to the A43 should be explo red. It is con sidered that a combination of the ne w acce ss junction and the vi sual presence of the development will help p rovide a calmed yet flo wing traffic solution.

St rategic land scaping and green infrastructu re: High quality strategic land scaping and green in fr astructu re mu st enhance the cha racter of the development and en sure that it is integrated into the surr ounding count ryside. The existing woodland areas and othe r impo rtant featu res and habitat s mu st be retained and enhanced, whe re app rop riate. Woodland creation and hedgerow planting will be requi red to create a green, access ible co rrido r which will pe rmeate the development; provide link s to the count ryside; act as a wildli fe co rridor; include area s of formal and in formal recreation; inco rpo rate footpath s, cycleways and sustainable drainage in fr astructu re; and c reate link s towards Kettering.

Heritage Ass et s: The Broad Walk Av enue (referr ed to above) frame s long di stance views from Boughton Hou se and the Registe red Park towards the ho rizon and the hedge row which forms the easte rn bounda ry of the development site. The views must be maintained, continuing the sen se of openness and the imp ress ion of a ‘vie w to in finity’. Propo sal s should screen the development whil st avoiding the appea rance of overly den se woodland along the easte rn bou nda ry of the site. Histo rically an avenue c ross ed the Broad Walk Avenue at a right angle and the development provide s an impo rtant oppo rtunity to re-establi sh the line of this lo st tree-lined avenue along the ea ste rn edge of the site with strip s of grassed land eithe r side. Thi s app roach could al so mitigate any vi sual impact o f the development on the he ritage a ss et s at Weekley and Warkton. West of the lo st co rrido r a sub stantial area of woodland could furthe r serve to sepa rate ne w development from the sen sitive easte rn edge of the site with a grass ride extending westwards across this woodland area, continuing the long di stance vie ws along the Broad Walk Avenue with furthe r screening bet ween the edge of the avenue and propo sed development to the west.

Built fo rm: The woodland setting of the site should provide in spiration for the development of contempo rary, innovative buildings. It will be ess ential to unde rtake a tree survey and en sure that the location of the se key ass et s is fully taken into account in de signing the site layout. Capitali sing on the vie ws of the land scape fr om within the buildings will provide a furthe r opp ortunity to c reate an excellent place.

The location of services and facilities: The planning pe rmi ss ion for the adjoining North Kette ring Busine ss Park include s pro vi sion for mino r retail development togethe r with a hotel, pub/ restau rant and a health and fitne ss centre. The propo sal s for North Kette ring mu st the refore provide for convenient and safe route s for pede strian s and cyclists to access the se facilitie s.

Renewable energy : The oppo rtunity to provide combined heat and po wer using the neighbouring estate woodland s should be fully explo red as pa rt of a strategy to minimise carbon emi ss ion s.

4.38 Policy

La nd at Kett ering North , as defined on th e Policy Ma p, is alloca ted primarily for employ ment uses. The site will provi de for a wide ra nge of opp ortun itie s incl uding a minimum of 40 ha of B1 (business) , B2 (general indust ry) and small scale B8 (st orage and dist ri bution) toge ther with approxi mately 3ha of lei sure (D2) related develo pment . Develo pment must be compatible with a detaile d masterpla n for th e whole of th e site agree d with th e local plann ing auth ori ty.

Proposal s must incl ude:

a) ve hic ular acce ss at safe and co nve nie nt locatio ns alo ng th e A6003 (via th e exi st ing Ke tt ering Business Park) and A43 ;

b) infra st ructu re requ ired to mitiga te th e imp ac t of th e develo pment on th e su rro unding hig hway netw or k;

c) an integrated tra nspor t netw or k th at is foc us ed on wal king, cycli ng and excellent pub lic transpor t and provi des st rong, co nve nie nt , per meable and safe ro ut es th at co nn ect Kettering North to th e adjoi ning North Ketteri ng Bus iness Park, th e town cent re, areas to th e south of th e A43 and to th e neighbouri ng co unt ryside;

d) hig h qu ality la nds ca ping wh ic h mitiga tes th e impact ca us ed by th e develo pment on th e setting of heritage ass ets to th e ea st and south-east and enhances th e setting of Bo ughton Hous e Regi st ered Park and Boughton Ho use;

e) a netw or k of hig h quality la ndsca ping and gree n infra st ructu re whic h integrates th e develo pment into th e co unt ryside and enh ances its character and its ecological and recrea tional value; and

f) oth er infra st ructu re re qu irements as set out in th e North North ampt onshire Infra st ructu re Delivery Plan.

Dear Sirs

CONSULTATION ON STRATEGIC HOUSING AND EMPLOYMENT SITES - NORTH NORTHAMPTONSHIRE

REPRESENTATIONS ON BEHALF OF THE BOUGHTON ESTATE AND BUCCLEUCH PROPERTY – CORBY SOUTH EAST

The Boughton Estate and Buccleuch Property (The Estate) have a number of land interests within the North Northamptonshire Area, in particular, on land surrounding Kettering and Corby. As you will be aware, The Estate is actively promoting a number of sites for inclusion within the North Northamptonshire Core Strategy Review. One of these sites is at Corby South East which is being promoted, alongside Tata Steel, as a mixed use urban extension comprising of approximately 1,000 dwellings, 10ha of employment land, a primary school and local shopping provision.

In responding to this consultation, regard has been had to the questions set out within the ‘Consultation on Strategic Housing and Employment Sites’ document published in August 2013. On this basis, these representations have been structured around these questions.

1. Is the methodology for assessing strategic sites, explained in the updated Background Paper, appropriate? If not, what changes are required?

1.1 The Estate generally supports the methodology applied when assessing the strategic sites; however, it is imperative to ensure that there is consistency between the assessments for each site. In addition, the assessments should take account of all the available information, be based on robust evidence and recognise mitigation measures that sites can provide to deal with potential areas of concern.

1.2 Of particular concern is that sites are only being assessed against existing services, facilities and infrastructure provision. This fails to take account of new provision which would be provided as part of developments. This is more apparent in the case of larger sites where a greater level of new services, facilities and infrastructure will be

provided as part of the development. In the case of Corby South East, no regard has been given to the range of services and facilities that the site could provide which includes a new primary school, employment provision, bus links and local shopping provision.

2. Are the traffic light scores for sites in the updated Background Paper appropriate and is the information contained in the paper up-to-date? Please provide details of any evidence you consider warrants an amended score or changes to the text.

2.1 The Estate has made detailed comments in respect of the site’s assessment at the previous stage of consultation, however, the revised assessment makes no alterations to the site’s scores, or supporting text, despite the fact numerous technical reports, which contained up to date evidence, were submitted to the Joint Planning Unit (JPU) for consideration. This is particularly disappointing given that the JPU’s own Committee Report of the 25 July 2013 specifically states that one of the scoring categories (‘Proximity to Services’) should be altered to reflect the evidence that was submitted.

2.2 In comparison the Committee Report did consider the representations that were made by The Estate during the previous consultation period and indicated that the scoring for the ‘Proximity to Services’ category should be revised from ‘red’ to ‘amber’.

2.3 Notwithstanding the above, it is considered that greater regard should be given to the evidence that was submitted alongside the previous representations prepared in summer 2012 in support of the allocation of land at Corby South East.

3. Having regard to the evidence in the updated Background Paper, are the strategic sites listed in table 1 the most appropriate housing and employment sites to deliver sustainable development across North Northamptonshire alongside the existing committed sites? If not, please explain the reasons for this and identify any alternative sites that should be included in the JCS?

3.1 The Estate has a number of concerns over the allocation of land at Corby West for a sustainable mixed use urban extension which is to provide 4,000 dwellings over the plan period.

3.2 It is recognised that a broad direction of growth to the west of Corby was identified in the adopted Core Strategy in 2008. However, unlike the other sustainable urban extensions, this has so far failed to come forward for development.

3.3 Corby has understandable aspirations for growth; however, the JPU’s expectation that Corby West will deliver 4,000 dwellings over the plan period is considered to be unrealistic. Taking account of the timescales which are required to deliver a large urban extension, such as Corby West, it is considered that the site will not be completed by the end of the plan period, and as a result, the required level of housing will not be delivered.

3.4 This is supported by evidence contained with the 2011/2012 Annual Monitoring Report. This states that Corby West will not start delivering dwellings until 2018. In

addition, it is also concluded that only 300 dwellings in total will be provided by 2021. On this basis, the balance of the 4,000 dwellings will be required to be delivered in the following 10 year period, at an average of 370 dwellings per annum. This rate of delivery is considered to be unrealistic and unattainable. Based on delivery of large urban extensions within the area, it is considered that this figure is overstated by circa 120 dwellings per annum. As a result a large proportion of Corby’s housing requirement will not be delivered over the plan period.

3.5 In addition, Corby already has a large urban extension that is being progressed at Priors Hall. It is noted that development at Priors Hall has been very slow and figures obtained from Corby Borough Council indicate that only 159 dwellings have been completed at 1 April 2013, despite development on site commencing in 2010; an average of 53 dwellings per annum. This clearly demonstrates the difficulty in this area of getting large strategic urban extensions up and running and providing the level of development that is expected of them over the plan period.

3.6 In light of the above evidence, it will be important to provide for a range and variety of development opportunities to ensure that the requisite amount of development is delivered during the plan period. Based upon the current strategy, there is a real danger that Corby’s growth aspirations will not be deliverable due to the lack of progress of the larger sustainable urban extensions. Corby’s future aspirations for growth can best be provided by having a range of sites in terms of their size and location, rather than solely relying on the delivery of Corby West, which as highlighted above, is unrealistic. It is therefore considered that additional strategic sites should be allocated within the Core Strategy Review as it is only in so doing that it will be possible to achieve the completion of the number of dwellings required to meet the needs of this important Growth Town.

3.7 One such site that could fill this role is Corby South East, which was included on the shortlist of potential strategic sites. The Estate considers that land at Corby South East should be allocated in the Core Strategy to make up the expected shortfall in housing from Corby West.

3.8 It is considered that the development of Corby South East would deliver a high quality mixed use development incorporating a range of employment uses and residential dwellings in a sustainable and attractive location to the south east of Corby. Although the site is located within Kettering Borough its development will provide for the needs of Corby. Further, the site needs to be considered in the context of the Corby Link Road which is scheduled to be opened no later than spring 2014. Although beyond the remit of the Core Spatial Strategy, once the Corby Link Road has opened, it would make logical sense for the administrative boundary of Kettering and Corby to be realigned along the route of the Corby Link Road.

3.9 Pedestrian and cycle links will be created to promote sustainable travel and modes of transport. An existing single track bridge over the railway line could accommodate a cycle link, footpath and bus link facilitating access to Oakley Vale and connections to Little Stanion and beyond.

3.10 The site is located close to nearby facilities which are accessible by a range of transport modes, including within easy walking distance of services and facilities in

the neighbouring residential areas. The connectivity of the site will also be enhanced through bus links and additional foot and cycle paths. The development will establish informal and formal open space and provision will be made for a new primary school. The scheme will also enhance the landscape character by softening the impact of the Corby Link Road with development providing an attractive approach to Corby along the new link road, whilst providing new tree planting alongside it. Enhancement of the existing woodland to the north and green links across the site together with a high quality layout and building design will provide a well-connected quality south facing site.

3.11 The importance of delivery is understood and it is envisaged that the first houses could be occupied within the next 5 five years now the Corby Link Road nears completion.

3.12 In view of the above, it is considered that land at Corby South East should be allocated in the Core Spatial Strategy to compensate for the anticipated shortfall in housing delivery that is expected to occur at Corby West over the plan period, as indicated by Corby Borough Council’s evidence.

If there are any queries or aspects you would like to discuss, please do not hesitate to contact me.

Yours faithfully

Dear Sirs

DRAFT INTERIM POLICY STATEMENT ON HOUSING REQUIREMENTS IN THE NORTH NORTHAMPTONSHIRE HOUSING MARKET AREA

REPRESENTATIONS ON BEHALF OF THE BOUGHTON ESTATE AND BUCCLEUCH PROPERTY

As you are aware The Boughton Estate and Buccleuch Property (The Estate) have significant land holdings and potential development interests in both the urban and rural areas of North Northamptonshire. It is in this context that it has a particular interest in the housing requirements for North Northamptonshire and specifically Kettering Borough and its rural areas.

In recent years The Estate has taken every opportunity to comment on, and make representations to, each and every stage of the Core Strategy Review process; most recently as part of the consultation undertaken in August 2012. At this time, objections were raised to the emerging Core Strategy and specifically draft Policy 28 ‘Housing Requirements and Strategic Opportunities’ because of the inadequate provision for new housing being made and the approach to identifying the requirement against which housing supply was to be calculated; neither of which were considered to accord with national planning policy as set out in the NPPF.

It is recognised that the approach now being adopted by the Joint Planning Committee and its constituent authorities in the ‘Draft Interim Housing Policy Statement’ has changed. Even so, The Estate has fundamental concerns about the approach now being proposed which calculates the housing requirement (the demand ) for each Borough / District on a different basis to the provision set out within the adopted Core Strategy but distributes the amended provision (the supply) in the same proportions as before. For Kettering Borough, this means that whilst it has by far the highest requirement of the four planning authorities (33% of the total for the sub-region) its actual provision is only 25% of the total.

There are currently positive signs of improvement in the housing market which may, in part, be due to the introduction of various Government initiatives to assist first time buyers and others. In these circumstances, it is a matter of concern that if the full objectively assessed need for housing is not met, as

is clearly the case in Kettering Borough, and instead growth is artificially constrained, there will be a shortage of new homes which will have an adverse impact on affordability.

Existing policies and those which preceded them have had an urban centric focus which, in the opinion of the Estate, has been to the disadvantage of the rural areas and its villages. Insufficient homes have been provided in the rural areas which has resulted in ever increasing affordability problems for those with close connections to, or employment in, the locality and who wish to remain within the area. Declining household size inevitably results in falling populations and therefore fewer people to support the services and facilities which still exist, thereby creating a circle of decline. The Estate wishes to reverse this trend which would accord with Outcome 8 of the Emerging Core Strategy (“a proactive approach to meeting rural needs, supporting greater self-reliance for the area as a whole.”) However, it cannot do so in the context of severely constrained housing provision across the plan area, including the rural areas; a situation which is exacerbated by the number of outstanding housing commitments within and adjoining the urban areas.

The Estate acknowledges that it has major interests in two of these extensions; namely East Kettering and Westhill, where development has not yet commenced. However, now that the S106 Agreements have been reviewed and revised, The Estate is confident that construction on site will commence in 2014. These developments will meet the needs of the urban area and it is therefore essential for the focus to now shift to the rural areas. In this respect, it is a matter of particular concern to The Estate that neither the draft Interim Policy Statement, nor the North Northamptonshire Strategic Housing Market Assessment Update (August 2012), contain any reference to the needs of the rural areas, which exacerbates The Estate’s concerns that the needs of the rural areas are being overlooked.

Further, this approach does not reflect the more positive approach to rural housing contained within the NPPF where it states, inter alia, that:

• “local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs”; and

• “to promote sustainable development in rural areas housing should be located where it will enhance or maintain the vitality of rural communities.” (Paragraph 55)

Rural housing provision is also addressed in the recently published National Planning Practice Guidance under the question “Should local authorities apply blanket policies preventing housing development in rural areas?” In answering in the negative, it is stated that:

• “It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability and the role of housing in supporting the broader sustainability of villages and smaller settlements”; all points raised in the representations above.

• “A thriving rural community in a living , working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, public houses and places of worship. Affordable housing is essential to ensure viable use of these local facilities”. (My emphasis)

• “Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However, all settlements can play a role in delivering sustainable development – and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be

avoided unless their use can be supported by robust evidence”. (My emphasis) As no evidence has been produced, there is no justification for ignoring the rural areas; in fact, to do so would be contrary to existing and emerging national policy on this important issue.

The Estate has not produced its own evidence on the requirement for new housing in North Northamptonshire nor the amount which should be provided for in the rural areas. However, in order for the emerging housing requirement to be consistent with national policy, it is requested that the Joint Planning Committee investigates this important issue and that, having done so, an appropriate amount of new homes are specifically identified to meet the needs arising in the rural areas, its villages and other settlements (but not the small market towns, which should be dealt with as part of the urban housing requirement). This figure should then be ring fenced so that the needs of the rural area are not diverted and met elsewhere, namely within and adjoining the urban areas.

As indicated above, the SHMA does not address the needs of the rural areas. However, it does consider the demographic influences and drivers; those in respect of the elderly are particularly pertinent to the rural areas where this group frequently comprise a significant proportion of the total resident population. Consequently, the findings that the elderly are increasingly likely to be home owners and the least likely to move home does have a bearing on the need to provide for family accommodation in the rural areas to meet the needs of the younger generation, who are crucial if the services and facilities and, in particular, the schools, are to be retained and maintained.

In summary, it is essential the need for new homes in the rural areas is acknowledged and minimum requirements for new homes are provided for within the Interim Housing Policy Statement and the emerging Core Strategy. It is therefore requested, on behalf of The Estate, that such provision is made and ring fenced in the Core Strategy, as it is only in so doing that the new homes which the rural areas require will be built and occupied, rather than being diverted elsewhere to the social detriment of rural communities.

If there are any queries or aspects you would like to discuss, please do not hesitate to contact me.

Dear Sirs

CONSULTATION ON STRATEGIC HOUSING AND EMPLOYMENT SITES - NORTH NORTHAMPTONSHIRE

REPRESENTATIONS ON BEHALF OF THE BOUGHTON ESTATE AND BUCCLEUCH PROPERTY - KETTERING NORTH

The Boughton Estate and Buccleuch Property (The Estate) have a number of land interests within the North Northamptonshire Area, in particular, on land surrounding Kettering. As you will be aware, The Estate is actively promoting a number of sites for inclusion within both North Northamptonshire’s Core Strategy Review and Kettering Borough Council’s Site Specific Proposals Local Development Document. One of these sites is at Kettering North, which is a proposed “employment” allocation within the emerging Core Strategy Review.

1. Is the methodology for assessing strategic sites, explained in the updated Background Paper, appropriate? If not, what changes are required?

provided as part of the development. In the case of Kettering North, no regard has been given to the range of services and facilities that are in the process of being delivered, or have already been provided as part of the North Kettering Business Park (paragraph 2.10 below refers). This includes a new petrol filling station, coffee shop and convenience store alongside the existing services provided by the hotel and food retail outlet.

2.1 The Estate recognises that some of the comments made during the previous consultation stage have been taken into account as part of the updated assessment. However, it is considered there are still a number of scores which do not accurately reflect the proposed development. These are discussed individually below.

Impact on the use of previously developed land

2.2 Although the site is classified as greenfield, the majority of the site is reclaimed quarry and low quality grade 4 agricultural land. As a result, it is not considered high quality greenfield land and should be considered as quasi-greenfield taking account of the site’s previous use. It is considered appropriate to recognise this in the assessment process, and therefore, the site should be classified as ‘amber’ rather than ‘red’.

2.3 It is noted that site 43 ‘Kettering South’ is also classified as a greenfield site; however, the majority of this site is high quality grade 2 and 3 agricultural land. There is a clear distinction to be made between both sites; however, this is not reflected in the assessment process. As set out above, it is requested that the score for Kettering North is revised from ‘red’ to ‘amber’ to take account of the site specific circumstances and to make a clear distinction between sites that are on high quality agricultural land and those which are not.

‘Impact on visual landscape’ and ‘Impact on heritage, listed buildings, conservation areas, scheduled monuments and historic parks and gardens’

2.4 The Estate recognises the importance of conserving and protecting the setting of The Boughton House and Gardens, and the Conservation Areas of Weekley and Warkton. In view of this, detailed discussions have been held with English Heritage over the past year. The Estate and English Heritage have worked closely together to draw up a scheme that not only conserves the setting of the Historic Park and Gardens by providing landscape mitigation measures which screen the proposed development and minimises its impact, but also by re-establishing a long lost historical avenue along the eastern edge of the site. This will enhance an appreciation of the historic design of the wider parkland, enabling the restoration of a historical asset.

2.5 This work has culminated in the production of a ‘Built Heritage Report’ covering the approach to landscaping and the mitigation measures the scheme will provide to maintain the surrounding views. The report has the support of English Heritage and

was submitted to the Joint Planning Unit (JPU) in July 2013. A copy of the report is enclosed as part of these representations.

2.6 On this basis, it is disappointing to see that the revised assessment for the site makes no reference to the discussions with English Heritage, the agreed mitigation and enhancement measures or the technical work which has been submitted, despite the fact these are referred to in the site’s proposed development principles.

2.7 It is considered that the assessment categories should be reviewed to take account of the extensive work that has been undertaken between The Estate and English Heritage. In the context of the ‘impact on visual landscape’ category, it is clear from the ‘Built Heritage Assessment’ that as a result of the mitigation measures proposed, the development will have limited impact on the existing landscape and The Boughton House and Gardens. In view of this, it is considered that the scoring for this category should be revised from ‘red’ to ‘amber’.

Proximity to services

2.8 For an employment site to be scored ‘green’ in this category, it must be on a high frequency bus route (30 minutes or more) and have a local convenience shop nearby (walkable).

2.9 The JPU’s assessment clearly states that the X4 bus service provides a better than half hourly service and could serve the proposed development. Reference is also made to proposals being formulated for a convenience store at North Kettering Business Park, which adjoins the site.

2.10 These proposals have now been finalised and the convenience store, alongside a petrol filling station and coffee shop, are in the process of being constructed. This provides certainty that these facilities, which are in walking distance of the site, will be delivered and available to users of the new business park. Based on this, it is considered that the site meets both the elements of the criteria for scoring ‘green’. In view of this, it is requested that the scoring for this category is revised accordingly.

Connectivity to the existing urban area

2.11 The JPU has indicated that although the A43 will receive capacity benefits from the opening of the Corby Link Road, the development of the Weekley Warkton Avenue and new housing at Kettering East will result in additional traffic flows along the A43. As a result, the site is scored as ‘red’.

2.12 The Estate is currently working in partnership with Northamptonshire County Council in respect of the delivery of the Weekley Warkton Avenue. Potential government funding for the new link is being discussed and there is a strong political will for this to be brought forward in advance of the timescale set out as part of the development of Kettering East. As part of this proposal, a range of new footpath and cycle links could be provided, linking Kettering North with the existing urban area of Kettering, as well as the new development planned at Kettering East.

2.13 The existing north south footpath between Scott Road/Sports Academy and the woodland north of Brambleside can be connected to the pedestrian and cycle routes along the Weekley Warkton Avenue. This can be extended further northwards, crossing the A4300 (A43) using the new roundabout proposed to access the eastern part of the development at Kettering North. Not only will this provide the site with linkages to the south, it will also connect the site with the eastern urban edge of Kettering by connecting to footpath HE1, which if upgraded to cycle status, would connect to Cleveland Avenue and Rockingham Road, or Carriage Drive. This will provide an alternative walking route and cycling route to and from Kettering North. This is demonstrated on drawing number 25134-001-043, which is included as part of these representations.

2.14 Notwithstanding the above, it is also possible to provide safe and accessible crossing points across the A43, as existing, linking into existing footpaths to the south of the site, within Brambleside Woods. In view of the potential options set out above, it is considered appropriate to score the site as ‘amber’ rather than ‘red’.

2.15 Again, when Kettering North is compared to Kettering South, the differences in connectivity are not drawn out by the assessment process. As set out above, there are numerous opportunities to link Kettering North with the existing urban area, however, Kettering South is detached from Kettering by the A14 with very limited opportunities for pedestrian and cycle links to be provided between either Kettering or Burton Latimer. This is not reflected in the assessment process.

Access infrastructure

2.16 The assessment for Kettering North indicates that due to the site’s shape it would benefit from a secondary access point.

2.17 As set out in previous representations, the site could be accessed from a number of points including via the roundabout on the A6003 and through the existing North Kettering Business Park. Work has been undertaken by Peter Brett Associates in respect of the site’s access arrangements. As a result, it is proposed to include a second access point linking the development with the proposed Weekley Warkton Avenue. A traffic speed controlled roundabout will be provided in this location, as demonstrated by plans 21534-001-043 and 27568/001/001 Rev B, which are included as part of these representations. The location of this new access point will also provide excellent opportunities for additional pedestrian and cycle links, as discussed above.

3.1 The Estate strongly supports the allocation of Kettering North as a strategic employment site within the Core Strategy Review.

3.2 It is considered the development of this site would deliver a high quality business park which is in a sustainable and attractive location adjoining the existing built up area of Kettering. The scheme could incorporate a mix of employment uses, including B1, B2 and small scale B8. Part of the site will include the establishment of a technology ‘hub’ to attract higher value added commercial activities supporting the provision of more knowledge based enterprise. In addition to employment uses, the site could also provide a small amount of other uses, such as food and drink (A3) and leisure activities totalling approximately 3ha.

3.3 The development will also incorporate a range of leisure uses encouraging a healthy and active working lifestyle, whilst helping the area become a ‘destination’ for people within the region, all set in a campus style development in a woodland landscaped setting. The landscaped setting will be enhanced by the provision of woodland planting, along with mitigation measures to ensure that any impact on The Boughton House and Gardens is limited.

3.4 A range of footpaths and cycle ways will also be provided as part of the proposed development to encourage sustainable travel modes. This includes the extension of a 2.5km circular cycleway / footpath created as part of the North Kettering Business Park and improvements to connectivity between the site and the northern edge of Kettering to create an attractive and healthy working environment which seeks to attract knowledge – based enterprise.

3.5 The site can be accessed from a number of points including via the roundabout on the A6003 and through the existing North Kettering Business Park. However, a secondary access point will be provided towards the eastern end of the site. This will link into the Weekley Warkton Avenue and provide opportunities for the site to connect with the existing urban area of Kettering through the provision of new cycle and pedestrian links.

3.6 The site is considered deliverable and is in the single ownership of the Buccleuch Group which has a track record of delivering high quality developments across Kettering and the surrounding area, as demonstrated by the progress made in the delivery of the North Kettering Business Park. As set out within these representations, a coffee shop, convenience store and petrol filling station are soon to be completed and all available commercial units are let. In addition, Northamptonshire Police is currently preparing plans for a £6 million Police Investigation Centre which it is proposed to locate at North Kettering Business Park. Northamptonshire Police have indicated that a planning application for this facility will be submitted in September 2013 and it is considered the development could be completed in spring 2015.

3.7 The progress on North Kettering Business Park to date demonstrates there is a good market in this location and the delivery of high quality B1 and B2 uses on Kettering North is deliverable and viable. This has been demonstrated by the ‘Viability Statement’ which was submitted to the JPU in July 2013. The Estate has taken the opportunity to update this Statement and remains confident the site is deliverable.

3.8 In addition, the development of Kettering North is not dependent on major infrastructure work. It also benefits from being in close proximity to the existing North Kettering Business Park and has excellent transport links. Subject to gaining planning

permission, the site is available for development and by utilising existing infrastructure, has the ability to be brought forward in phases; the first of which could commence within five years.

3.9 In support of these representations a range of plans have been submitted (drawing numbers: 27568/001/001 Rev B, 27568/001/001 and 25134-001-043), alongside the ‘Built Heritage Report’ which was submitted to the JPU in the summer.

4. Do the key principles and draft policies address all of the key issues associated with the relevant strategic site? If not, please indicate why amendments are necessary and the form of the wording that would satisfy your concerns.

4.1 Comments have been made in respect of the key principles and draft policies for Kettering North. For ease of reference, these have been included as part of a standalone document using tracked changes.

If there are any queries or aspects you would like to discuss, please do not hesitate to contact me.