Emerging Draft Report of Responses

Settlements and Countryside Local Plan Part 2

n o i t a lt u s n o C ft Em ra erging D

Report of Responses Chapter Page Number

- General 1

Chapter 01 11

Chapter 02 30

Chapter 03 34

Chapter 04 54

Chapter 05 77

Chapter 06 153

Chapter 07 252

Chapter 08 283

Chapter 09 295

Chapter 10 357

Chapter 11 365

Appendix B 381

Habitats Regulation Assessment 381

HELAA 382

Map 386

Sustainability Appraisal 395

Daventry District Part 2 Settlements and Countryside Local Plan-Emerging Draft Responses

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED5 Hannah Lorna Bevins

Organisation: Representing: Amec Foster Wheeler National Grid

Support/Object:

Supporting Documents:

Comment:

National Grid has appointed Amec Foster Wheeler to review and respond to development plan consultations on its behalf. We have reviewed the above document and can confirm that National Grid has no comments to make in response to this consultation. National Grid is happy to provide advice and guidance to the Council concerning our networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development please do not hesitate to contact us. To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect our infrastructure.

12 March 2018 Page 1 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED73 Stacey Wylie

Organisation: Representing: Northamptonshire County Council Development Management Support/Object:

Supporting Documents:

Comment:

Northamptonshire County Council’s Development Management Team welcomes the opportunity to comment on the draft Daventry District Local Plan Part 2 (the draft Plan) through the current consultation, supporting the development of planning policy at the local level.

The County Council’s Plan for 2016-2021 sets out the vision of ‘Making Northamptonshire a great place to live and work’. Northamptonshire is the largest single growth area in England outside London, with a population of more than 700,000 and set to grow by 20% by 2025.

Education Infrastructure and Facilities 1. As the Local Education Authority for the county of Northamptonshire, the County Council has a statutory responsibility for ensuring the sufficiency of provision for all pupils of school age across Early Years, Primary, Secondary and Sixth-form Education.

2. It is the County Council’s role to plan, commission and organise school places in a way that promotes the raising of standards, manages supply and demand, and creates a diverse infrastructure. The County Council’s ‘School Organisation Plan 2016-2021 – Local Places for Local Children’ (SOP) provides the framework for meeting these objectives, providing accommodation for school places that is high quality, fit for purpose, provides value for money and ensures flexibility to respond to changes in need.

3. New housing development creates additional demand for existing and new education provision. Across Northamptonshire 80,000 additional new homes are expected to be built by 2031. These are likely to lead to approximately 24,000 additional primary aged pupils and 16,000 secondary and sixth form pupils.

4. Since 2010, the County Council has invested £230m in the schools estate in Northamptonshire; its Capital Strategy 2016-2021 identifies a further £400m of investment that is required to meet the anticipated demand for school places in the county and ensure that the County Council continues to meet its statutory obligations.

General comments on the draft Local Plan Part 2 Approach to Education 5. The County Council welcomes the approach adopted by Daventry District Council (DDC) in preparing the draft Plan, and positively supports the need for collaboration between local authorities and other partner organisations, to ensure that the ‘duty to co-operate’ obligation is met – particularly in relation to those areas of the district allocated for development within the Northampton Related Development Area (NRDA) and allocated strategic housing sites situated at Sustainable Urban Extensions (SUEs) as set out in the adopted West Northamptonshire Joint Core Strategy.

6. The Plan clearly establishes the national and local policy context in which it will operate; in particular the need for Local Plans to be positively prepared, to meet the tests of the National Planning Policy Framework and to align with other local plans and policies.

7. The County Council remains committed to working with DDC and partners at all stages of policy shaping to support the development and implementation of planning policy. The County Council therefore welcomes opportunities to engage with DDC to discuss these matters, and to guide the planning and development of new education facilities and infrastructure to meet the needs of proposed growth. This should at all stages be underpinned by the Council’s

12 March 2018 Page 2 of 399 own SOP, evidence base and strategic priorities, and informed by the ‘Planning for Schools Development (2011)’ joint policy document as prepared by the Secretary of State for Education and Secretary of State for Communities and Local Government, which sets out the Government’s commitments to planning and delivery of state-funded schools. Specific comments on the draft Local Plan Part 2

8. The below forms specific comments on selected policies in response to the current draft Plan. These comments are made in relation to the provisions of education facilities and infrastructure on behalf of the County Council, which will be necessary to ensure sustainable development principles are adhered to, and to meet the needs of planned for growth.

9. The County Council recognises that maintaining a sufficient land supply is critical to fulfilling obligations under national planning policy, and therefore notes that additional sites have been identified during the delivery of the draft Plan to ensure that long-term development can be planned for in the most sustainable locations. The County Council would welcome the opportunity to be engaged in all potential future site allocation discussions as early as possible, to consider the potential impact on local education infrastructure and examine how this translates to the need for additional education provision. This is equally important for small and large/strategic sites across both rural and urban areas and will help to provide clarity to developers, schools and local communities.

Additional comments Northampton Related Development Area (NRDA) 14. The County Council recognises the significant levels of housing growth forecast for the District during the plan period, and the potential shortfall in provision of dwellings within the Northampton Related Development Area (NRDA). Sites within the Daventry District that fall within the NRDA already form a large proportion of the housing growth expected to be delivered during the plan period. It is equally recognised however that much of the impact of this housing growth will be felt by neighbouring authorities of Northampton Borough and South Northamptonshire District. This is particularly the case of education infrastructure. As such, the County Council strongly emphasises the need for close collaboration between all the interested parties to ensure that capacity across these areas can be monitored and delivered, in order to meet the statutory obligations of the County Council to provide sufficiency of school places. This will be of particular importance should the need arise to consider additional sites to those already allocated in the WNJCS to meet the 5 tear housing supply requirements. Developer Contributions - CIL and S106

15. The introduction of the Community Infrastructure Levy (CIL) by SNC in April 2016 has fundamentally altered the way in which developer contributions are secured in the district. The County Council's own 'Creating Sustainable Communities: Planning Obligations Framework and Guidance - January 2015' document (and any subsequent update) sets out the adopted approach of the County Council to requesting and securing Section 106 obligations in respect of education infrastructure (amongst other area).

16. It is recommended that the current Daventry District Developer Contributions SPD (2013) be reviewed and updated to reflect the latest available evidence base, including updates to the County Council's pupil forecasting methodology, to ensure that there is sufficient clarity on the approach to securing developer contributions, including the relationship between Section 106 and CIL in supporting delivery of education infrastructure, signposting to the County Council's adopted policy where appropriate. Concluding comments

17. The County Council welcomes the development of the Daventry District draft Local Plan Part 2 and remains committed to working with Daventry District Council and other partners in relation to the sustainable delivery of schools provision, including: the Education, Funding and Skills Development Agency, Free Schools, Academy Trusts, existing schools, education providers, developers and local communities.

18. Continued engagement is welcomed with Daventry District Council, particularly as the draft Plan is progressed and as the County Council's adopted Planning Obligations Framework and Guidance (2015) document is updated. This will ensure that current priorities and policies of the County Council and DDC are aligned in relation to the planning and delivery of new education infrastructure and the ability to secure appropriate developer contributions through Section 106 and CIL to effectively mitigate the impact of development.

19. This collaborative approach will help to ensure that appropriate infrastructure is provided which will meet the demands of anticipated growth, creating new and expanded schools which will serve local children and be a focus for communities for the future.

12 March 2018 Page 3 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED128 Douglas McNab

Organisation: Representing: Education & Skills Funding Agency

Support/Object:

Supporting Documents:

Comment:

Developer Contributions and CIL 13. One of the tests of soundness is that a Local Plan is ‘effective’ i.e. the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. The ESFA note that Daventry District Council have adopted a Community Infrastructure Levy. The Regulation 123 list indicates that education provision, excluding primary schools, will be secured through CIL rather than s106 planning obligations. The Council has an Infrastructure and Developer Contributions SPD providing some guidance on education section 106 contributions, however this was adopted in October 2013 and predates the introduction of CIL.

14. The ESFA recommends that the next version of the Local Plan Part 2 include a commitment to revise the Developer Contributions SPD in line with the latest evidence of the district’s infrastructure needs, pupil yields and build costs (including the cost of school expansion, new build and SEN provision) and taking into account the relationship between S106 and CIL. Any such review should be prepared in consultation with the county council as local education authority, and have regard to the county council’s ‘Creating Sustainable Communities: Planning Obligations Framework and Guidance’ document January 2015 (or any update). This will help to ensure appropriate rates are levied and the right infrastructure is secured across the district.

15. The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan/Schedule or review of infrastructure requirements, which will inform any CIL review and/or amendments to the Regulation 123 list. As such, please add the ESFA to the database for future CIL consultations.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED161 Gillian Prince

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

N/A

12 March 2018 Page 4 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED42A Yvonne Dean

Organisation: Representing: Welford Parish Council

Support/Object:

Supporting Documents:

Comment:

5.0 It was felt there was ineffective public participation as a whole in reviewing the proposed Settlements and Countryside. This was due to a consultation which ran over the Christmas period, effectively losing 2 weeks out of the six stated. Poor publicity and very limited exhibition times in the village hall led to poor attendance. This jeopardises the integrity of the plan although we are broadly in agreement with it.

12 March 2018 Page 5 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General ED57 Andy D'Arcy

Organisation: Representing: South Northamptonshire Council

Support/Object:

Supporting Documents:

Comment:

Conclusion

As highlighted, there is a significant shortfall against the housing requirements of the NRDA. This shortfall leaves both DDC and SNC open to speculative development around the edge of Northampton. This position is unlikely to change unless criteria based policy approach is adopted which can flexibly respond to development. The approach of imposing a blanket 'green wedge' to the north of Northampton restricts options for future housing development, the delivery of critical infrastructure and could create the unsustainable patterns of development it is seeking to avoid.

The current reality we face in West Northamptonshire is that the housing requirements set out within the WNJCS for the NRDA are unlikely to be met within the short term without intervention. In order to ensure that development remains plan-led, it is considered the correct place to seek to address these issues is within the Part 2a Local Plans, under the DtC. This is not an issue where a decision can be delayed further.

SNC objects to the draft plan as it is currently drafted and considers that there is a failure to meet the DtC with regard to housing delivery within the NRDA. The preferred approach, which includes large blanket areas of Green Wedge, not positive prepared and could therefore be considered 'unsound' if not amended in future iterations of the plan.

The acknowledgement that delivery for the NRDA remains an ongoing matter for the DtC is welcomed and SNC remain committed to working proactively with its partners to identify 'sound' approaches to the current challenges. Through on-going partnership working the issues set out within this letter have the potential to be resolved before the plan is submitted for examination.

Notwithstanding the our reservations set out above, South Northamptonshire remains committed to working positively and proactively with its partners to deliver the homes and other development. I hope our comments on the consultation plan are clear and helpful. As always, should you have any questions, we would be happy to discuss these as part of our ongoing commitment to working positively and proactively.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General General ED18B Jane Austin

Organisation: Representing: Overstone Parish Council

Support/Object:

Supporting Documents:

Comment:

The Plan should be divided into two documents one for Daventry and one for the remainder of the district.

12 March 2018 Page 6 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General General ED122 Tim Cross

Organisation: Representing:

Support/Object: Support

Supporting Documents:

Comment:

Overall I consider this Draft plan a very impressive document with the sustainability aspect particularly well thought through. It has clearly had a large amount of work put in to it, well done.

12 March 2018 Page 7 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: - General Policies ENV3, RA1, RA2, ED57 Andy D'Arcy RA3, para 8.3.03

Organisation: Representing: South Northamptonshire Council

Support/Object: Object

Supporting Documents:

Comment:

The following comments are made on behalf of South Northamptonshire Council (SNC), as agreed by the Planning Policy and Regeneration Strategy Committee on the 23 January 2018 in response to the Daventry District Part 2a Local Plan (Reg 18) 'Settlements and Countryside Local Plan - Emerging Draft Consultation'.

SNC is generally supportive of the Draft Settlements and Countryside Local Plan and considers the Part 2 plans are an important component of the Development Framework, providing additional advice and clarity for a range of matters including the settlement hierarchy. Part 2a Local Plans are an important part of the framework for those seeking to promote development and for communities choosing to prepare Local Plans. These plans provide the opportunity to create a positive plan for the rural areas.

In light of the fact that the rural housing figures set out within policy S3 of the WNJCS have been met, SNC agree that it is not necessary for the Part 2a Plan to make extensive allocations for housing within the rural areas. These allocations could undermine the overall spatial strategy for the area. Notwithstanding, there is a need in accordance with the NPPF to provide a positive plan that will significantly boost the supply of housing. As a partner authority, SNC remains committed to working proactively with its neighbours and Northamptonshire County Council to deliver the spatial strategy for West Northamptonshire as part of the ongoing commitment to the Duty to Cooperate (DtC). A strong, positive working relationship across the area is crucial to meet the ongoing challenges of balancing the need for housing and continued economic growth with environmental protection and regard to social sustainability.

However, whilst SNC is broadly supportive of the emerging Daventry Countryside and Settlements Local Plan, it has fundamental concerns with the proposed approach to the NRDA, including the Green Wedge (ENV3: Green Wedge) and the associated infrastructure requirements. These concerns run to the heart of the plan and the DtC.

Duty to Cooperate - Housing Delivery The emerging plan and the DtC background paper (version 1 - November 2017) establishes that a number of strategic DtC matters have already been agreed through the WNJCS. This includes the scale and distribution of housing development (WNJCS Policy S1 and S3 respectively. However, it acknowledges (para 1.4.10) that delivery in the NRDA is 'ongoing'; SNC agree.

Delivery of homes for the NRDA has been slower than anticipated resulting in a significant delivery shortfall against identified housing needs. It is estimated that the 5YLS for the NRDA is somewhere in the region of 3 years. The exact position will be confirmed following the publication of the Joint Monitoring Report in early 2018. The reasons for the shortfall against projections are complex and are, by and large, outside the control of the partner authorities. Whilst many of the SUEs do now have consent (at least in outline), implementation and build out rates envisaged in the WNJCS are some way off. It remains unlikely that these sites will deliver at a rate that will address the shortfall within the short term. There is, therefore, a need to bring forward smaller sites that are able to deliver quickly and contribute to the current 5 year supply.

SNC acknowledges and welcome she recent report by NBC in respect of site identification within the urban area. The report indicates there could be sufficient sites to meet Northampton's needs over the plan period (e.g. to 2029). Meeting housing needs of the town within the urban area is considered a priority and is fully supported in order to help minimise the amount of greenfield development in accordance with the Objectives of the WNJCS. SNC has made specific comments in response to this report as part of NBC's consultation. Our response raised the following

12 March 2018 Page 8 of 399 matters: • The robustness of the methodology and approach to windfalls • The ability of the identified sites to deliver in the shorter term • That the report identifies further work is required to assess the suitability of the sites in further detail

Based on our assessment SNC considers sites within the borough boundary alone will not meet the housing shortfall. Therefore, there is a pressing need to take action to boost delivery, whilst also seeking to maximise opportunities to deliver the critical infrastructure identified within the WNJCS.

The SNC Local Plan Part 2 is seeking to address the issues of supply within the NRDA through the inclusion of a positive, criteria based policy that will allow limited development adjoining the NRDA until such time as the Part 1 Local Plan is reviewed or it is possible to demonstrate a 5YLS. DDC, as part of the DtC is urged to consider a similar approach.

SNC disagrees with the assertion made in the table (page 11) that the approach could "undermine" the plan-led system. To the contrary: the approach set out within the plan is considered a realistic, pragmatic and plan-led approach to managing development on the boundary of the NRDA. This approach is not a decision SNC has arrived at lightly and the decision to include such a policy within the plan has been arrived at following a thorough and realistic assessment of the situation, having regard to National Policy, emerging case law and appeal decisions.

Duty to Cooperate - Policy ENV3: Green Wedge The current consultation document appears to suggest the approach favoured for positively addressing issues of delivery within the NRDA by DDC is to impose a blanket restriction on development through Green Wedges on land to the north of Northampton.

SNC has not been party to the development of this approach, as evidenced in Appendix 1 of the DtC statement. The council also notes that the proposals map does not show the NRDA boundary or land required for the safeguarding of the northwest bypass/Northampton orbital route. It is considered that both these matters should be rectified in future versions of the plan as a matter of urgency.

As a neighbouring district, SNC shares the concerns of DDC with regard to the rural areas. It is clear under-delivery and the 5YLS position for the NRDA is leaving rural areas vulnerable to speculative development. However, a blanket restriction policy is not a positive approach and may have unintended consequences, not least directing development to areas beyond the 'protected' fringe to locations that are, by their nature, less sustainable. This will increase the length of car journeys, contributing to congestion and pollution. SNC consider it prudent to highlight the experience of other areas who have sought to introduce a comparable approach. In Cherwell, a 'green gap' policy was proposed in its Part 1 Plan in June 2014. This policy was subsequently removed as the Examiner (Mr Nigel Payne) who considered that there were sufficient policies in the plan and that a Green Buffer would introduce unnecessary constraint and was, therefore, unjustified.

Moreover, we now have the benefit of Supreme Court judgement (Suffolk Coastal District Council v Hopkins Homes Ltd Anor [2017] UKSC 37) in respect of Cheshire East. Whilst this judgement confirms that Green Wedges/Gaps are not policies for the supply of housing per se (a point that SNC and DDC have argued), they are 'restrictive' policies and the weight to be given is a matter of planning judgement. Lord Carnworth states at para 56: "Restrictive policies in the development plan (specific or not) are relevant, but their weight will need to be judged against the needs for development of different kinds (and housing in particular), subject where applicable to the "tilted balance".

In addition, Lord Gill adds at para 79: "Among the obvious constraints on housing development are development plan policies for the preservation of the greenbelt, and environmental and amenity policies and designations such as those referred to in footnote 9 of paragraph 14. The rigid enforcement of such policies may prevent a planning authority form meeting its requirement to provide a five years supply."

Given the context of Policy ENV5, it is considered a blanket policy with the principal aim of restricting development. This policy must be carefully reviewed to ensure it is flexible enough to allow some development that will meet Northampton's needs and to the emerging work on the Northampton Orbital/Relief Road. If this flexibility is not built

12 March 2018 Page 9 of 399 in, there is a risk that the plan and policy ENV5 could be out of date from the point of adoption. This runs counter to the very principle of preparing a plan for the rural areas.

Notwithstanding reservations with regard to the principle of the Green Wedge policy, SNC also has the following detailed observations:

• The Daventry Landscape Study builds on the earlier West Northamptonshire Landscape Sensitivity Study. This was a key part of the evidence base for identifying areas for the SUEs. It is important to recognise that ‘high’ sensitivity was not intended to preclude all development, rather it is intended to act as a signal that other mitigation may be required (such as a more sensitive design approach). • The Sensitivity Study was looking at sites of 5ha or more. There is a need in the Part 2a local plan to look at smaller parcels than were assessed as part of the original study. • Landscape evidence constitutes one dimension of the overall sustainability. Other considerations must be made to the social and economic sustainability when carrying out proposed designations. Some parts of the proposed ‘wedges’ may be more appropriate for sensitively designed, small scale development. This should be recognised. • No regard is had within the study to the route of the North-west bypass/Northampton Orbital. This will have a significant impact on the landscape character and quality around the north of Northampton and may mean that sites presently considered as medium sensitivity become more appropriate.

DtC - Connections We note the plan makes reference to the route of the Northern Bypass/Northampton Orbital Route. This is considered to be 'critical' infrastructure within the WNJCS. SNC is highly concerned by the statement at paragraph 8.3.03 of the consultation document which states: "The policies emerging in this plan will be relevant considerations for the determination of the most suitable route for the roads"

The extensive Green Wedge proposed to the north of Northampton has the potential to undermine the delivery of the route. This would render the WNJCS undeliverable given the number of units that are predicated on its delivery.

SNC would also draw attention to the preferred directions of growth of Northampton Borough Council to the north, in order to support the delivery of the route and provide additional sources of funding for its delivery. SNC would be interested to understand what regard has been had to the delivery of the route and the potential impact on connectivity around the north of the town when developing options for the Green Wedge.

DtC - Rural Housing We note and support the Plan's conclusions that the housing requirement has been met in the rural areas and that additional housing should only be permitted where it meets 'an identified local need' (Polices RA1, RA2 and RA3). It is suggested that further clarification is provided on this policy approach including for example whether this is for both market and affordable housing, what constitutes 'local' and indeed how a local need is to be established and by whom.

Conclusion As highlighted, there is a significant shortfall against the housing requirements of the NRDA. This shortfall leaves both DDC and SNC open to speculative development around the edge of Northampton. This position is unlikely to change unless criteria based policy approach is adopted which can flexibly respond to development. The approach of imposing a blanket 'green wedge' to the north of Northampton restricts options for future housing development, the delivery of critical infrastructure and could create the unsustainable patterns of development it is seeking to avoid.

12 March 2018 Page 10 of 399 The acknowledgement that delivery for the NRDA remains an ongoing matter for the DtC is welcomed and SNC remain committed to working proactively with its partners to identify 'sound' approaches to the current challenges. Through on-going partnership working the issues set out within this letter have the potential to be resolved before the plan is submitted for examination.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.1.01, 1.1.02 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object: Object

Supporting Documents:

Comment:

Badby Parish Council notes that policies R1 and H6 of the Joint Core Strategy will eventually be replaced by the Local Plan. While understanding the aim of providing more detailed policies appropriate to local interests, we are concerned that there could be cases where the new policies conflict with or do not fully cover the scope of R1 and H1. In such cases, we should wish to be assured that R1 and H1 would still apply and take precedence.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.1.03 ED14 Martin Bagshaw

Organisation: Representing: John Martin & Associates Maidwell Hall School

Support/Object: Object

Supporting Documents:

Comment:

The following representation is submitted on behalf of Maidwell Hall School, who welcome the opportunity as an education provider, local employer and landowner within and around the village of Maidwell to make the following representation on the Draft Local Plan (Part 2).

Paragraph 1.1.03 – Objection is raised to the stated intention that Policies R1 & H6 of the WNJCS will be superseded once the Local Plan Part 2 is adopted. Such an approach can only be considered to be appropriate in such circumstances where the proposed policy within the Local Plan Part 2 replicates and/or has the same intent as that of the strategic policies; however this is not the case with the relevant draft Policy RA3 - Other Villages which is considered to be far more restrictive than WNJCS Policy R1 (i-v) where those criteria relate to further new housing development where the proposed housing requirement has already been met in the rural areas.

12 March 2018 Page 11 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.1.03, Appendix E ED79E Paul Johnson

Organisation: Representing: Francis Jackson Homes

Support/Object: Object

Supporting Documents:

Comment:

As confirmed by Figure 1 (page 4), the Part 2 Local Plan (LP) sits under the adopted West Northants Joint Core Strategy (WNJCS). The Part 2 LP must be in general conformity with that adopted higher tier development plan, including Policy R1 as adopted.

We are therefore seriously question of the legality of the assertion in the above noted paragraphs and Appendix, that the proposed Part 2 Local Plan (a lower tier development plan) can revisit, refresh or supersede elements of the adopted WNJCS. This would neither seem lawful, nor in general conformity to it. Our view would be that the correct way to undertaken this would be via the WNJCS Review.

We therefore object to the wording and assertion of the LP as drafted. We cannot see how the LPA can ‘pick and choose’ elements of the adopted WNJCS, and look to superseded, evolve or move away from them as part of this process. This is tantamount to a re-writing or re-visiting of that higher tier development plan. The Part 2 Local Plan should instead look to be in general conformity with the WNJCS, including Policy R1, until such time as that policy is revoked or superseded in a Core Strategy review.

Moreover, this is compounded in this instance by the fact it is a joint core strategy that applies to 3 LPA’s areas. As the document is adopted and has due weight as part of the development plan in all of these areas – can 1 LPA now seek to move away from its requirements, whilst the others do not?

12 March 2018 Page 12 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.4.04 ED110 Gary Stephens

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

One of the key purposes of the Part 2 Local Plan is to support the delivery of the JCS, namely its Vision, Spatial Objectives and Policies.

Policy S3 of the JCS makes provision for additional dwellings in the plan area for the period 2011 to 2029, including specific provision for Daventry District which is split across three areas (namely Daventry Town, Daventry Rural Areas, and Northampton Related Development Area).

The Part 2 Plan Emerging Draft Consultation sets out the progress that is being made in relation to ensuring that the provision of additional dwellings is being met within Daventry Town and Daventry Rural Area, and further proposes additional allocations of land around Daventry Town to ensure the provision for those areas is met by 2029 (paragraph 6.1.09). Indeed, the Emerging Draft rightly proposes to allocate additional land over and above that required to provide some flexibility in the event that delivery stalls or is delayed. The extent of that over provision will need to be carefully monitored prior to submission of the Plan as the proposed trajectories for the existing and proposed allocations around Daventry are considered ambitious (see comments below on the Housing Background Paper).

However, the Emerging Draft does not clearly address the position within the Northampton Related Development Area (NRDA). Paragraph 1.4.04 states that this issue is explained more fully in the [Duty to Co-operate] Background Paper, which then cross-references to the Housing Implementation Strategy (HIS) for Daventry. However, progress made towards meeting the NRDA requirement is not addressed within the HIS.

Paragraph 1.4.04 goes on to state there has been issues around the delivery rate on sites within the NRDA, although applications have been submitted and therefore no policy response is necessary in this Plan. However, the paragraph concludes by stating this position will be kept under review. The evidence to support the statement that no policy response is necessary is not published by the Council. Therefore, it is not possible to comment on whether it is appropriate that this Plan does not make any provision to address any potential shortfall that may arise in delivery within the Northampton Related Development Area.

12 March 2018 Page 13 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.4.04 ED124A Val Coleby

Organisation: Representing: Berrys Vanderbilt Strategic Ltd

Support/Object: Object

Supporting Documents: Attached - site map and Northampton Fringe Inset Map with alterations

Comment:

We welcome the opportunity to submit representations on the Daventry Settlements and Countryside Local Plan Part 2 on behalf of Vanderbilt Strategic Ltd.

Our representation is specific to a site known as Overstone Farm (plan reference 1 refers). The site presents a unique set of circumstances which we consider the part 2 Local Plan has failed to address in a positive way as required by the NPPF 2012. Paragraph 157 of the NPPF requires local authorities when making Local Plans to, ‘crucially’…’plan positively for the development of the area to meet the objectives, principles and policies of the Framework.’ and ‘Be based on cooperation with neighbouring authorities and private sector organisations.’

In examining Local Plans the NPPF advises at paragraph 182 that it is the role of an independent inspector to assess whether the plan has been prepared in accordance with the Duty to Cooperate and whether it is sound. There are four tests to soundness; that a plan is positively prepared, justified, effective and consistent with national policy.

Positively prepared A key test to soundness is that a plan is positively prepared. In this regard the NPPF advises that – ‘the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.’

The site at Overstone Farm adjoins the Northampton Related Development Area (NRDA) on three sides. It is almost surrounded by the Northampton North Sustainable Urban Extension (NNSUE). The parcel of land was omitted from the NNSUE as it was unavailable at that time due to the land-owners wishes. However, the site is significantly impacted by the surrounding SUE and this is becoming recognisably evident as the SUE development is now appearing on the ground with significant highway infrastructure and highway realignment around the site. Since the original conception of the NNSUE in 2008 much has changed. The NNSUE was adopted as a strategic site with Daventry District Council area in the West Northants Joint Core Strategy (WNJCS) in 2014 and commenced development in 2016 with new highway infrastructure close to the site nearly complete. Also in the intervening period the site has become available with the sad death of the former land-owner. The site is now available and deliverable as a development site.

In our view, for the plan to be positively prepared the plan-makers should reassess the potential of the site as a development opportunity in the context of its position almost within the NNSUE and in its role of meeting ‘unmet requirements from neighbouring authorities’.

The Council’s Duty to Cooperate and Northampton Borough Council’s poor five year land supply are central to the soundness of the Part 2 Local Plan and the plan-makers must demonstrate that there has been a necessary cooperation between adjoining Local Authority areas on key issues.

At paragraph 1.4.04 of the emerging Part 2 Local Plan it is commented:- “The only duty to co-operate issue that needs to be resolved is the issue of housing delivery in the NRDA. This is explained more fully in the Background Paper, but in outline there have been potential issues around the rate of delivery on sites within the NRDA. However these sites are now progressing, with planning applications on each of the SUE’s in Daventry District that contribute towards meeting the NRDA requirement, and some completions on these sites, most notably North of Whitehills. Furthermore as set out in the consultation on a schedule of sites published by

12 March 2018 Page 14 of 399 the Borough in October 2017 there is sufficient sites to meet the Borough’s needs (outside of the NRDA). As the SUE’s start to progress and the Borough has sufficient sites within its boundary it is not considered that it requires a policy response in this plan. However it is important to keep this position under-review as further cooperation takes place to ensure that the WNJCS spatial strategy is delivered.”

We would agree that the issue to be addressed is the issue of housing delivery but disagree that there are ‘potential’ issues about the rate of delivery. These issues are very real and represent themselves as a very poor housing land supply for Northampton Borough which is failing to deliver housing for its community. The Borough’s housing supply is currently at 3.2 years and has failed to improve over time. Daventry Council suggest through the emerging Local Plan that housing supply should continue to be monitored and kept under review. However, in this regard the plan fails to plan positively to provide a response to the continuing housing shortfall for the Borough to which Daventry District must continue to play its part as it was required to do through the West Northamptonshire Joint Strategic Committee.

The approach taken by the Council through the emerging plan is not a positive one, rather a wait and see approach. However the emerging Local Plan provides an important opportunity to fully address the housing difficulties currently clearly evident and to ensure objectively assessed development needs are met in a cooperative and plan led approach.

It is also noted that the approach taken by South Northamptonshire Council is entirely at odds with the approach taken by Daventry District Council. South Northamptonshire Council (SNC) has recently closed a consultation on its draft Part 2 Local Plan wherein the plan proposes a draft policy to support the delivery of housing for Northampton Borough to meet the Borough’s housing need on sites within South Northamptonshire Council area adjoining the NRDA. SNC has provided a positive policy response to a cross-boundary issue of key significance which accords with the objectives of the NPPF, which seeks not only to meet housing requirements but to boost significantly the supply of housing. This is an approach that we would recommend to Daventry District Council in order to have a positively prepared and responsive plan. Our client’s site is ideally placed to help fulfil this housing need gap.

Hence we consider this site along with the site at Welford Road which has been allowed on appeal (for the sake of consistency) should be allocated as sites to help to meet Northampton Borough’s housing need.

Duty to Cooperate The duty to cooperate is embodied with the NPPF at paragraph 178 and within the Localism Act 2011. It is therefore a legal obligation on adjoining authorities to cooperate on matters of strategic importance, such as housing supply, and to demonstrate that such cooperation has been a part of plan-making for a continuous period.

As set out at paragraph 4.6 of the Council’s Duty to Cooperate background paper, “the issue of most significance relates to delivery of the housing requirements for the Northampton Related Development Area”.

In Northampton Borough Council’s response to the Duty to Cooperate process the Borough’s response states:- “ - NBC sites consultation confirms that capacity to meet Northampton Boroughs needs as set out in the WNJCS but difficulties with meeting Northampton Related Development Area(NRDA) requirement. NRDA sites progressing in Daventry District but at rate considerably slower than envisaged in the WNJCS - NBC don’t currently have a 5-year housing land supply”

The Borough consulted on a sites assessment in Autumn 2017 and this consultation has yet to determine whether all the sites identified are deliverable and deliverable within the WNJCS timeframe. In the meantime the Borough continues to fail to provide its residents with the necessary housing.

It is also of relevance that the Statutory Instrument that bound the partnership authorities together in the plan- making process that delivered the Joint Core Strategy has now been dissolved at the partner authorities request with effect from 1 January 2018. At paragraph 3.17 of the adopted WNJCS it is commented that, “Daventry District, Northampton Borough and South Northamptonshire Councils commit to undertaking a review of the West Northamptonshire Joint Core Strategy to a plan period end date of 2036 or such longer period as the Councils choose, with the aim of having an adopted plan in place by 2020.” The likelihood of having a joint strategic plan in place by 2020 is highly remote as the West Northants Joint Committee has been dissolved and the review of the plan has not yet commenced. The Part 2 Local Plans therefore offer the best and most appropriate means to address the unmet

12 March 2018 Page 15 of 399 housing need within the West Northants Housing Market Area through the plan led process and Daventry District Council should take the opportunity to deal with this key issue rather than ignore it.

Daventry District Council advises at paragraph 4.7 of the Duty to Cooperate Background Paper that it ‘remains committed to helping to ensure that Northampton’s needs can be met however this should be in a plan-led manner…’ this plan provides the ideal and timely opportunity for the Council to support the Borough’s housing needs in a plan-led manner.

Our client’s site, almost entirely within the NRDA being bounded by it on 3 sides, provides a logical completion of this area of development. Its identification for development would ensure the plan has been positively prepared and embraces the duty to cooperate. The site is a stand-alone site in development delivery terms, therefore it can come forward quickly and is not constrained by a phasing programme or by wider infrastructure provision associated with the neighbouring SUE. The site is a ‘quick win’ and has the ability to deliver housing development to support the Borough’s housing supply shortfall in the short term.

Justified To be sound the plan must be the most appropriate strategy. In the 1997 Local Plan the site at Overstone Farm and its surrounds are shown as Green Wedge and open countryside. With the advent of the Core Strategy the NRDA was created and the SUE allocated. Hence the Green Wedge and open countryside polices were no longer applicable to the SUE allocation.

With the emerging Part 2 Local Plan the Council has taken the opportunity to remove the Green Wedge designation from the Overstone Farm site which we support and is entirely logical. It follows that the site no longer serves a Green Wedge purpose with regard to the separation of settlements and is now disassociated from the wider open countryside by the surrounding development. This change in context is recognised through the removal of the Green Wedge and in our view its separation from the open countryside should equally be recognised.

The site includes a nucleus of buildings comprising the main former farmhouse, other former farm residence, barns now converted to office development and a range of other former agricultural buildings. The land is clearly no longer in agricultural use having been separated entirely from its agricultural hinterland which is now under development for housing and a local centre forming the North Northampton SUE which will in time deliver 3,500 dwellings.

The site is already partly developed with a variety of uses and is no longer agricultural in use or form and the group of buildings is set within a well-defined curtilage.

Of note is the appeal allowed at Welford Road, Northampton for 41 dwellings (reference APP/Y2810/W/15/3011449), a site within Daventry District area. In allowing the appeal the Inspector commented, “22. The Council stated at the hearing that development outside the NRDA boundary was not required because all of Northampton’s needs would be met within the defined NRDA boundary. However except for the SUEs, which are allocated and set out within the JCS, I do not have evidence to demonstrate that sufficient other sites have been identified to meet the NRDA’s housing needs. In addition it is agreed between the parties that Northampton Borough Council is not able to demonstrate a 5 year supply of deliverable housing sites within the NRDA. Instead there is a 4.87 year supply of housing land with a shortfall of 223 dwellings.” The appeal is dated 2015 and as can be seen the housing supply position has worsened since then from 4.87 years to 3.2 years for Northampton Borough.

The Inspector goes on to address the aims of the Core Strategy commenting that, “24. The overall vision and objectives of the JCS are to focus development within and around Northampton and the key towns within West Northamptonshire. The site directly adjoins the NRDA, with existing houses to the south and the NWSUE to the east. Furthermore the bypass is proposed to be constructed to the west and north of the appeal site.” Taking the above into account the Inspector concludes, “that the proposal would constitute development for the NRDA and would therefore be in compliance with JCS Policies S1 and S4. The development would not be in conflict with JCS Policy R1 which sets out the spatial strategy for rural areas, as the appeal site would be development for the NRDA. On this basis it would also accord with JCS Policy S10 which sets out sustainable development principles.”

The site at Overstone Farm bears a number of similarities to the Welford Road site, including its proximity to the NRDA and an SUE and its separation from the wider open countryside. The same conclusion can therefore be drawn, that the development of the site in principle would not be in conflict with the aims and objectives of the

12 March 2018 Page 16 of 399 adopted Core Strategy.

Whilst an appeal for 75 houses on the edge of the NRDA at Holly Lodge Drive (reference APP/Y2810/W/17/3178842) was dismissed, in this instance the site was not disassociated from the wider countryside and landscape and the inspector felt that the intrusion of development into the wider open landscape was in conflict with policy. Nevertheless, with regard to the principle of development the inspector commented, “I acknowledge that the proposal could contribute towards meeting housing need within the NRDA”.

The site at Overstone Farm is partly developed, virtually within an SUE that is currently being built out, it is separated from the wider open countryside beyond, adjoins the NRDA boundary on three sides and is proposed to be removed from the Green Wedge notation. In our view its continued designation as open countryside is not justified nor the most appropriate strategy for the site. The emerging plan has the opportunity to correct this anomaly through the plan led process.

Effective The third test of soundness is that a plan is effective which requires that the plan is deliverable over its period and based on effective joint working on cross-boundary strategic priorities. We have set out above our concerns regarding effective joint working and whether the outcomes from joint working are really addressing the unmet housing need in the housing market area as a strategic priority. In our view the issue is being entirely ineffectively addressed by the approach adopted by Daventry District Council.

As also set out above the site as a compact site with limited infrastructure requirements can easily be delivered within the plan period.

One of the key cross-boundary strategic priorities identified in the emerging plan at ‘Policy SP1 – Daventry District Spatial Strategy’ is, “To ensure a sustainable pattern of development to meet the overall spatial strategy of the West Northamptonshire Joint Core Strategy, sustainable development in Daventry District will be guided by the following spatial principles…… B. Assisting with the delivery of plan-led development to meet Northampton’s needs where it is identified that this cannot be accommodated within the Northampton Related Development Area.

The allocation of the site to support Northampton’s needs would be entirely compliant with part B of Policy SP1.

The emerging plan proposes sites to be allocated for development over and above those strategic sites identified in the Core Strategy. The Overstone Farm site is not a strategic site and its allocation for development would support the aims and objectives of the Core Strategy. The site is not of a scale to disrupt the delivery of allocated sites or jeopardize the strategy of the plan.

The emerging plan identifies four housing allocations for Daventry Town to support its growth to complement the strategic allocations of the JCS which provides a strategic allocation of 4,000 dwellings (2,600 to be delivered within the plan period). H01 – Daventry South West - minimum of 800 dwellings H02 – Micklewell Park – 180 dwellings H03 – Middlemore – 100 dwellings EC3 - Land to the North and West of Daventry town centre – 120 dwellings

Overall the plan allocates a further 1,100 dwellings over and above the strategic allocation of 2,600 to be delivered within the plan period to support the growth of Daventry.

A small allocation to support the growth of Northampton to allow it to meet its housing needs is not a strategic issue and can readily be accommodated in the emerging Part 2 plan. The Overstone Farm site would accommodate in the region of 100 dwellings.

Consistent with national policy The final test of soundness is related the plan process enabling the delivery of sustainable development. Sustainable development is defined in the NPPF as development that contributes to economic, social and environmental roles.

Development at Overstone Farm would support the growth of Northampton as the County town and the main centre for employment, housing, retail, leisure and services. With the new infrastructure associated with the NNSUE the

12 March 2018 Page 17 of 399 site will have excellent connectivity through a variety of modes of transport to Northampton town centre and its services and facilities. Furthermore the site adjoins the new local centre to be delivered as part of the SUE which will also provide a primary school. The school will be within walking distance of the site.

As a social role the development of the site for housing will provide housing to meet immediate needs and will create a high quality built form helping to secure the future of non-designated historic assets and create a cohesive sense of place around the focus of the new local centre.

In an environmental context the new landscape setting to be provided for the new housing development will support biodiversity. The highly sustainable location of the development will allow for accessibility to services and facilities by means other than the private car and journeys made by private cars will be shorter due to the proximity of Northampton centre for higher order services and facilities and an accessible and newly refurbished railway station for longer journeys.

Overall we consider the opportunities the site presents as a development site to support the unmet housing need in Northampton have been erroneously overlooked in the emerging plan. Whilst the Green Wedge designation has been rightly removed the site is not open countryside and its protection as such is unjustified in the context of immediate housing need.

We request that the site is allocated as an extension to the SUE and will be happy to work with the Council to agree a suitably worded policy similar to those included in the plan for housing development at Middlemore, Micklewell Park and Daventry South West.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.7.01, section 1.8 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object: Support

Supporting Documents:

Comment:

HPC support the Settlement and Countryside Local Plan (Part 2) for Daventry District. Broadly, the SCLPs emphasis on preserving open spaces, the historic environment and sustainable development is congruent with views expressed by HPC. However, in some instances the detailed information provided is incongruent with the development plans already imposed on Harlestone. The observations below relate to the impact this policy document has on Harlestone, seek clarity in some instances and urge the SCLP to extend the policy or guidance where appropriate.

Observations: Chapter 1: Introduction Section 1.7.01 states that only made NDPs are part of the statutory development plan. The Advice Note on Neighbourhood Planning and the Historic Environment (recently consultation ended 15th December) states that NDPs do not have to be ‘made’ to carry significant weight and consideration in planning decisions. While unmade plans may not be of statutory significance, it would be helpful to local councils with emerging NDPs if the SCLP specifically referenced the Advice Note on Neighbourhood Planning and the Historic Environment in this section and mirrored the status given to NDPs in the Advice Note.

Section 1.8 Presumption in Favour of Sustainable Development. HPC reluctantly, and with reservations regarding size and design of development, accept the necessity of large scale housing development the council would like to see this section explain what “sustainable” means. There should be greater specificity surrounding the nature of the services together with how and when those services are to be delivered.

12 March 2018 Page 18 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Para 1.7.05 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object: Object

Supporting Documents:

Comment:

Badby Parish Council is currently in the process of drafting its neighbourhood plan. It is clear from 1.7.05 (also elsewhere, e.g. 5.2.18/22/24) that 'made' neighbourhood plans will be adopted within the local plan, and that neighbourhood plans 'made' after the local plan is finalised must comply with the latter.

The situation is less clear with regard to neighbourhood plan, like ours, that will be made between now and the finalisation of the local plan. Our view is that where such neighbourhood plans have been through the interim consultation and inspection stages before the finalisation of the local plan, then those neighbourhood plans should prevail above the draft local plan. Clarification on this issue is requested.

12 March 2018 Page 19 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Policy NP1 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Land at Lilbourne Road, Yelvertoft, Northamptonshire on Behalf of Davidsons Developments Ltd

Thank you for the opportunity to comment on the consultation (Regulation 18) into the Emerging Draft Settlements and Countryside Local Plan (Part 2) for Daventry District (“Draft LPP2”) that runs from 27th November 2017 until 4:30pm on 26th January 2018. I write on behalf of Bidwells’ client, Davidsons Developments Ltd in response to the consultation.

I enclose with this response a Site Location Plan (Promap) of my client’s land interest at Land at Lilbourne Road, Yelvertoft, Northamptonshire and a Planning Promotional Document prepared in support of the site’s representation to the Draft LPP2. I also enclose a completed Response Form to the Draft LPP2 to be included in this representation.

We consider that the Draft LPP2 is not sound under the ‘test of soundness’ in paragraph 182 of the NPPF. The plan has not been positively prepared, it is not justified or effective and it is not consistent with the NPPF. The Draft LPP2 does not comply with the WNJCS as the plan is not based on co-operation with neighbouring authorities under paragraph 157 of the NPPF and the Council have not worked jointly and collaboratively with other bodies to meet development requirements which cannot wholly be met under paragraph 179 of the NPPF.

Where relevant, suggestions for changes to the Draft LPP2 to address the concerns in respect of soundness are identified in these representations. It is requested that the Council considers these representations, makes appropriate changes as identified in these representations and undertake a further consultation under Regulation 18. We note that South Northamptonshire Council (SNC) have objected to the Draft LPP2, details of which are available at SNC’s Planning Policy and Regeneration Strategy committee on 23rd January 2018. SNC note in their response that the Draft LPP2 does not accord with the WNJCS and fails to meet the Duty to Cooperate with regard to housing delivery.

Chapter 1: Introduction Policy NP1 – Community led planning and neighbourhood development planning Policy NP1 of the Draft LPP2 identifies criteria (limbs ‘i’ to ‘v’) for community led planning and neighbourhood development planning. Overall, we are supportive of the Council’s approach to encourage neighbourhood development planning in accordance with the Government’s aspirations and national planning policy.

Limb ‘iii’ of Policy NP1 states that “allocations (in Neighbourhood Development Plans) should comply with the criteria set out in the relevant settlement hierarchy policies of this Local Plan.” The criteria contained within the settlement hierarchy policies under the Draft LPP2 restrict residential development outside of village boundaries.

The National Planning Policy Framework (NPPF) states that neighbourhood plans will be able to shape and direct sustainable development in their area (paragraph 184). Therefore, local communities should be able to prepare Neighbourhood Development Plans that allocate housing growth outside of the village boundaries. Local communities should not be restricted to identifying development only within their village confines. We therefore object to this sentence under Policy NP1 and request that it is omitted from the policy.

In view of the above, we consider that part of Policy RA1 is unsound as the policy is inconsistent with national policy. Object to Policy NP1: The wording “allocations should comply with the criteria set out in the relevant settlement

12 March 2018 Page 20 of 399 hierarchy policies of this Local Plan” should be omitted from the policy.

12 March 2018 Page 21 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Policy NP1 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

1 INTRODUCTION 1.1 Background 1.1.1 This representation is made by Gladman Developments Limited (Gladman). Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure and has land interests in West Northamptonshire, including sites within Daventry District.

1.1.2 Gladman has considerable experience in the development industry across a number of sectors, including residential and employment development. From that experience, it understands the need for the planning system to provide local communities with the homes and jobs that are needed to ensure that residents have access to the homes and employment opportunities that are required to meet the future needs of the area and contribute towards sustainable economic development.

1.1.3 Gladman has been involved in contributing to the plan preparation process across the UK and through the submission of representations and participation at local plan public examinations. It is on the basis of that experience that these representations have been prepared.

1.2 Overview 1.2.1 The West Northamptonshire Joint Core Strategy (WNJCS) sets out the long-term vision and objectives for the boroughs of Northampton, Daventry and South Northamptonshire from 2011 until 2029, including setting a housing target for the urban and rural areas.

1.2.2 The emerging Settlements and Countryside Local Plan Part 2 for Daventry District (DLPP2) intends to build upon the policies of the WNJCS. On adoption, it is also expected to replace all of the remaining saved policies of the 1997 Daventry District Local Plan. This consultation relates to an emerging draft version of the DLPP2 and has been published for consultation under Regulation 18 from Monday 27th November 2017 until Friday 26th January 2018.

1.2.3 The consultation document also proposes to supersede elements of the adopted WNJCS. This would be limited to the geographical area of Daventry District and is intended to relate to the ‘Spatial Strategy for Rural Areas’ (set out within WNJCS Policy R1) and ‘Provision for Gypsies, Travellers and Travelling Showpeople’ (set out within WNJCS Policy H6).

1.3 Structure of Representations 1.3.1 These representations are structured to cover a number of key topic areas as well as the specific policy proposals contained within the consultation draft, namely: • The Housing White Paper, February 2017 • Duty to Cooperate • Sustainability Appraisal • Neighbourhood Plans • Presumption in Favour of Sustainable Development • Spatial Strategy • Development in Rural Areas • Settlement Hierarchy and Village Confines • Housing Mix

12 March 2018 Page 22 of 399 • Vibrant Economy • Built and Natural Environment • Community Facilities • Local Green Space

1.3.2 Gladman has a number of land interests in Daventry District, which are being promoted for inclusion within the local plan as residential site allocations: • Land at Holly Lodge Drive, Northampton • Land at New Street, Weedon • Land at Brington Road, Long Buckby

1.4 Plan Making 1.4.1 The Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard we submit that in order to prepare a sound plan it is fundamental that it is: • Positively Prepared – The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development. • Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base. • Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and • Consistent with National Policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2 FIXING OUR BROKEN HOUSING MARKET – WHITE PAPER FEBRUARY 2017 2.1 Overview 2.1.1 The Government is in no doubt that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today.

2.1.2 Average house prices are almost eight times average earnings which is an all-time record and soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation.

2.1.3 The reason for this crisis is that the country is simply not building enough homes and has not done so for far too long. The consensus is that we need at least 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.

2.1.4 Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that ‘the housing shortage isn’t a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.’

2.1.5 Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever-widening gap between the property haves and have-nots.

2.1.6 The challenge of increasing supply cannot be met by Government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities.

2.1.7 The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.

2.1.8 Local planning authorities have a responsibility to do all that they can to meet their housing requirements, and this allocations document represents an important policy tool to ensure local needs are met in full.

2.1.9 Plans should be reviewed regularly, and are likely to require updating in whole or in part at least every five

12 March 2018 Page 23 of 399 years. An authority will also need to update its plan if its existing housing target can no longer be justified against its objectively assessed housing requirement.

2.1.10 Policies in Local Plans should also allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector including opportunities for SME housebuilders to deliver much needed housing.

2.1.11 In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently find it hard to afford to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.

2.1.12 Finally, the Government has made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled people.

2.1.13 The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious about the provision of the right number of houses in the right places. Local plans therefore need to consider these policy intentions now in order to ensure that it fulfils the Government’s agenda and provides the homes that its local communities need.

2.1.14 More recently, in October 2017, the Prime Minister reaffirmed the Government’s commitment to addressing the broken housing market by bringing forward measures to boost home ownership and housing supply, stating: “I will dedicate my premiership to fixing this problem – to restoring hope. To renewing the British Dream for a new generation of people. And that means fixing our broken housing market.”

“For 30 or 40 years we simply haven’t built enough homes. As a result, prices have risen so much that the average home now costs almost 8 times average earnings. And that’s been a disaster for young people in particular.”

2.1.15 Furthermore, in a message to housebuilders, the Prime Minister indicated that: “We, the government, will make sure the land is available. We’ll make sure our young people have the skills you need. In return, you must do your duty to Britain and build the homes our country needs.’”

2.1.16 The Autumn Budget 2017 brought further details of the Government’s commitment to building a Britain that is ‘fit for the future’. A prominent feature of this is tackling the housing crisis, with housebuilding featuring prominently amongst the Chancellor’s announcements, indicating that: “The Government is determined to fix the broken housing market, and restore the dream of home ownership for a new generation.”

2.1.17 The affordability of housing for young people is a key challenge for the Government, and whilst it is recognised that there is no ‘single magic bullet’ to solve the housing crisis, the Government is actively seeking to tackle obstacles standing in the way of first-time buyers. The Government sees a ‘big step up’ in new house building as an important element in its strategy to address the acute affordability problem and has set a goal to build 300,000 homes a year by the mid-2020s.

2.1.18 The vital importance of housing to the economic success of our cities and regions is also highlighted in the Government’s “Industrial Strategy: building a Britain fit for the Future”, November 2017. This includes reference to the introduction of planning reforms that will ensure more land is available for housing, and that better use is made of underused land in our cities and towns. It also sets out the challenge to raise housing supply to 300,000 per year before the end of the current Parliament. The Government wants to support places with ambitious and innovative plans to build additional homes where they are needed, and those which will support wider economic growth. Furthermore, the Government wants to support greater collaboration between councils, a more strategic approach

12 March 2018 Page 24 of 399 to the planning of housing and infrastructure, more innovation and high quality design in new homes and the creation of the right conditions for new private investment.

3 LEGAL COMPLIANCE 3.1 Duty to Cooperate 3.1.1 The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan preparation. If a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.

3.1.2 Whilst Gladman recognises that the Duty to Cooperate is a process of ongoing engagement and collaboration1 as set out in the PPG, it is clear that it is intended to produce effective policies on cross-boundary strategic matters. In this regard, Daventry District Council must be able to demonstrate that it has engaged and worked with neighbouring authorities, alongside their existing joint working arrangements, to satisfactorily address cross boundary strategic issues. This is not simply an issue of consultation, but also a matter of effective cooperation.

3.1.3 It is noted that Daventry District Council intends to take the opportunity to move away from elements of the adopted WNJCS. This decision will need to be carefully managed in the context of the Duty to Cooperate and Sustainability Appraisal. Furthermore, the scope of this particular Development Plan Document will need to be clearly explained in order for any associated issues of legal compliance or soundness to be explored as the DLPP2 is further developed.

3.1.4 The Emerging Draft Consultation Document provides an overview on the duty-to-cooperate2 and makes reference to the issue of housing delivery. This is further explored through the Council’s Duty to Cooperate Background Paper. The Paper highlights a number of potentially significant cross boundary issues and it is therefore essential that these matters are further explored through effective joint working as the plan making process progresses. In particular, the Background Paper indicates that it is a key requirement for the DLPP2 is to ensure delivery of development. The Background Paper also confirms that concerns exist with regards to the ability of the West Northamptonshire authorities to deliver in full against the housing needs of the HMA as a whole. This is as a result of the Sustainable Urban Extensions that were allocated for the Northampton Related Development Area (NRDA) delivering at a slower rate than had been anticipated by the West Northamptonshire authorities at the time that the WNJCS was examined. This is a matter that must be thoroughly considered through the duty to cooperate and then addressed through policies that will ensure that effective part 2 local plans are put in place across the area that is covered by the WNJCS.

3.2 Sustainability Appraisal 3.2.1 In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act, policies set out in local plans must be subject to Sustainability Appraisal (SA). Incorporating the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004, SA is a systematic process that should be undertaken at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s proposals on sustainable development when judged against reasonable alternatives.

3.2.2 The DLPP2 must ensure that the results of the SA process clearly justify all policy choices, including the need to consider options for development and growth against ‘all reasonable alternatives’. The Council’s decision making and scoring should be robust, justified and transparent and should be undertaken through a comparative and equal assessment of each reasonable alternative. Too often the SA process flags up the negative aspects of development, whilst not fully considering the positive aspects which can be brought about through new opportunities for housing and employment generating development.

4 SETTLEMENTS AND COUNTRYSIDE LOCAL PLAN PART 2 4.1 NP1 – Community Led Neighbourhood Development Planning 4.1.1 Policy NP1 relates to the preparation of neighbourhood development plans (NDPs) in Daventry District. The intention of the Council to set out its role in assisting groups preparing NDPs within a policy of the local plan is to be welcomed. Whilst there is no requirement for communities to prepare NDPs, where they choose to do so, the inclusion of a related local plan policy provides the opportunity for the local planning authority to set out a proactive, positive and collaborative approach to working with qualifying bodies that wish to prepare them.

12 March 2018 Page 25 of 399 4.1.2 The inclusion of a policy relating to NDPs provides the opportunity for the local planning authority to support the preparation of positively framed NDPs within its area and enable them to contribute towards the delivery of sustainable development. It will also provide the opportunity for the local planning authority to align with the requirements of the Neighbourhood Planning Act 2017 (Commencement No 3) Regulations.

4.1.3 The clarification that is provided within NP1(ii) and Appendix F with regards to the strategic policies of the Local Plan is noted and has the potential to provide a greater degree of certainty to qualifying bodies on which policies their NDPs must be in general conformity with if they are to meet the related NDP basic condition.

4.1.4 The draft policy includes NP1(iii), which highlights that NDPs can provide for more development than set out in the WNJCS. This policy should however go further by making it clear to communities that all settlements can play a role in delivering sustainable development and that additional sites to those in a Local Plan can be included within NDPs where this is supported by evidence to demonstrate need above that identified within the Local Plan (V4 Planning Practice Guidance Paragraph: 044 Reference ID: 41-044-20160519) .

4.1.5 NP1(v) sets out that all neighbourhood plans should include proposals for monitoring and review. Recognition should also be given here to the need to provide sufficient flexibility within NDPs to ensure that development which is sustainable can come forward without delay in accordance with the presumption in favour of sustainable development.

4.1.6 The proposed policy should also be complemented by the Council’s Statement of Community Involvement (SCI), which should then be regularly updated so that it provides up-to-date guidance to groups seeking to prepare and implement NDPs. It is noted that the Council has developed content on its website to assist in this process and it is essential that this is maintained to ensure that any changes to guidance are reflected, particularly the emerging regulatory changes that following the publication of the Housing White Paper in February 2017 and the Neighbourhood Planning Act 2017.

4.2 Presumption in Favour of Sustainable Development 4.2.1 Section 1.8 of the Draft Plan relates to the Presumption in Favour of Sustainable Development and includes an explanation of the purpose of Paragraph 14 of the National Planning Policy Framework in a generalised fashion.

4.2.2 In bringing forward individual Part 2 Plans across West Northamptonshire, the local planning authorities of Daventry, South Northamptonshire and Northampton will need to ensure that the ‘Presumption in Favour of Sustainable Development’ continues to operate in accordance with WNJCS Policy SA. In particular, the policy approach taken forward by Part 2 Plan(s) should provide sufficient flexibility in order to enable the policies of the development plan as a whole to be positively responsive to changing circumstances during the plan period. It is therefore important that policies are included that support the delivery of development in sustainable locations to meet objectively assessed needs across the HMA in full over the whole plan period, whilst maintaining a rolling five year supply of housing land.

4.2.3 Gladman wish to raise a concern that the emerging DLPP2 appears to move away from the presumption in favour of sustainable development that is required by the Framework and Policy SA of the WNJCS.

4.2.4 The WNJCS is founded on a strategy that relies on the delivery of housing from several large scale urban extensions to Northampton and Daventry. Indeed, the baseline housing trajectory for the WNJCS relied upon early and sustained delivery from these strategic sites over the plan period to secure a rolling five year housing land supply.

4.2.5 The WNJCS makes clear that “Daventry District, Northampton Borough and South Northamptonshire Councils will work proactively to ensure planning is not a barrier to new development” (Para 5.4 WNJCS). However, as currently drafted, there is no mechanism included within the DLPP2 to provide the flexibility that is needed to enable a positive response to rapid change that is required by paragraph 14 of the Framework. Further flexibility is required to allow for development to be brought forward to meet housing needs without delay, for example to mitigate the impact of lower than expected delivery rates across the suite of large scale sites upon the overall housing trajectory. Whilst the DLPP2 provides a broad update on the progress of the SUEs (6 Paragraph 1.4.04, Daventry Settlements and Countryside Local Plan Part 2 (November 2017), in particular noting that planning applications have been

12 March 2018 Page 26 of 399 submitted for SUEs within Daventry District, a number of other issues must be taken into account such as the determination period for outline applications, legal agreements, reserved matters applications, discharge of pre commencement conditions, site preparation and the construction of site enabling infrastructure. The strategy is therefore inevitably susceptible to changes in circumstance that can occur in relation to the delivery of large scale and complex development proposals of this nature.

4.3 Vision and Objectives 4.3.1 The Plan includes a spatial portrait of the area which focuses on issues including the plan area, population, housing, the economy, transport and the environment. In relation to housing, it is important that the plan remains responsive to the needs of rural areas and careful consideration will therefore need to be given to the preparation of policies that enable a continual pipeline of sustainable development to come forward in these areas over the remaining 12 years of the plan period.

4.3.2 The WNJCS requirement for Daventry District’s rural areas of 2,360 is not expressed as a maximum figure. It is therefore important that an effective mechanism is included within the Plan to ensure that additional market and affordable housing can be supported in a manner that is responsive to needs in these areas. It will also be necessary to ensure that the Plan reflects the fact that development may not all be able to be accommodated within the current confines of a settlement and that opportunities exist for sustainable forms of development beyond the current settlement edge.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 Policy NP1 ED42A Yvonne Dean

Organisation: Representing: Welford Parish Council

Support/Object:

Supporting Documents:

Comment:

4.0 There should be a statement that no clauses in the Daventry plan should over rule and compromise 'made' local neighbourhood plans.

12 March 2018 Page 27 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 & 04 ED57 Andy D'Arcy

Organisation: Representing: South Northamptonshire Council

Support/Object:

Supporting Documents:

Comment:

Duty to Cooperate - Housing Delivery

The emerging plan and the DtC background paper (version 1 - November 2017) establishes that a number of strategic DtC matters have already been agreed through the WNJCS. This includes the scale and distribution of housing development (WNJCS Policy S1 and S3 respectively. However, it acknowledges (para 1.4.10) that delivery in the NRDA is 'ongoing'; SNC agree.

SNC acknowledges and welcome the recent report by NBC in respect of site identification within the urban area. The report indicates there could be sufficient sites to meet Northampton's needs over the plan period (e.g. to 2029). Meeting housing needs of the town within the urban area is considered a priority and is fully supported in order to help minimise the amount of greenfield development in accordance with the Objectives of the WNJCS. SNC has made specific comments in response to this report as part of NBC's consultation. Our response raised the following matters:

• The robustness of the methodology and approach to windfalls • The ability of the identified sites to deliver in the shorter term • That the report identifies further work is required to assess the suitability of the sites in further detail

12 March 2018 Page 28 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 01 & 05 Para 1.1.03, 1.1.04, policy ED105B Nigel Ozier RA1, RA5

Organisation: Representing: Aitchison Rafferty Brixworth Parish Council and Brixworth Neighbourhood Plan Steering Group Support/Object: Object

Supporting Documents: Attached - Landscape Statement

Comment:

I refer to the emerging draft Local Plan and enclose representations on behalf of Brixworth Parish Council and Brixworth Neighbourhood Plan Steering Group. These representations were endorsed by the Parish Council at its meeting held on 25 January 2018.

These representations are split into three parts; namely – 1. General representations on the form and content of the Emerging Draft Consultation document 2. Representations by the Steering Group setting out their comments and concerns in respect of the Landscape Study which forms part of the evidence base to the Local Plan 3. A critique and review of the landscape evidence base and objection to the revised Special Landscape Area Boundary as set out in the Local Plan

Policy RA1 It is considered that the emerging Local Plan is confusing in respect of Development in Rural Areas, the role of Policy R1 of the West Northamptonshire Joint Core Strategy and the subsequent weight applied to Policy RA1 (Primary Service Villages).

Paragraph 1.1.03 indicates that it is intended that Policy R1 and Policy H6 of the WNJCS will be superseded for the purposes of Daventry District, yet in paragraph 1.1.04 it confirms reference is still made to Policy R1 where appropriate, for example the header for each policy sets out which WNJCS policies it will help to deliver.

It is considered this is confusing and the weight given to Policy R1 of the WNJCS and Policy RA1 (Primary Services Villages) is not clear, particularly for decision making. Policy R1 of the WNJCS is clear about the framework for development whereas Policy RA1 as proposed, is vague and in our view, leaves the weight given to controlling development open and unclear.

This is further confusing where a settlement has a ‘made’ Neighbourhood Plan in that Policy R1 of the WNJCS makes specific reference to a Neighbourhood Plan whereas Policy RA1, as proposed, reverts back to requirements A to C in the policy potentially weakening the Neighbourhood Plan, which should carry significant weight being part of the Development Plan.

The confusion is also evident in paragraph 5.1.07 in that it is stated that once adopted, the Local Plan policies RA1 to RA5 will supersede Policy R1 of the WNJCS. This will not provide the clear policy position weakening the guidance on development in the WNJCS and the weight which should apply to the Neighbourhood Plan.

It is not unexpected that Brixworth would be identified as a Primary Service Village. However, while is was considered in the former Local Plan as a Limited Development Village, also the top classification for settlements, the role of Brixworth as a LDV is different to the role it should now have, given the significant development which recently has been approved and the pressure now evident on its services and sustainability.

We consider, therefore, that Policy R1 should not be superseded by Policy RA1. In addition, Policy RA1 should be reworded to strengthen control of development and to include the Neighbourhood Plan process as an important part of considering development.

12 March 2018 Page 29 of 399 The emerging Local Plan indicates that Policy R1 of the WNJCS will be superseded and yet sets out in paragraph 5.2.17 the requirements which are in Policy R1 to be considered in assessing development. As these would no longer be part of the policy, the requirements are weakened and it is considered less weight can be given. This would be unclear in assessing proposals.

Policy RA5 indicates that development in the open countryside will be restricted. However, the implication of Policy RA1 (B) and paragraph 5.2.17 indicate that development might be permitted. It is important, therefore, that attention is given to the importance attached to that open countryside outside the confines of the village. Reference needs to be made in Policy RA1 to this and to the continued protection of valued countryside outside the confines of the settlement.

Therefore, in summary, we object to Policy RA1 as proposed, and suggest that alterations are made to link it to Policy R1 of the WNJCS which remains valid. On the positive side, we support the proposed confines boundary as shown on the Inset Map for Brixworth.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 ED11 Stephen Lucas

Organisation: Representing: Lucas Land & Planning Redinvest Ltd.

Support/Object:

Supporting Documents: Map and photos attached

Comment:

Reference is made to the above consultation draft and we make the following observations on the emergent plan. We attach a plan showing an appropriate confines boundary at Manor Farm off Bull Inn Close Weedon Bec.

Chapter 2 Spatial Portrait Weedon Bec needs to be mentioned in the Spatial Portrait as it is one of the most important villages in the whole district. 1. Weedon Bec is one of the largest rural settlements in the district, with a significant and growing employment sector. The community acts as a rural service centre to its rural hinterland to the south east and south west of the district.

2. The settlement is already one of the most important rural employment locations in the rural area outside Daventry Town. Recognition of this should be noted.

3. In 2011 ONS figures showed 1300 persons working in Weedon Bec and there were planning approvals for some 14,260sqm of retail, workshop, office, museum and leisure uses within the village: this is therefore potentially a sub- regional employment centre within the district and indication of one of the most sustainable development locations in the whole district.

4. The location of Weedon Bec astride the A5 (T) and adjacent to the new A45 (T) bypass and main road link to Daventry Town from junction 16 of the M1 motorway make this location extremely important to the future economy of the whole district.

12 March 2018 Page 30 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 Para 2.2.01 ED98A ED98B Steve Harley

Organisation: Representing: Oxalis Planning Pedrix Ltd.

Support/Object:

Supporting Documents:

Comment:

Introduction 1.1 As a small, Northamptonshire based company with a direct and genuine interest in the continued success of the local economy, Pedrix welcomes the chance to comment on the emerging Draft Part 2 Local Plan for Daventry District.

1.2 Pedrix is promoting non-strategic employment site development in the District, and keen to help ensure that the Part 2 plan is sufficiently proactive and flexible in supporting and enabling investment in the continued sustainable growth of the local economy. The objections and suggestions included below are geared around our understanding of the stated objectives of the emerging Plan, and informed by our understanding of, and involvement in, the local economy.

Spatial Portrait 1.3 The Spatial Portrait gives an unhelpfully selective and partial overview of the District and overlooks or underplays a number of important, highly relevant, issues. For example, the portrait makes no reference to the net outflow of commuting from Daventry District to other local authority areas. The 2011 Census shows that, although overall the net difference between the flows into and out of the District to access work is not great, there are significant flows of Daventry District residents travelling to Northampton, South Northamptonshire, and Rugby Borough to access employment.

1.4 The spatial portrait at paragraph 2.5.04 acknowledges that data shows the vast majority (in excess of 46%) of journeys to work are taken by private car, considerably higher than the national average. In a an extensive and largely rural District this is not uncommon, but does raise questions about how to best respond through land-use and other policies to reduce the need to travel.

1.5 The references to ‘Economy’ focus on age structure, economic activity rates, and unemployment rates. No reference is made to the dynamic and multi-faceted economy of the area, nor the priority sectors and local ambitions for growth, and no reference is made at all to employment land supply issues. Given the significant shortage in non-strategic employment sites – as identified by the Council’s recently commissioned evidence base, and referred to in later sections of the Plan – it is surprising that there are no references at all to this key land-use planning and economic issue.

1.6 Pedrix objects to the selective approach taken, and suggest that the above weaknesses should be addressed by a more rounded and fuller depiction of some of the key issues (challenges and opportunities) facing the District.

1.7 Notwithstanding the above, the Spatial Portrait also contains some very important information which should directly inform subsequent sections of the emerging Part 2 Local Plan. For example, the important role of villages in Daventry District is clear with reference to the presence of as many as 78 villages. It is clear that the vast majority of the District’s growing population – somewhere in the region of 53,500 people – live in the villages or rural areas rather than in Daventry Town. Although Daventry is clearly the largest single urban area and the main centre of population, it’s clear that other settlements play a key role in accommodating the majority of people, and implicitly a significant proportion of the jobs and services located in the District. In this context, the explicit reference to several of the largest villages, including Brixworth, as “other main centres of population” is supported.

1.8 As expressed in later sections of this representation, it is unclear how successfully or fully this recognition then

12 March 2018 Page 31 of 399 translates into the proposed draft spatial strategy and policies regarding land allocations, and other development policies. The polycentric nature of the District, while described in brief and referred to in several parts of the emerging Plan, does not seem to have informed or influenced the spatial strategy in a direct way. Such an urban and socio-economic geography presents a number of development, environmental, and economic challenges and opportunities in Daventry District which the Part 2 Local Plan should identify more clearly, and respond to more proactively and positively.

1.9 The NPPF requires positive planning, and in testing the soundness of the Plan the Inspector will be assessing the extent to which the Plan represents the most sustainable strategy, with regard to the policies of the NPPF. Some of the core principles at paragraph 19 of the NPPF include (emphasis added): • Local Plans should “set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth”; • Planning should “proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth.” • “Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking into account the needs of the residential and business communities”. “actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable”.

1.10 It is clear that the draft Plan should be amended to ensure it does more to respond more positively and more fully to these national planning policies – as set out in the following sections of this representation, as drafted it is unsound in terms of not being ‘positively prepared’, or ‘justified’ as the most appropriate strategy.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 Para 2.5.03 ED33 Cliff Cooper

Organisation: Representing: Crick Parish Council

Support/Object:

Supporting Documents:

Comment:

This further Consultation document has largely taken on board the matters which the Crick Parish Council put forward in its response to the first Consultation on Part 2a last year.

In relation to this new Consultation document, the comments the Crick Parish Council wish to make concerning its village and its surrounding area are as follows: - 2.5.03 This continues to refer to ’good access to bus services’ for the named villages. Whilst this may be true of other of the named villages, it is not true of Crick. There is no service to Daventry and the 96 service between Rugby and Northampton is an hourly service but effectively runs only in business hours and therefore does not provide any access to either Rugby or Northampton for social, leisure or cultural activities, leaving such access as only available by car. The 96 service is subsidised by Northampton County Council and it has indicated that such subsidies will be reviewed in their current financial problems. Therefore, this analysis of public service availability needs to be reviewed and, in reality all the rural communities continue to rely predominately on the car for transport.

12 March 2018 Page 32 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 Para 2.6 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object: Support

Supporting Documents:

Comment:

We note and support the general description of the rural built and natural environment. This statement and the retention of the features described should underlie implementation of all policies.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 Paras 2.2.02, 2.4.01, 3.1.02 ED38 Frances Albury

Organisation: Representing: Lamport and Hanging Houghton Parish Council

Support/Object: Support

Supporting Documents:

Comment:

The age group 55 and over is not catered for in any category, housing being a good example where there is a lack of provision for retirees who may wish to downsize but remain in the parish. Interestingly this was mentioned at our meeting with the Maidwell team who are making just such a proposal in their Neighbourhood Plan.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 02 Section 2.4 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 2.4 fails to recognise the very significant differences between the rural and urban economies and demographic present throughout Daventry District. HPC believe that planning decisions would be better informed if a distinction was made.

12 March 2018 Page 33 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 ED22A Calum Morris

Organisation: Representing: Greenvolt Development

Support/Object: Object

Supporting Documents: Site promotion document attached

Comment:

Land to the South of Boughton Road, Moulton Park, NN2 8RE Greenvolt Development wish to make representation regarding the ongoing public consultation of the Settlements and Countryside Local Plan (Part 2) for Daventry District. Following review of the draft plan and associated supplementary documents, we are concerned to note that that the plan does appear to fully meet the vision in which it seeks to achieve. Whilst it is accepted that the plan delivers a strategy for today, the lack of safeguarding land for future development is evident, and it is evident that there is a lack of cohesion with the approved West Northamptonshire Joint Core Strategy Local Plan (Part 1) 2014, (WNJCS) and Northampton County Council.

Firstly, we are concerned to note the exclusion of Site 318 - land to the south of Boughton Road, Moulton Park as a future housing allocation which was promoted by written representation through and the lack of reference and inclusion within the draft plan to the proposed Northampton Northern Orbital Route. Although the site was not promoted through the initial 'call for sites' stage of the development plan review, a late representation submitted on 12 January 2017 to Daventry District Council following initial pre-application discussions with council officers (Appendix 1).

Being located adjacent to the proposed Northampton Northern Orbital Route, the site holds potential for future sustainable growth within the area and we believe that the site excellent has prospects to help safely deliver and act as a secure long term housing site, meeting the needs of Daventry District's future housing demand.

We are also concerned to note that the draft plan does not allocate the land in which the proposed Northampton Northern Orbital Route for future development, and instead proposes an ENV3 Green Wedge allocation. It is our opinion that to help support the future of the District, allow successful and purposeful development; the land associated with the proposed Northampton Northern Orbital Route should be included within the emerging plan and safeguarding for logical and purposeful future growth of Daventry District.

Site 318 - Land South of Boughton Road, Moulton Park The site is located adjacent to the industrial estate of Moulton Park, which lies within the Northampton Related Development Area (NRDA). However, the site is also positioned adjacent to the NRDA, and within the Daventry District. The site forms part of a wider land holding and is bound by Boughton Road to the north, Boughton Lane and the NRDA boundary to the south, and the proposed Northampton Northern Orbital Route to the east - as detailed on the attached plan.

Central Northampton is approximately 5.2km to the south, and central Kingsthorpe is approximately 2.6km to the south. The large village of Moulton is 1.3km to the east, the village of Boughton is 1.2km to the west, and Pitsford is 2.7km to the north. Boughton Lane bounds the site to the south, and adjoins Boughton Green Road and then the A508, which connects the site to central Northampton.

There is an abundance of nearby services and employment opportunities. The site is adjacent to the industrial estate at Moulton Park. The nearby village of Moulton contains bus services to Northampton, a sports centre, a secondary school, a further education college, several churches, pubs, cafes, a special education needs school, a primary school, restaurants, a theatre, a small supermarket, a pharmacy, several small shops, a library, a working men's club, a garden centre, a vet, a post office and a petrol station. The nearby village of Boughton contains a primary school and church.

12 March 2018 Page 34 of 399 The villages of Moulton and Boughton are within cycling distance of the site. The site is also adjacent to the Greater Northampton area, and close to the M5 motorway which extends south to London.

The proposed development would be delivered as a phased scheme, with potential for up to 650 units which would to be delivered over a number of years. Within the planned layout, there is the opportunity to incorporate areas of open spaces and provide a networks system that easily links with the existing services within the nearby villages at Moulton and Boughton, and with Northampton. There is also the option to develop commercial road-side facilities tied into the proposed orbital route. With all current options of the new proposed Northampton Northern Orbital Route running directly through the site, the development would provide an ideal opportunity to link in with this infrastructure proposal, providing a logical long-term expansion of Northampton whereby the phased development of the site would help to reduce infrastructure costs and help to provide greater certainty for future development.

Given the strong merits of the site, its location on the edge of the existing development boundary and potential future connection with the proposed Orbital Route, we consider it to be of great value to the future requirements of the District and therefore believe it should be included within the emerging plan.

Housing Site 318 - Land South of Boughton Road Policy S3 of the WNJCS sets out that between 2011 and 2029, 12,730 should be delivered within the District. The 2017 Housing Land Availability Report as issued on 1st April 2017 identifies that the District since 2011, either matched or exceeded the identified supply requirement, and has a current housing land supply of 6.13 years.

NPPF however states that other 'deliverable sites' without allocation or planning permission can be considered capable of being delivered within a five year time frame provided that there are no significant constraints to be overcome. The NPPF states that to be considered 'deliverable' sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that the site is viable. Sites with planning permission should be considered deliverable unless there is clear evidence that the schemes will not be implemented within five years.

Whilst it is accepted that the current 5 year housing land supply within Daventry District has been met and that the site at Moulton Park is unlikely to be fully delivered within the 5-year period as set out within NPPF, we consider the merits of the site, should the Northampton Northern Orbital Route be approved be of considerable strength to justify the inclusion of the site within the emerging plan.

The development of this site, although allocated within the draft plan as 'Green Wedge' sits to the immediate north of Moulton Park, an area identified as being within the Northampton Related Development Area. The site benefits from minimal constraints and as such, could easily comply with the overarching policies set out within the draft plan, proving it to be suitable and achievable. Being located on the edge of the existing settlement, the site accords with the criteria set out in Policy HO6 - Rural Exception sites, which we are pleased to see mirrors the aims of Policy H3 set out within the WNJCS, allowing the appropriate form and scale of housing to be delivered adjacent to built up areas.

Although the site would be reliant on successful delivery of the Northern Orbital Route as detailed below, we oppose to the rejection of this site given the significant contribution it holds towards the long term future of the District's housing supply requirement. The location of this site forms a logical and obvious option for future residential development within Daventry District and as such the land should be allocated this status.

Northampton Northern Orbital Route The proposed new Northern Orbital route has been planned to support the growth proposals to the north and west of Northampton where some 10,000 new homes are to be built at sites such as Dallington Grange, Buckton Fields and Northampton North. The road is expected to create capacity for future development beyond that already planned.

Northampton County Council state that 'the delivery of this ring road to the north of Northampton will reduce the amount of traffic passing through northern parts of Northampton, and a number of surrounding villages such as Boughton, Moulton and Pitsford. The road will also create a new route for traffic heading for the Moulton Park industrial estate.'

12 March 2018 Page 35 of 399 The Northampton Northern Orbital Route has recently been under examination and went through a consultation exercise to identify the most suitable route, ending 4th August 2017. The consultation identified 4 possible routes and subsequently following public comments, two alternatives were considered. The report was planned to go to the county council's cabinet meeting in November 2017 to recommend a preferred route for the scheme will now be taken early in 2018.

Following the decision on the preferred route, further work will be needed to design the new road and gain the necessary powers and funding before construction can commence.

Given the work and consideration towards this proposal undertake thus far, it appears that the council are determined to make this project happen, and although no date for completion is available, the evidence base behind the projects suggests that the new orbital route is crucial to meet the demand of current developments as well as to support the pressures from future proposals.

With this in mind, it is difficult to understand why almost no consideration project features within the draft local plan. Paragraph 8.3.03 of the plan states that given the lack of detail regarding the route, the plan cannot do anything at this stage other than to refer to the project.

With a number of options set out of by Northampton County Council, all of which detail the necessary land requirements, we that these should be identified within the forthcoming local plan to safeguard land for future expansion. Without an appropriate allocation, as it stands, ENV3 Green Wedge fails to account for any future infrastructure proposals, such as the Orbital Route, and therefore would make such a proposal contrary to the plan. This could be a huge restriction in allowing deliverable and sustainable growth within the urban fringes, which contravenes the areas identified as Sustainable Urban Expansion sites set out within Policy S4 of the WNJCS.

Within the 'Vision' as set out within Chapter 3 of the draft plan, it states that new development and successful and expanded economies will flourish in the future. Objective 2 - Infrastructure and Development of the vision seeks to protect and enhance existing local services and to ensure social, physical and green infrastructure is adequately provided to meet the needs of people and business in a timely and sustainable manner in response to regeneration and new development. Without appropriate planning at this stage, the potential of this vision will be limited, with loss of 'Green Wedge' to be expected in few years to come.

Conclusion The draft plan does not take into account the wider issues facing the medium-to-long term future of the District and fails to identify and protect assets which have the opportunity to address and deliver these. The Vision set out within Chapter the draft plan seeks to the transform the District to form an outstanding UK location of choice for diverse employment opportunities, high academic and vocational education attainment, high quality housing for all and a superb quality of life for its communities. Without a long term, forward thinking strategy, working collaboratively with the neighbouring authorities, it will become increasingly difficult to successfully deliver the necessary housing and infrastructure requirements needed to support a successful vision.

Should the plan be adopted as proposed, we believe that the future of the land to the north of Moulton Park is being put at risk. Evidence demonstrates that this area of land to be a natural and logical expansion area to meet the infrastructure, housing and economic demands of the area of the mid to long term, which Daventry District Council need to deliver to help achieve the vision of this plan. As such, we would consider it coherent to allocate this land as such, allowing a natural pattern of sustainable and achievable development to be successfully delivered in future years.

12 March 2018 Page 36 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 ED40 Sue Halkett

Organisation: Representing: Weedon Bec Parish Council

Support/Object:

Supporting Documents:

Comment:

Weedon Bec Parish Council has a number of concerns about the proposals put forward in the current draft Settlements and Countryside Local Plan. The Vision (p18, 3.1.2) is so far from what is ever likely to be achieved within Daventry town and District, bearing in mind the present national economic and legislative situation.

For example, it is difficult to see how Objective 3, reducing the need to travel, can be met given the proposal to impose tight rural confines boundaries which do not allow for the expansion of employment opportunities in village. In Weedon it is likely that our local post office will close during the period of the plan and although some services are currently available at Flore, service hours have been reduced and the facility is also scheduled for closure. The result will be that a combined population of about 4,500 people, many of them elderly will have to travel to Daventry or Northampton to access a post office.

The draft plan aspires to shorten journeys and facilitate access to jobs and services. Weedon is designated a Primary Service Village on the assumption that it will continue to provide a 'range of services and facilities to meet the day to day needs of their own residents and those of surrounding villages and settlements'. The plan states further that it is important to ensure that that role is protected but offers no suggestions about how the District Council will support the continuance of local convenience services like post offices in primary service villages.

Small businesses, with people working from home, are becoming increasingly popular in villages and many of these need access to post office services. The options of using Daventry and Northampton will generate more vehicle traffic and require more town centre parking. It is observable that post office customers often choose to use rural post offices rather than incur the cost of petrol and parking and counter queues which are such a regular feature of the Daventry office.

It is evident from the plan that the District Council is desperate to raise the level of housing development in Daventry Town which is way below the requirements of the Joint Core Strategy. It has chosen to do this by restricting opportunities for development in the larger rural settlements. Primary service villages are not likely to be able to sustain services to meet 'day to day requirements' if entrepreneurs and retailers are denied an expanding local convenience market. In Weedon, since the original scoping exercise for the plan took place, we have seen the closure of the local green grocer and there are question marks over the long-term future of Tesco and any convenience retail on the A45, once the DDL is in place. It appears to us that the District Council is happy to see a decline in the economy of village in the hope that Daventry town will flourish. The nearest post office in Daventry gives no incentive to travel there on the chance of an opportunist shop. Given the slack retail market Daventry, is most unlikely ever to be able to compete with the already flourishing and rapidly expanding options at Sixfields, Northampton and Elliots Field, Rugby.

Although the plan allows for development on exception sites in rural areas if a high proportion of affordable housing is included, it is unlikely that developers are going to find that an attractive proposition. In Weedon development opportunities are now shut down by the village confines boundary and the imposition of Conservation Area. The likelihood is that within the duration of the plan Weedon will become a large centre of population but with few sustainable services and therefore will hardly qualify as a Primary Service Village. There is however no provision within the life of the plan to review the designation or for initiatives to maintain services.

Bearing in mind the emphasis on concentrating development and services in Daventry town, we are surprised we cannot find any mention in the plan of future proposals for the bus station in Daventry. This is a concern to village

12 March 2018 Page 37 of 399 residents who, in the absence of a post office and having a static and ageing population leading to a probable decline of the village retail offering, will need to make more journeys into Daventry. The present organisation of the bus interchange is not good from any prospective and give a depressingly poor impression of the town.

On a separate topic, Weedon residents have repeatedly expressed concerns about the safety of the traveller family site on the A5. We note that the plan does not propose any expansion of this site and hope that this views holds (p64 para 6.2.27) because access tot his site is dangerous. Traffic often exceeds speed limits on this section of the A5, there are multiple junctions and there was a serious accident in the past 2 months. The vision splay to the site is poor to non-existence and vehicle and caravan exiting must do so very slowly at risk of 'bottoming out' because of the steep incline; as a result, traffic is blocked across the width of the A5. The Parish Council raised this issue when planning permission was retrospectively applied for but it seeks to have been ignored by both yourselves and Highways England.

In Chapter 10 (p116 et sequi) your plan rightly stresses the importance of healthy living being supported by a varied and good provision of recreation facilities. You will be aware, we trust, that Weedon village is below average for the provision of sports and recreation facilities for all ages. In comparison with other Primary Service Villages in the District, Weedon is very badly off. The proposal to impose a village confines boundary removes any opportunity there might be to negotiate with local landowners to acquire additional flat land for sports provision or to encourage landowners to offer land because enabling development of a suitable high value would, under the current plan, not be permitted. This leads us to further question whether it is appropriate to designate Weedon a Primary Service Village. Our neighbours Flore have much better provision but they are a bus/car drive aware which is no use to families with young children. It seems somewhat discriminatory that the standards set within the plan for Daventry Town are not deemed necessary for Primary Service village communities.

Overall the rhetoric of improvement and aspirations for vibrant communities expressed within the plan is not born out by the reality of the plan's content. Shutting down the possibility of development in rural areas is a restrictive and negative intervention in the housing market. It is unlikely to encourage developers to flock to Daventry town which is not amenable to the sort of high value/quality properties they prefer. No high value properties will mean reduced council tax/Cil to support town centre improvements. Furthermore, restricting development in Primary Service Villages will mean that shops and facilities become unsustainable and any possibility of betterment shut down. Point 10.0.01 highlights the considerable importance of sustainable community services in 'all village in the district' but offers no positive initiatives or help for improvement or development. While the scrutiny of regulations such as change of use is desirable, it exemplifies the negativity of this plan which offers nothing positive for the betterment of village life, as it focuses all its energies on promoting the interests of Daventry town over that of rural areas.

12 March 2018 Page 38 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Chapter 3 Objectives ED68A Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object:

Supporting Documents:

Comment:

SPC were disappointed to see that a more robust approach has not been taken in relation to the policy development of Daventry Town in the area of retail and leisure. Over the last 40 years the town has gradually declined with many villagers commenting that it ‘use to be very easy to get to Daventry (Staverton had an hourly bus service which has been cut to one a day) and there was a wealth of choice in relation to the retail and leisure offer”. Disappointingly, Staverton has witnessed the closure of the open air pool, pitch and put course, cinema, and many shops. The recent opening of BM’s in Daventry has demonstrated how retail can rejuvenate an area, evidenced by the fact what was once an often empty car park you now struggle to find a place to park in. Of more concern is that over the last ten/twenty years there has supposedly been a Daventry Masterplan/Vision which has promised a better offer in the Town which has simply not materialised, yet all round us other towns have seen upgrading of facilities, not the loss of facilities (Banbury/Rugby). SPC would like to see more emphasis on a vigorous policy approach which will enable the delivery of improved retail/leisure facilities and infrastructure as opposed to the decline that has transpired.

12 March 2018 Page 39 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 1 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Supporting Documents: Attached - Site boundary plan, Flood Risk Review, Access Feasibility Report, Heritage Appraisal, Technical Note: Ground Conditions and Utilities, Ecology Summary - Constraints and Opportunities, Air Quality Constraints Assessment, Landscape and Visual Appraisal: Technical Note, Residential Constraints Sketches-Noise, Education Technical note, Population Forecasting Study

Comment:

Objective 1 – climate change

2.3 We support Objective 1, which is to mitigate and adapt to climate change through the promotion of sustainable design; ensuring allocations are resilient to climate change and flooding; encouraging renewable energy; and ensuring new development promotes the use of sustainable travel modes.

2.4 Daventry South West is located adjacent to the built up boundary of Daventry Town which is a sub regional centre of West Northamptonshire and a focus for development in the District (see Policy SP1 of the Part 2 Local Plan). The site has strong, sustainable connections to the town centre through pedestrian and cycle routes and benefits from a number of bus routes that run adjacent to the site. Bus routes D1, D2 and D3 provide access into the town centre and route 200 provides a direct link to Daventry bus station. From the town centre, bus route 11 provides a direct link to Long Buckby railway station. Connectivity to Daventry Town will be further enhanced through the infrastructure delivered by the scheme, including new and enhanced A45 crossings for pedestrians and cyclists. The sustainable location of the site will enable the site to be designed to minimise the demand for resources and be resilient to future climate change and risk of flooding. Further information on the risk of flooding is provided in appendix 2.

2.5 Accordingly, it is clear that Daventry South West accords with Objective 1 of the Local Plan.

12 March 2018 Page 40 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 10 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 10 – Protecting and Supporting Rural Communities

2.23 We support Objective 10 which aims to protect the rural communities. The emerging allocation of Daventry South West is located adjacent the main settlement of Daventry, away from existing villages and therefore helps preserve the rural communities by focusing large scale development on the edge of the larger urban areas.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 11 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Objective 11 – Rural Diversification and Employment

2.24 Objective 11 has no particular relevance to Daventry South West and therefore we raise no specific comments in this regard.

12 March 2018 Page 41 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 12 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 12 – Green Infrastructure

2.25 We support Objective 12 which seeks to protect natural species in the District and enhance the existing strategic green infrastructure network.

2.26 The development at Daventry South West will be built upon a strong green infrastructure (GI) strategy, delivering a significant component of open space and connections to the wider GI network, which would benefit both the new and existing communities. Furthermore, it will deliver substantial benefits in terms of health and wellbeing, biodiversity and access to recreation, in accordance with paragraph 73 of the NPPF.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 13 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 13 – High Quality Design

2.27 We support Objective 13, which seeks to achieve high quality design in both rural and urban areas that takes account of local character and heritage.

2.28 The emerging allocation at Daventry South West will be informed by high quality design, delivering a planned new community that has its own established identity.

12 March 2018 Page 42 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 14 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 14 – Heritage

2.29 We support Objective 14 which seeks to conserve and where possible enhance heritage assets and their setting. A heritage assessment is submitted at appendix 4, which, for example, provides detail on how the reintroduction of a wooded environment to the south of the Daventry South West will provide a positive reinstatement of the landscape character and protect the setting of the adjacent grade II listed building, Badby House.

12 March 2018 Page 43 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 2 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

2.6 We support Objective 2, which states that social, physical and green infrastructure will be adequately provided to meet the needs of people and businesses. As the NPPF acknowledges, the supply of housing can sometimes be best achieved through large-scale development (paragraph 52). Furthermore, these forms of development can in particular enable the delivery of on-site infrastructure, minimising the need to travel long distance for services and facilities (paragraph 38 of the NPPF). Daventry South West presents such an opportunity, providing a large quantum of much needed housing with significant on-site infrastructure to the benefit of new and existing communities, including a primary school and a new local centre. Significant opportunities also exist to deliver meaningful green infrastructure in the form of high quality open spaces and recreational facilities, helping promote the health and well-being of communities, in accordance with paragraph 73 of the NPPF.

2.7 An Access Feasibility study (appendix 3) has been undertaken by WYG, which identifies that a three arm roundabout would be the most suitable form of junction off the A45 and A425, providing access to the whole site. Furthermore, the pedestrian bridge across the A45 would be improved to allow safe and convenient pedestrian and cycle access into the town centre. Further work on the infrastructure required will be undertaken during the preparation of any planning application on the site.

2.8 It is therefore clear that Daventry South West would accord with Objective 2 of the SCLP and aid the Plan in delivering this objective.

12 March 2018 Page 44 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 3 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 3 – Connections

2.9 As detailed above, Daventry South West, being a strategic allocation, will provide a range of on-site infrastructure, reducing the need to travel by car. In addition, the site is in a highly sustainable location, on the edge of the principal settlement in the District. The site benefits from existing connections to the town centre via a pedestrian bridge and the allocation will enhance the A45 crossing through an at-grade cycle / pedestrian link. The scheme could also allow for enhanced bus links through the site to the town centre.

2.10 The Department for Transport’s report on Local Cycling and Walking Infrastructure Plans: Technical Guidance for Local Authorities (April 2017) states that cycling has the potential to replace trips made by other modes, typically at distances up to 10km, whilst walking has the potential to replace trips by other modes up to 2km. The town centre is located only 1.6km to the north east via pedestrian routes, a distance where walking and cycling is therefore considered to be a meaningful alternative to the private car. There are also a number of bus routes which the site could easily access (number D1, D2 and D3), providing fast and frequent services into the town centre. 2.11 Accordingly, we support this objective and it is clear that Daventry South West would help deliver it.

12 March 2018 Page 45 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 4 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 4 – Protecting and building Urban Communities

2.12 We support objective 4, which ensures new development in urban areas effectively supports and links new and existing communities physically and socially, to achieve social cohesion and address the areas of deprivation identified in parts of Daventry.

2.13 Daventry South West will provide a high quality urban environment with links to the existing community. Providing a new urban area with significant on site infrastructure will help elevate the overall profile of the town. Accordingly, we support this objective.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 5 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 5 – Supporting Daventry Town Centre

2.14 We support Objective 5 which identifies that the regeneration of Daventry Town Centre will be through planned growth and infrastructure delivery.

2.15 Daventry South West is a substantial strategic housing allocation on the edge of the existing settlement, which will provide enhanced pedestrian and cycleway access to the Town Centre. Whilst the site will provide some on-site infrastructure, it will nevertheless rely upon, to some degree, the services and facilities within the Town Centre. The new population will of course generate additional expenditure, helping to support existing services and facilities, contributing to the local economy that will in turn aid the regeneration of the Town Centre.

12 March 2018 Page 46 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 6 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 6 – Economic Advantage

2.16 We support Objective 6. By strengthening and diversifying the local economy, more existing and future residents will be able to live and work in Daventry, which will provide an economic benefit to the whole of the District.

2.17 Furthermore, Daventry South West will of course help contribute towards economic development during both the construction phase and operational phase, principally through job creation. The creation of a new Primary School along with a local centre has the ability to further increase the number of jobs available as a direct impact from the Site. The high quality environment will also provide economic benefits for whole of Daventry.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 7 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge High Cross Farm Limited and Drayton Lodge High Cross Farm Limited and Drayton Lodge Support/Object: Support

Comment:

Objective 7 – Specialist Business Development

2.18 We support Objective 7. By developing specialist business in Daventry, which focuses on a low carbon economy, Daventry can gain recognition within specialist industries and attract further economic growth, ultimately enhancing the profile of Daventry as a whole.

12 March 2018 Page 47 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 8 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 8 – Educational Attainment

2.19 We support Objective 8 which seeks to raise education achievement and the skill base of the community.

2.20 Daventry South West would provide a new primary school on-site. The provision of a new school will of course contribute towards the educational achievement and skill base of the community.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Objective 9 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Objective 9 – Housing

2.21 We support Objective 9 which aims to provide a range of housing in sustainable locations. Daventry South West is located on the edge of Daventry, which supports the objectives of identifying sites in sustainable locations. As a strategic scale development, it will provide a highly sustainable residential led mixed-use development. Large scale sites such as this can deliver a broad range of dwelling types, sizes and tenures, including a significant quantum of affordable housing.

2.22 It is therefore clear that Daventry South West would support with this objective.

12 March 2018 Page 48 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Para 3.1.02 ED138N Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Object

Supporting Documents:

Comment:

The Vision for Daventry in the Local Plan part 2 appears to follow the Vision from the WNJCS – which enables the reinforcement of the more strategic vision and provide consistency between the two interlinked plans. However, Daventry Town Council considers that this is still too idealistic and generic and opportunities have been missed to make the vision more specific and localised to Daventry.

The Vision reiterates the position in the WNJCS that the town centre will offer ‘a robust commercial core moving strongly towards a well-developed office sector.’ However, it is considered that this aspiration, while laudable, will not materialise unless a significant policy position is created. Small market towns do not in themselves produce an environment attractive for significant office development. The experience of the Heartlands Business Park and the initial phase of its development should be considered as an example. This demonstrated, that despite heavy promotion, over many years, the provision of a sizeable fully serviced, landscaped Business Park, for office development, failed to an occupier (Northamptonshire Strategic Employment Land Assessment 2009). For an office/research and development employment led plan to work, very careful consideration of the associated attractors and infrastructure is essential to attract and sustain this type of employment.

Daventry Town Council considers a high-quality research and development facility should be located close to allocated B1 employment sites, to create a rationale for larger service companies to locate. Daventry District Council should target manufacturing companies and small scale service industries which will be able to procure their employees more locally. In the Town Centre, the mixed-use regeneration sites (1, 3 and 5) will be difficult to deliver with office space included as these types of development require specialist developers and often need incentives for non-viable elements of the scheme. It is very unlikely that the town itself will provide a big enough magnet for companies to invest particularly given the high out-migration rates for work to other centres.

If diversifying the employment base and focusing on more service-oriented businesses is a key priority of the Local Plan then it is essential that further dedicated policies should be included within the plan to achieve its aims.

12 March 2018 Page 49 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Para 3.1.02, 3.1.03 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object:

Supporting Documents:

Comment:

Vision (3.1.02) and objectives (3.1.03) We feel that not including health and wellbeing in the vision and objectives of the Local Plan Part 2 is a significant oversight. We feel that health and wellbeing should be included in the Vision for Daventry and we feel strongly that health and wellbeing should be included as an objective (section 3.1.03). We believe there is a compelling argument for its inclusion in this way, including:

Health and wellbeing is a key element of a sustainable community, which we understand is the ultimate goal of the planning system and thus the Daventry Local Plan part 2.

Health and wellbeing is fundamental to achieving many of the objectives already contained in the vision/Local Plan Part 2, not least; educational attainment, economic prosperity, social cohesion and quality of life etc.

As noted in section 10.1.02 of the draft Local Plan Part 2, Health and Wellbeing is identified as a key objective in both the Daventry District Community Strategy and Daventry District Council's Corporate Strategic Plan. Given the important role of the planning process in contributing to this, we feel strongly that it should also be reflected in the Vision and Objectives of the Local Plan Part 2.

The Northamptonshire Health and Wellbeing Strategy 2016-2020 (supported by all key partner organisations in the county) recognises the role of environment/place in determining the health and wellbeing of its residents

Health and wellbeing is included in the Sustainability Appraisal objectives.

We propose the following wording for consideration for inclusion in the Local Plan Part 2: Vision: New development will contribute to the health and wellbeing of Daventry residents, including through design which supports and encourages healthy and active lifestyles.

Objective: Objective X - Health and Wellbeing To support the health and wellbeing of new and existing communities through designing new development which supports and encourages healthy and active lifestyles.

By including Health and Wellbeing in the vision and objectives, we understand that health and wellbeing would then be included in the Monitoring Framework and thus progress in contributing to health and wellbeing would be embedded in the Local Plan Part 2 monitoring processes.

12 March 2018 Page 50 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Para 3.1.02, 3.1.03 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Chapter 3: Vision and Objectives It is important to recognise the housing requirements in the vision and in the objectives. We have concerns that the vision does not sufficiently consider the necessary growth implications for the District’s rural area and does not sufficiently identify the settlements in the rural area to which the amount of growth will be directed.

Objective 9 in the Draft LPP2 seeks to “provide a range of housing in sustainable locations to ensure all residents have access to a home that they can afford and that meets their needs.” However, “housing development will be focused at the most sustainable location of Daventry with limited development in the rural area to provide for local needs and support local services.” As currently drafted, the vision and objectives do not include the rural area’s growth requirements and instead only focusses on additional growth at Daventry town. No additional residential land has been identified for the rural area of the District.

Whilst we support some of the objectives intended to deliver the vision, we are concerned that the objectives and in particularly Objective 9 restricts growth in the District’s rural area to “limited development”. Further consideration of this matter is discussed below in relation to development in the District’s rural area.

Object to Vision and Objective 9: The vision and objective should be amended to consider the necessary growth implications for Daventry District’s rural area and the sufficient amount of growth for settlements in the rural area.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Para 3.1.03 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 3.1.03 is welcomed by the council. HPC would like the SCLP objective to go further. It should protect the character of rural communities by committing to protecting and retaining urban/rural separation. It should insist that development take account of local character by using locally sourced building materials and reflecting local designs. Where urban and rural meet, HPC would like the SLCP to insist that the design of the development should include some transitional elements, such as use of local stone, natural looking open areas and appropriate planting schemes

12 March 2018 Page 51 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 para 3.1.03 ED98A Steve Harley

Organisation: Representing: Oxalis Planning Pedrix Ltd.

Support/Object:

Supporting Documents:

Comment:

Vision and Objectives 1.11 Pedrix notes and supports several of the proposed Objectives for the Part 2 Local Plan – specific support is offered to: Objective 3 – Connections To reduce the need to travel, shorten travel distances and make sustainable travel a priority by maximising the use of alternative travel modes. In so doing, combat congestion in our main towns and town centres, reduce carbon emissions and address social exclusion for those in both rural and urban areas who do not have access to a private car.

Objective 6 – Economic Advantage To strengthen and diversify the local economy by taking advantage of our internationally well-placed location, strategic transport network and proximity to London and Birmingham.

Objective 7 – Specialist Business Development To support and develop opportunities for specialist employment clusters and business development focused on a low carbon economy.

1.12 In supporting these objectives, there are several key points which should be more explicitly recognised, and planned for, through the Part 2 Local Plan: • The introductory sections of the Local Plan make it clear that there are numerous villages, including a number of large villages, which serve as important centres in a largely rural District with one main town – as ‘main centres of population’ the largest villages clearly have the potential to deliver an appropriate scale and type of development to help reduce the need to travel, delivering social and environmental benefits to the communities of Daventry District, and supporting a number of the strategic objectives of the emerging Plan; • The explicit goal of the emerging Plan is to ‘strengthen and diversify’ the economy – in the context of a polycentric District, implicitly this requires a plan to deliver economic development in a range of places. Based on core sustainability principles, a strategy which seeks to deliver economic development in all of ‘the main centres of population’ across the District would deliver sustainable patterns of development. Such a spatial strategy must produce more sustainable patterns of development than only focusing employment allocations in Daventry; • Recognition of the role of ‘clusters’ and specialist economic sectors in the emerging Plan and other parts of the Council’s evidence base also implies the potential need for a geographic spread of economic development across different parts of the District, and also brings into question the rationale and sustainability of the proposed spatial strategy which focuses new allocations to support economic development only in Daventry town.

Changes are required to ensure that the Part 2 Local Plan provides a suitably positive, proactive, and sustainable strategy for Daventry District.

Summary of objections and suggested amendments: In summary, Pedrix’s representations are based around the following: • Support for recognition of the important and strategic role played in delivering employment and other development or services by Primary Service Villages, such as Brixworth, in the context of the largely rural District; • Support for the recognition of the need to support and plan for specialist business sectors and clusters in the District;

12 March 2018 Page 52 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Para 3.1.03 ED42A Yvonne Dean

Organisation: Representing: Welford Parish Council

Support/Object:

Supporting Documents:

Comment:

2.0 Although in 3.1.03 the vision statement recognises in Objective 3 the problems of social exclusion in rural areas, Welford which was originally regarded as a sustainable village, will no longer be that with the withdrawal of bus services to many villages in 2018. We seek a harder line policy to rectify that.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Vision ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

2.1 The vision for Daventry Town and the District is set out within Chapter 3 of the Part 2 Local Plan. Within Chapter 3, it is stated that the vision will be achieved through meeting specific objectives that are based on the West Northamptonshire Joint Core Strategy (WNJCS) objectives, which have been specified for the Daventry District. 2.2 We support the Council’s vision, which is set out through Objectives 1 -14 and outline below how Daventry South West assists the Part 2 Local Plan in delivering the 14 objectives, where relevant

12 March 2018 Page 53 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 03 Vision ED142B James Yeoman

Organisation: Representing: Savills Christ Church, Oxford

Support/Object: Support

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Settlement and Countryside Local Plan (Part 2)

The National Planning Policy Framework (NPPF) identifies a presumption in favour of sustainable development, to be seen as a golden thread running through plan-making and decision taking. Paragraph 14 of the NPPF reports that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change.

Daventry is clearly recognised as a sustainable development location with the northern part of the town having delivered strategic growth in recent years. The delivery of the Daventry North East Sustainable Urban Extension (SUE) will provide further housing growth. It is important that the LP2 conforms to the wider spatial strategy of the West Northamptonshire Joint Core Strategy Local Plan (December 2014). Our client supports the key focus of development in the District to be on the town of Daventry, as set out by the Vision of the Local Plan (Part 2, hereinafter referred as LP2).

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Chapter 4 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

No observations.

12 March 2018 Page 54 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Para 4.1, policy SP1 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object: Object

Supporting Documents:

Comment:

We note and support the general policies relating to development and regeneration. We comment later on the plans to expand the boundary of Daventry Town to Daventry SW, which we feel blurs the distinction between the policies relating to Daventry Town and those relating to the rural areas. We support in particular principles E. F, G and H.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Para 4.1.08, SP1 Daventry ED9 Anthony Hawkey District Spatial Strategy principle F

Organisation: Representing:

Support/Object: Support

Supporting Documents:

Comment:

With the advent of driverless vehicles, should plans include ways of reducing vehicle congestion in, and around, Daventry by means of some form of driverless transportation system, which would encompass the town, new housing developments and connection to Long Buckby station.

12 March 2018 Page 55 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED46A Chris Edge

Organisation: Representing: Co-op

Support/Object: Object

Supporting Documents:

Comment:

Whilst the Co-op is broadly supportive of the Part 2 Local Plan being consistent with the WNJCS there is concern that the Council's over-reliance on housing being primarily delivered on large-scale Sustainable Urban Extensions (SUE) is overly simplistic and optimistic. The Part 2 Local Plan rightly seeks to meet the identified housing requirement through a Plan-led approach, however, there needs to be a balanced approach to housing delivery across the whole District.

The evidence base demonstrates that housing within rural areas has been brought forward at a healthy rate between 2011-2017, to the extent that the rural areas requirement for the Plan period has already been met. However, to simply rely on SUE sites for the remainder of the Plan period, when there is already clear evidence of slippage in housing delivery on such sites, suggests the Plan has not been positively prepared, nor will it be effective. Indeed, the Daventry North East SUE is not yet subject to an outline planning application despite being anticipated to deliver 2,600 dwellings in the WNJCS. The Council now anticipates just 1,570 dwellings being delivered on this site in its latest Housing Land Availability report. This is symptomatic of the complex nature of SUE delivery yet there is an absence of evidence to support the assumed delivery rates incorporated within the housing trajectory. In addition, there may yet be more unmet need from the Northampton Related Development Area (NRDA) over the Plan period, which could increase the housing requirement within Daventry in due course.

Similarly, imposing what is, in effect, a moratorium on further housing outside Daventry town for the entire Plan period will undermine social mobility and prevent those other communities from meeting their needs. This cannot be a sustainable approach.

Given the (already apparent) risk of housing not being delivered on SUE sites as anticipated, or increased housing requirement from the NRDA as part of an early Plan review, the Part 2 Local Plan should go further and allocate reserve housing sites outside Daventry town. This approach would be commensurate with the WNJCS, ensure the Plan is flexible and can adapt to changing circumstances post-adoption and otherwise ensure the housing requirement can be met through a genuinely Plan-led approach. Whilst para 5.2.17 sets out the exceptions criteria for when housing applications may be considered favourably outside settlement confines, this is not enshrined in policy. A schedule of reserve housing sites, across the Primary Service Villages, which could come forward over the Plan period (should delivery stall on the SUE sites) would be a pragmatic and logical solution, which will enable the tests of soundness to be met.

12 March 2018 Page 56 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED75A Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents:

Comment:

Policy SP1 of the Emerging Draft Consultation sets out the proposed spatial strategy for the Part 2 Plan over the period to 2029. The spatial principles set out in the policy include focusing development on Daventry town to deliver its regeneration and reinforce its role as the sub-regional centre, assisting with the delivery of plan-led development to meet Northampton’s needs where this cannot be accommodated with the Northampton Related Development Area (NRDA), and protecting and enhancing existing services and facilities in the District’s villages through allowing limited development to meet their identified needs.

This policy is insufficiently clear in terms of the key issues that need to be addressed in the Part 2 plan, namely how the Council will deal with the under delivery of housing in Daventry and the NRDA against the requirements set out in the West Northamptonshire Joint Core Strategy. The policy adds very little to the overall spatial strategy as set out in Policy S1 of the Joint Core Strategy. The policy should be amended to set out a clear spatial strategy for the District to address shortfalls in delivery of housing in the District.

To assist in the delivery of sufficient homes to meet the NRDA’s needs and to provide greater flexibility should delays be experienced in respect of NRDA sites, we recommend that additional housing land is allocated in deliverable locations. Our client, Gallagher Estates, have interests in ‘Land off Brockhall Road, Flore’ (HELAA ref 104) where there is the potential to develop up to 200 dwellings on land between the settlement and the Daventry Development Link Road. The allocation of the site would provide housing land in a sought after location (which would be highly deliverable as well as greater flexibility for the Local Plan to adapt to changing circumstances should the delivery of NRDA sites stall.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object: Support

Supporting Documents:

Comment:

We support the inclusion of health and wellbeing in this policy, recognising its importance in sustainable development.

12 March 2018 Page 57 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED91A Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents: Attached - Heritage Note, Landscape & Visual Constraints and Opportunities Report

Comment:

Policy SP1 - Daventry District Spatial Strategy We note that the Council's Spatial Strategy set out in Policy SP1 includes: "(B) Assisting with the delivery of plan-led development to meet Northampton's needs where it is identified that it cannot be accommodated in the Northampton Related Development Area" and; "(E) Protecting and enhancing existing services and facilities within the District's villages through allowing limited development to meet their identified housing needs".

Our comments in respect of Policy SP1 are set out below.

It is noted and acknowledged that the Joint Core Strategy for West Northants (JCS) sets out the spatial strategy for growth across the West Northants Housing Market Area, including Daventry District. Policy S1 of the JCS sets out the distribution of development; this provides for an open 'appropriate' amount of development in and adjoining the sub regional centre of Daventry Town, with a lesser focus of new development coming forward in the rural areas.

Policy S3 of the JCS provides for 'about' 12,730 dwellings in Daventry District of which 'about' 4,620 would be delivered in and around Daventry Town and 'about' 2,360 in the Daventry rural area. Significant delivery of 'about' 5,750 dwellings is proposed by the JCS within the part of the Northampton Related Development Area (NRDA) which lies within Daventry District

Whilst the Part 2 Plan will need to generally accord with the JCS, to be considered sound the Plan will need to be positively prepared and effective, i.e. deliverable. Unfortunately, development has not progressed as quickly as anticipated in and around Daventry or in the NRDA part of Daventry District. The 'Northampton Related Development Area Five Year Housing Land Supply Assessment' (April 2017) indicates that there is not currently a 5 year supply of deliverable housing in respect of the NRDA. The assessment demonstrates a supply of only 2.64 years - a significant shortfall of 2.36 years. Whilst we note that the Council consider that a policy response is not required, instead suggesting that the situation is kept under review (Local Plan Part 2, para 1.4.04), we do not consider this approach to be sufficiently proactive or effective in terms of ensuring Northampton's housing needs are met. These concerns are echoed in the draft consultation response taken to Committed by South Northamptonshire Council (SNC) on 23rd January 2018.

It is pertinent to note Policy S6 of the JCS - Monitoring and review - states that if policies remain ineffective after the initial measures (to 2018) a number of actions will potentially apply, including a review of targets and a review of policy or strategy. There is no intention, it is understood, to carry out such a review at the housing market area level, so it falls to the Part 2 Plan to consider the requirements of Policy S6 in bringing forward the Part 2 Plan.

The Part 2 Plan fails to consider or address delivery issues in the NRDA part of the District. Housing delivery information is only presented in respect of the District excluding the NRDA, which is surprising given that land in Daventry District is expected to make a significant contribution to delivery of the NRDA requirement element of the housing market area. This is a significant shortcoming of the Part 2 Plan. To be considered sound it is necessary for the plan to seek to address under-delivery in the NRDA - particularly given the limited opportunities to increase supply in the NRDA within the geographical constraints of Northampton Borough Council area.

It is noted that the Part 2 Plan identifies a residual requirement due to under delivery in Daventry of somewhere between 1,073 and 1,140 dwellings. No residual requirement is set out for under delivery in the NRDA. The Part 2

12 March 2018 Page 58 of 399 Plans' proposed solution to the identified shortfall is to allocate new sites at Daventry, including 800 to the south west of Town (Policy HO1) and an extension to Micklewell Park to the north of the Town for a further 180 dwellings (Policy HO2). No additional provision is proposed in the rural areas or on the edge of the NRDA.

In order for the Plan to be sound it is imperative that it makes provision to address housing supply shortfalls in respect of the part of the NRDA within Daventry District.

Proposed changes to Policy SP1 To assist in the delivery of sufficient homes to meet the NRDA's needs and to provide greater flexibility should further delays be experienced in respect of the sites within the NRDA, we recommend that additional housing land is allocated close to Northampton/adjoining the NRDA. Our clients, Gallagher Estates, have interests in 'Land South of Moulton Lane, Boughton', a proposed residential development site promoted through the Council's 'Call for Sites' consultation (see 'Indicative Concept Masterplan' attached). The allocation of this site would facilitate development in a sustainable location adjacent to the main urban area of Northampton and would contribute to meeting Northampton's housing needs. In addition, the site could also assist with the delivery of the Moulton Park Spur road.

To support the proposed allocation of 'Land South of Moulton Lane, Boughton), initial assessment work has been carried out in respect of heritage and landscape and visual considerations. In this regard, a 'Heritage Note' and a 'Landscape and Visual Constraints and Opportunities Report' accompany these representations.

If the Council choose not to allocate additional sites to assist with the NRDA housing shortfall, the Local Plan Part 2 should, at the very least, include a positive, criteria based policy to allow for appropriate development to come forward during the Plan period until such time as the Part 1 Local Plan is reviewed or it is possible to demonstrate a 5 year housing land supply. This is reflective of the approach that South Northamptonshire Council are proposing to adopt in their Local Plan Part 2.

12 March 2018 Page 59 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED64 Kate Thompson

Organisation: Representing: Pegasus Group Miller Homes

Support/Object: Object

Supporting Documents:

Comment:

I set out below objections to the Emerging Draft Consultation document on the basis that proceeding with the plan in its present form would be unsound. In particular, objections are raised to proposed Policies SP1, HO1, RA1, RA2 and Chapter 11: Parish Annex

Policy SP1 - Daventry District Spatial Strategy It is noted and acknowledged that the Joint Core Strategy for West Northants (JCS) sets out the spatial strategy for growth across the West Northants Housing Market Area, including Daventry District. Policy S1 of the JCS sets out the distribution of development; this provides for an ‘appropriate’ amount of development in and adjoining the sub- regional centre of Daventry Town, with a lesser focus of new development coming forward in the rural areas.

Policy S3 provides for ‘about’ 12,730 dwellings in Daventry District of which ‘about’ 4,620 would be in and around Daventry Town and ‘about’ 2,360 in the Daventry rural area. A significant ‘about’ 5,750 dwellings is proposed within the Northampton Related Development Area (NRDA) that lies within Daventry District.

It is pertinent to note Policy S6 of the JCS – Monitoring and Review – states that if policies remain ineffective after the initial measures (to 2018) a number of actions will potentially apply including a review of targets and a review of policy or strategy. There is no intention, it is understood, to carry out such a review at the housing market area level, so it falls to the Part 2 Plan to consider the requirements of Policy S6 in bringing forward the Part 2 Plan.

The Part 2 Plan fails to consider or address delivery issues in the NRDA part of the District. Housing delivery information is only presented in respect of the District excluding the NRDA, which is surprising given that land in Daventry District is expected to make a significant contribution to delivery of the NRDA requirement element of the housing market area. Indeed, Table 5 on page 39 of the JCS identifies that 2,420 dwellings should have been built in Daventry District between 2011 and 2017. The Part 2 Plan and its evidence base only appears to be considering a requirement of 1,786 over this period. This is a significant shortcoming of the Part 2 Plan and it is necessary for the Plan to be found sound for it to address under delivery in the NRDA – particularly given the limited opportunities to increase supply in the NRDA with the geographical constraints of Northampton Borough Council area.

The Plan identifies a residual requirement due to under delivery in Daventry as somewhere between 1,073 and 1, 140 dwellings. No residual requirement is set out for under delivery in the NRDA – this must be addressed in the part 2 Plan for it to be found sound.

The Part 2 Plan’s proposed solution to the shortfall is to allocate new sites at Daventry, including 800 dwellings to the south west of Town through Policy HO1 and an extension to Micklewell Park to the north of the Town for a further 180 dwellings – Policy HO2.

No additional provision is proposed in the rural area or on the edge of the NRDA. There is a serious question on the extent to which the additional dwellings in and around Daventry Town are going to be deliverable over the

12 March 2018 Page 60 of 399 remainder of the plan period.

It is noted that delivery in Daventry Town has not exceeded more than 151 dwellings per annum since 2011 and that Daventry North East alone is expected to deliver 200 dwellings per annum from 2023 to 2029. The proposed additional provision for Daventry is not considered to be deliverable when considered cumulatively with the outstanding commitments still yet to be delivered, particularly at Daventry North East. The Part 2 Plan is considered to fail the effectiveness test of soundness in that it simply will not be deliverable over the plan period due to the Daventry housing market not being strong enough to delivery what is now being proposed within the plan period (an average of 371 dpa 2019-2029).

Clearly delivery in the sustainable villages has been effective and there is no reason to doubt that further provision in the sustainable villages over the remainder of the plan period would be deliverable. Objection is therefore raised Policy SP1 as this should make provision for delivering additional housing development in and adjacent to the sustainable villages within the rural areas to assist in making up the shortfall of delivery in and around Daventry and the NRDA. Criterion D in particular requires amendment. West Haddon is such a sustainable village that accommodate some of the additional housing to help meet the expected shortfall.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED92 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents:

Comment:

Policy SP1 of the Emerging Draft Consultation sets out the proposed spatial strategy for the Part 2 Plan over the period to 2029. The spatial principles set out in the policy include focusing development on Daventry town to deliver its regeneration and reinforce its role as the sub-regional centre, assisting with the delivery of plan-led development to meet Northampton’s need where this cannot be accommodated within the Northampton Related Development Area (NRDA), and protecting and enhancing existing services and facilities in the District’s villages through allowing limited development to meet their identified needs.

This policy is insufficiently clear in terms of the key issues that need to be addressed in the Part 2 Plan, namely how the Council will deal with the under delivery of housing in Daventry and the NRDA against the requirements set out in the West Northamptonshire Joint Core Strategy. The policy adds very little to the overall spatial strategy as set out in Policy S1 of the Joint Core Strategy. The policy should be amended to set out a clear spatial strategy for the District to address shortfalls in delivery of housing in the District.

12 March 2018 Page 61 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED104B Simon Andrews

Organisation: Representing: DLA Town Planning

Support/Object: Object

Supporting Documents: Letter attached relating to policies SP1 and RA1, Appeal Decision (APP/P0240/W/17/3176444

Comment:

Introduction We have previously responded to Local Plan consultations setting out our proposals for Pool Farm Field in Woodford Halse. A flood alleviation project is needed in the village and there is no realistic prospect of public finance to enable its delivery. We are proposing to deliver this project in conjunction with an appropriately sized development at the Pool Farm Field site. Discussions are continuing with the Flood and Water Management Team at Northamptonshire County Council and we have also presented our proposals to the Parish Council. We are intending to seek pre- application advice from your Development Management colleagues in the near future.

Policy SP1 While we note the housing target for the Rural Areas has already been attained, we nevertheless consider that there are specific circumstances that merit an allocation in Woodford Halse. The flood alleviation scheme is important to the village and is of sufficient importance for the County Council to have invested money in a feasibility project. That project cannot currently be delivered because of a lack of funding. Development funding is the only realistic source of funding and this ought to be acknowledged in the emerging Local Plan. While there is currently scope for development that yields environmental benefits to be brought forward outside of the Local Plan, it would nevertheless be better if such development could be plan-led and secured through the Local Plan. We therefore consider that the Pool Farm Field site should be allocated in the emerging Local Plan because of the specific environmental benefits that can be secured for the village.

12 March 2018 Page 62 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED94 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents:

Comment:

Policy SP1 of the Emerging Draft Consultation sets out the proposed spatial strategy for the Part 2 Plan over the period to 2029. The spatial principles set out in the policy include focusing development on Daventry town to deliver its regeneration and reinforce its role as the sub-regional centre, assisting with the delivery of plan-led development to meet Northampton’s needs where this cannot be accommodated within the Northampton Related Development Area (NRDA), and protecting and enhancing existing services and facilities in the District’s villages through allowing limited development to meet their identified needs.

This policy is insufficiently clear in terms of the key issues that need to be addressed in the Part 2 Plan, namely how the Council will deal with the under delivery of housing in Daventry and the NRDA against the requirements set out in the West Northamptonshire Joint Core Strategy. The policy adds very little to the overall spatial strategy as set out in Policy S1 of the Joint Core Strategy. The Policy should be amended to set out a clear spatial strategy for the District to address shortfalls in delivery of housing in the District.

12 March 2018 Page 63 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Chapter 4: Daventry District Spatial Strategy Policy SP1 – Daventry District Spatial Strategy We note that the Council consider that to help deliver the vision and objectives of the Local Plan (Part 2), an overarching spatial policy should be followed in guiding development proposals across the District, which closely follows the spatial strategy identified in Policy S1 of the WNJCS adopted December 2014. This seeks to focus development in and adjoining the sub-regional centre of Daventry town and limit development in the rural areas.

Policy S3 of the WNJCS sets out the scale and distribution of housing development of about 42,620 net additional dwellings during the plan period 2011 to 2029 across West Northamptonshire. In respect of Daventry District, the WNJCS sets out that about 12,730 dwellings will be provided, distributed as follows: • Daventry Town – about 4,620 dwellings. • Daventry Rural Areas – about 2,360 dwellings. • Northampton Related Development Area – about 5,750 dwellings.

We note that the Council consider (paragraph 4.1.05 of the Draft LPP2) that it is crucial that the over-arching spatial strategy of the WNJCS is carried forward, and that with respect to the NRDA, it is important that Northampton’s needs are met in a plan-led manner to avoid piecemeal development. A pattern of piecemeal development in the District is not considered to be sustainable as this can increase the load on the current road and utilities infrastructure, without bringing forward the economies of scale that would make the provision of further infrastructure cost effective and therefore deliverable.

Policy SP1 of the Draft LPP2 states that to ensure a sustainable pattern of development to meet the overall spatial strategy of the WNJCS, sustainable development in Daventry District will be guided by the spatial principles as set out under Policy SP1. This includes: A) focusing development at Daventry town to deliver its regeneration and reinforce its role as the sub-regional centre of West Northamptonshire and its ability to support the surrounding communities; and B) assisting with the delivery of plan-led development to meet Northampton’s needs where it is identified that this cannot be accommodated within the Northampton Related Development Area.

We acknowledge that the WNJCS is the key driver to identifying the scale and distribution of housing development for West Northamptonshire including Daventry District. However, we are concerned that Policy SP1 of the Draft LPP2 restricts necessary housing growth in Daventry District’s rural area. Further consideration of this matter is discussed below in relation to development in the rural areas. We consider that Policy SP1 and the supporting text is unsound as the Draft LPP2 has not been positively prepared based on meeting current and future housing requirements.

Object to Policy SP1 and Daventry District Spatial Strategy: The policy and supporting text should be amended to consider the necessary growth implications for Daventry District’s rural area.

12 March 2018 Page 64 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED110 Gary Stephens

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

SP1 – Daventry District Spatial Strategy Policy SP1 seeks to ensure the overall spatial strategy for the JCS is delivered within Daventry District. In particular, it is noted that paragraph B seeks to support the delivery of plan-led development to meet Northampton’s needs outside of the NRDA.

Given the uncertainty identified above in relation to the speed of delivery of the SUE’s within Daventry District, and the trajectories for the proposed allocations, it is suggested that the Council should consider the merits of further allocations, or ‘reserve’ allocations to provide a contingency should the delivery of these sites not materialise. This approach would be an alternative to the suggested approach in paragraph 5.2.17 of inviting speculative applications when the Council has less than a five year land supply (see comments below in respect of Policy R1).

Our recommended approach would help ensure only plan-led development took place, and also put the Council in a good position when preparing for a plan review (given that the plan only goes up to 2029) in providing a direction of travel beyond the plan period in accordance with paragraph 157 of the Framework.

In this context, and in the likelihood that further allocations adjacent to Daventry or Northampton are likely to face similar delivery issues, the Council should consider alternative sustainable locations.

The Council’s settlement hierarchy identifies Primary Service Villages as the most sustainable locations outside these areas. However, it is considered that some PSVs are more sustainable than others. For example, Long Buckby is the only settlement that benefits from a railway station with frequent, direct connections to Northampton, Milton Keynes, London, Rugby Coventry and Birmingham. It is therefore well related to Northampton and the wider area in sustainable transport terms, as well as regular having bus services to Daventry (which are also planned to improve). It is therefore a location that has specific characteristics which differentiate it from other primary service villages, and this should be acknowledged within the settlement hierarchy.

HLM would also therefore encourage the Council to look at opportunities to provide further allocations or ‘reserve’ allocations around Long Buckby given its relationship to Northampton in sustainable transport terms. Further, it is a location where homes could be delivered quickly in order to promptly rectify any shortfall in delivery.

HLM would like to draw the Council’s attention to land it controls at Park Field, Long Buckby which it considers represents a suitable, achievable, and available site. The land could be a proposed allocation or proposed ‘reserve’ allocation and further details are provided below.

12 March 2018 Page 65 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED115 Ed Hanson

Organisation: Representing: Barton Willmore Landform Daventry Ltd.

Support/Object:

Supporting Documents:

Comment:

Daventry Local Plan Review Barton Willmore has reviewed the Regulation 18 Issues and Options consultation document and policies within it and we comment as follows

Overarching Strategy As a starting point, it is imperative that DDC establish the appropriate strategy for development to ensure the adopted Joint Core Strategy (JCS) can be delivered in full. The JCS was adopted in December 2014, but over the past three years DDC has struggled to demonstrate an up to date five-year housing supply. The proposed Sustainable Urban Extension (SUE) at Churchfields has not been delivered and is over four years late in coming forward. It is therefore essential that any review of the plan acknowledges this shortfall and only allocates housing sites that can be delivered in a timely manner.

Draft Policy SP1 - Daventry District Spatial Strategy To ensure a sustainable pattern of development to meet the overall spatial strategy of the JCS, policy SP1 states that development will be focused at Daventry Town. This objective is in accordance with the Daventry 2040 Vision Document and the general objectives for regeneration within the town. In short, Landform support the principle of focusing development in Daventry, before primary service centres.

Policy S1 and S3 further address the provision for the town and set out that new housing will be located within the existing town and again Landform support development of Daventry town first.

12 March 2018 Page 66 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.4 SP1 - Daventry District Spatial Strategy 4.4.1 The WNJCS set out the housing delivery trajectory over the period 2011-2029. Following the adoption of the Plan, there has been slippage from the initial delivery rates that were predicted and it has not therefore been possible to maintain a rolling five year housing land supply across the WNJCS area, specifically within the Northampton Related Development Area (NRDA). It is essential that the District’s spatial strategy operates within the context of the presumption in favour of sustainable development and for any principles that are established through this policy to be consistent with national policy through positively framed drafting that ensures that a suitably balanced approach is taken in applying the objectives that the Council is seeking to establish.

4.4.2 The Plan must include sufficient flexibility over its lifetime. Indeed a current example of the need to make positive responses to support the delivery of housing is the continued inability to demonstrate a five year housing land supply for the Northampton Related Development Area (NRDA) which is an area that extends beyond the administrative boundaries of the Town into the districts of Daventry and South Northamptonshire. The NRDA’s housing land supply has deteriorated in recent years, with a 3.10 year supply reported at April 2016 for the period 2016/17-2020/21 and a 2.95 year supply reported at April 2017 for the period 2017/18 to 2021/22.

4.4.3 As a result of the current land supply position, there is an urgent and pressing need for the Plan to respond to the rapid change that has occurred since the examination of the WNJCS, by embracing a positive approach to meeting the needs of the NRDA. Paragraph 14 of the Framework requires plan makers to ensure that local plans meet objectively assessed needs, with sufficient flexibility to adapt to rapid change. It is therefore important that the Daventry District Spatial Strategy that is put in place through Policy SP1 provides an appropriate basis for responding to this issue. This can be achieved in a plan led manner by supporting the release of sites in sustainable locations to assist in meeting the needs of the NRDA. As presently drafted, Policy SP1(B) fails to include a mechanism to release sites to support the delivery of much needed housing that is required now to meet the needs of the NRDA and is therefore considered by Gladman to be inconsistent with the Framework’s presumption in favour of sustainable development. In this regard, Gladman would wish to highlight to Daventry District Council that a positive mechanism to release sites to support the needs of the NRDA is proposed within the emerging Part 2 Local Plan in South Northamptonshire7 in a manner that is consistent with the WNJCS.

4.4.4 Policy SP1(E) seeks to protect and enhance existing services and facilities within the District’s villages by allowing ‘limited development’ to meet their identified housing needs. It is not clear from this statement of policy as to what is meant by ‘limited’ in this context, or how the Council will identify the housing needs of individual settlements to meet the requirement of this policy. Furthermore, the policy should not be limited to existing services and facilities and should look to pro-actively support opportunities for new services and facilities to be established. The Plan should not create a sustainability trap whereby smaller and rural communities are considered as unsustainable in principle. The Plan at present contains no mechanism by which a settlement that is assumed to function at a lower level within the hierarchy can migrate up the sustainability ladder. Paragraph 55 of the Framework requires local planning authorities to promote sustainable development in rural areas where it will enhance and maintain the vitality of rural communities and it is therefore considered important for an enabling approach to be embedded in the strategy that is contained within DLPP2.

12 March 2018 Page 67 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED141A, ED141B Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents:

Comment:

I set out below submissions to the Emerging Draft Consultation document on the basis that proceeding with the plan in its present from would be unsound for a number of reasons. In particular, objections are raised to proposed Policies SP1, HO1, HO7 and CF2. Clarification is requested in respect of Policies ENV6 and ENV7.

Policy SP1 – Daventry District Spatial Strategy

It is noted and acknowledged that the Joint Core Strategy for West Northants (JCS) sets out the spatial strategy for growth across the West Northants Housing Market Area, including Daventry District. Policy S1 of the JCS sets out the distribution of development; this provides for an ‘appropriate’ amount of development in and adjoining the sub- regional centre of Daventry Town, with a lesser focus of new development coming forward in the rural areas.

Policy S3 provides for ‘about’ 12,370 dwellings in Daventry District of which ‘about ‘ 4,620 would be in and around Daventry Town and ‘about’2,360 in the Daventry rural area. A significant number ‘about’ 5,750 dwellings, is proposed within the Northampton Related Development Area (NRDA) that lies within the Daventry District.

There is though, a serious questions on the extent to which the additional dwellings in and around Daventry Town are going to be deliverable over the remainder of the plan period.

It is noted that the delivery in Daventry Town has not exceeded more than 151 dwellings per annum since 2011 and that Daventry North East alone is expected to deliver 200 dwellings per annum from 2023 to 2029. The proposed additional provision for Daventry is not considered to be deliverable when considered cumulatively with the outstanding commitments still to be delivered, particularly at Daventry North East. The Part 2 Plan is considered to fail the effective test of soundness in that numbers of dwellings proposed within Daventry Town will not be deliverable over the plan period as the Daventry housing market is not strong enough to deliver the numbers now being proposed within the plan period (an average of 371 dpa 2019-2029).

Clearly, delivery in the sustainable villages has been effective to date. There is no reason to doubt that further provision in the sustainable villages over the remainder of the plan period to meet the identified shortfall in provision would not be equally effective and sound. Such provision would not compete in market terms with new housing at Daventry North East.

Objection is therefore raised to Policy SP1 as this should make provision for delivering additional housing development in and adjacent to the sustainable villages within the rural areas to assist making up the shortfall of delivery in and around Daventry. Criterion D in particular requires amendment to facilitate this.

12 March 2018 Page 68 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Policy SP1 – Daventry District Spatial Strategy

2.30 We support Policy SP1, which sets out the overall spatial strategy for Daventry District.

2.31 Daventry Town is the main settlement in the District, the most sustainable settlement and therefore rightly a focus for growth to deliver its regeneration and re-inforce its role as the sub-regional centre of West Northamptonshire. Importantly this aligns with the spatial strategy outlined within WNJCS, which is of particular relevance given the ‘Part 2’ nature of this Local Plan.

2.32 Policy S3 of the WNJCS (which as already detailed informs the Part 2 Local Plan) outlines the housing requirement for Daventry over the period 2011-2029, detailing that Daventry will be a focus for about 4,620 of those dwellings.

2.33 However, the Council’s Housing Background Paper (2017) identifies a shortfall of between 1,073 and 1,140 dwellings to be delivered at Daventry over the Plan period against the WNJCS requirement, which is to be delivered through the Part 2 Local Plan. Daventry South West is identified as a residential allocation at Policy HO1 to meet the majority of this residual requirement for Daventry town. The Site is identified to accommodate at least 800 dwellings, although as detailed within our representations to Policy HO1, it is considered that the capacity of the site can be increased to approximately 1,200 dwellings. The Housing Background Paper sets out the anticipated delivery of the site, however as also detailed within our representations to Policy HO1, we consider that housing can be delivered from the site sooner than currently anticipated by the Housing Background Paper.

2.34 The identification of strategic growth at Daventry South West (Policy HO1) clearly aligns with the Spatial Strategy within the Policy SP1 of the Part 2 Local Plan (and the WNJCS), which we support although the merits of this allocation are addressed later on in these representations.

12 March 2018 Page 69 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 Policy SP1 ED142B James Yeoman

Organisation: Representing: Savills Christ Church, Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

It follows that the general Objectives, set out at 3.1.03, allow for economic development (Objectives 6 and 7) and a focus of residential development at Daventry (Objective 9). Policy SP1 focuses development at Daventry town which is a principle supported by our client. This is particularly relevant in respect of residential development, owing to the Council’s recognition that the majority of delivery has, to date, been in the rural areas. Furthermore, it is evident that the northern aspect of Daventry provides for a sustainable development location, as identified by previous allocations / consents in this general location (e.g. Middlemore allocation of the 1997 Local Plan).

12 March 2018 Page 70 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04 & 05 paras 5.2.15, 5.2.18 ED98A, ED98B Steve Harley

Organisation: Representing: Oxalis Planning Pendrix Ltd.

Support/Object:

Supporting Documents:

Comment:

Overall Spatial Strategy 1.13 The Settlement Hierarchy within the draft Plan identifies that Daventry will be the main focus for development in the Borough with the second tier of the hierarchy being the ‘Primary Service Villages’. While it is appropriate for Daventry to remain the primary focus for growth, we question and object to the stark difference in approach and the significant constraints imposed upon the next level of settlement in the hierarchy below Daventry.

1.14 Although the words of the emerging Plan indicate that Primary Service Villages are suitable locations to accommodate some growth, in practice their potential is severely limited by tightly drawn development boundaries, and an absence of development land allocations proposed to date in the emerging Plan. As a result these settlements are not positioned to play as full a role as they might in delivering sustainable growth across the District.

1.15 For example, Brixworth is a Primary Service Village ideally situated to assist in delivering job growth as part of delivering sustainable economic growth. The village already has a ‘Strategic Employment Area’ defined in Policy EC4 and identified on the emerging proposals map insets (EC4d). As referred to below, this existing, operational employment area remains outside of the village, and it is unclear how this approach sits with that explained in paragraph 5.2.08 of the consultation draft which refers to peripheral residential sites being “regarded as being within the village confines” once built out. The justification for this inconsistency is unclear.

1.16 Similarly, paragraph 5.2.12 refers to village confines including Strategic Employment Areas where these adjoin the village – the Brixworth Employment Area remains outside of the village, and this could also be addressed by the Part 2 Plan.

1.17 The adopted WNJCS is quoted in the emerging Part 2 Plan – the WNJCS states that (emphasis added): Primary Service Villages - Have the highest level of services and facilities within the rural area to meet the day to day needs of residents including those from surrounding settlements. These settlements are the most appropriate for accommodating local housing and employment needs and would be the focus for service provision in the rural areas;

1.18 The WNJCS also encourages a robust analysis of services and facilities in defining local hierarchies.

1.19 It is not clear how this positive strategic policy context with regard to the role of the Primary Service Villages like Brixworth has informed the approach proposed in the emerging Part 2 Local Plan for Daventry District. Pedrix object to the emerging spatial strategy which does not represent the most sustainable strategy, and should be revisited and amended.

1.20 The emerging ‘Spatial Strategy’ as set out in draft policy RA1 and the text which precedes it identify the important economic and employment role of the Primary Service Villages, including at the ‘Strategic Employment Areas’ which are located in some of the villages as well as in Daventry town. The relatively good accessibility by public transport of this category of Villages is also recognised. The term ‘Strategic Employment Area’ could be mis- interpreted as suggesting that these villages do or should accommodate strategic (i.e. large-scale) development, but is helpful in underlying the strategic importance of some of the villages in economic terms. It is understood that the term reflects the ‘more than local’ nature of the employment offered by these villages, and the important role they collectively play in delivering the sustainable economic growth required and sought across the District.

1.21 The important economic function of Brixworth is recognised in the adopted Neighbourhood Plan which seeks to

12 March 2018 Page 71 of 399 maintain a “vibrant local economy” as one its key objectives (paragraph 5.7, Brixworth Neighbourhood Plan, December 2016).

1.22 Despite this, and the obvious synergy with WNJCS, the Emerging Draft Consultation document makes reference (at paragraph 5.2.15 and 5.2.16) to the development which has been consented or delivered in the villages, and the risks of undermining the distribution of development established in the WNJCS if further development were allocated to the Primary Service Villages . It is clear from paragraph 5.2.17 that the concerns and risks relate to the proportionately high levels of residential development seen outside of Daventry town over recent years which means further residential allocations are not required or appropriate. While these residential development issues are clear, there is no explicit reference to employment development, and the justification and rationale for taking a ‘one size fits all’ or blanket approach to any kind of development in the Primary Service Villages is unclear. As referred to below (in the context of Policy EC4) the evidence base regarding the market demand for, and opportunities for, additional appropriate ‘non-strategic’ employment space is compelling.

1.23 Indeed, the relative over-delivery of residential development in the rural area since adoption of the Core Strategy, including places like Brixworth, would represent a sound justification for making additional, appropriate allocations of employment land to support sustainable patterns of development, and to reduce the need to travel.

1.24 While recognition of the strategic employment role of Brixworth is welcomed and supported, Pedrix object to the approach to employment development in this location which is overly restrictive, unsustainable, and should be revisited. In seeking to re-focus residential development on Daventry the emerging Plan includes very tightly drawn settlement boundaries at the Primary Service Villages. There are no new employment site allocations proposed in Brixworth, and the existing Strategic Employment Area remains outside of the settlement confines.

Summary of objections and suggested amendments: Changes are required to ensure that the Part 2 Local Plan provides a suitably positive, proactive, and sustainable strategy for Daventry District. In summary, Pedrix’s representations are based around the following: • Support for recognition of the important and strategic role played in delivering employment and other development or services by Primary Service Villages, such as Brixworth, in the context of the largely rural District; • Objection to the spatial strategy which represents a restrictive and unsustainable approach to the role of Primary Service Villages to deliver additional, suitable, employment sites and floorspace; • Objection to the apparent lack of consistency regarding the approach to sites outside of settlement boundaries and village confines – the suggestion is that residential sites will be regarded as being within the confines once built-out, but there is no similar approach to employment sites;

12 March 2018 Page 72 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04, 05 Policies SP1, RA1 ED95 Susan Green

Organisation: Representing: Home Builders Federation

Support/Object:

Supporting Documents:

Comment:

Introduction Thank you for consulting with the Home Builders Federation (HBF) on the above mentioned consultation. The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which includes multi-national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing. We would like to submit the following representations and in due course appear at the Local Plan Part 2 Examination Hearing Sessions to discuss these matters in greater detail.

Spatial distribution & Housing Land Supply (HLS) The Local Plan Part 2 will establish a local strategy for the settlements and countryside in Daventry in accordance with the adopted West Northamptonshire Joint Core Strategy (WNJCS). The Council states that Policy R1 as set out in the adopted WNJCS is no longer required. It is proposed that Policies RA1 to RA5 in the Local Plan Part 2 supersede Policy R1. However Policy R1 may remain relevant as the housing requirement in the WNJCS is not a ceiling so the supersession of this policy may not be appropriate and beyond the scope of the Local Plan Part 2.

It is also noted that Policy SP1 Bullet Point (H) prioritises development on previously developed land (PDL) contrary to national policy. The NPPF (para 111) encourages the effective use of land by re-using land that has been previously developed (brownfield land) but it does not prioritise the use of such land against sustainable development on non- brownfield land.

The Daventry Local Plan Part 2 proposes a settlement hierarchy comprising of Primary Service Villages, Secondary Service Villages, Other Villages and Small Settlements / Hamlets. It is proposed that a “confine” or development boundary for each settlement is established. Under Policy RA1 development within the confine of a settlement is permitted but outside a settlement confine development is only permitted in exceptional circumstances. It is suggested that these proposed settlement confines are not drawn too tightly. The use of settlement confines to arbitrarily restrict sustainable development from coming forward on the edge of settlements is not a positive approach. A more flexible approach to development in the rural area should not be ruled out. It is important that the Council recognises the difficulties facing rural communities including lack of housing supply and unaffordability. The NPPG emphasises that all settlements can play a role in delivering sustainable development in rural areas so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided. One of the core planning principles of the NPPF (para 17) is to “take account of the different roles and character of different areas … recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”. This principle is re-emphasised in para 55 which states “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The Council should consider permitting sustainable development that is well related to and not just within settlement confines if any unforeseen problems occur with existing consents and / or strategic site allocations which in the past the Council has experienced at the North East Daventry Sustainable Urban Extension (SUE).

The Council has acknowledged that the North East Daventry SUE has not progressed as expected with still no planning application submitted. As a consequence the Council has revised downwards the number of expected completions leaving a residual housing requirement of 511 dwellings. The Local Plan Part 2 proposes three housing site allocations in Daventry as set out in Policy HO1 – Daventry South West (minimum 800 dwellings), Policy HO2 – Daventry Micklewell Park Extension (approximately 180 dwellings) and Policy HO3 – Middlemore (at least 100

12 March 2018 Page 73 of 399 dwellings) but no site allocations in the rural area.

The Council’s overall HLS includes a contingency of circa 11% to cater for unforeseen circumstances such as slower than expected delivery, non implementation of existing consents, economic change, and flexibility and choice in the housing market. The Council should justify that this level of contingency is sufficient. The HBF is supportive of such contingency planning but always recommends a contingency greater than circa 11%.

Furthermore if the Council cannot demonstrate a 5 YHLS on adoption of the Local Plan Part 2 then the Plan cannot be found sound. The HBF’s preferences for the calculation of 5 YHLS are the Sedgefield approach to shortfalls as set out in the NPPG (ID 3-035) with a 20% buffer applied to both the annualised housing requirement and any shortfall.

12 March 2018 Page 74 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 04, 05, 06 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

5 SITE SUBMISSIONS 5.1.1 There is a continued need for the local plans in West Northamptonshire to remain responsive to the needs of the Housing Market Area by enabling the delivery of new housing in sustainable locations. The approach taken through part 2 plans must therefore be suitably flexible to allow rapid and positive responses to be made during the plan period should there be any changes in circumstance, such as the inability to maintain a rolling 5 year housing land supply. Changes in circumstance could include sites not coming forward as anticipated or delivering fewer units than expected when these issues were considered during the examination of the WNJCS.

5.1.2 It is important that the three authorities in West Northamptonshire work collaboratively to ensure that the Part 2 Plans find a solution to the need to secure a rolling five year housing land supply across the WNJCS area. It will also be important to allow a wider range of housebuilders (including those that are Small and Medium Sized) the opportunity to deliver sites, thereby increasing the range of products available and speeding up delivery in West Northamptonshire. This approach would also supplement the slower rates of delivery than initially expected on a number of strategic sites that were identified in the WNJCS, including those relating to the NRDA.

5.1.3 The Plan should also positively respond to the national policy imperative to plan for thriving rural communities. This can be achieved by ensuring that the Local Plan Part 2 enables the delivery of housing on sites across the settlement hierarchy to ensure that the needs of both the rural and urban areas of the district are genuinely addressed.

5.1.4 Gladman are promoting the following sites, which can each be successfully integrated into sustainable settlements and are available, achievable and deliverable. Further details relating to these sites are provided in the sections that follow: • Land at Holly Lodge Drive, Northampton • Land at New Street, Weedon • Land at Brington Road, Long Buckby Land at Holly Lodge Drive, Northampton

5.1.5 Gladman propose that land off Holly Lodge Drive, Northampton (shown in Figure 1 below) is allocated for residential development.

Figure 1: Land at Holly Lodge Drive, Northampton – See attachment

5.1.6 The site has a functional relationship with Northampton, adjoining the NRDA and therefore is considered that the site would contribute directly towards meeting the housing need for the NRDA.

5.1.7 Northampton is the major focus for housing development in the adopted WNJCS and as outlined earlier, the housing land supply position in the NRDA has deteriorated in recent years. Consequently, there is an urgent and pressing need for this Plan to respond, by embracing a positive approach to meeting the needs of the NRDA, such as allocating suitable, smaller scale sites to help address the existing housing need.

5.1.8 The site, off Holly Lodge Drive, is well contained with defensible boundaries along all of the site borders. It is conveniently located for access to services and facilities by walking and cycling in Northampton and surrounding villages and would form a logical extension on the edge of Northampton.

12 March 2018 Page 75 of 399 5.1.9 Technical information in support of the proposal demonstrates that up to 75 dwellings can be constructed on- site and is available, achievable and deliverable in the next 5 year period in order to meet the pressing need for new housing to meet Northampton’s need.

5.1.10 This development, as proposed, clearly constitutes ‘sustainable development’, is viable and deliverable and should be considered as a potential site to be allocated. Land at New Street, Weedon Bec

5.1.11 Gladman propose that land at New Street, Weedon Bec (shown in Figure 2 below) is allocated for residential development.

Figure 2: Land at New Street, Weedon Bec – See attachment

5.1.12 Weedon is identified in the DLPP2 as a Primary Service Village and consequently is considered to be a sustainable location for further growth.

5.1.13 Weedon Bec in fact has a significant range of services and facilities within the settlement including; Primary School, Doctors, Employment, Convenience and Comparison Shops, Pubs and Takeaways. There is also a good range of employment opportunities nearby which are accessible by public transport. Therefore it is clear that Weedon Bec is a suitable location for development.

5.1.14 The proposed site is well contained and defined by existing development to the north and west, existing development and Farthingstone Road to the east and hedgerows to the south. Development of the site would constitute a natural extension to the village.

5.1.15 The site is also conveniently located close to a range of facilities and services in the village.

5.1.16 There are no technical constraints that will prevent development from coming forward in this location and it is considered that the site could deliver 121 dwellings.

5.1.17 This development, clearly constitutes ‘sustainable development’, is viable and deliverable and should be considered as a potential site to be allocated.

Land at Brington Road, Long Buckby 5.1.18 Gladman propose that land at Brington Road, Long Buckby (shown in Figure 3 below) is allocated for residential development. Figure 3: Land at Brington Road, Long Buckby – See attachment

5.1.19 Long Buckby is categorised in the DLPP2 as a Primary Service Village. It has a number of facilities including Primary School, Doctors, Convenience and Comparison Shops, Pubs and Takeaways. There is also a good range of employment opportunities nearby which are accessible by public transport.

5.1.20 The site is located on the southern edge of Long Buckby and is considered to be a logical extension to the village which is well enclosed with existing residential development bounding the site on three sides. It is also conveniently located close to existing public transport

5.1.21 The site is suitable for residential development and there are no technical constraints that will prevent development from coming forward in this location. It is considered that the site could deliver 87 dwellings.

5.1.22 This development, clearly constitutes ‘sustainable development’, is viable and deliverable and should be considered as a potential site to be allocated.

6 CONCLUSIONS 6.1.1 Having considered the DLPP2, Gladman have raised a number of matters that should be taken into account as the plan preparation process develops. This includes the need for planning policies to take a positive approach towards delivering the development needs of the urban and rural communities across Daventry and to support delivery across the wider West Northamptonshire Area.

12 March 2018 Page 76 of 399 6.1.2 When allocating land for new development, local plans must be suitably pragmatic in order to ensure that they become an effective tool in managing development. To achieve this, they must provide a suitable level of flexibility and contingency to respond to changes in circumstance over the plan period. The housing requirement contained within the WNJCS and associated part 2 local plans must be treated as a minimum requirement for the purposes of allocating land for development and sufficient land should be identified within the plans to demonstrate that this requirement can be achieved and exceeded whilst maintaining a rolling five year housing land supply in both the NRDA and the rural area. To achieve this, an appropriately flexible strategy for accommodating growth must be taken forward. In doing so, development should be directed to locations that are well related to the NRDA as well as to all sustainable settlements to support their future vitality and viability in terms of the services and facilities that they can provide now and in the future to meet the needs of residents.

6.1.3 Gladman have highlighted a number of sustainable development opportunities through these representations and request that they are included as residential allocations.

6.1.4 We trust that these comments have been constructive and request to be added to the consultation database and to be kept informed regarding the progression of the emerging DLPP2 and future consultations.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 ED11 Stephen Lucas

Organisation: Representing: Lucas Land & Planning Redinvest Ltd

Support/Object:

Supporting Documents: Map and photos attached

Comment:

Chapter 5: Development in the rural areas: 5.1 Rural areas 1. 5.1.05: All local housing need surveys must be fully comprehensive.

2. In previous years some housing needs surveys have lacked the required comprehensiveness and their use is therefore questionable. If reliance is to be placed on these surveys for planning policy purposes then there needs to be close liaison and agreement with recognised external housing consultancies and outside organisations.

3. 5.1.09: There needs to be the opportunity for landowners to be kept fully informed and appraised of any emergent character studies or appraisals as these studies have important policy implications - the district council should contact landowners who might be affected.

4. In this respect any such studies or exercises cannot be 'bottom drawer officer only' policies which have not been through effective and thorough public consultation. Too often land and property owners are the last to find out about any planning studies which might affect their land. The need therefore is to keep owners abreast of emergent planning studies so that best practice takes place as noted under paragraph 155 of the National Planning Policy Framework (NPPF).

12 March 2018 Page 77 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 ED99 Gareth Jones

Organisation: Representing: Savills Society of Merchant Venturers (SMV)

Support/Object:

Supporting Documents:

Comment:

Reserve Sites

Furthermore, we would recommend that the Council identify reserve sites and include a policy mechanism to release reserve sites. This would make the Plan more robust i.e. to ensure that development is plan-led and has been positively prepared to respond to changed circumstances.

Accordingly, a policy mechanism for reserve sites to be released should be included in the Plan if monitoring identifies a failure against the rural area or District housing trajectory and/or a shortfall against the five year land supply. The reserve sites approach represents an ‘insurance policy’ by increasing the likelihood of meeting the baseline housing requirement for the rural area and/or District. An example of the new policy wording for the reserve sites is set out below:

RECOMMENDED NEW LOCAL PLAN (PART 2) POLICY ‘The following sites with anticipated housing capacities as shown, are identified as Reserve Sites for the rural area on the relevant Proposal Map: Brixworth · Land off Northampton Road (Ref: 114) – for approximately 150 dwellings. · Land off Station Road (Ref: 115) – for approximately 15-20 dwellings.

Crick · [insert reserve sites]

…etc. The Local Planning Authority will permit housing and related development on one or more of the Local Reserve Sites in accordance with the Council’s Settlement Hierarchy only if monitoring indicates that: a) the housing requirement for the Daventry District rural area is unlikely to be achieved, or b) the most up-to-date baseline housing requirement for Daventry District is unlikely to be achieved, or c) there is an identified shortfall against the five year land supply in Daventry District.

The sites will remain subject to countryside policies unless and until the Local Planning Authority identifies a need for them to be released for housing.’

This ‘reserve sites’ approach has been recommended by the Local Plan Expert Group to the Government. The reserve sites should be plan-led and in accordance with the Council’s Settlement Hierarchy, rather than relying on windfall sites coming forward. In this respect, Brixworth is identified as a ‘Principle Service Village’ and is the one of the most sustainable villages in the District.

The SMV’s land off Northampton Road and Station Road are immediately adjacent to the built-up area of Brixworth. As a result, it is considered that our client’s land at Brixworth could help meet any identified housing shortfall and be identified as reserve sites.

12 March 2018 Page 78 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 5.2.19 - 5.2.22, policy RA2 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Object

Supporting Documents:

Comment:

We the Badby Parish Council Neighbourhood Plan Group believe that Badby should be categorised as an Other Village rather than a Secondary Service Village for the following reasons.

While the methodology of allocating points to facilities and services to create a hierarchy of village types is clearly designed to achieved a level of objectivity it creates problems insofar as it attempts to do the impossible by equating schools with bus services or pubs or shops in what can only be an arbitrary way. Also certain qualities which equally important in determining village status such as topography or ability to cope with additional traffic and parking are ignored although they may be quite critical in determining the planning policies which should be applied to a village. So the concept of applying policy RA2 to all Secondary Service Villages is too simple. Furthermore facilities such as pubs and bus services are without any guarantee of permanence and a hierarchy classification may quickly become out of date.

Whilst Badby meets the minimum general requirements on a points basis for a Secondary Service Village, it has neither a food store, post office nor other shops for residents' daily needs, all of which are considered to important that they are classified separately. Indeed, a food store and a post office are both within the Most Important Services and Facilities category. Surely, at least one of these two facilities should be a pre-requisite of a Secondary Service Village. These are used by all ages within the community whereas a pre-school facility is used by a limited range of the community. The main usage of the bus service (no. 200) is not to access village facilities but to allow residents to access facilities in Daventry and Banbury to meet their day to day needs. Furthermore the bus stop is on the edge of the village and is not easily accessible for all villagers, particularly those with mobility problems.

Newnham, Overstone, Ravensthorpe and Welton are all of a similar size to Badby and these have been classified as Other Village, the main difference being a pre-school facility and the bus service provision. Indeed, Ravensthorpe has a post office and a store which are surely more important to the whole community than a pre-school facility but they are classed as an 'other village'.

12 March 2018 Page 79 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Chapter 5 ED33 Cliff Cooper

Organisation: Representing: Crick Parish Council

Support/Object:

Supporting Documents:

Comment:

Chapter 5: Development in the Rural Areas. The major part of this is the creation of the Settlement Hierarchy. Unfortunately, whilst stating that the methodology has been two-stage, no details are given as to how the 2 stages have been implemented. In particular, how the ‘reflective’ element has been achieved and what weighting was given to each of the 9 elements in R1(2-10) is not explained. It is not therefore possible to comment on the results. It is perhaps unsurprising that Crick is seen in the Primary Service Village Category(PSV). What has been taken on board is that this Category has seen disproportionately high levels of development that have impacted and are continuing to impact on the quality of life of the villages concerned. In the Surveys for the Crick Village Neighbourhood Development Plan the stand out concern for adverse impact on the village and its character and tranquillity was the level of car activity in the village and parking problems.

What the proposals in Chapter 5 appear to take as accepted is that the Primary Service Villages will service other, less well serviced, communities.

This brings more traffic into the centres of the PSVs for access to those facilities and services.

What does not appear to be considered as part of future planning is that smaller villages are continuing to lose facilities and services and therefore are growing more and more into ‘dormitory’ villages and more and more dependent on PSVs to provide the facilities that they have lost.

Strategic planning should take this need on board and be supportive and encouraging in helping communities to retain and increase facilities as part of any development being undertaken in the other categories to seek to spread diversification over the rural area and to limit the need for car journeys between rural communities. This should be noted at this stage but should form a major aspiration when a new Plan is required for 2029 onwards to ensure the rural area generally remains vibrant and sustainable and does not become a few ‘small towns’ with pockets of sleeping quarters between them.

12 March 2018 Page 80 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 General ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

Finally, the Parish has had an ongoing problem with people purchasing small parcels of land (2 - 6 acres or thereabouts) and then populating the land with various sheds, abandoned cars, mobile homes, sea-containers and even a canal boat. Since none of these features are deemed as “Permanent” even though many have been there for a considerable time, there seems to be no planning power to ensure that they are disallowed. Can some wording be included to cover non-permanent fixtures such as sheds, caravans, etc so that they can be prevented from being littered in fields in open countryside?

12 March 2018 Page 81 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 LAA - Site ID86 ED126D Sebastian Charles

Organisation: Representing: Aardvark Planning Law

Support/Object: Object

Supporting Documents: Map of consented scheme (ED126E) Moulton inset map (ED126F) Access Review (ED126G) Detailed plan (ED126H)

Comment:

Previous submissions In March 2016 and again in September 2016 Daventry District Council made a Call for Sites to assist in their Land Availability Assessment (LAA). Land behind The Nest, Moulton was put forward as suitable and available for residential development. These plan representations build on that submission and include both The Nest and Land behind the Next.

Site ID 86 Land behind The Nest, Boughton Road, Moulton - Description of the site and background The Nest is located on the north-western edge of the village of Moulton, on the south side of the road that joins Moulton and the village of Boughton, to the west. There is residential development (Avant Homes/Salisbury Landscapes site) immediately opposite under construction, and recently consented residential development (Hallam Land) immediately adjacent to the east. Further east there is new residential development both, on both sides of Boughton Road. To the west of the site is the “Adventure Ways” business and then open fields.

Comments on the Council’s Assessment of Site ID 86 MOULTON – Land behind the Nest. Site ID 86 is described in the local authority’s assessment as a; ‘Greenfield site located outside the village confines. Unlikely that its development would result in environmental improvements nor has it been demonstrated that it is required to support retention of local services that are under threat.’

This statement is clearly not correct. Since 2011 the land between the village confines of Moulton and the Nest have all been granted planning permission for housing development so that the Nest & Land behind The Nest now sits on the very edge of the village’s confines and no longer sits in open countryside.

Those sites have been the former Salisbury Landscapes Depot, Hallam Land Management’s site on Land South of Boughton Road and the site now known as Mulberry Gardens developed by David Wilson.

In summary whilst the assessment of the Council was “Not Suitable” that finding is clearly out of date and not correct. It is submitted that the site is highly suitable in addition to being available and achievable, and hence is Deliverable.

The site is not within the village and would therefore be contrary to policy H1. Again, this statement is clearly not correct. Moulton village has now extended to the boundaries of the Nest on two sides and hence the Nest is immediately adjacent to and will on completion of the Construction of the Hallam and Avant developments comprise part of the Village.

Suitability Summary (Residential) The greenfield site is situated in an isolated location outside the existing confines and is not considered to meet the requirements of the JCS or Moulton Neighbourhood Plan at present. Once again, this statement is not correct. The Nest is no longer isolated and immediately abuts built or consented development.

Comments on the Moulton Neighbourhood Development Plan

12 March 2018 Page 82 of 399 In the Moulton Neighbourhood Development Plan Areas of Separation are identified (Fig 6 of Plan) to preserve a distinction between the villages of Moulton, Boughton and Moulton Park Employment area. However, the Salisbury Landscape site identified on this plan has already been found suitable for residential development and been granted planning permission and construction is now well advanced. Hence the intended line of separation is weak and out of date and hence the Neighbourhood Plan is out of date in that regard. The residence The Nest now abuts built development. The minimal landscaping on the western boundary of the Hallam Site does not form a suitable or defensible boundary or transition. Whilst the principle of an Area of Separation is supported it is submitted that the Neighbourhood Plan is out of date and the Area of Separation should be redrawn taking into account Avant/Salisbury Landscapes and the opportunity that development of the Land behind the Nest presents to create a strong and defensible edge to the settlement of Moulton.

Why the village envelope proposed in the Local Plan is wrong. The existing plans do not include the Nest which is now surrounded by development on two sides. It follows that the recently completed HELAA assessment is also out of date as does not recognise the Hallam Land permission on the adjacent site to the East of the site or the housing site immediately to the North. The Nest properly now forms part of Moulton.

The current situation has not been achieved in a planned way but by default, leaving an abrupt edge to the village boundary between development and countryside. This is indefensible in landscape terms and we would contend contrary to the wishes of the local community when the Neighbourhood Plan was drafted.

What is proposed by the owner for this site? The edge of the village needs to be re-established. Currently the edge of the village is defined by high density residential development that has been granted planning permission out with the Local Plan system. Northamptonshire villages are characterised by low density housing at their peripheries and woodland. We would propose that this site should contain low density housing that would be suitable for self-builders with a 12 to 15 metres band of land around the perimeter of the site given over to woodland landscape. This band should contain not only native species to establish early on a protective hedgerow but should be planted to allow over time native broad leaf trees to establish. A band of this width within a period of 20 to 30 years will produce a band of woodland that will obscure not only this development but also the high-density housing adjacent to this site.

Why the site is suitable for development? The site will no longer sit in isolation when the adjacent sites are developed. It will have easy access to new footpaths and cycle routes and is in easy walking distance of the village’s commercial, cultural and sporting facilities. It is easily accessed from the Boughton Road and all major services either run though the site or are adjacent to the site.

Sustainability As part of the Call for Sites, no request was made to demonstrate how bringing the site forward would contribute to the retention of local services. However, it is easy to demonstrate that the site is in walking distance of Moulton with its many facilities and is in cycling distance of one of Northampton’s major employment areas. A low density residential site would contribute to the viability of these services and yet not overburden crucial medical and education services.

On recent schemes of a similar size we have been able to demonstrate that the 12 to 15 metre landscape zone that we are proposing for the site is able to successfully screen high density housing on adjacent sites. This level of tree planting also makes the need for Swales and other SUDS schemes redundant as within 3 years the trees will start to take up naturally the rainwater that the SUDS schemes on other sites are holding, thereby making their need redundant. This approach has significant benefits for wildlife.

Access fully compliant with all relevant standards is achievable see Create report Our clients have recently appointed Create Consulting Engineers Ltd to assess the possible access options for this site, the current traffic speeds and the vision splays necessary. They have considered all options and conclude that a simple access is adequate to serve up to 40 dwellings although between 15 to 20 are proposed. That entrance would be situated mid-way between the Nest and the site’s western boundary that meets the Boughton Road. Create Consulting’s report is included in the appendices.

12 March 2018 Page 83 of 399 Gas main and sewers on the site are not a material constraint A gas main and mains sewer run through the site, but the planning of the site is not materially constrained by a these and they merely create an opportunity for landscaping within the site and the opportunity to create new habitats and improve biodiversity.

What type of development is the site suitable for? Follow the status quo? A continuation of the type of residential development as per the Hallam proposal is possible – this is inevitable on the site if it isn’t planned for and will be likely to come forward on appeal if and when the Council is unable to demonstrate a 5-year housing land supply (as demonstrated by David Wilson Mulberry Gardens site

Or a lower density scheme with a defined edge offering self-build. The Government introduced in 2015 the Self-build and Custom Housebuilding Act 2015. This act was introduced to place a duty on certain public authorities to keep a register of individuals and associations of individuals who wish to acquire serviced plots of land to bring forward self-build and custom housebuilding projects and to place a duty on certain public authorities to have regard to those registers in carrying out planning and other functions.

It therefore follows that local authorities should be minded to bring forward suitable sites for self-build and custom housebuilding in their local plans. There is an absence of these sites in this consultation document and it is incumbent on the local authority to recognise this growing need. This approach would meet local demand for choice for non-estate house types and would demonstrate that the local authority was taking a pro-active approach to planning and were in accord with the direction of current government policy.

Why should the site be allocated now? By allocating the site it would end the uncertainty for the owner who has seen his private residence engulfed by development. It is certain that it will come forward for development one day, but uncertainty as to the timing unless allocated has a severe an impact on his personal circumstances and family. Although planning permission has be granted for various works to the Nest, including to potentially accommodate an elderly relative, the expenditure would be wasted if the Nest and/or Land behind the Nest was to come forward for development. This is a human rights issue.

If allocated now, the development would be able to come forward in a planned way, for instance providing a footpath and cycleway connections that could be made to the adjacent Hallam development as it is being built. Furthermore the landscape could be developed in consultation with the local authority to achieve a transition between open countryside and the adjacent high-density housing for the village boundary. The result would be development that could fulfil the aspirations of Moulton village as originally proposed in the Neighbourhood Plan with a strong and defensible Area of Separation created.

12 March 2018 Page 84 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.1.03 ED111 Toby Haselwood

Organisation: Representing: Sworders Baker Family Trust

Support/Object: Object

Supporting Documents: Attached - map

Comment:

Local plan site representations. BAK1737 215356 - Land at Crick, Daventry. See attached site plan – drawing number BAK1737 215356 DWG100 submitted alongside these representations.

Paragraph 5.1.03 of the emerging plan states that; the requirement for the rural areas has been exceeded, as at 1st April 2017 by 520 dwellings with 12 years of the plan period remaining.

Whilst this is not disputed, it should be noted that the potential delivery issues set out below could easily lead to the District falling behind with their numbers which in turn will lead to a shortfall in their five year housing supply that could then lead to speculative residential applications in rural locations in the district that have not been positively planned for.

As such, we believe that to ensure greater flexibility the plan should include some small scale allocations and increase the requirement for the rural areas over the plan period.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.1.03 ED113 Toby Haselwood

Organisation: Representing: Sworders Michael Thompson

Support/Object: Object

Supporting Documents: Attached - site plan

Comment:

Local plan site representations. THO1911 216388 Re: land at Boddington Road, Byfield. See attached site Plan – drawing number THO1911 216388 DWG001, as submitted alongside these representations.

Paragraph 5.1.03 of the emerging Plan states that; the requirement for the rural areas has been exceeded, as at 1st April 2017 by 520 dwellings with 12 years of the Plan period remaining.

Whilst this is not disputed, it should be noted that the potential delivery issues set out below could easily lead to the District falling behind with their numbers, which in turn will lead to a shortfall in their five year housing supply that could then lead to speculative residential applications in rural locations of the district that have not been positively planned for.

As such, we believe that to ensure greater flexibility the Plan should include some small scale allocations and increase the requirement for the rural areas over the Plan period.

12 March 2018 Page 85 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.1.05 ED97 David Ward

Organisation: Representing: Wilson Bowden Develoments Ltd

Support/Object: Object

Supporting Documents: Attached - aerial photograph and map

Comment:

In respect of Land north of A45 High Street, Weedon Introduction and Background to Objections

Weedon is rightly identified as a Primary Service Village in the emerging Plan. It offers a range of service provision and it represents a sustainable location where some residential growth should be accommodated to meet local needs and to provide choice and flexibility in housing provision across the District.

Weedon is currently experiencing considerable change as a result of the bypass implementation. Indeed, this significant spatial intervention also indicates a need for specific plan-led consideration of land use issue arising in the settlement.

The emerging Plan seeks to argue that it doesn’t need to allocate further residential land within the wider rural areas because WNJCS target figures for the supply of housing land have already been met. Indeed, in our judgement the emerging Plan seeks to avoid taking responsibility for such allocations by delegating them to future Neighbourhood Plans, and only then in the event that ‘need’ is identified.

We do not consider that this is a satisfactory approach (which goes to the ‘soundness’ of the emerging Plan), especially given the clear principles in NPPF that the planning system should (inter alia) be seeking ‘to boost significantly the supply of housing’ and ‘identify a supply of specific developable sites’ not just to meet a 5 years’ supply, but well into the future. Furthermore, the presumption in favour of sustainable development and the need to positively plan for development within the area are not being properly addressed by the current draft of the Plan.

Indeed, when one then considered that the recent Neighbourhood Plan exercise for Weedon has ended-up in the Draft Neighbourhood Plan being withdrawn, this also demonstrates that the opportunity to plan positively for this ‘Primary Service Village’ is being overlooked. (A further problem with delegating responsibility to Neighbourhood Plans is that historic boundaries for Parishes do not always sensibly reflect a logical land use/sustainable development considerations in today’s world – This is certainly the case in Weedon, where land north of the A45, but close to the village centre, is out – with the current Parish boundary).

It is in this broader context, that we seek to promote the inclusion of a new residential allocation on land north of the A45 High Street Weedon. (Identified on the attached plans). This 16 acre site is now clearly defined by the alignment of the new bypass. It relates extremely well to the village centre and it creates a sensible and justifiable addition to the ‘confines’ of the built area.

Access is achievable from the frontage and there are no other constraints which would restrict development.

Development of the site would support local services, offer affordable housing, respond to market demand, provide choice and flexibility, and be a sustainable form of development for the village of Weedon, whilst, at the same time, helping the District to plan-positively to meet the NPPF objectives.

Objection to Para 5.1.05 The supporting text in this paragraph is inappropriate. The Plan should be positive in its approach and identify appropriate locations for growth (especially in Primary Services Villages). In our views, it is not sufficient to delegate responsibility for residential allocations to the Neighbourhood plan-making process in the context of positive

12 March 2018 Page 86 of 399 planning as required by NPPF.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.1.07, 5.1.09, 5.2.16, ED83 Mark Blaber 5.3.01, policies RA1 to RA5

Organisation: Representing: BRANE

Support/Object:

Supporting Documents:

Comment:

Brixworth Residents Against New Estates (BRANE) was formed in 2011 in response to an unplanned application for significant housing development ln land that was (and still is) important to the setting of Brixworth. BRANE has co- operated with the Brixworth Parish Council (BPC) and the Brixworth Neighbourhood Plan Steering Group (BNPSG) and BRANE is a strong supporter of the Brixworth Neighbourhood Development Plan.

The Daventry District Council (DDC) draft Countryside and Settlements Plan (the Part 2 Local Plan or LP) addressed the issues of development in the district until 2029 and the purpose of this response is to express concern in two main subject areas referring to development in the rural area of DDC.

Development in the Rural Area - Chapter 5 a) Issues relating to policy R1 The draft LP makes reference in para 5.1.02 that Policy S3 of the West Northants Joint Core Strategy (WNJCS) sets out what the rural areas will be focus for about 2360 dwellings to 2029 - although this figure not a ceiling. In para 5.1.03 it is acknowledged that the requirement for the rural areas has been exceeded by 520 by April 1 2017. Para 5.1.04 states that the WNJCS spatial strategy would be significantly undermined if this trend were to continue and therefore managing further developments in the rural areas is "clearly an important issue". Para 5.1.07 refers to "Policy R1 has provided clear guidance since adoption of the WJNCS" but then goes on to say that "Policy R1 will not longer be required. Its purpose having been achieved…..Consequently once this Plan is adopted policies RA1 to RA5 will superseded Policy R1". This Group believes that the word "superseded" is incorrect here as Policy R1 is part of the WNJCS and has been fully accepted by DDC. It is not unreasonable to have slightly different development assessment approaches for the settlements in the different hierarchies and suggest that the Policies RA1 to RA5 are supplements to Policy R1 and therefore do not replace it.

BRANE supports entirely the para 5.1.09 suggesting that there are important features that are fundamental to a village's character, including open space and key views and recognising the importance of considering evidence such as conservation appraisals, village design statements and neighbourhood development plans; all of which Brixworth has in place and all are supported by the community. In particular as accepted by the Examiner in the recently "made" Brixworth Neighbourhood Development Plan, certain areas on the north, south and south west of Brixworth are important to the community and the setting of Brixworth.

In para 5.2.16 BRANE also supports the statement that (in Primary Service Villages) "a number of villages have experienced higher levels of development in recent years….certain services and facilities are under pressure…..development within those villages will generally be focused on sites within the confines." BRAN believes that the word "generally" when applied to Brixworth is too vague and should be deleted. Brixworth has had significant development and during the lifetime of this Plan will have growth by at least 16% - without taking into account the development that will arise from infill within the confines.

Finally, with regard to Settlement Hierarchy, we believe that any assessment of amenities and infrastructure would be incomplete and misleading without an informed and accurate appraisal of their capacity to cope with any increases in demand due to development in both the Primary Service Village and the other villages it serves.

12 March 2018 Page 87 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2 ED3 Susan Poole

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

Brixworth needs Sufficient Roads, Pollution Controls, Health and Education facilities FIRST before any more houses. The Development which has taken place already has resulted in Brixworth becoming Unsustainable. Cars queue to park at the shops and are parked on pavements in many areas in the village forcing pedestrians to walk on the roads. Journeys that took 25 minutes now take 1 hour or more. The Health and Prescription Services are overwhelmed, and the School is close to bursting point. It would be sensible to promote Secondary Service villages such as, for example, Guilsborough (whose Primary School is so undersubscribed that they are having to advertise in other Villages for pupils) to Primary status so that Development can take place there, and not make the Sustainability problems in Brixworth even worse.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2 ED69 Anne Cowan

Organisation: Representing: Maidwell with Draughton Parish Council

Support/Object: Object

Supporting Documents:

Comment:

Overall we believe the draft plan will help to set an appropriate context for any development proposals in our rural settlements and countryside. There are two points that Maidwell with Draughton Parish Council would like to be taken into consideration in preparing the final version of the Local Plan Part 2. 1. Paragraph 5.2: As a Hamlet there would be no development in Draughton in the period to 2029. This seems too restrictive and that appropriate growth of say 1 or 2 new dwellings, in total in Draughton in that period of over ten years, would be healthier than a complete freeze.

12 March 2018 Page 88 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2 ED71 Karen Edwards

Organisation: Representing: Residents of Staverton

Support/Object: Object

Supporting Documents:

Comment:

Our objection relates to the 2 stage approach used to establish the proposed Settlement Hierarchy. Therefore, all references relate to the supplementary ‘Settlements Hierarchy’ document, used to inform paragraph 5.2 of the Local Plan part 2.

For the following reasons we believe that Staverton Village has been allocated incorrectly to the category of Secondary Service Village and should be re-designated as Other Village: -

1. Scoring mechanism used for the Quantitative Assessment a) We believe that the weighted scoring system is fundamentally flawed as the presence of a facility/service is afforded the same points regardless of how many of them exists e.g. Braunston has 4 pubs and Staverton has 1 pub yet they both score 10 points. In terms of Employment Provision Braunston has:- a General Store, a Post Office, a Butchers, a Hairdressers, a Community Café, Gongoozler Café, a Canal Museum, Boat Hire, a Marina, a Fish and Chip shop, a Chandlery, Wharf House Narrowboats, Direct Marine Components Ltd, Minden Systems Ltd, Inspiron, Days Afloat, Vega Racing Components, Braunston Garage, a canal side Shop, Coffee Classics Ltd, Union Canal Carriers Ltd, Beta Marine Spares and Service, Lister Spares, ISUZU Sales and Service Dealer and perhaps more of which we are unaware. In contrast Staverton has extremely limited Employment Provision, yet we both score 5 points. How the presence of a Pub can be deemed more important than a large number of employment opportunities is beyond us. Whilst you state that these areas are compensated for in the reflective assessment, it is not clear to us how this has been achieved in respect of Staverton i.e. you do not state that the most important services are limited to a primary school, a pub, a village hall (see related comments under 2)

b) In terms of Staverton you have awarded 5 points for a daily bus service. There is a bus from Daventry via Staverton to Leamington in the early morning and a bus from Leamington via Staverton to Daventry in the early evening. This service does not run 7 times a day or every day as stated. Therefore, the nearest employment opportunities within Daventry can only be reached by one bus in the early evening with no return service until early morning the next day. Part 2 of the Plan designates the Strategic Employment Areas as Crick, Brixworth, Long Buckby & Woodford Halse. Therefore, this service cannot be deemed to provide sufficient access to designated nearby Employment Areas on a day to day basis. Yet Staverton scores the same points as say Walgrave that is stated to have a bus (11 x daily) to two large employment areas of Northampton and Kettering, or Badby that has hourly services to Daventry & Banbury. This is a clear example that just because a service is present it does not follow that it fulfils a functional day to day need. Due to the extremely restricted and impractical nature of the bus service in Staverton, we believe our score should be 0.

c) Staverton has been awarded 5 points for shops/takeaway neither of which exist. The limited shop at Skylarks Farm was closed some time ago.

d) You have awarded Staverton 1 point for a Playground and 1 point for a Sports Ground, these are one and the same, so have been counted twice.

e) Taking the above observations and facts into account our total quantitative assessment score is significantly reduced.

f) Comparing Staverton to the general requirements for a Secondary Service Village Minimum Score, it fares as follows: -

12 March 2018 Page 89 of 399 3/8 Most Important Services and Facilities 30 Pub, Village Hall, Primary School = 30 2/4 of the Important Services and Facilities 10 Employment Provision = 5 2/3 of the Other Services and Facilities 2 Combined play area/sports ground = 1 Be located on a daily bus service 5 No daily bus service = 0 Total 47 Total 36

g) You state that Criteria 1-10 of policy R1 provided guidance on what should be considered when establishing the Settlement Hierarchy, with the emphasis in regard to the quantitative assessment largely related to criterion 1, i.e. The presence of services and facilities to meet the day to day needs of residents, including those from other surrounding settlements. The Primary School could be argued to meet this criterion for a very small percentage of Staverton residents, and for a greater number of surrounding settlements. However, it is ridiculous to conclude that the presence of a village hall and a pub meet the day to day needs of residents, or surrounding settlements.

2. Reflective Assessment a) It is stated that the 65 bus provides a daily service to Daventry, Southam and Leamington Spar, operating 7 times a day offering relatively good access to employment opportunities. As already mentioned (in 1 above) this is incorrect.

b) It is stated that since 2011 two dwellings have been completed, this is incorrect three dwellings have been completed (3 bed house Vine Tree Farm). A 3-bedroom house has also recently been built on Badby Lane with a further 4 houses along Badby Lane nearing completion. In addition, a Barn conversion has been granted permission within Staverton Village, which is due to commence within the next few months. A total of 9 since 2011.

3. Businesses in Staverton/Employment Provision - Appendix A You have cited several Businesses offering employment provision, please find corrections as follows: 2 8 0 5 3 8 6 6 Milburn Boats = No longer exists (closed) 28050537 M Davies Ltd Showroom Hillside Badby Lane Staverton NN11 6DE = Counted 3x 28003235 M Davis Ltd Hillside Badby Lane Staverton NN11 6DE all same 28057707 Workshop New House Badby Lane Staverton NN11 6DE Business 28003325 J A Hall Garden Machinery Badby Lane Staverton NN11 6DE = No longer exists (deceased) 28042621 FURNITURE FIRST LTD Vine Tree Farm Daventry Road Staverton NN11 6JH = B8 Storage only 28002955 Staverton Garage Daventry Road Staverton NN11 6JH 28043204 Paint N Powder Services Catesby Road Staverton NN11 6JP 28050431 Rural Enterprises CIC Green Acres Catesby Road NN11 6JP = Majority of staff are Volunteers 28050432 Nice & Stripey Green Acres Catesby Road Staverton NN11 6JP 28051782 Frazer James Furniture Ltd Catesby Road Staverton NN11 6JP 28003312 Staverton Park Golf Club Daventry Road Staverton NN11 6JT = All part of the Hotel complex 2 8 0 5 4 4 0 1 Hand Carwash Staverton Park Hotel Daventry Road = No longer exists (closed)

In addition:- 28044484 Community and Public Pavilion Daventry Road Staverton = Does not exist

4. Most Important Services/Facilities We appreciate that your initial work was informed by those that chose to respond to your Consultation in 2016. Unfortunately, like the vast majority of Staverton Parishioners we were unaware of this Consultation.

We have since learnt that our Parish Council Representatives offered ‘No Comment’, although none could recall the Consultation.

Therefore, you have to an extent been informed by the minority who did respond.

You state that Services/Facilities that offer an important role in meeting the day to day needs of residents and contribute to their sustainability, warrant inclusion in the most important category. Again, we would argue that a Public House should not fall within this category.

5. In Summary Staverton has sparse facilities limited to a Public House, a Primary School, and a Village Hall, none of which are under threat. It also has a small play/sports area, where recently play equipment has been condemned. All day to day needs are met by Daventry e.g. Secondary School, GP Surgery, Shops, Post Office, and employment opportunities.

12 March 2018 Page 90 of 399 There is a very small employment provision provided by the presence of a handful of Small Businesses. There are no safe walking or cycle routes to the outlying employment provision. There is an extremely poor and impractical bus service that does not run every day, therefore the majority of residents are dependent on private transport to travel to work, shops doctors etc. A substantial area of the Village lies within the Conservation area and the Village is entirely surrounded by SLA. The Staverton Housing Needs Survey indicated that 11 existing residents may have a housing need. To date since 2011 four houses have been built and a further 5 are currently under development, which could help meet this need. Staverton has low capacity to build within its confines and in terms of infrastructure it has many roads and lanes unsuited to an increase in cars, and an at capacity sewage system. Part 2 of the Local Plan intends to allocate a minimum of 800 units within 10 mins safe walk of Staverton, therefore any residual need could easily be met by that development in particular any affordable needs, or by a small amount of development within Staverton. Encroachment onto ‘Open Countryside’ should be declined as the rural housing need has been exceeded.

Based on elements covered by our feedback to the proposed Settlements Hierarchy, the limited range of services and facilities, and relatively small scale of Staverton, we believe that Staverton should be re -categorised as an ‘Other Village’ as defined below.

Other villages - These villages have an even more limited range of services and are more reliant on the services of larger centres for day to day needs. The scope for development within these villages is likely to be limited to windfall infill development, although some housing to provide for local needs may be suitable.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.01 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object:

Supporting Documents:

Comment:

Badby Parish Council questions the allocation of Settlement Hierarchy and the way that both the quantitative and qualitative assessments have been applied. Although it does recognise the points system of allocation being used, the weighting system seems not to reflect the true degree to which each service contributes. We do not find the descriptive analysis of Badby (notwithstanding the erroneous reference to Yelvertoft) justifies the retention of Badby as a Secondary Service Village.

Badby has no shops or other retail outlets, and it is a half-mile walk for residents in the centre of the village to the bus stop. We accept that the school provides a service for some residents, but a minority (Daventry town rather than neighbouring villages is a major contributor), and that situation is unlikely to improve, given the ageing population of the village.

In our view Badby is more properly described as having 'an even more limited range of services and are reliant on the services of larger centres for day to day needs" - i.e. it would be better suited as and 'Other Village'.

12 March 2018 Page 91 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.01, Appendix A, ED23 Geoffrey Edwards stage 1

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Staverton fits perfectly into the definition of ‘Other Villages’. We rely totally on Daventry for all our needs. We are an infill only village totally surrounded by Special Landscape Areas. We have no shop or takeaway (scored 5 points). A single bus service to Leamington (07:30) and to Daventry (18:15). (scored 5 points)

So Staverton should be scored 37 not 47 on the Quantitative Assessment Scoring Sheet Several of the businesses used in the reflective appraisal are no longer in existence - Hand Car Wash (ref 28054401), Milburn Boats (ref 28053866) , Skylarks Farm Shop (ref 280492855) M Davies Ltd is triplicated. And lies outside the village and is only safely reachable by car.(ref 28050537, & 28003235 & 28057707 - workshop) Furniture First is B8 storage only. The company is based in Daventry. (ref 280426261) The Pavilion burned down 10 years ago and no longer exists (ref 280444484)

In essence Staverton is a small residential village with sparse facilities & services and fits perfectly with the definition of Other Villages in The Settlements & Countryside Local Plan (Part 2) para 5.2.23

12 March 2018 Page 92 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.05 ED68A Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object:

Supporting Documents:

Comment:

SPC would like to congratulate DDC on the hard work that has gone into the production of all the documents in relation to the plan. There is a very good suite of documents that encompasses a model and principles that seem fair. They commend the council on the use of both quantitative and qualitative assessments and feel by using the two types of assessment this is the best way of establishing the correct hierarchy to place each settlement within the appropriate category. It is noted that there is in fact, not that much difference, in policy between the hierarchy levels and that the hierarchy is supported overall by a strong framework. Therefore, SPC are not of a mind as to which settlement it falls in. However, SPC would like to point out the following anomalies in the quantitative and qualitative assessments: INFRASTRUCTURE (1) Staverton has a daily bus service consisting of one bus service a day not the seven that are listed. Furthermore the service sees two buses a day Monday to Friday one leaving at 7:30am in the morning to Leamington and one at 6:15pm in the evening resulting in the position it is not possible to get a daily return to Daventry. (2) The village no longer has a shop as Skylarks (the local farm shop) has closed LEISURE (3) Staverton has been listed as having a cricket pavilion, but this has in fact burned down BUSINESS (4) M Davies, a local business, has been listed three times where it is in fact just the one business (5) Furniture First has B8 storage and therefore does not have individuals employed on the site but is a transitional station ENTERPRISE (6) The rural enterprise scheme listed is in fact a voluntary organisation We therefore ask that DDC correct the anomalies listed above and ensure the assessment is factually correct . In addition it has been noted that regardless of the amount of service/facility a village has e.g.. 1 pub or 4 pubs the score awarded is the same.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.05 Table 2 ED154 Terry Dougan

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

The specific criteria used to allocate villages to the hierarchy should be clearly set out and the relative weight given to each element clearly identified. There should also be details of a review process to be applied should circumstances change.

12 March 2018 Page 93 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.05, Table 2 ED10 Gill Wells

Organisation: Representing: West Haddon Parish Council

Support/Object:

Supporting Documents:

Comment:

West Haddon Parish Council reviewed the consultation at its meeting Tuesday 5th December and forward the following observations:- Concern was raised that West Haddon had been designated as a secondary service village. However, with the potential and most probable cuts to the bus services as a result of forthcoming NCC budget funding cuts these services are likely to reduce transport services to and from the village significantly. Further, the medical provision / facilities in the village have declined rapidly over recent years. Shops are closing and / or under threat of closure. The telephone box is currently out of order and has been so for some months now.

The Council therefore queries the designation of West Haddon as a secondary service village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.05, Table 2 ED113 Toby Haselwood

Organisation: Representing: Sworders Michael Thompson

Support/Object:

Supporting Documents: Attached - site plan

Comment:

During the settlement hierarchy review in 2016 Byfield was demoted from Primary Service Village status to Secondary Service Village status and we believe that this should not have happened for several reasons.

As stated in the Settlement Hierarchy Background Paper, Version 1 – November 2017, Byfield has the required number of services and facilities to qualify as a Primary Service Village including; a GP surgery, preschool facilities (with capacity for a further 32 children), post office and general food store.

Although the local village shop/petrol station combination, Marley Farm shop, Cooperative and Post Office are not deemed to be sufficient to qualify for a Primary Service Village, we believe the other 30 different clubs, organisations and eateries in the village supplement this. For example the Byfield Village Club, the Cross Tree Inn, Byfield tennis club, the village hall, Holy Cross Church, several recreation grounds and The Brightwell which has bowls, cricket, football and tennis clubs, as well as an active Scout Group in the village - today providing activities for approximately 60 young people aged 6-14.

Supplementing this further, the number 200 bus provides an hourly service to the main towns of Daventry and Banbury. Both towns are conveniently accessed from Byfield, each approximately 9 miles away. This excellent service provides easy access to other shops and employment opportunities in the local area.

We therefore believe that Byfield, as a sustainable location for some small scale residential development, should be reinstated as a Primary Service Village as illustrated in table 2. PLAN ATTACHED

12 March 2018 Page 94 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.05, Table 2, Policy ED11 Stephen Lucas RA1

Organisation: Representing: Lucas Land & Planning Redinvest Ltd

Support/Object:

Supporting Documents: Map and photos attached

Comment:

5.2 Settlement hierarchy Classification of settlements in the hierarchy: 1. We agree with the designation of Weedon Bec as a Primary Service Village - this designation as the highest order rural settlement in the district is long overdue and was recommended by the previous Local Plan inspector some 22 years ago.

2. The policy classification is recognition that Weedon Bec performs an important rural service role, with a significant and growing employment base with excellent and improving transportation links to the main regional centre in Northampton and emergent sub-regional centre at Daventry on a new main road link to the M1 motorway at junction 16.

3. In this context it is worth noting the approval of the Northampton Junction 16 Strategic Employment Site under Policy E8 of the West Northamptonshire Joint Core Strategy (WNJCS) this employment site is a mere few miles east of Weedon Bec.

Therefore we agree with the draft Primary Service Village classification for Weedon Bec: this policy notation for the village is entirely logical and frankly should have been initiated many years ago.

4. 5.2.7 confines: reference is made to the word 'confines' in the plan text but there is no definition as to what this means when the word is first introduced on page 30. We suggest a clear definition to be introduced on page 30 would be appropriate.

5. Confines, appear to us to mean all land within the village, which is separate from the open countryside beyond the village. Reference is made in the text that in drafting the confines 'professional site judgements have been made'. In our view it is essential that all site judgements are logical and consistent.

6. We note page 37 Table 3 which lists criteria for defining village confines. We refer to criteria A which is applicable to the Manor Farm curtilage and locality at Bull Inn Close. The text states the following will be classified as being inside the confines: 'Buildings and curtilages which are contained and visually separate from the open countryside that are clearly part of a coherent network of buildings that form the village'.

7. We refer you to the attached plans and photographs which clearly show the whole Manor Farm curtilage and complex as being part of the domestic extent of the village separated from open countryside beyond the village to the south by a historic curtilage hedge and line of mature trees.

8. That aspect is clear on plan, on the ground and from any photographic interpretation and we advise your officers to review the village confines in this locality as we are absolutely certain in land use and visual terms that the whole Manor Farm complex lies within the village. The area in question is neither important open space nor agricultural land - it is part of the domestic curtilage of Manor Farm.

Policy RA1 Primary service villages: 8. 5.2.18 Policy RA1: We agree with the designation of Weedon Bec as a Primary Service Village but we are firmly of the view that the draft confines boundary with respect to the Manor Farm area on the Inset Map is illogical and

12 March 2018 Page 95 of 399 inconsistent (please refer to attached plans and photographs).

9. Any conservation area appraisals as part of this policy need to be undertaken with the full involvement of the entire community which includes land and property owners who may be affected by any designations or appraisals. Best practice guidance noted in the NPPF and by the Institute for Historic Building Conservation (IHBC) and Historic England must be followed - this policy initiative as noted cannot be a 'bottom drawer' policy approach.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07 ED29 Patricia Fox

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I do not agree with the Confines as mapped as I believe the Confines in the Badby Village Plan as proposed are the correct Confines in order to keep the village the size it is currently enabling development to happen within these Confines only.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07 ED30B Katie Griffiths

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

We do not agree with extending the confines of Badby. We have lived in Nene Side Close for more than 10 years. We chose to live here because it is peaceful and lies within beautiful countryside.

Nene Side Close is a separate group of dwellings surrounded by fields and on the other side of the River Nene from Badby village. What we like most I that we are surrounded by fields rather than being in the village surrounded by houses. The fields around us are a sanctuary for wildlife. We often see sparrow hawks, owls, bats, foxes and deer even Red Kites! This is important and this matters to us. Nene Side Close is excluded from the confines of the village by the Neighbourhood Plan and our relationship to the village has not been changed by the building of new house on Pinfold Green.

The bungalows in Nene Side Close are mainly reserved for older people to enjoy the tranquillity of open fields and have a more relaxed life style. There are no advantages to us being included in the village confines but only disadvantages by allowing the fields around us to become exception sites to build more houses.

To extend the confines to include Nene Side Close would only risk jeopardising the countryside and the corridors for wildlife around us that give Badby its character mean so much to us. No confines line is going to change the fact that we are geographically and topographical separate to the village of Badby. We who live on Nene Side Close do not consider or feel ourselves to be part of the village of Badby.

12 March 2018 Page 96 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object:

Supporting Documents:

Comment:

Badby Parish Council would question the methodology of mapping the confines of villages. The confines of Badby village as presented in the draft Local Plan differ from those adopted in the draft Neighbourhood plan. In particular, Nene Side Close and also the top of Bunkers Hill have been included in DDC's version. The Parish Council believes that the confines in the NDP are in line with DDC's own criteria of 'detached building areas' being outside of the confines.

With regard to Bunkers Hill, there is no direct access to the residences from the village itself except up Bunkers Hill - a narrow lane with no pavements presenting risks to pedestrians. There is no street lighting for the group of 8 bungalows. Further, it is our view that those residences with gardens adjacent to open countryside (on the west side) are clearly outside of the confines of the village. There is an inconsistency in the treatment of garden on the east and west sides, such that the Parish Council believes that there is a contrived continuity of inclusion which it does not agree to be good planning policy.

Nene Side Close also feels and is physically separate from the main village. It is separated by the River Nene, and access is only via the pavement along the side of the A361. Views across the village tend to show the Nene Side development as physically separate from the rest of the Badby. We would argue that the Nene Side development has all the attributes of a rural exception site, in types of housing and positioning; were such a designation to have existed when it was built then it would now be deemed to fall outside the confines.

Finally, we do not find a consistency of approach in the inclusion or exclusion of the gardens of Trifidia, Bunkers Hill House and East View. The garden of Trifidia has been excluded from the confines when it is clearly a residential garden. We seek clarification as regards the inclusion within the confines of Bunkers Hill House and the gardens of East View. The Parish Council believes that the above differences need to be addressed and resolved before adoption of the draft Local Plan.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07 ED119 Catrina Signey

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I don't agree with the extension of the Badby confines. These are not the original boundaries of Badby village itself and by extending the confines you will encourage development that would spoil the beautiful vistas of this historical village. The surrounding countryside needs to be preserved for it's native wildlife, flora and fauna.

12 March 2018 Page 97 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07, Policies and ED116 Nigel Griffiths Inset map 11

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I object to the element of the Plan whereby it is proposed that the Village Confines for Badby will be extended to include Nene Side Close - NSC. My reasons are as follows: 1. Our property and all others in NSC share the same village address of Badby, Northamptonshire and therefore extending the Confines to confirm or underpin this fact is unnecessary. 2. My own research has, with the aid of DDC and other agencies, confirmed that extending the Confines to include NSC has zero benefits attached for either the Close or the Village. 3. Conversely to (2.) above there is an alarming DISADVANTAGE for NSC to be included within the drawn Confines and that is; by doing so the farming land adjacent to it could then become subject to planning application for residential property within 'infill land' which is in direct opposition to the protection that should be persuade for this area of 'outstanding beauty and interest'. And, would detract from the obvious and generous opportunities already available within the current Confines to provide housing for future generations.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07, Policies and ED68B Sue Porter Inset Maps 22

Organisation: Representing: Staverton Parish Council

Support/Object:

Supporting Documents:

Comment:

As part of the Neighbourhood plan process SPC have mapped and submitted to DDC a confines map. The SNDP confines map is not that dissimilar from the one that has been produced by DDC. SPC would hope that DDC adopt within their plan the plan that has been produced by SPC for the Staverton Neighbourhood Development Plan.

12 March 2018 Page 98 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.07, Policies and ED81 Kenneth Morris Inset Maps 9

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Object

Supporting Documents:

Comment:

We, the Badby Plan Neighbourhood Plan Group have two major concerns relating to the confines as detailed in the Policies and Inset Maps.

Badby is a compact, topographically defined village set in a hollow and we believe that both the bungalows on the north side of Bunkers Hill and Nene Side Close dwellings should not be included in the village confines. Both these areas meet the criteria for exclusion in table 3 of your plan as being detached or peripheral to the main body of the settlement.

Bungalows on the top of Bunkers Hill are a contrived addition to the confines by the use of one garden to link these dwellings to the rest of the village. Other gardens adjoining this one have been excluded from the confines. There is no pavement between the bungalows and the village. Above all, they are topographically disjointed from the village, which nestles on the southern flank on the Nene Valley and does not extend beyond the top of that flank.

The Nene Side estate, which lies to the north of the village and is separated from the village by the River Nene, cannot be accessed from the village other than by the A361. If constructed today the Nene Side estate would clearly be designated as an exception and therefore not included within the village confines. The estate is clearly outside the natural topographical confines of the village, which lie to the south of the Nene.

Both these areas were shown outside the confines on the map reproduced by DDC in 2003 and that map, in the case of Nene Side, was referenced in subsequent planning judgements.

We are also concerned by the inconsistency of the garden of Eastview, Brookside Lane but not that of Trifidia, Church Hill when both are clearly cultivated gardens.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.18, Policies and ED105B Nigel Ozier Inset Map 2 - Brixworth

Organisation: Representing: Aitchison Rafferty Brixworth Parish Council and Brixworth Neighbourhood Plan Steering Group Support/Object: Support

Supporting Documents: Attached - Landscape Statement, letter dated 26 January 2018

Comment:

Notwithstanding the objection made on behalf of Brixworth Parish Council and Brixworth Neighbourhood Plan Steering Group concerning the landscape study and proposed SLA boundary, we do however support the confines boundary as proposed on the Inset Map, and referred to in the Policy RA1(A).

12 March 2018 Page 99 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.19 ED68B Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object: Support

Supporting Documents:

Comment:

SPC are pleased to see that DDC are taking a policy approach to protect services and facilities within villages. Of particular priority for Staverton and many rural villages is the retention of local bus services. Daventry District has many small villages which does not create natural conditions for commercial bus operations. Furthermore, the current transport legislation offers limited powers/controls for the county/district councils to fundamentally change the commercial bus provision. However, SPC would ask that the plan sets out a specific framework of strategic and detailed policies in relation to the bus infrastructure that provides the basis for local solutions within a district wide context to enable a sustainable bus service.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.21 ED68B Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object: Support

Supporting Documents:

Comment:

SPC is pleased to see that DDC have included scope for provision of development outside of the confines and have subsequently then quantified the approach to regulate it. We would ask however, that DDC consider quantifying the approach further to include for only allowing for development adjacent to confines to ensure that there is no erroneous development adrift of a settlement.

12 March 2018 Page 100 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.21 ED42A Yvonne Dean

Organisation: Representing: Welford Parish Council

Support/Object:

Supporting Documents:

Comment:

3.0 There is an anomaly in statements that Daventry housing needs have been met against para 5.2.21 which states that housing needs surveys could over rule that expectation especially where neighbourhood plans have sought to limit development. In paragraph 4.1.03 reference is made to the WNJCS seeking 12,730 dwellings, 2,360 being in rural communities. This gives 30 dwellings across the 78 villages and in the same paragraph it should be made clear this target has been met as it still conflicts with Objective 9 of the Vision statement seeking 'limited development' in rural areas.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.21, policy RA2 ED107B, ED107B William Young

Organisation: Representing: Fisher German LLP

Support/Object: Object

Supporting Documents: ED107B Map

Comment:

In relation to the above policy and with particular relation to Spratton and the land shown on the attached plan – 8791/1 outline in red being approximately 6.2 acres, it is important that additional land outside the confines of development is made available for residential development in relation to Secondary Service Villages. When viewed in the context of the draw village confines, there is very little potential available for potential development both in relation to Spratton and other Secondary Service Villages.

With particular reference to Spratton the land identified on the plan attached outlined in red is in a highly accessible and sustainable location in close proximity to goods and services, and within walking distance.

Policies SB1 and HS1 of the Spratton Neighbourhood Plan specifically allow for the expansion of the village by accepting the development on individual housing sites of up to 15 dwellings within and immediately adjacent to the village settlement boundary, and do not place a cap on the total number of houses. This strategy specifically seeks to maintain the village’s strong and established sense of place. This approach has regard to the NPPF, where it requires policies to recognise housing growth and respond to local character. At the same time, the Plan in its entirety includes requirement for the provision of affordable housing and support for community facilities. To disregard this would mean that the housing development strategy for Spratton cannot achieve these aims.

12 March 2018 Page 101 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.2.23, Table 3B ED18B Jane Austin

Organisation: Representing: Overstone Parish Council

Support/Object:

Supporting Documents:

Comment:

Provide a definition for directly adjacent to.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.3.01 ED123 Karen Alexander

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Object to development in open countryside at site HO1 setting a precedent of developing on SLA.

12 March 2018 Page 102 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.4 ED16 Stephen Lucas

Organisation: Representing: Lucas Land & Planning

Support/Object:

Supporting Documents: Maps attached

Comment:

Housing Reference is made to the evidence base in respect of this matter and we make the following comments and observations

Section 5 Evidence Base and implications for the Local Plan: Paragraph 5.4: Comment is made that the Daventry North East SUE in part will come forward in the next 5 years. Due to issues with this site over a number of years we now need complete clarity as we do not believe anything on timing with regard to this matter.

We recall the Position Statement of March 2014 by the WNJPU and the then prospective developers Croudace Homes, which we know then was a complete fantasy. Despite this being the case the fantasy was carried forward to the WNJCS Inquiry. We knew at that time there were no development options agreed.

The requirement (particularly with regard to the emergent legislation) is an absolute need for a frank Position Statement concerning all the current approved allocations.

In this regard we are guided by paragraph 154 of the Framework: 'Local plans should be aspirational but realistic.'

12 March 2018 Page 103 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 5.5.21, policy RA2 ED107A William Young

Organisation: Representing: Fisher German

Support/Object: Object

Supporting Documents: ED107B map

Comment:

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 6.5.17 ED68B Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object: Object

Supporting Documents:

Comment:

SPC support the policy approach to address housing need, in particular to ensure a proportion of any development provides for smaller dwellings and bungalows. There are far too many executive style developments with 4/5 bedroom dwellings being built. It is noted that the text in paragraph 6.5.17 refers to bungalows whereas there is no descriptive text in the table referring to bungalows. It is felt this is contradictory and could lead to confusion and suggest the table should refer to bungalows as well. During the consultation process for the SNDP it was identified that there is a need/demand for the provision of bungalows within Staverton and neighbouring villages due to an ageing population. Therefore, it is felt the policy could be stronger and allow for a percentage of any development to include for a provision of bungalows.

12 March 2018 Page 104 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Para 9.2.03 ED68B Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object: Support

Supporting Documents:

Comment:

SPC support the Green wedge policy approach as the green wedge will not only act as a buffer between Staverton and Daventry, but also for other undeveloped open spaces and settlements within Daventry District. This approach will also provide for a separation between existing developments, enabling identity/character of individual settlements to be retained.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.1.01-5.1.11, 5.2.03 – ED59 Geoffrey Smith 5.2.04, Policy RA3, Policies and Inset Maps 50

Organisation: Representing: Welton Parish Council

Support/Object: Support

Supporting Documents:

Comment:

1. Chapter 5. Development in the Rural Areas 5.1 Provides a helpful and informative introduction including the footnotes. 5.2.03 – 5.2.04 Welton Parish Council agrees with the robust methodology used to determine where settlements were categorised in the settlement hierarchy and with Welton’s classification in the final hierarchy i.e. within the category of ‘Other Villages’ Policy RA3 ‘Other Villages’ Welton Parish Council supports this policy

12 March 2018 Page 105 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.1.02, 5.1.07, 5.1.09, ED87 Sarah Stock 5.1.10, 5.2.05/Table 2, 5.2.23

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 5.1.02 notes that the WNJCS reduces the housing requirement in rural areas from 2,360 to 2,029. Harlestone Parish has received outline planning applications for 1400 new dwellings, on top of the 250 either under construction or recently developed. Given the reduced requirement, HPC would urge DDC planning authority to reduce the number of dwellings planned for Harlestone Parish. Such a reduction would better reflect the Vision and Objectives set out in Chapter 3 which clearly state a desire to protect and preserve the rural character of the village and its surroundings.

Section 5.1.07 In the interests of clarity, it would be helpful if the text reflected that RA3 Other Villages and RA4 Small Settlements/Hamlets replaces EM15 Restraint Villages. This is not clear until Appendix E, page 156.

Section 5.1.09 & 5.1.10 welcome the intention to preserve the landscape and historic buildings which are fundamental to the character of the village. However, the policy does not cover/acknowledge the open space surrounding the village. Often such open space, creating separation from the urban area is fundamental to the character of a village and the policy should reflect this. It should preserve the rurality of an area. This is somewhat covered by Chapter 9/Section 9.2 but this section could be strengthened by including the intent to preserve rural separation in Section 5 Policy RA5-Open Countryside.

Section 5.2 Settlement Hierarchy. The definition of ‘Other Villages’ refers to “windfall infill development”. It is unclear what is meant by this term.

5.2.05/Table 2 (page 30) cite Upper Harlestone and Lower Harlestone as two separate villages under different classifications. We understand that there is a historic precedent for citing these villages separately. However, given that Upper & Lower Harlestone share the few services available, have one parish council, are protected by one conservation area and face identical challenges resulting from extensive local development in the parish; HPC ask that parity between the two villages is preserved so that both are classified as ‘Small Settlement/Hamlet’.

Section 5.2.23 Suggests that development in ‘Other villages’ should be limited to the confines of the village and should be small scale. While the confines of Harlestone Villages have been preserved in the current WNJCS, the Parish has increased from 210 dwelling to about 1800 dwellings. This impacts the rural character of the original village and HPC would like the definition of ‘Other Village’ to reflect that the setting and surrounding areas are as important as the confines of the village, as such any development outside the confines of the village but within the parish boundary must be considerate of the rurality of the village and planned new services can not have a detrimental impact on the village.

Section 5.3 Open Countryside. HPC are broadly welcoming of this policy but note that current plans for development in Harlestone Parish are incongruent with this policy.

12 March 2018 Page 106 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.1.03 - 5.1.05 ED84 Sharon Foster

Organisation: Representing: Badby Parish Council

Support/Object: Support

Supporting Documents:

Comment:

Badby Parish Council request qualification of how long into the 12 year period of the housing land availability does Daventry District Council actually meet or exceed the requirement. We note that this paragraph states a 'land supply in excess of 5 years'.

We note the fears that the scale of rural development could exceed the urban: rural ration envisaged in the Joint Core Strategy spatial strategy. While some development can be managed to maintain this balance, we are concerned that opportunistic and independent development shows no sign of abatement, and we hope that DDC will, in implementing the Local Plan, do all it can to reduce the effects of such development.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.2.05 - 5.2.18 ED65 Chris Myers

Organisation: Representing:

Support/Object: Support

Supporting Documents:

Comment:

I am pleased that confines will continue to be upheld in this Local Plan and hope that the concept will not be watered down or abandoned at a later stage. I support the proposed Strategic Employment Area in Long Buckby. I strongly agree that there is no justification for further allocations for residential development in Primary Service Villages. I would hope that in 5.2.16 the word "generally" can be removed from the sentence: "Development within these villages will generally be focused on sites within the confines of the village". Finally, I hope that the Local Plan can make strong statements about the need to have a currently valid housing needs survey in place in order that sufficient affordable housing is available for truly local people.

12 March 2018 Page 107 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.2.05 & 5.2.22, policy ED53 DJS & SE Wilson RA2

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

For the reasons set out below, we do not agree with and do therefore object to the classification of Badby as a Secondary Service Village (SSV) in the Hierarchy of Villages.

We do not agree with the weight attached in the quantitative assessment to certain services and facilities and feel also that too little weight has been afforded in the qualitative assessment to those fundamental assets such as the distinctiveness, character and role of the village and its landscape setting. In our view it is these assets that can neither be built nor bought which contribute most and matter most to people, their sense of place, their wellbeing and their quality of life.

Quantitative Assessment Bus Service. A major factor in classifying Badby as an SSV above comparable villages such as Welton and Newnham is the apparently arbitrary and, in the context of Badby, the wholly disproportionate weight attached to a bus service which stops only at the very edge of the village. In the absence of passenger numbers using the 200 service and their reasons for doing so, we think it most likely that people are leaving the village to access the services to be found in Daventry and Banbury rather than the other way around. People travelling northwards will hardly stop at Badby when just a few minutes more travel reaches the retail, financial, medical, sport, educational and entertainment facilities available there.

Proximity of Daventry Town. It appears that little account has been taken of the most important factor in determining the presence and viability of services in Badby, namely the nearby and dominating presence of Daventry Town. It is this above all, no doubt re-enforced by the connecting bus link to it, that serves to militate against the need for and hence viability of services within the village.

Badby Post Office was closed in 2008 because it was less than 3 miles from the town, and the shop that it helped support closed shortly thereafter.

It is noteworthy however that the more distant village of Byfield supports 2 shops, including a Post Office, a medical practice, one garage for fuel and another for repairs / servicing. Some of these services are also used by people from Badby.

With Byfield and Weedon nearby to the South and the East, and Daventry Town so close to the North, it is hard to see how Badby or any other village without public transport links will benefit from Badby being designated as an SSV.

Qualitative Assessment Character, Role and Distinctiveness of Badby Village. Badby fills a special role as an increasingly rare haven of rural tranquillity for the quiet enjoyment of the countryside, not just for its residents but for the wider community of the entire District and beyond.

The attractive and unobtrusive presence of the village compliments its surrounding unspoilt natural and historic landscape setting within the SLA. The Upper Nene Valley offers tranquillity and a sense of rural remoteness, dark skies and clean air, distant views, flora and fauna including Ancient Woodland, plus a footpath network with direct access to the countryside, long distance walks and a wonderful contrast to life in a town.

12 March 2018 Page 108 of 399 This is why people come to Badby. Few will remember its services, but most will not forget their country walk, the landscape, the Woods and the bluebells.

It is these priceless and irreplaceable assets that are becoming the more valuable and the more vulnerable due to their very proximity to the rapidly expanding urban area of Daventry and it is fundamental to the overriding principles of sustainable development that they are handed on to future generations in as good or better condition than they now are.

Implications of classification as SSV. Badby village has already expanded to the point where, given the topography and the importance of the scenic, natural, and historic quality of the adjoining countryside, little more growth can be achieved without spilling beyond its valley setting to the serious detriment of that landscape and substantial harm to the historic setting and character of the village within that landscape.

This would be especially undesirable in the case of Badby, where the landscape setting of the village is recognised the Draft Badby Parish Neighbourhood Plan as its principle asset.

We note that development will be looked upon more favourably in an SSV where it will help retain, improve or enhance services available to the village. As we see it, in addition to more houses, this could lead to the proliferation of the likes of farm shops, nursery gardens, animal rescue / shelter /educational establishments, with or without tea rooms and general retail additions. These often have scant connection to a village, derive little of their produce locally or from associated land and give rise to the sort of scruffy developments that fringe many settlements leading to the blurring of their edges with the countryside to the detriment of both.

The outskirts of rural settlements are especially vulnerable to the fragmentation of land holdings into uneconomic agricultural units. Securing additional facilities and services to improve the quality of life of village residents should not carry the risk of attracting further such development in circumstances such as these.

Conclusion Badby’s most important contribution to the District is in its role as a place of resort for the peaceful enjoyment of the countryside. Badby and the Upper Nene Valley are the gateway from Daventry to the SLA of the Ironstone Hills of the West Northamptonshire Uplands to the South.

Badby village can sustainably support as much new development as can be contained within its confines (see below) and without spilling outwards into the surrounding countryside to the detriment of both the compact character of the village and the quality of its landscape setting.

Given the paucity of existing services, the proximity of the town and the bus link to it, the growth of internet shopping, “click and collect” and home delivery services, and the lack of public transport connections to other nearby villages, it is hard to see how Badby can fulfil a meaningful role as an SSV, regardless of the amount of additional future development and except at the expense of its primary contribution to the District. Due to its narrow streets and dearth of off road parking problems, the village can scarcely cope with its present traffic congestion and parking problems, let alone cater for more.

For the reasons set out above, we ask please for a reassessment of the classification of Badby as an SSV with a view to its placing in the category of an Other Village in the hierarchy of villages.

12 March 2018 Page 109 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.2.05 and 5.2.22, ED30B Katie Griffiths policy RA2

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Do not agree with paragraph 5.2.05/5.2.22 and policy number RA2. WE do not agree with Badby becoming a secondary service village. There are no advantages to this and it will only weaken the argument to keep the surrounding countryside as fields by encouraging more building that will change the look and history of the village.

We cannot understand the reason for this decision. When we looked into the list of Other Villages we are no different to Newnham which has a bus stop, church and school. Farthingstone that has a golf course, pub, church, a garage and village hall. Badby no longer has a shop or post office. There was not the support due to cheaper prices in Daventry. All our shopping is done in Daventry or surrounding areas. We don't go into the village for work or supplies and the nearest petrol station is Daventry. The buses do not go through the village so you have to be able to walk a distance to the bus stop on the A361, or if you live on Nene Side Close you have to walk out of Nene Side Close alongside a very fast A361 and into the village to catch the bus. Badby needs protecting to maintain its beautiful surroundings and history. Just because we have a main road at the bottom of the village does not make us a secondary service village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.2.05 and 5.2.22, ED45 Ian Bromwich policy RA2

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I do not think the facilities available in Badby justify its classification as a Secondary Service Village. It would appear to fit more logically into the Other Villages category. It does have a successful primary school but this mostly provides schooling for children from Daventry (only some 25% of the roll are from Badby or surrounding villages without their own schools). This is a complete reversal of the conventional logic (and causes significant traffic problems in narrow village roads without the capacity to meet the demand placed on them). It is not the role of a rural village to provide services to the adjacent town. Badby has no shops or other service facilities. While it is on a bus route because it is abuts a main road, that merely serves to take people out to use the services not available in the village. Badby is too close to Daventry to support the services required to be classified as a Secondary Service Village.

12 March 2018 Page 110 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Paras 5.2.19, 5.2.21, 2.2.03, ED144A Katrina Jones Policies and Inset Maps 14

Organisation: Representing: Creaton Parish Council

Support/Object:

Supporting Documents:

Comment:

The concerns and comments of Creaton Parish Council are as follows:- 1. The support for long term sustainability of rural communities appears to be at best minimal and actively seeks to prevent any organic or planned growth by way of 5.2.19 ".....there is no justification for further allocations for Secondary Service Villages within this plan." As there are no allocations within the current plan and therefore it limits development to "....being small scale within the confines of the village." 2. The confines of the village are we assume on Inset Map 14. This has been drafted so as to provide a totally restricted boundary to the extent of ignoring existing dwellings and simply mirrors the 1994 plan. This inevitably leads to the conclusion that no small scale development will be permitted except in "exceptional circumstances". 3. The exceptional circumstances within 5.2.21 are to say the least, very limited and are effectively where a need is identified in the Housing Needs Survey or to support under threat local services. In the case of Creaton the last HNS was carried out in 2012 and identified need. This has not been adopted or even recognised within the plan. Within the heavily constrained village confines it cannot be satisfied unless accepted as "exceptional" despite it being known in 2012. 4. The demographics in 2.2.03 identify a growing % of an ageing population higher than the national average and a lower than average younger age group. The plan does not show how this situation is to be addressed but in fact seeks to frustrate the ability to create low cost housing in rural areas by increasing supply. it actively seeks to artificially restrict supply so that housing relevant to ageing and younger members of society cannot be provided and therefore they cannot remain within their own communities. 5. The effect of this is to create sterile rural communities where there is no opportunity for under occupied large houses to be bought by families because there are no smaller houses being built to enable ageing resident to stay within their own community. Similarly the restricted and often non-existent starter homes means newly formed household have to move to urban areas and out of the villages. 6. Without an active growth of rural communities they will stagnate and bring about loss of schools and place a heavy burden upon healthcare facilities due to inappropriate housing for the elderly. This should not need to be "exceptional circumstances" it should be planned. 7. The Parish Annexe was intended to be a mechanism for smaller Parishes who could not afford to go through the Neighbourhood Plan process, to allow adoption of local development needs. Creaton went through this process of consultation and passed the findings on to DDC whereby the vast majority of respondents were in favour of limited development to support a sustainable community. This process has simply been used to provide an opportunity to protect Local Green Spaces. Whilst this is laudable, there is no mention of the development opportunities and need and therefore seems a totally negative approach. The NPPF seeks to respond positively to wider opportunities for growth. The Councils plan appears to be looking achieve the complete opposite.

Conclusions. We therefore ask that consideration be given to the following:- 1. The village confines be expanded to include the built areas and residential garden land and not selectively ignore some properties. 2. To allow some margin for infill sites that are not protected Green spaces 3. To recognise the findings of the Housing Needs Survey 4. To recognise the findings of the village consultation 5. To remove the tests for "exceptional circumstances" where they have already been demonstrated 6. To remove the " no justifications " element of 5.2.19 7. To actively plan for the ageing populations local housing needs

12 March 2018 Page 111 of 399 8. To actively plan for starter homes within the rural areas so as to retain the younger population.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policies and Inset Map 6 - ED126B, ED126D Sebastian Charles Moulton

Organisation: Representing: Aardvark Planning Law

Support/Object: Object

Supporting Documents: Map of consented scheme (ED126E) Moulton inset map (ED126F) Access Review (ED126G) Detailed plan (ED126H)

Comment:

The Nest properly now forms part of Moulton. The current situation has not been achieved in a planned way but by default, leaving an abrupt edge to the village boundary between development and countryside. This is indefensible in landscape terms and we would contend contrary to the wishes of the local community when the Neighbourhood Plan was drafted.

Policy Change requested Through these submissions the owner seeks that the Moulton inset plan be deleted and replaced with the attached proposed amended inset plan which includes The Nest and Land behind The Nest within the Village Boundary for Moulton and excludes The Nest and Land behind the Nest from POLICY ENV 3 Green Wedge.

12 March 2018 Page 112 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policies RA1 & RA2 ED79A Paul Johnson

Organisation: Representing: Francis Jackson Homes

Support/Object: Object

Supporting Documents: ED79F Screenshot of pre school website

Comment:

We object to the assessment in the Settlement Hierarchy Background Paper Version 1 – November 2017, and carried forward into the Emerging Part 2 Local Plan Draft Consultation, in particular: - • Table 2 (page 29); • RA1 and RA2 (pages 33-34 and 35-36 respectively).

The assessment considers Guilsborough to be a Secondary Service Village. We note that Table 7 (page 21) of the Background Paper states the village has only 1 of the important services and facilities. This is also noted on page 29 in the settlement qualitative assessment.

Looking at Appendix A: Stage 1 (page 23), the chart incorrectly notes the village does not have pre-school facilities, when in fact it does. We attach information to support this. As such, the village should score at least a further 5 points and the above noted assessment is also therefore flawed.

As one of only a tiny handful of settlements within the District to have a Secondary School in the village (accessible by foot/bicycle), we believe this should attract notable additional weighting.

The assessment also fails to acknowledge the significant employment opportunities at both the Secondary School (cleaners, teachers, ground staff, gardeners, maintenance staff, TA’s, office staff) and local Surgery, Pharmacy, local shops, pub, Deli, etc. As such, to state there is no local employment provision there is to our mind totally incorrect and without factual basis.

We therefore are strongly of the view, given the above and the wide catchment they service, support, provide employment opportunities for and enhance, that the village should be reassessed as a Primary Service Village.

We object to policies RA1 and RA2 on the basis that they are not in conformity with key elements of the higher tier WNJCS Policy R1. The objection stems from the fact that policies RA1 and RA2, and also RA3 to much the same extent, remove flexibility and pragmatism whereby development may be permitted adjacent to a settlement where there are other material benefits i.e. environmental benefits, e.g. re-use of previously developed land even where next to a settlement or outside/adjacent to the village confines. As drafted, these policies appear more restrictive, less flexible, less able to accommodate exceptional circumstances (there is certainly no expression of what such circumstances may be) and so could act as a barrier to the delivery of housing, not aid in boosting it as the NPPF requires and expects.

12 March 2018 Page 113 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policies RA1 & RA2 ED64 Kate Thompson

Organisation: Representing: Pegasus Group Miller Homes

Support/Object: Object

Supporting Documents:

Comment:

Policies RA1 & RA2 – Service Villages In light of the objections set out under Policy SP1 above, for the Plan to be deliverable it will be necessary for the service villages to accommodate additional housing. Criterion B, to both Policy RA1 and RA2 is restrictive of further housing growth and thus requires amendment to provide for additional housing growth to help make up the shortfalls of housing delivery in both Daventry town and the NRDA.

12 March 2018 Page 114 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policies RA1, RA2 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Chapter 5: Development in the Rural Areas Rural Areas We note that the Council consider (paragraph 5.1.03 of the Draft LPP2) that the housing requirement under the WNJCS, as set out in the Council’s Housing Land Availability Report 2017, has been exceeded by 520 dwellings as at 1st April 2017 with 12 years of the plan period remaining. The Council consider that, following the grant of planning consent for a number of sites, the housing land supply position has improved significantly and they can demonstrate a land supply in excess of 5 years.

The Council consider (paragraph 5.1.04 of the Draft LPP2) that if there was to be a continued focus on the rural areas rather than Daventry town under the current spatial distribution of permissions, this approach would significantly undermine the spatial strategy of the WNJCS. Therefore, managing any further development in the rural areas is clearly an important issue. Further to this, the Council therefore consider (paragraph 5.1.05) that it is not necessary to make any allocation for development in the rural areas in this plan or to identify specific targets for individual settlements. However, further allocations could come forward through neighbourhood development plans or exception sites.

We consider that the Council cannot simply assert that further allocations could come forward through neighbourhood development plans or exception sites without this undermining the spatial strategy in the WNJCS. Furthermore, the Council have not even indicated the number of dwellings that could come forward under Neighbourhood Plan allocations and/or exception sites in the rural area and the specific settlements to which the amount of growth will be directed through these Neighbourhood Plan allocations and/or exception sites.

The housing requirements and the Objectively Assessed Need (OAN) set out in the WNJCS are underpinned by the West Northamptonshire Strategic Housing Market Assessment (SHMA) 2009 (Report of Study Findings, May 2010) prepared by Opinion Research Services. The housing requirements and OAN in the SHMA are based on the East Midlands Regional Plan (RSS) published March 2009. The RSS was revoked by the Secretary of State on 20th March 2013.

The WNJCS was adopted in December 2014. The OAN identified in the WNJCS is not a maximum figure. Furthermore, a condition of the WNJCS being found sound by the Examination Inspector was that a review should be undertaken and the plan be adopted by 2020. This will need to be underpinned by a review of the technical evidence including a review of the OAN for West Northamptonshire. At the time of writing, there has been no review of the OAN and it is considered that the WNJCS must be reviewed and adopted within the next two years. A review of the OAN could take the form of a shared evidence base in part underpinning preparation of separate Local Plans for the Districts and the Borough within the context of the statutory duty to co-operate.

The Housing White Paper (published 7th February 2017) set out how the Government will deliver their 2015 commitment of a million new homes by 2020, and want to supply a further half a million by 2022. It is also relevant to note that the Government’s ‘Planning for the right homes in the right place’ consultation (published 14th September 2017) identified indicative assessment of housing need based on the proposed standard methodology from the current local assessment of housing need. The measures in this consultation will help ensure that local authorities plan for the right homes in the right places through up-to-date Local Plans. The Government’s consultation sets out a number of proposals to reform the planning system to increase the supply of new homes and

12 March 2018 Page 115 of 399 increase local authority capacity to manage growth. The housing need for West Northamptonshire authorities based on the standard methodology would need to be considered as part of a review of the WNJCS. The Government’s consultation sets out a number of proposals to reform the planning system to increase the supply of new homes and increase local authority capacity to manage growth.

Paragraph 156 of the NPPF requires local planning authorities to set out the strategic policies for the area in the Local Plan, including strategic policies to deliver the homes and jobs needed in the area. Furthermore, paragraph 157 of the NPPF requires, crucially, Local Plan to plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of the Framework. In addition, paragraph 158 requires Local Plan’s to be based on adequate, up-to-date and relevant evidence and paragraph 159 requires local planning authorities to have a clear understanding of housing needs in their area and should prepare a Strategic Housing Market Assessment (SHMA) to assess their full housing needs.

The housing provision in the WNJCS is based on an evidence base that has been revoked under the RSS and the OAN is fast approaching its “sell-by date”. One can deduce that the OAN contained within the WNJCS should be considered out-of-date by 2020 (less than two years from now). Whilst the Council consider that they have exceeded the WNJCS housing requirements by 520 dwellings (as at 1st April 2017) with 12 years of the plan period remaining, the reality is such that the Council should, jointly with the other West Northamptonshire authorities, begin a review of the WNJCS now to allow sufficient time for the review of the plan to be prepared and then adopted by 2020. The Council’s Local Development Scheme (2017- 2019) published 8th December 2017 anticipates adoption of the Local Plan Part 2 by July-August 2019. If this timetable is adhered to, it is unlikely that there will be a sufficient period of time (e.g. less than 6 months) for the Council to review and adopt the WNJCS by 2020. We also note that in the planning appeal decision (reference: APP/Y2810/W/17/3178842), it is common ground that the Council cannot demonstrate a five-year supply of housing land within the NRDA (Northampton Related Development Area).

We consider that the approach taken by the Council to identifying additional housing growth at Daventry town and no housing at the District’s rural area is not a positive approach to plan-making based on a strategy which seeks to meet the objectively assessed need of the WNJCS, is not justified by a robust evidence base and is inconsistent with the requirements of the NPPF.

We consider that the Council should take a more proactive approach to identifying additional housing in the Local Plan Part 2 based on potential additional housing need from more up-to-date evidence base that will underpin a review of the WNJCS. The Council should seek to identify additional housing allocation in the Draft LPP2 in the District’s rural area. This includes identifying the amount of growth specific to individual settlements within the rural area. A more positive approach will help to ensure continued housing delivery and a five-year housing land supply position is maintained as the Council progress towards a review of the WNJCS. Smaller, more deliverable sites in the District’s rural area should be allocated for housing as they can meet housing need and delivery in the short term. These smaller sites are much less reliant (than larger sites) on significant infrastructure in order for them to come forward. The Draft LPP2 as drafted does not provide flexibility in the development strategy and we consider that the approach to identifying growth in the rural area (e.g. no growth) should be adjusted accordingly.

Object to approach to development in the District’s rural areas: The Council should consider the necessary growth implications for Daventry District’s rural area and the sufficient amount of growth for settlements in the rural area. Allocate additional housing in the District’s rural area in the Draft LPP2. Smaller sites should be allocated for housing as they are more deliverable, can meet housing need in the short term and are not reliant on significant infrastructure in order for them to come forward.

Policy RA1 – Primary Services Villages We note that the Draft LPP2 identifies a settlement hierarchy for the rural area. Table 2 identifies where each village sits within the settlement hierarchy and policies RA1 to RA4 provide more detail for each of these categories.

Policy RA1 defines Primary Service Villages as performing a crucial role in helping to provide an important range of services and facilities and access to employment opportunities to meet the day to day needs of the local communities which they serve. The Primary Service Villages are identified as: Brixworth, Crick, Long Buckby, Moulton, Weedon and Woodford Halse.

My client objects to Policy RA1 for the reason that Yelvertoft has not been included as a Primary Service Village. We

12 March 2018 Page 116 of 399 consider that Yelvertoft is a sustainable village which comprises a number of local amenities and services including a primary school, local shop, post office, village hall, church, public house, church, publicly accessible open space and local bus services. Yelvertoft is also located in close to a wide range of amenities and services in Rugby and a significant number of employment opportunities at the Daventry International Rail Freight Terminal (DIRFT). Yelvertoft comprises a similar number of local amenities and services to the villages identified under Policy RA1.

We note that the Draft LPP2’s evidence base is supported by the Settlement Hierarchy Background Paper (Version 1 – November 2017). Appendix A of this document identifies Yelvertoft with a score of 53. We object to the scoring for Yelvertoft of ‘0’ for General Food Store, ‘0’ for identified employment area, ‘0’ for pre-school and ‘0’ for public transport. Yelvertoft comprises a village shop which should be considered as a General Food Store, the village is located in close proximity to Rugby and DIRFT which are identified employment areas, the village comprises a pre- school (which operates from the village hall) and the village has a frequent bus service. The scoring for Yelvertoft should therefore be correct to ‘10’ for General Food Store, ‘10’ for identified employment area, ‘5’ for pre-school and ‘10’ for public transport. This would significantly increase the score for Yelvertoft to 88 which we consider suitable enough to identify the village as a Primary Service Village due to the similar scores for the other Primary Service Villages such as Weedon and Crick.

For the reasons above, we consider that Policy RA1 is unsound as the policy is unjustified in terms of its evidence base and request that Yelvertoft is included as a Primary Service Village.

Object to Policy RA1: We request Yelvertoft is identified as a Primary Service Village in the policy.

Policy RA2 – Secondary Services Villages Policy RA2 defines Secondary Service Villages as performing an important role in helping to provide some services and facilities for the local communities which they service. Policy RA2 identifies a total of 18 no. Secondary Service Villages including Yelvertoft.

My client objects to Policy RA2 for the reason that Yelvertoft has been identified as a Secondary Service Village and request the village is identified as a Primary Service Village for the reasons discussed above under Policy RA1.

We consider that Policy RA2 is unsound as the policy is unjustified in terms of its evidence base and request that Yelvertoft is included as a Primary Service Village.

Object to Policy RA2: We object to the identification of Yelvertoft as a Secondary Service Village under Policy RA2 and request the village is identified as a Primary Service Village under Policy RA1.

12 March 2018 Page 117 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policies RA1, RA2 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.5 Development in the Rural Areas 4.5.1 Gladman wish to raise concerns with regards to the manner in which the WNJCS’s broad figure of “about 2360 dwellings in the rural areas” is being applied within the emerging DLPP2. Paragraph 5.1.02 of the consultation document correctly indicates that the figure contained within the WNJCS is not a ceiling, however it goes on to suggest that it is a crucial figure in underpinning the overall spatial strategy contained within the WNJCS. Gladman would suggest that flexibility is needed to ensure that the Council can respond positively to opportunities for sustainable development at settlements that are defined within the plan as being within the rural area. The claim that further sustainable growth in the rural settlements would unduly impact upon the spatial strategy contained in the WNJCS is considered to be unfounded. Indeed, the WNJCS Inspector’s Report (Chapter 9, Housing to meet the Needs of Northampton, South Northamptonshire Local Plan Part 2: Pre-submission Draft for Consultation, September 2017) highlighted at paragraph 163 that Part 2 plans will consider all relevant local circumstances and the realistic capacity of suitable sustainable sites in respect of the provision of rural housing to bolster that coming forward in and around the towns.

4.5.2 Local Plans face the challenge of ensuring that they promote sustainable development throughout their areas and Paragraph 55 of the Framework establishes the need to enhance or maintain the vitality of rural communities. This is an important challenge and must be considered carefully through the Council’s proportionate evidence base. It will require the need to establish an effective baseline of facilities and services together with a vision for how they can be maintained or improved. Rural settlements of varying sizes can make a meaningful contribution towards meeting overall housing needs in a sustainable manner. No settlement should be placed in a sustainability trap whereby it is not able to improve the range of services and facilities available to residents that would allow it to escalate up the sustainability ladder.

4.5.3 In terms of villages and rural areas, Section 3 of the Framework sets out that planning policy should support economic growth to create jobs and prosperity by taking a positive approach to sustainable new development. The Framework states that local plans should promote the retention and development of local services and community facilities, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship. Paragraph 55 of the Framework states that “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.” The PPG provides further detail on how planning policy can support sustainability and vitality. The PPG (Planning Practice Guidance, Reference ID: 50-001-20160519 references the importance of recognising 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. It also states that it is important for local planning authorities to recognise the particular issues that are facing rural areas in terms of housing supply and affordability. Rural housing is highlighted as being essential to ensuring the viable use of local facilities and the role of housing in supporting the broader sustainability of rural settlements is also an important consideration for plan makers. All settlements can play a role in delivering sustainable development in rural areas and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless they can be supported by robust evidence.

4.5.4 Where a part 1 local plan such as the WNJCS does not identify specific housing requirements for any settlements beyond the area’s principal town(s), it is considered appropriate and necessary for associated part 2 local plans to give due consideration to housing needs at a sub-district level by exploring what a suitable level of

12 March 2018 Page 118 of 399 housing need would be for individual settlements within the hierarchy. The Framework requires local planning authorities to enable the creation of sustainable, inclusive and mixed communities which includes the consideration of market trends and the needs of different groups in the community (NPPF Para 50). Furthermore, the Framework (NPPF Para159) indicates that local planning authorities should give consideration to catering for housing demand and the scale of housing supply necessary to meet this demand within the consideration of housing needs. In particular, if there is to be continued support for facilities and services within rural settlements, then consideration needs to be given to the maintenance of the working age and school age population within them.

4.6 Settlement Hierarchy and Village Confines 4.6.1 The Plan must provide a positive Framework to enable growth in settlements across the rural settlement hierarchy. In establishing the settlement hierarchy and associated planning policies, consideration should be given to how the role and functionality of settlements may change over the course of the plan period, ensuring that individual settlements are not permanently held back from enhancing their individual sustainability credentials in both qualitative and quantitative terms. Issues to take into account include the continued availability of services and facilities; the ability of those services and facilities to improve, or for new facilities to be established; the ability to address housing demand and the needs of the wide range of groups within the community; and, the maintenance of young and working age residents within settlements. The delivery of a supply of new housing is important way of ensuring, securing and improving the sustainability of existing communities as well as meeting local housing needs.

4.6.2 The local plan must also recognise the relationship that some of the wider parishes around Daventry District’s rural settlements have with the NRDA. Locations that are well related to the NRDA benefit from the wide range of services, facilities and employment opportunities that are provided in Northampton. It is therefore essential that the local plan assists the maintenance of a rolling five year housing land supply for the NRDA by enabling development to come forward in locations that have the ability to form part of the NRDA in a manner that positively reflects the presumption in favour of sustainable development.

4.6.3 Gladman considers that settlement boundaries should not be arbitrarily used to restrict otherwise sustainable development from coming forward. The Framework is clear that development that is sustainable should be approved. The use of settlement boundaries to arbitrarily restrict sustainable development coming forward, including sites on the edge of settlements, does not accord with the positive approach to growth required by the Framework. Policies should not create blanket restrictions against development and instead seek to positively enable current and future development needs in sustainable locations whilst recognising the intrinsic character and beauty of the countryside and the need to support thriving rural communities.

4.6.4 Gladman are of the view that a criteria led policy approach should be introduced which sets out the circumstances in which sustainable extensions to the settlements would be appropriate. In addition to taking account of any land necessary to make a meaningful contribution towards meeting existing and future development needs, any such approach should provide flexibility to respond to changing circumstances in terms of the supply of housing land to ensure that it is an effective policy tool that recognises that the settlement edge is often a sustainable location for growth.

4.6.5 The Housing White Paper identified potential future changes to the National Planning Policy Framework that would require local planning authorities to provide neighbourhood groups with a housing requirement figure. The methodology for this has not been fixed, but it is a signal that settlements will need to meet their share of local housing need. Consideration should therefore be given to the level of growth that will be required at rural settlements across the settlement hierarchy in order that their sustainability can be maintained and enhanced over the plan period.

4.7 RA1 - Primary Service Villages and RA2 – Secondary Service Villages 4.7.1 Primary Service Villages are highlighted within the Plan as having the highest level of services and facilities within the rural area to meet the day to day needs of residents, including those from surrounding settlements. Secondary Service Villages are also well served by services and facilities which the local plan should seek to maintain and enhance over the plan period. Rural Service Villages are appropriate for accommodating local housing and employment needs. Indeed, such settlements are well positioned to accommodate additional new development over the remaining years of the plan period, including that which is needed to address specific local needs for both market and affordable housing.

12 March 2018 Page 119 of 399 4.7.2 It is clear from the Council’s emerging evidence base that the Primary and Secondary Service Villages are sustainable settlements in their own right. It is therefore essential that the local plan creates a positive framework of policies to maintain and wherever possible enhance the sustainability of these settlements over the remainder of the plan period. Policy RA1(B) and RA2(B) make reference to the potential to support development proposals outside of the current development limits in exceptional circumstances, or where it is required to meet identified local needs. In preparing the submission version of the DLPP2, further clarification will be required within the wording of these policies with regard to the circumstances in which these exceptional circumstances would be triggered and how the specific needs of individual settlements will be determined and addressed, taking into account the points covered in paragraphs 4.5.1 to 4.6.5 above.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED46C Chris Edge

Organisation: Representing: Co-op

Support/Object: Object

Supporting Documents: ED46B Map

Comment:

Whilst the Co-op supports the identification of Long Buckby as a Primary Service Village within the settlement hierarchy, the Co-op objects to the lack of reserve housing sites being allocated in the Primary Service Villages (for consistency with the representations made to Policy SP1). This would mitigate against slippage in housing delivery on the SUE allocations, which is already evident even prior to the adoption of the Part 2 Local Plan.

The Settlement Hierarchy Background Paper assigns a total score of 103 to Long Buckby in terms of its access to services and facilities. This is identical to three other Primary Service Villages (Brixworth, Moulton, Woodford Halse) and superior to the scores for the two remaining Primary Service Villages (Crick and Weedon). There can be little dispute that Long Buckby is a suitable and sustainable location for new housing in principle (as confirmed by recent permissions to the south of Long Buckby). However, to not allocate any additional housing in Long Buckby, even on reserve sites, over the remainder of the Plan period carries significant risks. There is also a risk that the Plan may not deliver sufficient housing if slippage on the SUE continues to become evident.

On this basis, the Co-op seeks the allocation of land west of The Banks, to the north of Long Buckby, as a reserve housing allocation in the Part 2 Local Plan. This 2.5 ha site could accommodate approximately 75 dwellings and is not subject to any physical or legal constraints that would encumber redevelopment for residential purposes. A site location plan is enclosed.

12 March 2018 Page 120 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED75B Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents:

Comment:

Policy RA2 identifies 18 Secondary Service Villages including Flore. These are settlements with a more limited range of services compared with Primary Service Villages, but provide scope to meet some local needs for housing. The policy indicates that development will be located within the confines of the villages and development outside the confines will only be acceptable in exceptional circumstances.

This approach reflects the Council’s view that, as the rural requirement set out in the Joint Core Strategy has been exceeded, there is no need for the Part 2 plan to make any allocations in the rural area.

Whilst the identification of Flore as a Secondary Service Village is supported, we object to the proposed strategy to make no further provision for growth in the more sustainable rural villages over the plan period.

The Council’s monitoring of housing land supply confirms that development has not progressed as quickly as anticipated in and around Daventry or in the NRDA part of the District. A critical issue for the Part 2 Plan is to demonstrate that the housing needs of the District can be met in the plan period.

The plan identifies a residual requirement due to under delivery in Daventry of between 1,073 and 1,140 dwellings. The Part 2 Plan’s proposed solution to allocate new sites at Daventry, including 800 dwellings south west of the town through Policy HO1 and an extension to Micklewell Park to the north of the town for a further 180 dwellings under Policy HO2.

No provision is proposed in the rural areas. There is a serious question as to the extent to which additional dwellings in and around Daventry are going to be deliverable over the remainder of the Plan period.

The supporting evidence shows that housing delivery in Daventry Town has not exceeded more than 151 dwellings per year since 2011, and that the Daventry North East SUE alone is expected to deliver 200 dwellings a year from 2023 to 2029. In the context of the significant outstanding commitments still to be delivered for Daventry Town, the proposed additional provision as set out in the Part 2 Plan is not considered to be deliverable.

As currently framed, the Part 2 Plan is not effective as it promotes a spatial strategy to address shortfalls that will not be deliverable over the plan period.

A more appropriate strategy would be to plan for further limited housing release in the more sustainable settlements to address the identified under-provision at Daventry Town. It is clear that the provision of smaller sites in the rural settlements are attractive to the market and can be delivered effectively.

Policy RA2 should be amended to make specific allocations at the Secondary Service Villages to help to address the shortfalls in provision at Daventry Town and to provide for further growth in the more sustainable rural settlements to meet local needs over the plan period.

Our client, Gallagher Estates, have interests in ‘Land off Brockhall Road, Flore’ (HELAA ref. 104) where there is the potential to develop up to 200 dwellings on land between the settlement and the Daventry Development Link Road. The allocation of the site would provide housing land in a sought after area (which would be highly deliverable) as well as greater flexibility for the Local Plan to adapt to changing circumstances should the delivery of the NRDA sites continue to experience delays.

12 March 2018 Page 121 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED101B, ED101C, ED101D, Katrina Jones ED101E, ED101F, ED101G

Organisation: Representing: Naseby Parish Council

Support/Object:

Supporting Documents: Maps of nominated LGS attached

Comment:

Six nominations for Local Green Space: 1. Naseby Village Hall and Recreation Ground, Haselbech Road, Naseby 2. Allotments, Land Off High Street, Naseby 3. Woodland behind (east of) allotments, Land Off High Street, Naseby 4. Obelisk, Clipston Road, Naseby 5. Cromwell Monument, Naseby 6. Fairfax Viewing Platform, Clipston Road, Naseby

12 March 2018 Page 122 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED88 Daniel Hatcher

Organisation: Representing: Rosconn Strategic Land

Support/Object:

Supporting Documents:

Comment:

Rosconn Strategic Land are making representations to the Daventry Emerging Draft Settlements and Countryside Local Plan (Part 2) in respect of its land and development interests within the District.

RA1 Primary Service Villages Rosconn Strategic Land objects to the Policy RA1: Primary Service Villages which as currently written could limit sustainable development being brought forward in those settlements which have a wide range of services and facilities. Part A of the policy sets the requirement that development will be located within the village confines which is considered too restrictive and inflexible. It is suggested that the policy should be worded to accept development of an appropriate scale outside the confines to existing settlements but well related to the built up area using well defined boundaries that form logical limits to development.

Part B seeks to restrict development outside the defined confines of the villages unless it is demonstrated there are exceptional circumstances or where it is required to meet an identified local need. The requirement for essential local services to be under threat is not only a stringent test on bringing forward new housing to Primary Service Villages but also a reactive one which may not factor in the time delay between gaining consent for new housing and the benefits accrued by the occupation of those houses. This policy does not factor in the level of completions and commitments in each settlement. The Settlement Hierarchy Background Paper (November 2017) acknowledges that the amount of growth towards Weedon for instance has been relatively low compared to other villages of the same scale. The policy as currently worded does not ensure that settlements are allowed to grow to maintain the provision of local services. It is considered that this does not accord with the thrust of paragraph 55 of the NPPF which considers to ensure housing enhances and maintains the vitality of rural communities.

Part D states that development provided within a made Neighbourhood Development Plan (NDP) must accord with the requirements of parts A to C of Policy RA1. This is considered to be overly prescriptive when considering the overarching aims of Neighbourhood Planning. The National Planning Policy Guidance (NPPG) paragraph 001 outlines when describing Neighbourhood Planning: "Neighbourhood planning gives communities direct power to develop a shared vision for their neighbourhood plans and shape the development and growth of their local area. They are able to choose where they want new homes, shops and offices to be built, have their say on what those new buildings should look like and what infrastructure should be provided, and grant planning permission for the new buildings they want to see go ahead." (our emphasis)

The prescriptive nature of Policy RA1 requiring accordance with parts A to C would limit the ability for NDP qualifying bodies to genuinely direct development to areas supported by the local community in a number of ways. Not only does part A restrict development to be located within the predefined village inset maps part B limits development to exceptional circumstances or meeting an identified need. This runs contrary to the principles of the NPPG which emphasises that communities are best placed to decide the most appropriate locations for local growth. The restriction for NDP policies to be in accordance with parts A to C is also considered to be a more onerous replication of the requirement of NDPs to be in general conformity with the strategic policies of the development plan as per the basic conditions as set out in paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990.

12 March 2018 Page 123 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED104A Simon Andrews

Organisation: Representing: DLA Town Planning

Support/Object: Object

Supporting Documents: Letter attached relating to policies SP1 and RA1

Comment:

Policy RA1 The adopted Core Strategy policy R1 sets out how additional development in the rural area may be permitted where it delivers, for example, environmental improvements on a site. However, this policy is proposed to be superseded by policy RA1. This policy does not contain the same provision for development delivering environmental benefits. Policy RA1 (B) states that “Development outside the defined confines will only be acceptable in exceptional circumstances or where it is demonstrated that it is required to meet an identified local need.”

This policy is more restrictive than it needs to be as written but even more so given that the “exceptional circumstances” are actually listed in paragraph 5.2.17. As a general principle, there is no need to define a closed list of exceptional circumstances at this stage. The three bullet points given in 5.2.17 could be illustrative of the type of circumstances likely to be considered exceptional. More specifically, environmental improvements need to be included within the exceptional circumstances.

The approach to development in the NPPF is characterised by a balancing of benefits versus harm. It has been established at number of appeals (see appendix (Inspector’s paragraph 6) to this representation for an example) that policies that seek to restrict development without consideration of benefits and harm are not consistent with the balanced approach in the NPPF. Draft Policy RA1 restricts development (and we understand the reasons for this restriction) but it needs to include a balancing exercise that potentially allows development outside village confines where substantial benefits would be delivered so as to outweigh the harm. This balancing exercise is required in order for the plan to be consistent with national policy and therefore “sound”. Some suggested replacement wording is set out below: “5.2.17 Taking forward policy R1, there may be scope for development outside of the confines but only in exceptional circumstances where the benefits of development outweigh any harm. Such circumstances may include; • Where the housing land supply is less than five years (three years where a neighbourhood development plan is in place that allocates sites for housing); or • Where the housing provided would clearly meet an identified local need such as that identified through an up-to- date Housing Needs Survey carried out by Daventry District Council; or • Where a scheme is required to support an essential local service that has been demonstrated to be under threat, especially a primary school or primary health service; or • Where development would bring substantial environmental benefits that cannot be delivered otherwise. “

12 March 2018 Page 124 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED97 David Ward

Organisation: Representing: Wilson Bowden Develoments Ltd

Support/Object: Object

Supporting Documents: Attached - aerial photograph and map

Comment:

Objection to Policy RA1 (B) We consider that the wording in this policy is unduly negative, and in any event, it is not necessary to demonstrate ‘exceptional circumstances’. Hence, and not withstanding out representations in respect of Policy RA1 (A) above, we consider that the wording of part (B) should be changed to reflect a positive approach to development, in line with the NPPF, so that it reads: ‘Development outside the defined confines will be acceptable where it is demonstrated that it is required to meet an identified need’. PLAN ATTACHED

12 March 2018 Page 125 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED110 Gary Stephen

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

RA1 – Primary Service Villages It is noted that paragraph 5.2.17 defines the exceptional circumstances for development outside of Primary Service Village (PSV) confines. One of which is where the housing land supply for the district falls below five years. This element of flexibility is welcome to provide a contingency for the Plan should housing delivery falter.

However, it is considered that it would be more appropriate to identify reserve sites within the plan to provide more certainty about where additional growth would be directed if necessary. This would also accord with the proposed Policy SP1 as it could assist with the delivery of plan led development where it is identified that this cannot be accommodated within the NRDA. The Council’s evidence is sufficient enough to identify reserve sites around Primary Service Villages. And as expressed above, it is considered that some PSVs, such as Long Buckby, are more sustainable than others.

On this basis, HLM would contend that Land at Park Field (HEELA Site ID 23) should be identified as a ‘reserve’ allocation. As the HEELA notes, the site is available and achievable and could be delivered quickly to address any potential housing land supply issues the Council may face.

It is noted that the HEELA considers the site not suitable as ostensibly it would not support the delivery of the JCS. Whilst the NPPG methodology for assessing suitability of sites states that existing development plan policy should be taken into account, this is dependent upon the age of the policy and the weight to be given. For instance, many local authorities with HEELA sites in the Green Belt will deem the sites suitable – subject to exceptional circumstances being identified through the development plan process.

Similarly, it is considered that Land at Park Field does support the strategy of the JCS as its allocation as a reserve site would help to ensure that the housing requirement for the plan period is met.

The HEELA site assessment also suggests that it is unlikely that environmental improvements would result from development. Given that the assessment does not identify any significant environmental constraints, it is considered that development could in effect deliver environmental net gains such as in terms of flooding, and biodiversity, and retain and improve the existing footpath.

12 March 2018 Page 126 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1 ED126A, ED126D Sebastian Charles

Organisation: Representing: Aardvark Planning Law

Support/Object: Object

Supporting Documents: Map of consented scheme (ED126E) Moulton inset map (ED126F) Access Review (ED126G) Detailed plan (ED126H)

Comment:

Gas main and sewers on the site are not a material constraint A gas main and mains sewer run through the site, but the planning of the site is not materially constrained by a these and they merely create an opportunity for landscaping within the site and the opportunity to create new habitats and improve bio diversity.

12 March 2018 Page 127 of 399 certain public authorities to have regard to those registers in carrying out planning and other functions.

This approach would meet local demand for choice for non-estate house types and would demonstrate that the local authority was taking a pro-active approach to planning and were in accord with the direction of current government policy.

12 March 2018 Page 128 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1, Policies and Inset ED140D Roy Hammond Maps 3

Organisation: Representing: Howkins & Harrison Mr & Mrs Tyrrell

Support/Object: Object

Supporting Documents: Attached - Site plan

Comment:

Howkins and Harrison LLP act on behalf of landowners of multiple sites throughout the villages in the District. This submission is made on their behalf.

This submission is made in respect of proposed policies RA1, RA2, RA3 and the associated explanatory text set out in the consultation draft. The submission is made as an objection to those policies for the following reasons.

Many of the villages, certainly those listed under policies RA1 and RA2, must be considered sustainable locations for growth, meeting the sustainable development objectives set out in the National Planning Policy Framework.

Restricting development outside of the confines of the villages, whether defined or not, to exceptional circumstances (undefined) and local needs only is too restrictive. This approach would compound the inflation of house prices in villages, deterring young people and families from remaining in the village, with consequential harmful effects on the demand for services and facilities and a reduction in the sustainability of the settlement. Conversely, allowing limited development outside of confines at a scale appropriate to the settlement, but well related to the built up area and on appropriate sites, would assist in the delivery of housing, and would help to retain essential local services and facilities, consistent with sustainable development objectives and to the benefit of the vitality of the settlement.

Please refer to the attached aerial image accompanying this representation.

I act on behalf of the owners of the land and have been asked to make representations on their behalf in respect of the residential development of the land edged red. My clients object to lack of provision for additional growth in Crick (beyond infill development, exceptional circumstances and local needs) and consequently object to paragraph 5.1.05, policy RA1 and the proposed confines boundary for the settlement.

The land is shown outside the confines boundary to the settlement of Crick.

The lack of allocated land for housing growth in Crick over the plan period would compound the inflation of house prices in the village, deterring young people and families from remaining in the village, consequential harmful effects on the demand for services and facilities and a reduction in the sustainability of the settlement.

Whereas, the allocation of the site, would help to meet a likely need for housing, and would have a positive impact on the vitality of the settlement.

There are no significant physical constraints to the development of the site, and there are suitable opportunities for vehicle access and pedestrian links.

12 March 2018 Page 129 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1, Policies and Inset ED100 Edmund Fox Maps 40

Organisation: Representing: David Wilson Homes South Midlands

Support/Object:

Supporting Documents:

Comment:

Parish Annex Local Green Space Designation Thank you very much for providing us with the opportunity to offer our views on the proposed Local Green Space Designation for Cow Pasture Spinney, Overstone. I am writing on behalf of David Wilson Homes South Midlands who are acting as promoter of the land in question. Cow Pasture Spinney is a retained landscape and POS corridor that forms part of the southern edge of the North Northampton SUE. Please accept this letter as a formal objection to the proposed Local Green Space Designation for Cow Pasture Spinney in Overstone (ref 114). We feel that this proposed designation has not been given due consideration with to either the National Planning Policy Framework and associated guidance or the practicalities of delivering the North Northampton SUE. This letter will set out the various aspects that we feel are problematic.

NPPF To be considered for Local Green Space design (LGSD) these areas must conform to paragraph 77 of the NPPF. This advises that LGSD will not be appropriate for most green areas or open space. With regard to the criteria we concede that Cow Pasture Spinney, at 450m from Sywell Road is reasonably close to the community, however we have no evidence that Cow Pasture Spinney is demonstrably special to the local community. Upon visiting the area there was no evidence that any persons had deviated from the route of the Public Right of Way (PROW) into the spinney itself. Without some evidence of supposed conformity of Cow Pasture Spinney with para. 77 we feel the proposal cannot be considered to be appropriate for LGSD.

NPPG There are elements of the NPPG that relate to LGSD that do not appear to have been given due regard in this proposal. Given the restrictions that the LGSD may place on development within the Cow Pasture Spinney, it may fetter our ability to deliver the North Northampton SUE in a sustainable way. This would have to the effect of the LGSD being contrary to local planning policy. That said, the spinney has been a key element of the scheme from very early on. Although detailed designs have yet to be completed, it is essential for us to utilise sections of the LGSD to deliver the Sustainable Drainage solution and provide a green corridor creating a walkable link from the SUE into the surrounding area. As such, any regulatory limitation placed on any essential operations within the Spinney will place obstacles in the way of the delivery of the wider scheme. The NPPG states that no new restrictions should be placed upon landowners as a result of LGSD however no detail on this has been provided as part of this consultation. As a result, we would like to make it clear at this stage that BDW Trading Ltd will not relinquish any legal or statutory rights should the designation result in a conflict with our future proposals for the North Northampton SUE.

The fact that this proposal has been progressed in spite of the fact that the Western section of the proposed LGSD approved under planning application ref DA/2013/0850 is clearly contrary to the guidance. Given these circumstances, we feel it would have been preferable if Daventry District Council and Overstone Parish Council approached us in a more meaningful way to discuss shared aspirations for Cow Pasture Spinney. We have a vested interest in enabling this space to be a shared community resource however, we feel that this is not the best approach. The NPPG is clear that LGSD should not be used as a back door to prevent sustainable development. Without there being any evidence as to the demonstrable significance Cow Pasture Spinney has to the community of Overstone, outside of the use of the existing PROW, we feel this is a heavy handed way to deal with the issue that will only frustrate positive engagement between stakeholders.

Management of the shared resource

12 March 2018 Page 130 of 399 The approved Open Space and Play Area plan contained within the S106 provides for part of the spinney to remain as dedicated open space and forms part of the SUE’s important green space within the development scheme. We have always been committed to retaining the spinney and enhancing it to make it more accessible for more people to enjoy and for biodiversity to flourish. Precise details for the area will form part of subsequent RM applications. As such, we envisaged that we would enter into discussions with the Parish Council and the wider community at the appropriate time about how we can maximise this opportunity. These talks would need to give due consideration to planned interventions into the spinney to create new habitats, deliver drainage solutions or green infrastructure routes. We would also need to consider the ned to maintain and manage this shared resource. Our aspiration is to bring the Parish Council on board as a partner to help provide stewardship for this important local space. In that vein we feel that the proposed LGSD is heavy handed and would limit opportunities for us to have a meaningful engagement on how this space is enhanced and protected over time.

We would welcome the opportunity to meet with Daventry District Council Local Strategy team and representatives of the Parish Council to discuss how we might take this matter forward.

12 March 2018 Page 131 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1, Policies and Inset ED140A Roy Hammond Maps 5

Organisation: Representing: Howkins & Harrison Mr C Jackson

Support/Object: Object

Supporting Documents: Attached - Site plan

Comment:

Howkins and Harrison LLP act on behalf of landowners of multiple sites throughout the villages in the District. This submission is made on their behalf.

Conversely, allowing limited development outside of confines at a scale appropriate to the settlement, but well related to the built up area and on appropriate sites, would assist in the delivery of housing, and would help to retain essential local services and facilities, consistent with sustainable development objectives and to the benefit of the vitality of the settlement.

Please refer to the attached plan accompanying this representation.

I act on behalf of the owners of the land and have been asked to make representations on their behalf in respect of residential development of the land edged red. My clients object to lack of provision for additional growth in Long Buckby (beyond infill development) and consequently object to paragraph 5.1.05, policy RA1 and the proposed confines boundary for the settlement.

The site edged red is shown outside the confines boundary to the settlement of Long Buckby. The site is partly occupied by a dilapidated and unsightly farm yard on the edge of the settlement and is currently accessed via Watson Road. The farmyard is a constant source of anti-social behaviour visited frequently by Northamptonshire Police.

The inclusion of the farmyard and the wider site within the confines boundary would bring about environmental and social improvements, and provide an opportunity for improvement and expansion of the adjacent sports pitches and facilities.

The proposed confines boundary in the vicinity of the site appears arbitrary. The inclusion of the proposed site would provide a more meaningful and defendable edge to the village. Long Buckby must be considered a highly sustainable location for growth, fully meeting the sustainable development objectives set out in the National Planning Policy Framework. The village has a railway station, within walking distance of the proposed site, and a significant range of services, facilities and employment opportunities exceeding those in all the other Primary Service Villages, and second only to Daventry. The lack of allocated land for housing growth in

Long Buckby over the plan period would compound the inflation of house prices in the village, deterring young

12 March 2018 Page 132 of 399 people and families from remaining in the village, with consequential harmful effects on the demand for services and facilities and a reduction in the sustainability of the settlement. Whereas, the allocation of the site, would help to meet likely need for housing, and would have a positive impact on the vitality of the settlement. There are no significant physical constraints to the development of the site, and there are suitable opportunities for vehicle access and pedestrian links, other than Watson Road and Wright Road.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1, Policies and Inset ED97 David Ward Maps 7

Organisation: Representing: Wilson Bowden Develoments Ltd

Support/Object: Object

Supporting Documents: Attached - aerial photograph and map

Comment:

Objection to Policy RA1 (A) and Weedon Inset Map The objection site should be included as a residential allocation on the Inset Map. We therefore object to sub section (A) of this Policy which currently sets the criteria for development as being within the ‘confines’ of the village as defined. We take the view that the village ‘confines’ have not been defined correctly at the general level, having regard to positive planning for the locality, and at the specific level, having regard to the clear merits of the omission site.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA1, RA2, RA3 ED57 Andy D'Arcy

Organisation: Representing: South Northamptonshire Council

Support/Object:

Supporting Documents:

Comment:

DtC - Rural Housing

We note and support the Plan's conclusions that the housing requirement has been met in the rural areas and that additional housing should only be permitted where it meets 'an identified local need' (Polices RA1, RA2 and RA3). It is suggested that further clarification is provided on this policy approach including for example whether this is for both market and affordable housing, what constitutes 'local' and indeed how a local need is to be established and by whom.

12 March 2018 Page 133 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED26 Steven Rolt

Organisation: Representing: Braunston Parish Council

Support/Object: Support

Supporting Documents:

Comment:

This is the response from Braunston Parish Council, agreed at the council meeting on 8th January 2018. Braunston Parish Council notes the inclusion of policies including Policies RA2 (Secondary Service Villages) and ST1 (Sustainable Transport Infrastructure) that align with the Braunston Neighbourhood Plan and welcomes the support this lends to our objectives.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED29 Patricia Fox

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I do not feel that Badby has enough facilities to be considered as Secondary Service Village. We have two pubs that have been variously closed over the last ten years - currently both are open but this is not a given that they will remain open. We have a village school. However, we have no shops so anyone living in the village needs to shop elsewhere. Compared with villages such as Byfield, who have a medical centre, shops and service station as well as many other facilities/work places, we have very few facilities.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED41A Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object: Support

Supporting Documents:

Comment:

Kilsby accept their designation as a Secondary Service Village.

12 March 2018 Page 134 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED91B Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents: Attached - Landscape & Visual Constraints and Opportunities Report (Indicative Concept Masterplan referred to but not attached)

Comment:

Policy RA2 - Secondary Service Villages Whilst the Settlement Hierarchy criteria appear appropriate, we note that there is no consideration of the proximity of settlements/site opportunities to Northampton. For settlements within Daventry District close to the Northampton urban area, the assessment of their sustainability credentials should reflect the proximity to Northampton and access to the higher order range of services and facilities available.

Our client, Gallagher Estates, have interests in land to the south east of Boughton (a Secondary Service Village). There is the opportunity to accommodate development in this location to include the provision of new areas of parkland to safeguard the settlement's identity whilst allowing for further growth in a sustainable location adjoining Northampton.

Proposed changes to Policy RA2 The Settlement Hierarchy should take account of the proximity of settlement/site opportunities to Northampton. For settlements/site opportunities within Daventry District close to the Northampton urban area, the assessment of their sustainability credentials should reflect the proximity to Northampton and access to the higher order range of services and facilities available.

12 March 2018 Page 135 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED92 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents:

Comment:

Policy RA2 identifies 18 Secondary Service Villages including Byfield. These are settlements with a more limited range of services compared with Primary Service Villages, but provide scope to meet some local needs for housing.

Byfield is identified as a Secondary Service Village reflecting the range of services and facilities available. The Settlement Hierarchy Background Paper, 2017, sets out the Council’s approach to establishing the settlement hierarchy applying a two stage approach involving a quantitative assessment of facilities followed by a qualitative review. Under the first stage quantitative analysis, Byfield was identified as Primary Service Village reflecting the range of services and facilities available. The site was demoted to Secondary Service Village on the qualitative assessment on the basis of limited access to employment and the size of the settlement.

In our view the quantitative analysis should be the primary consideration as this provides a clear comparative appraisal of available services and therefore the relative sustainability of settlements. On this basis Byfield qualifies as a Primary Service Village and the plan should be amended accordingly.

The policy indicates that development will be located within the confines of the villages and development outside the confines will only be acceptable in exceptional circumstances. This approach reflects the Council’s view that, as the rural requirement set out in the Joint Core Strategy has been exceeded, there is no need for the Part 2 Plan to make any allocations in the rural area.

We object to the proposed strategy to make no further provision for growth in the more sustainable rural villages over the plan period.

The Plan identifies a residual requirement due to under delivery in Daventry of between 1,073 and 1,140 dwellings. The Part 2 Plan’s proposed solution is to allocate new sites at Daventry, including 800 dwellings south west of the town through Policy HO1 and an extension to Micklewell Park to the north of the town for a further 180 dwellings under Policy HO2.

No additional provision is proposed in the rural areas. There is a serious question as to the extent to which additional dwellings in and around Daventry are going to be deliverable over the remainder of the plan period.

The supporting evidence shows that housing delivery in Daventry Town has not exceeded more than 151 dwellings per year since 2011, and that the Daventry North SUE alone is expected to deliver 200 dwellings a year from 2023 to 2029. In the context of the significant outstanding commitment still to be delivered for Daventry Town, the proposed additional provision as set out in the Part 2 Plan is not considered to be deliverable.

As currently framed the Part 2 Plan is not effective as it promotes a spatial strategy to address shortfalls that will not be deliverable over the plan period.

12 March 2018 Page 136 of 399 settlements are attractive to the market and can be delivered effectively.

Policy RA2 should be amended to make specific allocations a the Secondary Service Villages to help to address the shortfalls in provision at Daventry Town and to provide for further growth in the more sustainable rural settlements to meet housing needs over the plan period and help sustain rural services.

Davidsons Developments Limited has interest in land at Boddington Road, Byfield. The site provides an opportunity to deliver additional residential development in a sustainable development to help address the shortfalls in provision at Daventry Town. Further provision for development in rural settlements like Byfield over the plan period, will help to maintain services and facilities and also ensure that the overall housing requirements for the district will be met over the plan period.

Davidsons Developments made submissions to the Call for Sites consultation identifying opportunities to provide some 33 dwellings on the site. The site should be included as a specific allocation under Policy RA2.

12 March 2018 Page 137 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED94 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents:

Comment:

Policy RA2 identifies 18 Secondary Service Villages including Naseby. These are settlements with a more limited range of services compared with Primary Service Villages, but provide scope to meet some local needs for housing. The Policy indicates that development will be located within the confines of the villages and development outside the confines will only be acceptable in exceptional circumstances.

Naseby is appropriately identified as a Secondary Service Village reflecting the range of services and facilities available. The Settlement Hierarchy Background Paper, 2017, identifies Naseby as one of the more sustainable Secondary Service Villages, having a primary school, general store, village hall, shops and local employment along with a daily bus service.

This approach reflects the Council’s view that, as the rural requirement set out in the Joint Core Strategy has been exceeded, there is no need for the Part 2 Plan to make any allocations in the rural area.

Whilst the identification of Naseby as a Secondary Service Village is supported, we object to the proposed strategy to make no further provision for growth in the more sustainable rural villages over the plan period.

The Plan identifies a residual requirement due to under delivery in Daventry of between 1,073 and 1,140 dwellings. The Part 2 Plan’s proposed solution is to allocate new sites at Daventry, including 800 dwellings south-west of the town through Policy HO1 and an extension to Micklewell Park to the north of the town for a further 180 dwellings under Policy HO2.

The supporting evidence shows that housing delivery in Daventry Town has not exceeded more than 151 dwellings per year since 2011, and that the Daventry North SUE alone is expected to deliver 200 dwellings a year from 2023 to 2029. In the context of the significant outstanding commitments still to be delivered for Daventry Town, the proposed additional provision as set out in the Part 2 Plan is not considered to be deliverable.

As currently framed the Part 2 Plan is not effective as it promotes a spatial strategy to address shortfalls that will not be deliverable over the plan period. A more appropriate strategy would be to plan for further limited housing release in the more sustainable settlements to address the identified under-provision at Daventry Town. It is clear that the provision of smaller sites in the rural settlements are attractive to the market and can be delivered effectively.

Davidsons Developments Limited has interest in land at Policeman’s Field, Naseby. The site provides an opportunity to deliver additional residential development in a sustainable development to help address the shortfalls in provision

12 March 2018 Page 138 of 399 at Daventry Town. Further provision for development in rural settlements like Naseby over the plan period will help to maintain services and facilities and also ensure that the overall housing requirements for the district will be met over the plan period. Davidsons has commissioned a number of supporting technical investigations to demonstrate that the site represents a deliverable opportunity. A Heritage Assessment has been undertaken and this is included as part of these submissions. This demonstrates that heritage issues do not represent overriding constraints to the development of the site.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED119 Catrina Signey

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I fail to understand why Badby has been given secondary service status when the only service we have is a bus stop at the end of the village. We no longer have a shop or a Post Office and the bus does not even go through the village. What is the difference between ourselves and Charwelton? Surely this is just another chance to extend this small village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED135 Maureen Holliday

Organisation: Representing: Pitsford Parish Council

Support/Object:

Supporting Documents:

Comment:

Following recommendations at our Planning Advisory Group Meeting on 23rd January, 2018 Pitsford Parish Council wish to have the following noted as our response and objections to the above consultation.

1. We dispute the designation of the village of Pitsford being a Secondary Service Village RA2. We believe that Pitsford fits into RA3 - Other Villages. Pitsford now has a very, very limited number of services and facilities for residents. A similar village to Pitsford is Maidwell which is designated under RA3.

2. We have serious concerns on the proposals being considered for Policy R1 and therefore fully support the representations of Brixworth Parish Council and object to the suggested changes.

12 March 2018 Page 139 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2 ED137 Mr & Mrs J Townsend

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

Prospective self-build development of land at Church Hill / Teeton Lane Guilsborough

Firstly thank you for your response following our last meeting. We have re-read the draft plan and as a group recognize the difficult task you have in delivering a balanced and equitable set of policies covering such divergent range of demands.

We have therefore limited our comments to those which may influence in some small way. Issues relating to the prospects facing us as a group wishing to undertake self-building, with an emphasis on future proofing those dwellings as we progressively become older (everyone is currently over retirement age). Each party does not wish to move from the village location, which in some instances have been home for their entire lives. The proposition is to self-build a group of properties which can deliver mutual benefits within the group whilst remaining in touch with the services already provided within the village, thus not burdening resources in the wider locality.

With the above as a preamble to our comments below, we have attempted to address the points annotated with the pertinent policy references as you suggested in your e mail.

RA2

The classification of “Secondary Service Village” is seen in its broadest sense as a positive policy protecting and controlling over development. However in certain conditions some freedom may be worthy off consideration when attempting to bring forward types of development promoted by other policy statements. In this particular instance, HO4 and the principles of “Homes for Life. This is especially so where the requirements are for an ageing owner. Opportunities to achieve such change are likely to be rare in the restricted and fully developed secondary Restricted Villages across the district. The existing housing stock in these locations is generally not suitable for any radical design change. To accommodate the flexible living approach is only possible in true terms with a clean start at the conceptual stage. Without this fundamental change ( on a limited and specific basis) the implementation of your progressive policies mentioned above will be curtailed. May we therefore suggest that this principle be considered in the forthcoming review.

12 March 2018 Page 140 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2, Policies & Inset ED130A, ED130B Charlotte Hutchison Maps 14

Organisation: Representing: Iceni Roseneath Estates Ltd.

Support/Object:

Supporting Documents:

Comment:

We write on behalf of Roseneath Estates Ltd “Roseneath” to submit representations to the Daventry District Council (“the Council”) Settlements and Countryside Local Plan (Part 2a) Emerging Draft Consultation. A site location plan of our client’s landholdings is attached at Appendix 1.

These representations are made further to Roseneath’s submission to Daventry’s Issues and Options consultation in 2016 and seek to reiterate matters that will ensure the emerging plan is found sound at examination of the plan in due course. Our objection to the plan as it stands relates to the lack of support for the long term sustainability of rural settlements within the district. Unfortunately, the Council has not sought to overcome our previous concerns and comments by directing some growth to smaller settlements and instead continues to rely on large scale strategic sites coming forward on the edge of Daventry.

As such, these representations seek to further confirm to the plan maker that the current approach to sustainable development within a predominantly rural area is unjustified and as such, the plan cannot be found sound in its current form.

a. Strategic matters Firstly, there are a number of strategic matters that need to be considered in the preparation of a new Local Plan in Daventry and a number of these are set out in further detail below. NPPF In order for the Local Plan to comply with the NPPF, it is necessary for the Local Plan document to, inter alia: • Widen the choice of high quality homes [9]; • Positively seek opportunities to meet the development needs of the area [14]; • Contain sufficient flexibility to adapt to rapid change [14]; • Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15]; • Respond positively to wider opportunities for growth [17]; • Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17]; • Boost significantly the supply of housing [47]; Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47]; Plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups [50]; and Be deliverable and viable [173].

Paragraph 182 goes on to confirm that, to be sound, a plan must be:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and where it is consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

12 March 2018 Page 141 of 399 Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

 Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

b. Land at Teeton Lane, Creaton

Roseneath previously submitted information highlighting the developability of the site to provide a small scale development that would contribute towards meeting the future housing needs of the village. We note this has been collated within the Council’s HELAA review provided as part of the evidence base; however, we would like to add in addition that the site: • Benefits from excellent connections to the local strategic road network including the A14 and M1, • as well as good public transport services towards Northampton and Welford where national rail services can be accessed; • Is in close proximity of the community facilities located within the village, including Creaton Post Office and Village Shop; Great Creaton Primary School; Creaton Village Hall; The Bricklayers Arms; and Village park; • provides an opportunity to provide for local housing needs as identified by the Parish Council, as well as a sustainable extension commensurate to the village of Creaton which will enhance the sustainability of the existing settlement.

Fundamentally, the Parish Council has suggested that the site is one of two preferred options for development within the village. This stems from a Neighbourhood Plan Consultation in 2012, when 43% of respondents felt that site was “very suitable”.

c. Reflecting on Policy R1

Paragraph 5.1.07 and 5.1.08 of the draft local plan document outlines how draft local plan policies RA1-RA5 will supersede Policy R1 contained within the West Northamptonshire Joint Core Strategy (WNJCS). It considers these policies will provide a clear policy position for each village, avoiding the need for unnecessary duplication.

As part of this, the Council’s evidence base document ‘Settlement Hierarchy Background Paper’ (November 2017) is of particular relevance in considering the criterion of Policies RA1-RA5. It states, specifically in relation to Creaton that ‘Since 2011 1 dwelling has been complete and as at 1st April 2017 5 dwellings had planning permission which is relatively lower than some other secondary service villages. A housing need survey conducted in December 2012 identified a need for 3 affordable houses which is considered will be met by existing permissions’.

We commend the Council for producing this evidence base document that highlights the village has 196 existing properties but just 6 units in the planning pipeline for delivery, and concludes its position as 20th in the hierarchy. The document goes on to assess the overall sustainability of each village but does not outline the level of growth considered commensurate to the size of the village to satisfy part c of emerging policy RA2.

We consider that the provision of additional housing in these locations can make the settlement more sustainable by supporting existing services and facilities. We consider that Creaton has significant potential to support additional development given the range of services and facilities available (e.g.school, public house, shops & post office).

The NPPF is clear that in the context of housing delivery, a presumption in favour of sustainable development should be applied [para 44]. As noted, the WNJCS has set the base level of about 2,360 dwellings to 2029 for housing provision in rural areas for which the Council consider has already been met. The Council should aim to model policy RA2 so ensuring that this provision can be met as a minimum, allowing for suitable flexibility as to not restrict the provision of sustainable, deliverable sites in addition to this.

d. Policy RA2 – Secondary Service Villages

As identified above, Policy RA2 identifies Creaton as a Secondary Service Village as a result of its scale and role in providing access to key services for local people. Paragraph 5.2.19 goes on to state that the rural requirement across Daventry has been met and there is no justification for further allocations for Secondary Service Villages within this

12 March 2018 Page 142 of 399 draft Plan.

Roseneath disputes this assertion that the housing requirement within the rural area has been met. This is not based upon any up to date quantitative evidence of housing need in rural areas, indeed Daventry Council’s latest Housing Need Survey for Creaton village is dated November 2012 and can no longer be considered a true representation of the needs of that particular village. Further, in stating that the Council has met its quota for rural housing, the target contained within the West Northamptonshire Joint Core Strategy (WNJCS) is based on a Housing and Market Needs Assessment dated 2006 ( West Northamptonshire Joint Core Strategy (Local Plan Part 1) Examination Hearings Documents List).

Paragraph 5.2.21 considers that ‘there may be scope for development outside of the confines, where housing provided would clearly meet an identified local need such as that carried out through an upto-date Housing Needs Survey carried out by DDC’. Roseneath queries at what stage the Council will consider undertaking these surveys?

Creaton Parish Council considers there has been consistent justification for development in the village as a result of the following key matters:

• an ageing population with no housing in the local area for the elderly to downsize into. This a national issue but is particularly heated in smallscale settlements in rural areas;

• the local primary school is struggling, mainly due to the ageing population and a lack of available houses for families; and

• there is currently 1 house for sale in Creaton.

In this regard, the policy objectives contained within Policy RA2 are unsound and unjustified. Daventry Council should first consider whether any updated evidence regarding housing need in these locations changes the policy requirements in section b of the Policy itself.

12 March 2018 Page 143 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA2, Policies and Inset ED140B Roy Hammond Maps 25

Organisation: Representing: Howkins & Harrison Mr C Jackson

Support/Object: Object

Supporting Documents: Attached - Site plan

Comment:

Howkins and Harrison LLP act on behalf of landowners of multiple sites throughout the villages in the District. This submission is made on their behalf.

Please refer to the attached plan accompanying this representation.

I act on behalf of the owners of the land and have been asked to make representations on their behalf in respect of the residential development of the land edged red. My clients object to the lack of provision for additional growth in West Haddon (beyond infill development, exceptional circumstances and local needs) and consequently object to paragraph 5.2.19, policy RA2 and the proposed confines boundary for the settlement.

The land shown outside the confines boundary to the settlement of West Haddon. The site lies between Morrison Park Road and the West Haddon bypass.

It is noted that the proposed inset map for West Haddon excludes the proposed site from the Special Landscape Area – this change is supported, given the divorced nature of the site from the open countryside beyond the bypass to the north and east, and its closer visual relationship to the settlement of West Haddon. NOTE: SLA REP

The inclusion of the site within the settlement boundary for West Haddon would provide a logical extension of the built up part of the village, on land that has now been excluded from the Special Landscape Area, up to a strong visual and physical boundary.

The lack of allocated land for housing growth in West Haddon over the plan period would compound the inflation of house prices in the village, deterring young people and families from remaining in the village, with consequential harmful effects on the demand for services and facilities and a reduction in the sustainability of the settlement. Whereas, the allocation of the site, would help to meet a likely need for housing, and would have a positive impact on the vitality of the settlement. There are no significant physical constraints to the development of the site, and there are suitable opportunities for vehicle access and pedestrian links off the Guilsborough Road.

12 March 2018 Page 144 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA3 ED14 Martin Bagshaw

Organisation: Representing: John Martin & Associates Maidwell Hall School

Support/Object: Object

Supporting Documents:

Comment:

RA3 – Other Villages – Objection is raised to the proposed wording of Policy RA3 as it does not accord with that of WNJCS Policy R1 (i-v) in particular that there is no reference to such circumstances where in the event that the housing requirement for the rural areas has been met that further housing development can be permitted where it can be demonstrated that it meets the relevant criteria (i-v) of the policy: i) Would result in environmental improvements on a site including for example the re-use of previously developed land and best practice in design or ii) Is required to support the retention of or improvement to essential local services that may be under threat; and iii) Has been informed by an effective community involvement exercise prior to the submission of a planning applicant; or iv) Is a rural exceptions site that meets the criteria set out in Policy 3; or v) Has been agreed through an adopted neighbourhood plan.

Proposed Policy RA3 provides no flexibility in its approach toward new housing development in the Other Villages as there is no reference within the policy to the relevant criteria (i-v) of WNJCS Policy R1, which provide the element of flexibility for new housing development to be considered more favourably subject to the criteria being met.

In addition whilst proposed Policy RA3 includes reference to development that is provided for in a made neighbourhood development plan also being supported there is a caveat that Neighbourhood development plan policies and/or allocations must accord with the requirements set out in the relevant parts of the policy. This approach to new housing development where the housing requirement for the rural area has already been met is in conflict with that of WNJCS Policy R1 (v) which references only that it be demonstrated that in such circumstances the proposed development has been agreed through an adopted neighbourhood plan.

Our client would therefore request that proposed Policy RA3 is amended to provide greater flexibility by the incorporation of the relevant criteria (i-v) of WNJCS Policy R1, to enable new housing development to be considered more favourably in such circumstances where the housing requirement for the rural areas has been met.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA3 ED31 Anthony Davies

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I welcome your description of 'Other Villages' and the definition of confines.

12 March 2018 Page 145 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA3 ED164 Sharon Henley

Organisation: Representing: Stowe Nine Churches Parish Council

Support/Object:

Supporting Documents:

Comment:

Further to my meeting with you last week when we discussed the intricacies of the village designations for the parish of Stowe Nine Churches and the implications thereof for community assets I reported back to the rest of the parish council. On balance we have decided not to query the designation of Church Stowe as an 'other village' as we now understand the protection this designation provides for our sole community asset namely the 'school rooms'. Although it does not necessarily sit comfortably with some councillors as a village hall due to it's restricted use it is all we have as a community meeting place and any protection we can obtain from policy RA3 Cii is welcome. Thank you for your clear explanation about both this and the village confines and taking the time to make yourself available.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA3 and RA4 ED122 Tim Cross

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I am concerned that RA3 & RA4 do not offer the same level of protection as the HS23 restraint policy. The existing restraint villages are of national architectural and historic interest and I feel that these new policies will allow individual development to gradually infill these villages. I accept that the restraint status is restrictive in planning terms but as these villages such as Harlestone have been little changed since the 1600’s and are rare nationally could the restraint status be incorporated in this new Local Plan.

12 March 2018 Page 146 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA5 ED1 Paul Tame

Organisation: Representing: National Farmers Union

Support/Object: Object

Supporting Documents:

Comment:

We assume policy RA5 refers to housing and not other forms of development. If so, it might be helpful to mention this in the policy. The policy does not seem to allow for development under class Q for barn conversions. We would like to see criteria (v) changed to read:- "v. The conversion or re-use of redundant or disused buildings…"

If policy RA5 is supposed to cover more development than housing then it needs to be extended to cover other forms of agriculture and rural development like barns, livery etc.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA5 ED46D Chris Edge

Organisation: Representing: Co-op

Support/Object: Object

Supporting Documents:

Comment:

For consistency with representations made by the Co-op to Policy SP1 and RA1, the exceptions criteria set out at para 5.2.17 should be incorporated within Policy RA5, alongside the allocation of reserve housing sites within the Primary Service Villages.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA5 ED82 Steward Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Policy RA5 refers to development which will be allowed in the countryside (as an exception) which will supported.

Historically, sewage treatment assets and major sewerage infrastructure (e.g. large pumping stations) have been sited at a distance from residential land uses. Therefore we would ask that reference is made to infrastructure as well as the use currently listed in Policy RA5 as follows: ‘v. The re-use of redundant or disused buildings that lead to an enhancement to the immediate setting vi. essential investment in infrastructure including utilities,’

12 March 2018 Page 147 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA5 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.8 RA5 - Open Countryside 4.8.1 Policy RA5 should be amended to reflect the intention of Paragraph 17 of the Framework, which seeks the recognition of the intrinsic character and beauty of the countryside and the need to support thriving rural communities within it. The general protection of rural ‘tranquillity’ that is currently referenced within the opening paragraph of Policy RA5 does not feature within the Framework.

4.8.2 Gladman would wish to raise concerns that Policy RA5 is more akin with now outdated national policy which sought to protect the countryside for its own sake. Flexibility will therefore need to be provided within the policy to recognise and reflect the circumstances in which sustainable forms of development alongside rural settlements (including Service Villages) will be considered and supported over the course of the plan period.

12 March 2018 Page 148 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Policy RA5 ED130A, ED130B Charlotte Hutchison

Organisation: Representing: Iceni Roseneath Estates Ltd.

Support/Object:

Supporting Documents:

Comment:

e. Policy RA5 – Open Countryside

Roseneath considers the wording of this policy should be amended to more closely align with the objectives and allowances for development on settlement edges within Policies RA2. The policy, as currently worded, does allow for such flexibility on settlement edges across the district which are located amongst the Open Countryside designation that covers a high percentage of the administrative area.

f. Conclusions

In summary, these representations respectfully request the Council considers the following in order to bring forward a sound plan:

• Support sustainable development in rural areas through both site allocation and windfall development in the context of the NPPF’s avocation of sustainable development; and

• Update housing need evidence in small settlements to allow for more closely aligned development commensurate to the size of each settlement.

Thank you for providing us with the opportunity to comment on the draft Local Plan document. We would be very grateful for confirmation that these representations have been received and confirm that we would like to be involved in future stages of the Local Plan process.

12 March 2018 Page 149 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 RA1 ED99 Gareth Johns

Organisation: Representing: Savills Society of Merchant Venturers (SMV)

Support/Object:

Supporting Documents:

Comment:

Housing in the Rural Areas

Table 2 – ‘Classification of Settlements in the Hierarchy’ of the Emerging Draft Paper identifies Brixworth as a ‘Primary Service Village’. Paragraph 5.2.01 confirms that Primary Service Villages “have the highest level of services and facilities within the rural area to meet the day to day needs of the residents including those from surrounding settlements. These settlements are the most appropriate for accommodating local housing and employments needs and would be the focus for service provision in the rural areas”.

However, we note that the overall housing requirement set out in the WNJCS for the rural areas has already been met through completions and commitments and, therefore, no sites will be allocated in the rural areas – including at Brixworth – in the Local Plan (Part 2). Despite this, the Council recognise that a policy approach needs to ensure that the role of these villages is protected, in particular by maintaining the services and facilities within the villages.

We consider that the current policy mechanism is flawed. Policy RA1 suggests that only in ‘exceptional circumstances’ will development outside of the village confines be acceptable. These include where the housing land supply is less than five years (three years where a NP is in place that allocates housing), a local need is identified through an up-to- date Housing Needs Survey and where a scheme is required to support an essential local service (i.e. primary school) that has been demonstrated to be under threat. However, we consider that this policy mechanism is too onerous and restrictive, and will not deliver the aims of the policy. In particular, we have concerns on the following:

a) It is not clear how the Housing Needs Survey (HNS) will work – how often will these be carried out and/or updated by the Council?

b) The approach is biased towards the first developer/landowner that submits an application following publication of a HNS to deliver the local need in that settlement directly in accordance with a particular scheme. This may not lead to the most sustainable sites in the village being delivered.

c) The assessment does not take account of the aim to enhance and maintain the roles of the villages, in accordance with the settlement hierarchy. Indeed, Policies RA2-RA4 have similar provisions and there is no distinction made that requires any additional housing requirement to be delivered first in the most sustainable locations i.e. the Primary Service Villages.

d) There needs to be more information on how and/or who will need to demonstrate that a local service is under threat and how development will be delivered to support that service.

The Policy should be amended to be more flexible to deliver appropriate sites adjacent to the settlement confines in the most sustainable villages.

12 March 2018 Page 150 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Section 5.2 ED19 G Walter

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I believe the Staverton Parish Council have not submitted the above plan and misrepresented it to increase the points to put our village into a higher and incorrect category. We have a school, 90% of the children are not resident in the village, no shop, no garage but it is a car sales business, one pub on the main road and only two buses twice a day. Please re-consider our rating in light of the above points.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Section 5.2 ED74 Sue Halkett

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

The Council has viewed your consultation and wishes to comment as follows:

It seems appropriate to delete references to R1 as these points have been covered elsewhere within the document.

The Council supports the plan's position with respect to those parishes that have 'made' neighbourhood plans. We also support the Plan's view of where Flore sits in the village hierarchy and support the village development boundary as shown on the inset plans. It is noted that this differs from the development boundary in the Neighbourhood Plan as it is proposed to include the two new major developments currently underway - Brockhall Road and the Bovis homes development. This is a sensible alteration.

12 March 2018 Page 151 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 Site 302 ED35 Dominic Kramer

Organisation: Representing: Morton Wykes Kramer Co. Christopher Hicks

Support/Object:

Supporting Documents:

Comment:

Site 302, page 380 Appendix B (vi) Rural Area Residential Assessments The site has easy access and is connected to mains water supply. It occupies land of low agricultural value (3). It can be developed without major inconvenience to the village. This is an area with an acute shortage of housing. It is difficult to see why a sympathetic development of eco friendly housing should not be allowed.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 05 & 06 Paras 5.1.05, 6.1.06, 6.1.22 ED31 Anthony Davies

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

5.1.05 states that there is no need for further development in rural areas 6.1.06 introduces Micklewell without acknowledging that it falls largely outside Daventry (in Welton Parish) 6.1.22 allocates a further 180 houses in Welton The line of the canal continues to be a sensible boundary for Daventry to avoid coalescence between Daventry and Welton. The A361 also is a sensible development boundary line. So why not continue the proposed Green Wedge further north?

12 March 2018 Page 152 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED11 Stephen Lucas

Organisation: Representing: Lucas Land & Planning Redinvest Ltd

Support/Object:

Supporting Documents: Map and photos attached

Comment:

The WNJCS inspector was careful not to put a cap on rural housing provision and was clearly following Government advice in the NPPF. 1. It is clear to us that the Daventry Town housing market is controlled by a small number of developers who have significant influence over the local town housing market. That market is now 'slowing down' as evidenced by the quarterly housing land reviews.

2. In the rural area despite the policy reference that the plan's housing needs have 'been met' it is obvious that housing needs are only met when they are fully built out. That clearly is not the situation at present.

3. There needs to be continuing policy flexibility under Policy RA1 and in particular a focus on allowing smaller builders and developers to progress smaller residential sites particularly those in the most sustainable development locations - Weedon Bec being a particularly good example.

Plans attached showing appropriate and logical confines boundary at Manor Farm Bull Inn Close Weedon Bec: Confines Plan: Manor Farm curtilage and plot plan 1899 25 inch plan showing historic curtilage and physical features including historic hedge at the southern edge of the village: Photographs of Manor Farm southern boundary: Aerial photograph of Manor Farm and historic curtilage

12 March 2018 Page 153 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED111 Toby Haselwood

Organisation: Representing: Sworders Baker Family Trust

Support/Object: Object

Supporting Documents: Attached - map

Comment:

In order for the Plan to be sound it needs to be in accordance with paragraph 182 of the NPPF which in turn is interpreted in paragraph: 021 Reference ID: 3-20140306 of the NPPG.

Whilst we are in general support of the emerging draft we consider the numbers currently provided by the proposed emerging draft Local Plan, may well result, if there are delays in delivery, in an undersupply of housing over the plan period.

Therefore, we believe that a number of additional allocations, that could obviously include this site, would assist in delivering further dwellings and as such would increase the flexibility of the plan in terms of supply, making it more robust and less likely to fall into shortfall.

We support the fact that the proposed allocations as a whole, (1200 dwellings) assuming that all of the allocation sites are deliverable, will allow for a certain degree of flexibility over the plan period and we therefore believe that the plan can be considered sound.

However, although the above oversupply helps to demonstrate that, in terms of proposed housing allocations, this element of the Local Plan has been prepared in a positive way, it should be noted that the West Northamptonshire Joint Core Strategy is likely to be reviewed within the next 18 – 24 months and the numbers that Daventry have to provide over the Plan period may well increase. This increase could be significant since Northampton Borough have an existing shortfall that is likely to worsen over the plan period.

We therefore believe that the inclusion of further, smaller scale residential development allocations, would help to illustrate that the plan has been positively prepared and is therefore justified. As such it is suggested that the proposed numbers for the rural areas are increased and more sites allocated to increase flexibility and ensure delivery.

The addition of further smaller scale sites would strengthen the plan’s soundness whilst also ensuring variety and diversity in the market. The inclusion of further smaller scale sites would also be consistent with the research carried out by the Federation of Master Builders and the Local Government Information Unit which has challenged the big site approach. It is clear that a larger number of smaller sites are more likely to be deliverable in the first five years of an adopted plan period than a small number of larger sites.

The plan has a degree of flexibility that should allow it to be effective in terms of deliverability, but it is important to note that the current levels of flexibility in the plan will be tested by over reliance on large scale allocations, such as the proposed South West allocation for 800 dwellings, that generally tend to come forward slower than is anticipated.

Figures The current WNJCS allocations for Daventry are about 12,730 dwellings to be provided over the plan period. These are distributed as follows; Daventry Town – about 4,620 dwellings Daventry Rural Areas – about 2,360 dwellings Northampton Related Development area – about 5,750 dwellings. The lack of a greater number of smaller sites across the District will inevitably lead to an over reliance on the larger allocations, which in turn is likely to lead to delivery issues.

12 March 2018 Page 154 of 399 In addition, the Government’s proposed standardised methodology for calculating housing need (subject to consultation last year) could see the housing requirement for the District or indeed the wider joint planning unit rise.

In light of this further potential upward pressure on housing numbers, it is important that the Plan incorporates as much in-built flexibility as possible and maximises the capacity of allocated sites, in accordance with the NPPF (paragraph 153 and 157).

In order to incorporate as much in-built flexibility as possible the plan should therefore increase its allocations, at the most sustainable locations, namely Daventry.

Deliverability It is important that there is variation in the portfolio of land available for residential development because; this increases the flexibility in supply, attracts smaller house building companies who will not be present upon larger strategic sites, ensures that there is variation in the timescales over which sites can be delivered and provides the consumer (i.e. the future resident) with choice about where they live.

NPPG Paragraph: 021 Reference ID: 3-021-20140306 is clear that a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time. This is essentially a judgement about the economic viability of a site, and the capacity of the developer to complete and let or sell the development over a certain period. It is considered that allocation of the larger urban extension sites, due predominantly to their scale, may not lead to the dwelling numbers set out in the trajectory.

To ensure that the plan is sound and remains sound the number of rural allocations should be increased to be a higher percentage of the total trajectory over the plan period. This will help to ensure that there is a greater flexibility in supply, a wider choice of housing tenure and most importantly ensuring a greater likelihood of deliverability enabling Daventry to avoid falling into a five year housing supply shortfall.

Even so, although we do have delivery concerns, that could be reduced by additional appropriate residential allocations such as this site, we also believe that this element of the plan has been prepared to be consistent with National Policy as its objective is to enable the delivery of sustainable development in accordance with the policies in the framework.

As set out in the emerging draft any proposal for an allocated site should be informed by a site/masterplan that will be prepared with regard to the third party assessments that are being undertaken, agreed by the LPA, which demonstrates that the site can come forward during the plan period.

The development could easily provide further dwellings at a sustainable location and could provide reasonable necessary contributions to infrastructure, both on site as part of a masterplan and off site financial contributions.

Any proposal that comes forward on this land will be informed by appropriate surveys and assessments that will also set out appropriate mitigation measure covering and relating to Archaeology, Heritage Landscape and visual, Ecological, Highways and transport, Flood risk and water infrastructure and Noise and air quality impact. These works will include and are being progressed: • Topographical Survey of the site • An Archaeological desk based heritage assessment • Landscape and visual impact Assessment • Phase One Ecological Survey • Initial Highways and transport Assessment • Flood risk and water infrastructure Survey and Report • Noise and air quality Survey and Report

12 March 2018 Page 155 of 399 The intention is for these works to be available to the LPA prior to the proposed submission stage consultation, currently proposed to be in August and October 2018, and help to inform the viability and deliverability of the site as a residential allocation possible of providing further dwellings at a sustainable location during the plan period.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED115 Ed Hanson

Organisation: Representing: Barton Willmore Landform Daventry Ltd.

Support/Object:

Supporting Documents:

Comment:

MICKLE WELL PARK – PHASE 2 (THE FARMSTEAD) SETTLEMENTS AND COUNTRYSIDE LOCAL PLAN (PART 2A) – ISSUES AND OPTIONS CONSULTATION (2ND) - REGULATION 18 OF 2012 LOCAL PLAN REGULATIONS

Barton Willmore Planning act on behalf of Landform Daventry Ltd, who are the promoters of Mickle Well Park - Phase 2. A plan of Mickle Well Park and the surrounding land is enclosed with this representation (Plan ref: 07789C_SK002).

Daventry District Council (DDC) is consulting on a new Local Plan, following consultation on the initial Issues and Options Regulation 18 in March 2016. When the draft was first proposed, Landform submitted representations in support of further growth to the north of the town (Option B).

Existing context 38 ha of land at Mickle Well Park benefits from outline planning permission granted on 3 July 2015 (Ref: DA/2014/0869). The permission allows for 450 units, a site for a 2-form entry primary school and a community hub. Reserved Matters are currently being prepared and proposals for Phase 1 will be submitted for determination in January 2018. Once the scheme is built out, we understand the boundaries will be redrawn and the site will be included within the Daventry town area as opposed to Welton parish.

Land ownership clarification At a meeting with DDC Planning Policy Officers on 21 December 2017, it was evident there had been some confusion as to the exact boundaries of the land being promoted to the north of Mickle Well Park.

We confirm that Barton Willmore on behalf of Landform are acting on the Mickle Well Park Phase 2 land (The Farmstead) comprising approximately 4.96 ha (12.25 acres). Additional land to the north west of Mickle Well Park, adjoining the A361 is being promoted separately by Sworders Agents on behalf of the land owner. A Development Brief and Masterplan (Drawing ref: 07789C_SK001) for Mickle Well Park Phase 2 are included with this representation.

12 March 2018 Page 156 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED128 Douglas McNab

Organisation: Representing: Education & Skills Funding Agency

Support/Object:

Supporting Documents:

Comment:

10. Ensuring there is an adequate supply of sites for schools is essential and will ensure that Daventry District Council can swiftly and flexibly respond to the existing and future need for school places to meet the needs of the district over the plan period. While it is important to provide clarity and certainty to developers, retaining a degree of flexibility about site specific requirements for schools is also necessary given that the need for school places can vary over time due to the many variables affecting it. The ESFA therefore recommend the council consider highlighting in the next version of the local plan that: - specific requirements for developer contributions to enlargements to existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that - requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use.

12 March 2018 Page 157 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED78A, ED78B Justin Gartland

Organisation: Representing: Lichfields Roundhill Northampton Limited

Support/Object:

Supporting Documents: Maps attached

Comment:

This letter responds to the consultation on the Draft Daventry District Settlements and Countryside (Part 2) Local Plan and is prepared by Lichfields on behalf of Roundhill Northampton Limited (RNL).

These representations are made specifically in respect of land under the control of RNL and other land at Moulton, north of Northampton. This land lies to the east and west of the A43 Highway, north of Round Spinney and the land allocated under Policy N3 of the West Northamptonshire Joint Core Strategy (Part 1) Plan, known as Overstone Leys and Overstone Green. This land is identified on Plan reference IL12110-06-003 revA attached at Appendix 1 of this letter of representation.

These representations constitute objections to the consultation Part 2 Plan. The basis of these objections as well as actions requested to remedy them are set out below.

Background RNL has a longstanding involvement in promotion and delivery of development within the North Northampton area in Daventry District. RNL has secured full planning permission for housing north of Moulton at Marsh Spinney, adjacent the recently developed Nursery Land and, through involvement in the Part 1 Plan, secured the allocation of 1500 dwellings and employment land at Overstone Green within Policy N3.

RNL is committed to assisting with the delivery of much needed housing and commercial development, community and transport infrastructure to meet the needs of Daventry district residents and those of Northampton, for whom the Northampton Related Development Area (NRDA) allocations such as Policy N3 were made in the Part 1 Plan. RNL proposes to bring forward land to the north of Moulton (known as ‘Moulton Heights’), north of Northampton for development in these respects.

RNL has been promoting the allocation of land at North Northampton, west of the A43 since 2009, in the context of the then Emergent West Northamptonshire Joint Core Strategy (WNJCS), where the West Northamptonshire Joint Planning Unit (WNJPU), with stakeholders including Northamptonshire County Council (NCC) as strategic planning and infrastructure authority, was proposing substantial housing growth in this location.

RNL promoted the allocation of land to accommodate 2000 dwellings at Moulton Heights through the WNJCS and presented the case for this allocation at the WNJCS Examinations in 2013 and 2014. It is relevant to note that the approach of RNL at the draft WNJCS stages was informed by the strategic position of NCC. NCC sought the allocation of 5,400 dwellings at Northampton North in response to the Emergent Core Strategy and at least 4,500 dwellings at Northampton North to provide for the NRDA housing requirement and to secure infrastructure delivery in this strategic location in the pre-submission draft Joint Core Strategies. NCC retained its objection to the lower growth allocations at Northampton North (as subsequently approved by WNJPU) through the main Modification and subsequent second Examination stages of the Plan. Suffice it to say that NCC as strategic planning, highway and infrastructure authority, has consistently maintained a position that the North Northampton area should accommodate higher levels of housing growth than the current adopted JCS allows for by Policy N3.

Also of relevance to the appropriateness of allocating land for NRDA-related development at Moulton Heights is the support provided to the proposed 2000 dwellings allocation by Moulton Parish Council (MPC), in the context of the submission draft WNJCS and that support expressed through attendance at the WNJCS Examinations. The recognition of the appropriateness of allocating land north of Moulton at Moulton Heights is reflected in the adopted Moulton

12 March 2018 Page 158 of 399 NDP as described below.

RNL submitted an application for planning permission on land north of Moulton in December 2014. This application at Moulton Heights for 1000 dwellings and community infrastructure included for the reservation of land between the housing development and the village of Moulton for education and leisure as well as substantial public open space uses. The scheme was also devised to deliver the first phase of the North Northampton Orbital Route (NNOR), which is and remains a priority of the Highway Authority. This application was withdrawn to accommodate the Highway Authority’s requirement that consideration of housing development in this area be set within a better understanding of the route and technical data underpinning NNOR.

It remains the intention of RNL to promote land at Moulton Heights for residential, commercial development and community infrastructure, to secure this development through the grant of planning permission and oversee its delivery. Having withdrawn the previous application, RNL is aware of the current progressed status of NNOR and now seeks the allocation of land at Moulton Heights in the Part 2 Plan to meet the housing needs of Northampton. The justification for the allocation of this land at this time is set out below.

Proposed Development Allocation Land proposed by RNL to be allocated north of Moulton (Moulton Heights) comprises 185 hectares of gently sloping land rising from the north of the village to a point where a natural ridge line allows a self-contained landscaped settlement extension to be delivered. Approximately 2,500 dwellings can be accommodated within the 157 hectares (gross) of the site that would be devoted to housing development, which will make a meaningful contribution to the needs of Northampton. The development has the potential to be delivered in line with garden village design principles and represent a highly sustainable form of development. It will be well related to services already provided within Moulton village and the planned urban extension at North Northampton and will be able to contribute to enhanced service provision by both on-site facilities and through contributions made to existing community facilities that can be expanded to serve the wider area’s needs.

Within a proposed Moulton Heights allocation of 2,500 dwellings, RNL proposes to bring forward a phase 1 housing scheme of between 400-800 dwellings to meet the short term 5-year housing land undersupply for Northampton Borough. This phase 1 development will be capable of being delivered in advance of the construction of the NNOR, but would not prejudice whatever of the two route options are ultimately preferred by NCC.

The plans at Appendix 2 and 3 to this letter identify the phase 1 housing options being developed by RNL and the relationship to the two outstanding NNOR route alignment options. Both phase 1 housing options and any proposal for development at Moulton Heights will reserve land for open space/recreation/leisure activities and potential leisure-related development between the southern part of a development area and the north of the village. This approach would be in line with the expectations of MPC and as expressed through the NDP and consultation in respect of the withdrawn Moulton Heights application of 2014 referred to above. These areas of reserved open land allow pedestrian and cycle connectivity into the village from any new development. This will ensure that while retaining a degree of locally sought separation, the development will secure a sustainably connected community. The approach to the delivery of the phase 1 housing scheme will accord with the general principles established in the withdrawn 2014 application and the Design and Access Statement, setting out those principles is attached at Appendix 4. This Design and Access Statement demonstrates the suitability of the site to accommodate the form of residential development proposed.

Housing Need There is a pressing need to allocate more land for housing to meet the needs of Northampton. The land at Moulton Heights is appropriately located close to Northampton to meet this purpose.

While the WNJCS allocated strategic sustainable urban extensions in South Northamptonshire and Daventry Districts to meet the needs of the Borough that could not be met within its constrained administrative area, these sites as well as anticipated build rates within the Borough, have failed to secure a trajectory of housing delivery that meets the needs of Northampton.

Northampton Borough Council’s Local Plan (Part 2 Plan), which has recently been published for consultation outlines that 18,870 dwellings need to be delivered during the period 2011 – 29. NBC’s Part 2 Plan envisages that this housing can be delivered within the NRDA and the Borough boundary without the need to allocate addition sites. This is not a

12 March 2018 Page 159 of 399 realistic expectation and it is unlikely that Northampton Borough will be able to accommodate the housing requirements on the current proposed sites. The NBC Part 2 Plan is supported by an evidence base which includes a Land Availability Assessment (September 2017). A consideration of the Land Availability Assessment supports our client’s view that there is no possibility that land within Northampton Borough can meet the required housing delivery to 2029. To support this concern, NBC has recently issued a 5-Year Housing Land Supply1 Assessment which confirms the Borough only has a 2.5 year housing land supply. The credibility of the approach adopted by NBC in its Part 2 Plan is questioned by a number of objectors.

South Northamptonshire’s pre-submission draft Local Plan Part 2, consulted on in July 2017, identified the current shortfall in housing supply for the NRDA and the need to address the overall shortfall in the Part 2 Plan. The SNDC Plan recognises the importance of including a policy approach that provides a controlled, positive and flexible approach towards additional housing within the District to contribute towards the under delivery in Northampton. In this respect, the South Northamptonshire District Part 2 Plan allocates two additional sites for NRDA housing for approximately 2,500 dwellings to help meet the identified 5,000 dwelling shortfall required to secure a satisfactory delivery trajectory for Northampton’s housing need to 2029.

It is critical that Daventry District Council follow a similar approach to SNDC and allocates further sites in the Part 2 Plan in order to meet the overall housing need in Northampton. While SNDC proposes to assist in meeting part of the additionally identified housing shortfall for Northampton, SNDC anticipates, quite rightly, that DDC will play its part in addressing this matter.

Planning Practice Guidance states that ‘the duty to cooperate is not a duty to agree. But local planning authorities should make every effort to secure the necessary cooperation on strategic cross boundary matters before they submit their Local Plans for examination.’ The Daventry District Council Duty to Cooperate Background Paper (dated November 2017) itself points out that ‘delivery of the WNJCS targets in respect of Northampton’s need will have to be monitored as potential shortfalls may have implications for the level of development Daventry District has to provide within the NRDA’. A failure by Daventry District Council to update its Part 2 Plan to accommodate the Northampton housing shortfall, particularly in the face of representations by SNDC to that effect, suggests a failure to comply with the duty to cooperate.

Appendix 1 to this letter show the area of land north of Moulton (Moulton Heights) that should be allocated in the Part 2 Plan as part of a positive approach to planning for the needs of Northampton and to meet the recognised housing shortfall once the positive approach of SNDC is taken into account in meeting the overall 5000 dwelling deficit for Northampton. Allocation of the identified land at Appendix 1 would overcome our client’s objection.

On the basis of the failure of the Part 2 Plan to address the requirement for additional sites for housing to meet the housing needs of Northampton and the failure to allocate land identified at Appendix 1 in that regard, the Plan is not positively prepared, the duty to co-operate has been failed and the Plan is unsound.

Northampton Northern Orbital Route As described above, the Northampton Northern Orbital Route (NNOR) is a highway commitment required by the strategic highway authority and which has undergone consultation in respect of route options. There is a high level of commitment to this highway infrastructure and the County Council has submitted a bid to government for Housing Infrastructure Funding, recognising the role the road will play in unlocking housing development North of Northampton. Extensive consultation on route options has derived two route alignment options for NNOR running westwards from the A43 across land north of Moulton. These route alignments are identified on the appended plans.

Completing a new ring road to the north of Northampton will reduce the amount of traffic passing through the northern areas of Northampton and reduce rat running through a number of surrounding villages such as Pitsford, Moulton and Boughton (all located within Daventry Districts borders). As stated previously, this route is also needed to support the growth proposals to the north and west of Northampton and plans to provide capacity beyond future development already planned. The scheme is anticipated to be funded by a combination of government and developer funding, with RNL intentions still being to deliver the first phase of the Northampton Northern Orbital Route.

Northamptonshire County Council (NCC) had proposed to confirm the preferred route of NNOR in late 2017, however this decision was deferred. The NNOR was due to be discussed at the January 16th 2018 Committee

12 March 2018 Page 160 of 399 meeting but this was also deferred, with no new date being agreed – but it is anticipated that a final route will still be confirmed by the highway authority in early 2018.

The Sustainability Appraisal which accompanies the emerging Part 2 Plan makes no reference to the NNOR when considering alternatives to the preferred options set out in the plan or in consideration as to likely cumulative effects of the policies in the plan with other proposals. Our client objects to the absence of any indication of the route of the Northampton Northern Orbital Route within the emerging draft Local Plan, the accompanying Policies Map and the accompanying sustainability appraisal. Given the progressed stage of the route, which has gone through public consultation and is due to be confirmed by NCC in the early part of this year, we believe that this should be clearly referenced within the Plan and the supporting documents.

12 March 2018 Page 161 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Housing Background Paper Version 1- November 2017

3.1 The Housing Background Paper identifies the housing trajectory for Daventry South West on page 28. Within this table, the anticipated date the submission of a planning application is August 2019.

3.2 Initial technical work on the site has already been completed, with further technical work currently underway. Based on the work undertaken to date, it is envisaged that a planning application could be submitted in Winter 2018, significantly earlier than currently envisaged by the Council. This, in turn, would enable the delivery of housing on the site in 2021 - a year earlier than currently assumed in the Housing Background Paper.

Changes sought:

3.3 The table on page 28 of the Background Housing Paper should be revised as follows: (SEE TABLE IN ORIGINAL REP WITH CORRECT FORMATTING) Action Anticipated date Carry out all outstanding investigations, prepare ES, complete technical work and finalise design matters required for preparation of planning application documents. November 2018 Submit an Outline Planning Application (including details of access). November 2018 Determination Period. March 2019 Prepare, submit and determine Reserved Matters application and details pursuant to clear planning conditions, etc. Submit Building Regulations. March 2020 Ground works and initial infrastructure. March 2020 Commence house building. November 2020 First dwelling completions 2021 Delivery 2021/22 50 2022/23 100 2023/24 100 2024/25 100 2025/26 100 2026/27 100 2027/28 100 2028/29 100 2029/30 100 2030/31 100 2031/32 100 2032/33 100 2033/34 50

3.4 Not only does this table demonstrate an accelerated delivery of much needed housing, it also marginally increases the assumed delivery rates on the assumption that a single housebuilder outlet will deliver 50 dwellings in the first year, increasing to two outlets by the second year and therefore a total build out rate of 100 dwellings per annum. Whilst it is noted that significant development has taken place around Daventry of late, some of which has experienced delivery issues; Daventry South West is considered to represent a stronger market for housing firstly due to its distance from other large housing sites, but also due to its connectivity with Daventry and ultimately contained nature, offering the opportunity to deliver a different product to the urban extensions Daventry has seen of late.

3.5 Technical work is currently underway on Daventry South West. The planning application will be aligned with the Local Plan process with an application submitted ahead of the Local Plan examination. This programme of works allows for the Council to issues a decision once the Local Plan is adopted.

12 March 2018 Page 162 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 ED142B James Yeoman

Organisation: Representing: Savills Christ Church, Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Savills (UK) Limited is instructed by Christ Church, Oxford to submit the following representations in response to the Regulation 18: Settlements and Countryside Local Plan (Part 2) consultation document’. Christ Church, Oxford owns land situated to the north-west of Daventry, namely:

• Middlemore Farm: situated immediately to the west of the A361 and promoted for residential use; and • Drayton Gate Farm: situated north of the A45 (Braunston Road) and promoted for employment use.

Background

This submission follows previous representations made in response to the Issues and Options Paper and Call for Sites (March 2016). In June 2017, the Consultant Team, appointed by Christ Church, attended a workshop organised by OPUN on behalf of Daventry District Council. A subsequent submission was made by our client on 7th July 2017. This provided a response to a number of issues discussed, including the expansion of development beyond the ‘Daventry Bowl’, impact upon the Conservation Area; coalescence with Braunston and the provision of an adequate landscape strategy. A technical Landscape, Ecology and Heritage Statement (prepared by EDP) was subsequently submitted to Daventry District Council to inform the Council’s site assessment process.

In support of our client’s representations to the Regulation 18 consultation, this submission is accompanied by the following documents:

• Landscape, Ecology and Heritage Statement, prepared by EDP (Reference EDP3630/03a, June 2017 as submitted in response to the OPUN workshop); • Landscape Briefing Note, prepared by EDP (Reference EDP3630_r001b, January 2018); and • Drawings SK01-05, prepared by Savills.

The Daventry District Local Plan (June 1997) allocated significant land for residential development to the north of the town via Policies HS4A (Ashby Fields / Lang Farm) and HS4B (Middlemore). Such developments are largely complete and therefore extend the built limits of the town to the College’s ownership at Middlemore Farm. Likewise, employment development extends the western limits of the town to Drayton Gate Farm. Our client’s land interest, identified by the supporting drawings (SK01-SK05) is held in single ownership. Both Middlemore Farm and Drayton Gate Farm are not unduly constrained by planning policy designations and represent a logical broad location for delivery of residential and employment growth at Daventry, within the plan period to 2029.

Settlement and Countryside Local Plan (Part 2)

12 March 2018 Page 163 of 399 Landscape, Ecology and Heritage Statement - Prepared by EDP

The enclosed Landscape, Ecology and Heritage Statement was submitted to Daventry District Council following the OPUN workshop. The document provides further assessment of the development credentials of Middlemore Farm, in respect of the disciplines listed. The document demonstrates how the ‘careful analysis of environmental constraints has given rise to a masterplan that is genuinely ‘constraints-led’. The sympathetic approach adopted and presented by the masterplan demonstrates how Daventry could grow whilst respecting its environmental context.’

The Council has since published the Evidence Base associated with the LP2. This includes the:

• Site Selection Background Paper Version 1 – November 2017; • Daventry Landscape Study – Part F – Daventry Site Assessments – 2017; and • Daventry Landscape Study – Part D Fringe Assessment – Section 5 Daventry.

Landscape Briefing Note – Prepared by EDP

The accompanying EDP Briefing Note provides an assessment of the above Evidence Base documents (refer to paragraphs 2.10 – 2.16), in view of both desk and field-work undertaken by the practice. The detailed conclusions of that Report are not repeated here, though attention is drawn to the contradictory nature of conclusions, concerning Christ Church’s land interest, as set out by the Site Selection Background Paper:

EDP’s Briefing Note undertakes further assessment of the development credentials of Middlemore Farm from a landscape perspective and concludes:

• EDP do not support the contradictory conclusions of the Site Selection Background Paper, since the site has only been assessed at high-level, whereas a more detailed landscape and visual impact assessment along with good site masterplanning is something that could easily overcome the constraints [heritage and landscape] above’. By way of example ‘a suitable landscape corridor within any proposed development would preserve the character of the conservation area itself’;

• With reference to the Daventry Landscape Study – Part F – Daventry Site Assessments, EDP is ‘in agreement that most of the site could accommodate development with mitigation in place’, noting the Study reports there are some areas of the site ‘where development would be more difficult to accommodate’;

• This reinforces EDP’s assessment that a ‘well-thought out masterplan which identifies the constraints and opportunities for this development potential and sensitivity of the site will be key in the site coming forward for development’;

EDP’s Briefing Note also assesses the proposed function of the Green Wedge, as set out by Policy ENV3 of the LP2. This policy relates to land at Drayton Gate Farm. EDP’s assessment concludes:

• The proposed policy does not constitute the protection of a local space, its implementation is to act as a spatial planning tool; • Arguments relating to the importance of the landscape setting (ENV3 policy requirements ii and iii) are illogical, since any greenfield development is likely to be at the settlement edge and thereby located within its setting; • With reference to Plan EDP5, analysis shows that the proposed Green Wedge measures circa 83 hectares. This proposed designation represents extensive tracks of land and in view of comments at section 5.7- 5.19 of EDP’s Note, the draft policy is not considered to meet the basic conditions as set out in the Localism Act 2011; • The land parcel identified does not display any qualities of a valued landscape in the context of Paragraph 119 of the NPPF. As a minimum it is suggested that the ENV3 area, to the west of Daventry is redrawn as per Plan EDP5. ‘The parcel referred does not contribute to the objective of preventing coalescence. Its development would not be perceived as a protuberance into open countryside but as a discrete and logical rounding off’; • Development at Drayton Gate Farm would, at worst, inflict only a small reduction in the gap between Daventry and Braunston. Excluding our client’s land interest would still result in a separation distance of at least 1.49 kilometres. It is concluded that the Green Wedge should be reduced in area, to reflect on ground features as set out by Plan EDP5.

In summary, EDP concludes that the strategic location of Drayton Gate Farm, at the edge of the town, requires a cohesive landscape framework to ensure development is appropriately assimilated in to the wider landscape setting. Nevertheless the site is capable of accommodating development to meet future employment growth needs of Daventry.

Regardless of the final allocations proposed by the LP2, amendment is required in respect of Policy ENV3: Green Wedge. The identified policy area to the west of Daventry should be reduced in area, as set out by Plan EDP5, to reflect existing on ground natural features.

Housing Growth

12 March 2018 Page 164 of 399 serve future communities and thereby create a sustainable extension to the town. Through the site evaluation process, the Council reports that only a single site, proposed by way of allocation HO1 (Daventry South West), is able to provide this scale of delivery. HO1 is currently located within a Special Landscape Area. Three additional sites, up to a capacity of 180 dwellings are also proposed for allocation at Daventry.

Middlemore Farm has been assessed under site reference 321 in the Council’s Site Selection Background Paper (November 2017). The Stage 3 assessment of that Paper reported:

‘Although this site has some constraints, including landscape and heritage, it is one of the least constrained sites of those assessed. Given that it does not offer the regeneration benefits offered by Daventry South East, this site was not considered the most appropriate for allocation at this stage.

However following the assessment of Daventry South East through the OPUN design review process, it was decided to further evaluate this and a site at Daventry South West through the OPUN review process at Stage 4b’

The OPUN report assesses potential for some development of Middlemore Farm, reported at circa 285 dwellings. However the report recognises potential for delivery of facilities that could serve the wider area (i.e. Middlemore and Micklewell Park), thereby offering wider sustainability credentials, beyond the site itself, as a result development of the site. As set out by the enclosed documents, notably the EDP Landscape, Ecology and Heritage Statement (June 2017), our client has undertaken a careful analysis of the environmental constraints which has informed the Concept Masterplan proposal. This confirms a sympathetic approach can enable Daventry town to grow in this this location whilst respecting its environmental context. ‘Residential development can be avoided in the most sensitive areas, with the linear nature of the conservation area protected and enhanced with generous green infrastructure links’ (refer Page 12 of the Landscape, Ecology and Heritage Statement, prepared by EDP).

For the above reasons our client contests that Middlemore Farm is a suitable location for delivery of residential growth (in excess of the 285 units reported by the Council’s Evidence Base) at Daventry, which could be delivered in the plan period. Development at Middlemore Farm could come forward in a form as proposed by SK01-SK05. Allocation of this site would avoid development within the existing designated Special Landscape Area and provides the potential for delivery of an improved strategic road network with potential for delivery of a link road between the A361 and A45.

Employment Development

The western extent of Daventry Town provides significant employment uses and represents a logical location for further employment provision for the town. As above, Drayton Gate Farm (situated north of the A45 (Braunston Road) has been identified in previous Call for Sites processes for the delivery of additional employment uses in Daventry.

It is noted that a Green Wedge (Policy ENV3) is proposed across the Drayton Gate Farm site. Our client notes that the extent of the proposed Green Wedge is unduly expansive and thereby restrictive at this stage. An existing planted boundary along the western edge of Drayton Gate Farm provides a suitable alternative boundary to the proposed Green Wedge whilst still allowing for future employment uses (refer to Plan EDP5). The trees which constitute this boundary were planted in 2009 and provide natural year round cover. We consider this is an appropriate amendment to the proposed ENV3 boundary, recognising both the need to provide a buffer between the settlement and wider countryside, but also balancing the need to provide continued opportunity for enhanced future employment provision at Daventry.

Our client’s interest at Drayton Gate Farm immediately abuts Apex Park and represents a logical, deliverable site for the future expansion of employment uses at this stage. The LP2 recognises the favourable credentials of the town for delivery of employment uses. The introduction of a Green Wedge which precludes the future expansion of Apex Park is not necessary, given the other definitive policies within the LP2 that will guide development both within and outside of the built up area.

We trust the enclosed documents are of assistance to the continued plan preparation process and would welcome the opportunity to further engage with Officers as the Plan progresses.

12 March 2018 Page 165 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 HELAA ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Housing and Economic Land Availability Assessment HELAA

2.43 The Housing and Economic Land Availability Assessment (HELAA) – November 2017, identifies that sites ref. 090, 202 and 322 are available, achievable and deliverable, the conclusions of which we support. Indeed as will be set out later in these representations, we consider that Daventry South West is ‘deliverable’, having regard to footnote 11 of the NPPF.

2.44 Appendix A of the HELAA, which sets out an overview of Deliverable, Developable and Not Developable Land, outlines that Site 090 is not currently suitable for development but is available, achievable and developable. Appendix B (iii) ‘Daventry Town Residential Assessments’ provides further detail in this regard, outlining that while site 090 is not of sufficient capacity to provide the necessary infrastructure to support a sustainability community itself, this could be overcome by combining it with adjacent sites (202 and 322). We support these conclusions and agree that sites 090, 202 and 322 should be considered comprehensively to facilitate the delivery of a truly sustainable new community.

2.45 Appendix A of the HELAA states that Site 202 is suitable for residential development, available, achievable and deliverable. We note that Appendix B (iii) ‘Daventry Town Residential Assessments’ for site 202 concludes that there is no evidence to suggest development of the site would not be viable based on the information provided, a point we agree with. However, the wording of the text in the notes section in Appendix A for site 202 needs to be updated to reflect the fact that the site is included within site 322 and not 202.

2.46 We agree that Site 322 is suitable for residential development, available, achievable and deliverable. The HELAA details an estimated capacity of the site at 1,044 dwellings, which includes sites 090 and 202. Whilst we support the identification of a minimum housing capacity greater than currently assumed in Policy HO1, it should be noted that the housing capacity methodology utilised by the HELAA simply applies 35dph to the site area of sustainable urban extensions on the edge of Daventry, having regard to Policy H1 of the WNJCS. As such, it is clear that the HELAA is not suggesting that 1,044 dwellings is the maximum capacity of the site, indeed Policy H1 of the WNJCS states that sustainable urban extensions should be at least 35dph, suggesting that this figure should in fact be viewed as a minimum.

12 March 2018 Page 166 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 HO1 ED4 Geoff Pullin

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I attended the Daventry Library session on Friday & I was amazed to find an area south west of the A45 allocated to housing. This is a completely new suggestion to me. The area is separate from the town and connecting it realistically will be disruptive to the national road network and the existing increasingly crowded Grange area. This bit of the A45 is the second NW - SE by-pass and was never completed. It should have gone along Browns Lane to avoid the dog’s leg into a residential / industrial area. The thought of yet another roundabout on the A45 is lunacy.

If you must build there, please sink the A45 under without any connection.

Building on this site extends Daventry away from the major national transport links on its east and north and from employment. With developers using the ‘viability’ loop-hole, the houses are unlikely to be suitable for employees of the vast warehouses within walking / cycle distance and hence distance commuting will be encouraged thus stretching the threads of sustainability.

The only fly-over in the area already exists at the A361/A45 junction - a good example that this can and should be done elsewhere - I do not agree with your reps view that it uses too much land! It certainly uses existing differences in levels, saves accidents. It also allows higher speeds to be maintained, reduces junction delays and thus adds to the country’s productivity and reduction in emissions. I await, with resigned interest, the queues on the new A5/A45 roundabout when the M1 is closed!

If the A361/A45 fly-over can be used as a way into the site all to the good but it would then provide a direct link for villages along the southern A361 to get direct access through the SW development to Daventry town centre instead of the 1.9 mile diversion via the ex- Penguin Hotel roundabout!

I am constantly alarmed by the casual way that our Highway Authority (it needs combining with regional economic planning) allows obstructions to main roads by inefficient roundabouts (see above).

For houses, a better plan, instead of this detached blister, will be to share the houses around the smaller villages. The long-standing strangling of their gentle growth is resulting in ageing populations, unaffordable houses for youngsters, nightmare parking and declining essential facilities. The urge to conserve is often led by incomers wanting to preserve their whereabouts purchased at higher prices than locals can afford. Please look closely and critically at the very selfish and over-tight confines being drawn in a close-by Neighbourhood Plan.

A northern ring road from the A361 (Kilsby) to the A45 (Braunston Hill) will access the vast new sheds in the NW and will help keep heavy vehicles out of residential areas and provide better access for further development, within that ring.

Funding of infrastructure is the conundrum that has yet to be solved in this country and we need to get MPs on side to sort it out once and for all. Too much increase in land value from agricultural to building goes to the original owner and developer and not the facilitator of the building - i.e. the local / county council and national utilities. It prevents plans for new roads, rail, trams, power cables etc being dotted onto maps to prevent the chaotic timid way we now have to proceed. The BBC reports that only 4% of DDC land area is built on but you wouldn't think so! It is the lack of improvement of facilities for existing residents that sets people against further development due to erosion of their own living place.

12 March 2018 Page 167 of 399 Please use your professional powers of persuasion! Remember how Milton Keynes Development Corporation started by improving all the existing village centres (and the roads)!

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 HO1 ED53 DJ and S Wilson

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

By providing a rural backdrop to the urban area of Daventry, the scenically attractive slopes, summits and skyline of the hills to the South of area HO1 make a positive contribution to the form, character and setting of the town. They also form a vital buffer which altogether screens the urban area with its noise, air and light pollution from the wider countryside to the South. It is this buffer which safeguards the sense of rural remoteness and tranquillity that pervades the Upper Nene valley despite the proximity of the town.

Every effort should therefore be made in the future development of area HO1 to respect and protect the present character of the North facing hillsides and the skyline in order to preserve their contribution to the setting of Daventry town.

Similarly, the peaceful and unspoilt rural character of the Upper Nene Valley and especially its northern skyline should be protected by every means possible from any urban encroachment or intrusion arising from this extensive expansion of the town. As well as sensitive layouts, this should include landscaping and screen planting, street lighting to designed to minimise glare and sky glow and wherever necessary the restriction of development to the lower levels. This is particularly important for the eastern parts of the site nearest to the A361 where the hills are not so high.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Housing Trajectory (Housing ED110 Gary Stephens Background Paper)

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object:

Supporting Documents:

Comment:

The Housing Background Paper sets out unrealistic time frames for the preparation, submission and determination of reserved matters, pre-commencement conditions, and building regulations approval. For example, the delivery timetable for H01 - Daventry South West allows five months for these tasks to be completed. Experience shows this is highly unlikely to occur within this timeframe, and twelve months would be a more realistic timeframe. Further, there is a lack of evidence to support the proposed trajectory for Daventry North East. It is suggested that the same information and timeline provided for the proposed allocations, should also be provided for Daventry North East.

12 March 2018 Page 168 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 OPUN Report ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

OPUN Report

2.50 The OPUN Report was commissioned by the Council to provide support and advice on potential residential allocations. As the Council will be aware, OPUN is a well-respected design review body based in the East Midlands. The OPUN Report (2017) considers three sites that emerged through the call for sites process and identified as potential sites through initial site appraisals. Those sites were: • Daventry South East; • Daventry North; and • Daventry South West.

2.51 In respect of Daventry North, OPUN concludes the following at page 4:

“The land at Daventry north presents significant design challenges that limit its capacity for new development. Managing the tensions between the landscape, the setting and location of the Grand Union Canal conservation area, long views from the neighbouring village of Braunston and onto the church spire of All Saints, and the topography, means much of the site is unlikely to be suitable for development. This is especially true for land north of the Canal.”

2.52 In respect of Daventry South East, OPUN concludes the following at page 16:

“The land at Daventry South East presents significant challenges that limit its capacity for new development. Managing the tensions between the landscape, the setting and location of scheduled monuments, and the topography means much of the site is unlikely to be suitable for development. Of particular note are concerns from Historic England about the impact any development in this area would have on the two heritage assets. The loss of employment land is also problematic.”

And

“…we urge the Council to carefully consider the balance of benefits before releasing sites in this location for development due to the various constraints on site, and to be mindful of the wider aspirations within Council policy to create sustainable new extensions to Daventry.”

2.53 Finally, in respect of Daventry South West, OPUN concludes the following at page 26:

“The land at Daventry South West presents a promising opportunity to add much-needed new housing to the town.”

And

“Overall, it is estimated that the site could deliver around 1,350 new homes at a density of 30 dwellings per hectare, although space needs to be allowed for a new school and new public open space on site.”

12 March 2018 Page 169 of 399 2.54 Given the above, it is demonstrable that in OPUN’s opinion, and following a detailed analysis of all three sites, Daventry South West is the most appropriate location for strategic housing growth, a conclusion we wholly support.

2.55 In respect of the capacity for Daventry South West, this is only based on an average density of 30dph, which is below the minimum density target set out at Policy H1 of the WNJCS (35dph). We have adopted a more conservative approach to developable areas than OPUN, and also accounted for the necessary infrastructure required by Policy HO1 of the Part 2 Local Plan, but even in doing so achieve a capacity of circa 1,200 dwellings. Accordingly, the currently assumed capacity of 800 dwellings at Policy HO1 is in our view (and it appears OPUN’s view) demonstrably too low.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.05.04 ED74 Sue Halkett

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

Housing needs We are glad to see it documented that the planning for additional dwellings in Daventry rural areas has been fulfilled for building up to 2029, albeit the requirement has been exceeded, and is in some cases this has been to the detriment of the villages concerned. This is also identified in the "Issues and Options" report. We understand that this is apparently due to the poor economic situation, plus the lack of a 5 year land supply for Daventry area.

We don't see any mention on p58: 6.05.04 (Housing Mix), of single storey housing (bungalows) which would be suitable either for those wishing to downsize (thus enabling the release of large family homes onto the market), or for mobility-impaired individuals or couples. We feel that this is one type of building development which is being ignored by both council and by developers.

12 March 2018 Page 170 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.1.14 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Object

Supporting Documents:

Comment:

The Badby Parish Neighbourhood Plan Group note with some concern that the Daventry South West Site extends to the south of the A45 bordering Badby Parish and bordering the grounds of the Badby Park Care Centre which is a specialist neurological care centre catering for those in need of long term very high level care. There is little doubt that the tranquil nature of the site is a considerable asset to the type of care being delivered. We would ask that this is taken into account in any planning decisions made in this regard and consideration given to a Green Wedge to separate the Care Centre from the development.

More generally the extension of Daventry to the south of the A45 gives cause for concern as further development south of the A45 could compromise the rural landscape setting of Badby village. It is therefore pleasing to see Policy ENV3 supporting the designation of Green Wedge areas to protect the character of settlements close to Daventry. The neighbourhood plan group would be very supportive of the designation of a Green Wedge to protect Badby village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.1.22 ED109 Toby Haselwood

Organisation: Representing: Sworders Mr P Noden

Support/Object:

Supporting Documents:

Comment:

It is agreed that the proposed Policy HO2 – Daventry Mickle Well Park Extension would be consistent with the direction of growth established by the permission of 450 dwellings at the site that also provides for a new 2FE primary school and neighbourhood centre.

12 March 2018 Page 171 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.1.24 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Paragraph 6.1.24

2.37 Paragraph 6.1.24 advises that the Strategic Flood Risk Assessment (SFRA) identifies three surface water paths traversing the site, where development may need to be avoided. However, development of the site will seek to implement sustainable drainage systems which could alter the current way in which surface water travels through the site. Accordingly, it is not considered that this would cause any significant constraints to the delivery of the allocation. Further information on this matter can be found in the Flood Risk Report prepared by Brookbanks which is attached at appendix 2.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.1.24, Policy HO2, Map ED37 Jacqueline Hibbert 49

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

The proposed green wedge should be extended to meet the A361 for the following reasons: The proposed Micklewell extension abuts fields known as "Dead Shells" and "Little Dead Shells" i. in the 1930's field map (available at Northamptonshire Records Office). In the thirteenth century, this area was known as "Dead Churls" (churl being an Anglo-Saxon word for a commoner). (I can give you references to original documents, if necessary). It is probable that this area was once a Saxon settlement and burial site. Ii. The Medieval area known as Dead Churls probably extended beyond these two fields as far as the road from the A361 to Welton, where one field was known in the 1930's as "Shell Pits". The area should be protected so that it can be saved for future excavation.

12 March 2018 Page 172 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.4 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

The Badby Parish Neighbourhood Plan Group note the need identified in the Badby Housing needs survey and we understand that Badby Parish Council will discuss with DDC appropriate ways of meeting these needs through development opportunities within the village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.4 ED117 Neil Gilliver

Organisation: Representing: NRHA

Support/Object: Support

Supporting Documents:

Comment:

We support the continued position of the Authority in terms of a Rural Exceptions Policy to enable the delivery of local needs homes. We welcome the position of policy 6.4.04 enabling rural exception to meet the needs of multiple settlements. I welcome the position of the Authority in terms of enabling Local needs market homes on Rural Exception sites to assist the financial viability of delivering affordable homes.

12 March 2018 Page 173 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.5.11, policy HO7 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object: support

Supporting Documents:

Comment:

6.5.11 space standards - we fully support the proposed requirement for housing in Daventry District to meet the 'National Space Standards', over and above the minimum legal space requirements within the Building Regulations. There is increasing evidence of the benefits of enhanced space to people's wellbeing and conversely the negative impacts that limited space can have. Examples of internal space influencing wellbeing include the impact of space on: - opportunity to study/educational attainment - social interaction - play opportunities - mental wellbeing - overcrowding - opportunities for privacy/quiet space - ability to prepare/cook food - ability to receive health/social care support in the home - family tensions

Increased internal spaces is also likely to make a home more flexible and adaptable to changing needs and circumstances of individuals/families. It is thus also likely to contribute to the future proofing of housing by ensuring people are able to live independently for longer in their home.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.5.16-6.5.17 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

The Badby Parish Council Neighbourhood Plan Group confirm that specialist accommodation was an identified need in the Badby housing needs survey. We hope this gives further weight to the case for such accommodation being provided within communities.

12 March 2018 Page 174 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Para 6.8, Policy HO1 ED16 Stephen Lucas

Organisation: Representing: Lucas Land & Planning

Support/Object:

Supporting Documents: Maps attached

Comment:

Section 6 Housing delivery and trajectory: Daventry Town Sites Paragraph 6.7: The information here is unfortunately difficult to read and understand: it is suggested this aspect is reviewed so that members of the public can grasp the essential planning arguments, with explanations for any proposed change in approach.

Paragraph 6.8: This paragraph notes a 'change in the delivery programme', what does this mean? It is concerning that a simple (yet frankly an unexplained sentence) results in additional land in the rural undeveloped area outside Daventry Town (see attached UDA Plan) being brought into the urban spread of Daventry - why?

Possible allocation HO1: It is a perfectly reasonable argument that the appropriate western edge of the town is the A45 (T) Stefan Way, this is the firm defensible and logical western boundary to the town, beyond which is attractive open undeveloped rolling agricultural countryside with woodland and fox coverts forming a clearly defined geographic edge to the town.

That is a clear simple and easily recognisable physical town boundary, which stops Daventry rolling out towards and over areas of Special Landscape Value comprising rising hills, woodland and protected county wildlife sites.

This is a firm fixed and defensible western boundary to the town and should remain as such. Prior to the Pre- Submission WNJCS and as part of the Main Modifications to the JCS we made observations that in future any housing location choices for Daventry Town needed to embrace landscape evaluation at the outset of the process. Three years on we are pleased that the Landscape Evaluation is now part of the Part 2 Local Plan - frankly it should have been properly initiated at the outset of the WNJCS.

We were concerned prior to 2014 that the Daventry Town plan future development choices did not show any information on the landscape setting of the town, which we believe to be fundamental to any evaluation exercise showing any possible future development locations (of course if it is decided they are needed and clarity on this is required).

Unfortunately the same concerns still apply to those comments we made in 2014. In this context it is useful to look at the 160m or old 500ft contour plans of the town which clearly shows a series of hills forming the attractive western edge of the town. The town sits in a bowl and the landscape gets flatter area to the east (towards the A5).

The logical development location for any future town growth, which we question in any case, is east not west. In the context of the above we find the future allocation of HO1 to supply any future Daventry Town housing completely illogical, going against established and sound planning principles reviewed in and as part of the initial Daventry Town Map (the arguments have not changed). Your plan proposals ignore a readily recognisable logical and permanent boundary, namely the A45 which forms the clearly defined western edge of the town.

For convenience in this argument we attach a plan showing the Daventry Town Map and the area to be developed to provide for a population of 34,400, showing the western edge of the town and the then proposed A45 (western bypass). It is worth noting the plan was to provide for a population some 11,000 greater than the current town population.

12 March 2018 Page 175 of 399 Future housing: The housing summary table on page 31 should in reality be called a Possible Draft Housing Summary Table as two of the proposed sites HO1 and HO2 lie in open countryside outside the town boundary within the rural area. Any allocation of these sites, particularly HO1 means a number of significant 'planning hoops' have to be tackled, because after all this will be an allocation and town expansion into open undeveloped countryside, quite apart from the other notable planning issues.

The whole situation regarding Daventry Town development we submit begs a number of questions which have never been addressed. In essence proposals for Daventry Town are continuing as if the Milton Keynes - South Midlands Sub Regional Strategy was still in place - namely that Daventry Town is a 'growth area'. Clearly if that was the reality the town housing market would be dynamic, that is clearly not the case and has not been so for many years. In this respect it is worth noting that the Daventry Town Development Area was scheduled to reach a population of 36,400 persons in the 15 years from 1966 to 1981. Slow growth has been characteristic of the town - the same applies today.

Prior to the Plan Submission to the Secretary of State in late 2018 there will have to be complete clarity on the emergent situation of the real role of the town, as a plan will not be endorsed which fails to deliver employment and housing.

We submit the real issue here is to reflect again on paragraph 154 of the Framework 'Local Plans should be aspirational but realistic'. We fell certain that any Part 2 Plan inspector will need absolute clarity over Daventry's future role, in effect they will require a long overdue reality check. A number of the town housing and mixed development sites are not moving forward and being developed as 'expected'. This plan has to address that reality. In our view there can be no endorsed expansion west into the undeveloped rural open countryside and attractive landscape setting of the town because this really is losing part of the attractive landscape fabric of the whole district and the question we ask is on what basis is this land being programmed into Daventry Town expansion, that is not clear from the plan at all.

We advise you to look again at the housing provision and need in the town and why development in the town is not moving forward, how matters can be changed: we think we have some answers but we were not invited to any workshop sessions.

12 March 2018 Page 176 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Paras 6.1.09 and 6.1.24, ED59 Geoffrey Smith Policies HO1, HO2 and HO3

Organisation: Representing: Welton Parish Council

Support/Object:

Supporting Documents:

Comment:

2. Chapter 6. Meeting the District’s Housing Needs Our strong concerns with the Draft Local Plan are contained within this section. They are also reflective of the concerns expressed within the consultation undertaken as part of Welton’s emerging Neighbourhood Plan, resultant in Policy 4 of the draft Neighbourhood Plan ‘Preventing Coalescence’ which states that ‘Development proposals should respect the individual and distinct identities of Welton village and Daventry and the open gap between them. Development will not be permitted if individually or cumulatively, it would result in the loss of the visual and physical separation of these settlements, which would harm their setting and identity or lead to their coalescence’.

6.1.09 The slippage in delivery of Daventry North East (SUE) is regrettable, since it inevitably increases the requirement to build elsewhere. Welton Parish Council trusts that the planning application for the site will be expedited in view of the positive involvement of Daventry District Council, local villages such as Welton and Norton, as well as the developers themselves in the thorough initial consultation process. Further slippage must be avoided at all costs.

6.1.24 Welton Parish Council acknowledges that the following has been recognised as crucial with regard to the proposed Micklewell Park Extension: …’It is important to ensure that proposals for the extension to the site include appropriate measures to mitigate its impact on the landscape. In addition it will be important that the development protects the setting of Welton village and avoids settlement coalescence’.

Policy HO2 Daventry Micklewell Park Extension. This site will extend the number of dwellings to 630 at Micklewell Park. As the mode share of journeys to work for Daventry District residents is predominantly based on the car and higher than the national average and travel by bus markedly lower than the national average, then it is clear that extra pressure will be placed on the local road network, particularly the already busy A361.

The centre of the site is a considerable distance from the centre of Daventry and much further than the centre of HO1, Daventry South West, to the centre of Daventry or the centre of Daventry North East to the centre of Daventry. Part A of the policy is crucially important (proposals for this site must be informed by a master plan etc.); Parts Bi and Bii and the whole of C in the policy are similarly important in terms of mitigating the impact on the setting of Welton and preventing coalescence.

Policy HO3 Daventry land at Middlemore. This makes provision for at least 100 dwellings which means that further development in the north amounts to 280 dwellings and possibly more.

12 March 2018 Page 177 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policies HO1, HO2 ED54 Richard Hill

Organisation: Representing: Thames Water

Support/Object:

Supporting Documents:

Comment:

Thames Water on the above document. Thames Water is the statutory sewerage undertaker for the a small part to the south of Daventry and is hence a "specific consultation body" in accordance with the Town & Country Planning (Local Development) Regulations 2012.

Policy specific comments Thames supports the requirements of Policy HO1 and HO2 for all development to be informed by assessments suitable mitigation relating to water infrastructure.

We however feel that this would be better covered by a capture all development in the district policy which directly relates to water and wastewater infrastructure. We propose a policy as follows: "Proposed Policy - Water and sewerage infrastructure capacity: Planning permission will only be granted for developments which increase the demand for off-site service infrastructure where: 1. sufficient capacity already exits or 2. extra capacity can be provided in time to serve the development which will ensure that the environment and the amenity of local residents are not adversely affected. When there is a capacity constraint and improvements in off- site infrastructure are not programmed, the developer should set out how the infrastructure improvements will be completed prior to occupation of the development."

It is considered that text along the following lines should be added to the Local Plan to support the above proposed policy: "Proposed new policy supporting text: The Council will seek to ensure that there is adequate water supply, surface water, foul drainage and sewerage treatment capacity to serve all new developments. Developers will be required to demonstrate that there is adequate capacity both on and off the site to serve the development and that it would not lead to problems for existing users. In some circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing infrastructure. Where there is a capacity constraint and no improvements are programmed by the water company, the Council will require the developer to set out how the infrastructure will be delivered."

Site specific comments None of the draft allocations fall within Thames Water's supply area, as such we have no specific comments to make.

12 March 2018 Page 178 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policies HO2 and HO3 ED73 Stacey Wylie

Organisation: Representing: Northamptonshire County Council Development Management Support/Object:

Supporting Documents:

Comment:

Policy HO2 & HO3 - Micklewell Park Extension and Land at Daventry Middlemore 12. The proposal to extend the Micklewell Park SUE by approximately 180 dwellings and Middlemore SUE by 100 dwellings is noted. Currently, a new 2 Form of Entry Primary School is proposed to be delivered at Micklewell Park through the ESFRA's Free School programme, linked to the existing proposals for 450 dwellings. The proposed increase in housing set out into eh draft Plan will therefore need to be carefully assessed by the County Council and ESFA to ascertain whether the existing scheme will have sufficient capacity to accommodate the likely increase in pupil demand at the School as a result of the additional homes being delivered. This may result in a requirement for additional forms of entry and/or additional land to be made available for expansion of the Primary School to accommodate the additional pupils. The draft Plan should therefore ensure that there is flexibility with the Plan to enable provision of additional capacity at the Primary School above the current 2 Form of Entry proposal should this need be identified.

13. As well as the additional land allocations in the draft Plan, the County Council will continue to monitor capacity and pupil generation forecasts across the existing schools estate, and assess the ability of these facilities to adapt, expand and/or enhance existing provision where possible to mitigate the impact of development. The draft Plan should reflect the County Council's strategic priorities for ensuring sufficiency of pupil places as a standard consideration in the assessment and determination of planning applications and in the securing of developer contributions through CIL and s106.

12 March 2018 Page 179 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy H04 ED115 Ed Hanson

Organisation: Representing: Barton Willmore Landform Daventry Ltd.

Support/Object:

Supporting Documents: Attached - Development Proposals, Indicative masterplan

Comment:

Draft Policy HO4 - Self build and custom build housing Draft Policy HO4 states that outline applications for Self-Build and Custom Housebuilding schemes of more than one dwelling must be accompanied by a design code. The policy lists matters that the design code should include and Landform supports the inclusion of this type of policy.

Landform recognises the need for self-build and custom build plots across the district. The Government’s Right to Build policy states that all councils must make land available for such homes.

The Government wants the number of self builds, which is currently about 7% of all new housing, to double. Self- build plots also widen the sales market and often lead to higher land values.

Home buyers benefit because they have access to individually designed homes as well as help with the more difficult technical and legal aspects of self-build. More than half of the UK’s home buyers say they would love to build their own home but are put off by the difficulties. The local community benefits because of the improved quality and diversity of housing schemes instead of look-a-like housing developments.

The lack of availability of consented land with infrastructure and services is the single biggest constraint to delivery of self-build housing and DDC should positively plan for this through the use of the self-build register to inform the emerging Local Plan.

Landform has a proven track record of delivering self-build plots as part of wider housing proposals and is currently involved in three schemes (Mickle Well Park, Daventry - 24 plots, Land north of Smee Lane, Norwich - 11 plots and Cleeve Park, Thornbury – 14 plots).

We trust this information is of use and we look forward to commenting at the next stage of the Local Plan consultation. We also welcome the opportunity to present emerging proposals for the farmstead and seek pre- application advice.

12 March 2018 Page 180 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED56A, ED56B Ann Plackett

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I consider that new development should not jump across the bypass into an area which has acknowledged landscape, biodiversity and historic environment value, including direct impacts on the Special Landscape Area, features of landscape and biodiversity value and the setting of historic sites and buildings. The development of this site would not be consistent with the emerging policies on the protection of the environment or the relevant sections of the National Planning Policy Guidance. The Non-technical summary seems to be consistent when identifying the severity of the negative effects. On page 20 it suggests that the effects on the landscape of development in this area would be significantly negative, while on page 24, it identifies them as minor negative effects. I do not consider that the adverse impacts could be successfully mitigated.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Site-specific comments 12. The following site specific comments are made in the absence of any detailed highway or transport assessments being presented alongside the Plan. While they represent the County Council’s best assessment of the implications of development at the sites at this time, these comments are made without prejudice to further requirements for highway or transport mitigation or measures which may be required in response to future planning applications and transport assessments or statements. Daventry South West (Policy HO1)

13. A new junction with the A45 is proposed as part of this development. However, no rationale is presented as to why the principal junction is proposed with the A45, which forms part of the Department for Transport’s indicative Major Road Network (currently subject to consultation), rather than with the A425 or A361. In the absence of such evidence we would recommend that policy HO1 is amended to refer to “two direct vehicle accesses from the highway network”.

14. We would not regard an at-level crossing across the 60mph A45 as intrinsically safer than the current footbridge, and would recommend that until an appropriate assessment of alternatives is carried out policy HO1 is amended to refer to “improved pedestrian connectivity to Tyne Road and onwards to Daventry town centre”.

15. It is not clear how the proposal to have two junctions – to the A45 and A425, both relatively close to the A45/A425 junction will “enable public transport to be routed through the development” (para 6.1.16) since both junctions will be in the western part of the development. Neither is it clear how such a service could be integrated with existing bus services in Daventry, and we recommend that further discussions are held with the County Council (as local transport authority) and Stagecoach (the local bus operator) to discuss how this might best be achieved.

12 March 2018 Page 181 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED73 Stacey Wylie

Organisation: Representing: Northamptonshire County Council Development Management Support/Object:

Supporting Documents:

Comment:

Policy HO1 - Daventry South West 10. The County Council notes the proposed inclusion of a new Sustainable Urban Extension of up to 800 dwellings at Daventry South West. The requirement for land to be provided within the SUE for a new two form of entry Primary School is welcomed, and the County Council remains committed to working with DDC and the developer/promoter of the site to establish detailed requirements for construction and delivery of the school.

11. Where possible, further detail within the policy would be welcomed as to the proposed phasing of the SUE and delivery of the school, in addition to which it would be useful to ascertain at as early a stage as possible any opportunity for future expansion of the school, where this may be required to support additional future demand and development. The policy should also be explicit in the requirement for housing development related to the site to contribute towards the construction cost of the new school in order to adequately mitigate against the impact of the development on local infrastructure.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of housing development on this site.

As set out in Daventry Water and Wastewater infrastructure Assessment provided by Anglian Water this housing site is expected to require improvements to the water supply and foul sewerage network to enable this site come forward.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy H01 includes reference to the above requirement. Therefore it suggested that reference to water infrastructure could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

12 March 2018 Page 182 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED64 Kate Thompson

Organisation: Representing: Pegasus Group Miller Homes

Support/Object: Object

Supporting Documents:

Comment:

Policy HO1 – Daventry South West In light of the above, objection is also raised to Policy HO1 South West Daventry as in addition to existing commitments in and around Daventry, the site is simply not going to be deliverable in the plan period. Policy HO1 should thus be deleted, or at least the trajectory from the site pushed back so most is delivered post plan period.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED120 Mark Wesley

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

This is clearly an unsustainable development being built outside the current bypass. The paper clearly shows this and talks of the need for links but overplays the current infrastructure links to the rest of the Town and the centre. The proposal fails across the board on the sustainability front. The mitigation would be have to be so radical to link the development it would clearly hinder the bypass and traffic flows.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED123 Karen Alexander

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I object to HO1 plan for 800 houses to be built on a special landscape area, when there are more suitable sites. This is a huge development on a Greenfield site in the countryside and could lead to more development into the SLA.

12 March 2018 Page 183 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED128 Douglas McNab

Organisation: Representing: Education & Skills Funding Agency

Support/Object:

Supporting Documents:

Comment:

1. The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level.

2. The ESFA, launched on 1st April 2017, brings together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children, young people and adults. The ESFA are accountable for £61 billion of funding a year for the education and training sector, including support for all state-provided education for 8 million children aged 3 to 16, and 1.6 million young people aged 16 to 19.

3. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and the ESFA is the delivery body for many of these, rather than local education authorities. As such, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We do this through a variety of means, including by supporting the adoption of sound local plan policies, site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools. In this capacity, we would like to offer the following comments in response to the proposals outlined in the above consultation document.

General Comments on the Local Plan Approach to New Schools 4. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 72).

5. The ESFA notes that substantial growth in housing stock is expected in Daventry District; the adopted West Northamptonshire Joint Core Strategy (WNJCS, 2014) confirms the annual housing target of 12,730 homes over the period 2011 to 2029. This will place significant pressure on social infrastructure such as education facilities. The Local Plan will need to be ‘positively prepared’ to meet the objectively assessed development needs and infrastructure requirements.

6. The ESFA notes that this draft Local Plan Part 2 sits alongside the adopted WNJCS. The WNJCS includes objective 10 on educational attainment and a number of policies that support the delivery of new schools, including Policy E6 Education, skills and training; Policy INF1 Infrastructure Delivery; and Policy INF2 Contributions to infrastructure requirements. In addition, 11 site-specific policies for sustainable urban extensions include requirements for new schools (the vast majority being primary schools).

7. The Local Plan Part 2 is being prepared to further guide planning decisions in the district. It sets out the Daventry District Spatial Strategy and includes policies on development in rural areas, housing, economy, transport, environment and community facilities. The housing section includes new proposed allocations for Daventry Town. One of these, Daventry South West (minimum 800 homes) includes a requirement for a 2FE primary school (Policy H01). This site specific school allocation is welcomed by the ESFA, however it will be important to update the Infrastructure Schedule (which is said to be currently under review), working with the county council, so that the evidence base to support this requirement (in terms of need and capacity) can be made clear; and to confirm that no additional site allocations for schools are required (above and beyond those in this document and the WNJCS) to

12 March 2018 Page 184 of 399 support the proposed level of housing growth.

8. It would be useful if this site allocation could also clarify requirements for the delivery of the new school, including when it should be delivered to support housing growth, the minimum site area required, any preferred site characteristics, and any requirements for safeguarding additional land for future expansion of the school where need and demand indicates this might be necessary. For an example of the latter, see draft policy CC7 in Milton Keynes’s Plan:MK Preferred Option draft from March 2017 . The policy should make it clear that the development will be required to contribute to land and construction costs for the new school, to meet the need generated by the development.

Forward Funding 12. In light of draft policy H01, emerging ESFA proposals for forward funding schools as part of large residential developments may be of interest to the council. We would be happy to meet to discuss this opportunity at an appropriate time.

12 March 2018 Page 185 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED138K Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Object

Supporting Documents:

Comment:

Policy HO1 – Daventry South West proposes to allocate 800 houses together with land for a two-form entry Primary school and a local centre to provide local shopping facilities; this will create a small urban extension to the south of Stefen Way (A45).

Daventry Town Council strongly objects to this proposal as the allocation breaches the A45 ring road and extends the town into a Special Landscape Area. The development would also impact on the listed building and the setting of Badby House. The Site Selection Background Paper – November 2017 also indicates that the ‘transport infrastructure constraints in particular need careful examination including access and the ability to safely cross the A45 as a pedestrian.’ Daventry Town Council objects to the location of this development as it would be isolated and not integrated with the rest of the town, specifically links to the town centre. The proposed development is 1.5km away from the town centre and although there is an existing pedestrian ramped bridge, which connects the western side of Staverton Road with the Eastern town side, it does not provide a user-friendly accessible crossing for pedestrians and/or cyclists, particularly those with mobility issues, prams and buggies. Research has shown that people use the shortest route and the development is bordered by a highway with a speed limit of 60mph.

Daventry Town Council considers that the site would need to gain a primary access from both the A425 and the A361. Stefen Way is an orbital ring road with a national speed limit, it is not considered appropriate to downgrade the road and add further junctions with the inclusion of an ‘at grade pedestrian crossing’ connecting to Tyne Road. This would compromise the function of the road and decrease road safety. Due to the existing road infrastructure and bus networks, there is no direct route into the town centre.

This large-scale development would be intrusive into the open countryside and would break into the boundary of the town’s built environment south of the A45.

Daventry Town pre-existing development that an alternative approach would be to split this requirement for 800 homes into smaller requirements and parcels.

Daventry Town Council considers that the requirement for 800 homes in Daventry should be allocated, in smaller parcels, adjacent to pre-existing committed developments, specifically the North-East SUE, land to the north west of Middlemore (part of site 321). This would enable these new development areas to be more sustainable by being able to plan for and provide more community facilities.

The Canal Conservation Area is a potential constraint in this location, however, existing planning permission for Micklewell Park (DA/2014/0869) indicate that mitigation and design can adequately protect this heritage asset. The location of residential housing in this location will also enable a link through to the employment allocation EC7 and the existing commercial area of Drayton Fields Industrial Estate. Site HO1 will not be as well located for access to employment areas by foot or by bicycle.

Daventry Town Council therefore advocates an approach to the allocation of residual residential requirements for the Local Plan Part 2 to focus on the North of the town, expansion of the North-East SUE which would build upon the growth in these locations rather than expanding the town to the South West.

12 March 2018 Page 186 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED141A, ED141B Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents:

Comment:

In light of the comments above, objection is also raised to Policy HO1 South West Daventry as in addition to existing commitments in and around Daventry, the site will not be deliverable in the plan period and would compete directly with the effective delivery of the Daventry North East SUE, an allocated site. Policy HO1 should thus be deleted or at least the trajectory from the site pushed back so most is delivered post plan period.

12 March 2018 Page 187 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

1.1 These representations have been submitted by Nexus Planning on behalf of High Cross Farm Limited and Drayton Lodge (“the Client”) in respect of the Daventry District Settlements and Countryside (Part 2) Local Plan herein referred to as “the Part 2 Local Plan”, in relation to Land at Daventry South West (“the Site”).

1.2 The Site measures approximately 54 hectares and is identified in the Part 2 Local Plan under Policy HO1 as a draft housing allocation. The Client controls the entirety of this allocation and the Site boundary is shown at appendix 1. These representations are accompanied by initial technical reports, which have been prepared in support of these representations.

1.3 Overall, we support the identification of the Daventry South West (Policy HO1) as the principal strategic allocation within the Part 2 Local Plan to deliver a minimum of 800 dwellings and can confirm that the land is available for a residential-led mixed use development. We do however raise a number of detailed comments relating to the draft allocation, namely that we consider that the site can accommodate approximately 1200 dwellings.

1.4 As will be set out in our representations, this location for strategic growth, on the edge of the most sustainable settlement in the District, is fully justified through the Council’s evidence base prepared in support of the Part 2 Local Plan. Furthermore, the scale and location of this allocation presents a genuine opportunity to deliver a vibrant new community based upon high quality and green infrastructure led design principles.

1.5 Overall, the allocation will create a significant new community that delivers upon the three dimensions of sustainable development set out in the National Planning Policy Framework (NPPF) and will help enhance the profile of the town, in accordance with Policy HO1.

Technical work undertaken to date

2.63 Policy HO1 refers to any development on site needing to be informed by assessments and suitable mitigation. To date high-level technical work has been undertaken in support of the emerging allocation and further work will of course be undertaken to support any planning application on the site. A summary of the technical work undertaken to date is set out below:

Access Feasibility Report

2.64 An initial Access Feasibility Report has been prepared by WYG (see appendix 3) and details the general principles in terms of a suitable form of junction onto the A45 Stefan Way and the A425 Staverton Road and initial junction capacity. Discussions with Northamptonshire County Council (NCC) as the Local Highways Authority are currently ongoing.

2.65 The Access Feasibility Report concludes that a three arm priority junction on both the A45 Stefan Way and A425 could provide a suitable form of junction to cater for the predicted level of traffic flows associated with the scale of development proposed. Furthermore, a signal-controlled pedestrian crossing on the A45 could be provided at the

12 March 2018 Page 188 of 399 proposed main site access junction, without adversely impacting on the operational capacity of the junction. The report also concludes that the predicted traffic associated with the proposed development could be accommodated at the A45/A425 roundabout junction during the typical weekday peak hours. The impact of development traffic on the wider highway network would need to be assessed as part of a detailed Transport Assessment that would be provided in support of any planning application on site, but not required at the local plan stage.

Heritage Appraisal

2.66 An initial Heritage Appraisal has been undertaken by Orion (see appendix 4). This technical work identifies there are no archaeological assets within the site or within the immediate vicinity, such that their setting or significance would be affected. Furthermore, it identifies that the potential for significant buried archaeological remains within the site is low. With regards to the built heritage, the technical note identifies no built heritage assets within the Site. However, one designated asset located adjacent to the site is the Grade II listed Badby House. The appraisal concludes that planting in the south and south eastern parts of the site will result in a positive reinstatement of the landscape’s historic character, which has the potential to enhance the setting of Badby House. This is a significant factor weighing in favour of the draft allocation (paragraph 137 of the NPPF)

Initial Flood Risk Report

2.67 Brookbanks consulting have undertaken an initial Flood Risk Report (see appendix 2), which addresses both the flooding risk and surface water drainage considerations. The Site is located in Flood Zone 1, and is therefore an area of low probability of flooding, outside both the 1 in 100 and 1 in 1000 year flood events. With regards to surface water any development will seek to implement sustainable drainage systems in line with the SFRA. The Site has low probability of flooding from overland flow, ground water and sewer flooding. Brookbanks has also carried out initial analysis on ground conditions and utilities (see appendix 5) which confirms that such considerations would not prevent the delivery of the allocation.

Ecology Appraisal

2.68 Baker consultants have undertaken an initial desk based Ecological Study (see appendix 6) which concludes that the ecological impacts as a result of the development will be limited and where constraints exist, mitigation will be carefully designed to ensure that important habitats are retained or compensated. Further, it identifies opportunities to deliver a number of contiguous ‘green corridors’ that connect the site to the wider countryside, maximising the ecological functionality of the site.

Air Quality Assessment

2.69 WYG has undertaken an Air Quality Assessment (see appendix 7) on the site and this has assessed the worst case 2017 emissions, which have been modelled using the assumed worst-case proposed receptors. Clearly this will lead to an identification of the worst-case scenario. The report concludes that following a review of the baseline conditions and the DMRB modelling results, it is predicted that levels of NO2 or PM10 will not exceed the air quality objectives of the Part 2 Local Plan. Accordingly, air quality will not present a constraint to the delivery of the site.

Landscape and Visual Appraisal

2.70 Define has undertaken an Landscape and Visual Appraisal (see appendix 8) which appraises the landscape and visual aspects of the site by describing the baseline conditions of the surrounding landscape character and visual amenity, and considering how the proposed development would relate to this baseline condition. The appraisal concludes that the site sits on the lower slopes of the Ironstones Hills Landscape Character Type (LCT), which is an area of distinctive undulating hills. The proposed development effects on the Ironstone Hills LCT/Staverton Hills LCA, and the on-site landscape resource, is moderate in its significance, and includes both beneficial effects (due to the introduction of native woodland elements and restored hedgerows) and adverse effects (due to the replacement of agricultural land use with a new settlement.

2.71 The likely visual effects of the proposed development are naturally limited by the topography, which forms a distinctive edge and screens the site from the wider LCT to the south. When considering the establishment of the proposed woodland, corpses and hedgerows over a 15 year period, the proposed development will successfully

12 March 2018 Page 189 of 399 assimilate into the landscape, and is unlikely to give rise to visual effects any more than moderate to substantial significance for views immediately adjacent to the site, and slight to negligible for views beyond. The effects have beneficial elements (additional visual landscape structure and restoration of hedgerows) and adverse (some visibility of new development and infrastructure). The long-term visual effects are therefore highly contained and restricted to the immediate vicinity of the site.

2.72 The development of land within the sites red line (appendix 1) will not reduce the physical gap where neither the identity of Daventry or Staverton is visible or recognised. The actual recognised gap between settlements lies to the west of the proposed draft Green Wedge designation, and includes the local hills of Staverton Clump and Big Hill, and also Staverton Golf Course.

Noise

2.73 WYG has undertaken an initial noise investigation survey to determine the baseline ambient noise levels currently experienced on the site (see appendix 9). This survey demonstrates the worst case scenario for potential noise attenuation and does include an allowance for any physical on-site mitigation measures such as additional planting or fencing along the A45. Even when adopting this approach, it is clear that only limited mitigation is required for the site to achieve the relevant noise standards (in the form of enhanced glazing) and that overall, noise considerations will have no impact upon the developable areas of the site.

Education Technical note

2.74 Policy HO1 currently requires the site to deliver a two form entry (2FE) primary school to support 800 dwellings, which Nexus Planning has reviewed in terms of whether the development would generate such a demand (see appendix 10).

2.75 The assessment identified that based on Department for Education standards a 2FE Primary School has capacity to accommodate 420 pupils. However, in line with the National Audit Office report on Capital Funding for new school places published in 2013, schools are considered to be at capacity when the number of pupils in relation to the total capacity of the school is equal to or exceeds 95%. Therefore, a 2FE Primary School with a total capacity of 420 pupils will be considered to be at capacity once the number on roll (“NOR”) reaches or exceeds 399 pupils.

2.76 Based upon a development comprising 800 dwellings, this would yield circa 244 primary school pupils, leaving a significant headroom (39%) and at 1,200 dwellings the pupil yield would be 365 places, leaving a headroom of 9%.

2.77 In light of this analysis, it is evident that to ensure the delivery of a 2FE Primary School the following options will need to be considered as the preparation of the Local Plan progresses:

a) Amend Policy HO1 B(i) to require provision of 1,200 dwellings (our suggested strategy); or b) Identify which other housing allocations / development will provide infrastructure contributions towards the delivery of a 2FE Primary School on the Daventry South West site.

Housing Mix

2.78 The approach to housing mix for the site is referenced in paragraph 6.1.19 of the accompanying text for Policy HO1. The paragraph states:

‘The Site will need to make provision for a mix of dwelling types, which will help to meet the needs identified in Policy HO7. However in order to help meet wider regeneration aims of Daventry, in particular to attract new residents to live and work in Daventry, there may be scope for some larger properties to be provided as part of the housing mix. However this should only be at a level that still provides a mix that is broadly consistent with Policy HO7.’

2.79 Policy HO7 identifies the need to provide a mix of dwelling types and sizes to cater for current and forecast accommodation needs, which will in turn contribute to the creation of sustainable mixed and inclusive communities. The policy identifies a definitive housing mix for market and affordable housing, with deviations only permitted where “they are evidenced by a robust assessment of needs at an appropriate local level”.

12 March 2018 Page 190 of 399 2.80 It is therefore clear that whilst Policy HO1 seeks to provide some flexibility with housing mix and only requires it to be “broadly consistent” with Policy HO7, which we support, this is not reflected in Policy HO7 and as such, there appears to be a disconnect between the two. To rectify this issue, we consider that the Council should provide a further explanation of the market and affordable housing mix that would be appropriate for the site within Policy HO1 itself. Any housing mix would of course need to meet the policy objectives of HO7 and this policy could helpfully acknowledge the alternative approach for Daventry South West.

Summary

2.81 Given the above, it is clear that there is a strong evidence base which supports the allocation of Daventry South West for a residential-led mixed use scheme and our technical analysis to date demonstrates that there are no technical issues that would prevent the delivery of approximately 1,200 dwellings on the site.

2.82 Increasing the allocation to 1,200 dwellings, without additional environmental harm or compromising the objectives of the Plan would better help the Council to boost significantly the supply of much needed market and affordable housing within Daventry (paragraph 47 of the NPPF). It would also make a more effective and efficient use of a greenfield site, reduce pressure to develop further greenfield sites and ensure that the potential of the site to accommodate development is optimised (paragraph 58 of the NPPF).

2.83 Overall, Daventry South West will deliver a number of significant benefits to the local community, Daventry Town and indeed the District as a whole, including but not limited to:

a. a new primary school; b. a significant quantum of much needed affordable and market housing; c. a diverse mix of dwelling sizes, types and tenures to aid the regeneration of Daventry; d. a green infrastructure led design with access to significant areas of open space; e. new local centre; f. improved connectivity with Daventry Town Centre for cyclists and pedestrians; and g. significant new highway infrastructure, including a substantial new roundabout on the A45.

2.84 Furthermore, whilst the site is located adjacent to the built up area and will benefit from the array of services and facilities within Daventry, the allocation will be separated from the existing settlement by the A45. This, in combination with the contained nature of the site, provides the opportunity for its own character to be defined. The development will therefore have the potential to reflect both the vernacular seen across Daventry District, but also to create a new character, set within a high quality landscape led scheme, which in turn would further enhance the profile of Daventry Town - a clear policy aspiration of the emerging Local Plan.

Changes Sought to Policy HO1:

2.85 In light of the above, the following changes are considered appropriate to Policy HO1 sections A and B.

HO1 – Daventry South West

A. Site HO1 is allocated for residential development. Proposals for this site must be informed by a comprehensive Masterplan, agreed by the Council as local planning authority that must demonstrate how the site will come forward comprehensively.

B. The development will make provision for all of the following: i. A minimum of 800 dwellings Approximately 1200 dwellings; ii. Land for a two form entry Primary school; iii. A local centre providing local shopping facilities of an appropriate scale to serve the needs of the community and surrounding area; iv. A mix of house types, and flexibility in the approach to housing mix including housing to assist with the regeneration of Daventry and to help enhance the profile of the town; v. An integrated transport network serving the site focused on sustainable transport modes that provides: a. Improved pedestrian and cycle links from the site to Staverton Road

12 March 2018 Page 191 of 399 b. Direct vehicle access from the A45 which also includes provision of an at grade pedestrian crossing connecting to Tyne Road; c. At grade pedestrian connection to Daventry Sports Park; d. Improvements to the existing Staverton Road – Yeomanry Way crossing; e. Improvements to the existing footbridge to support use by pedestrians and cycles; f. Access to public transport providing connections to Daventry Town Centre, Strategic Employment Areas and Northampton; vi. Structural green space and wildlife corridors which retain important existing landscape features including hedgerows, woodlands and mature trees and include appropriate landscape buffers to mitigate the impact on the setting of Big Hill and Badby House; vii. Necessary financial contributions to off-site highway works to mitigate the impact of the development on the highways network; viii. Maintenance and enhancement of appropriate landscape features along the A45 to function as a green link; ix. On-site surface water drainage systems; and x. Necessary financial contributions to contribute to the enhancement of sport and leisure provision within Daventry; xi. A comprehensive site wide masterplan to be submitted and agreed by the Council ahead of any planning application being taken to planning committee; xii. A site wide Infrastructure Delivery Plan demonstrating how a phased development will support the costs of the associated infrastructure.

2.86 In respect of the insertion of a more strict requirement to provide a comprehensive site wide masterplan, it should be noted that whilst Daventry South West benefits from only two landowners, the site is nevertheless strategic in scale and includes the provision of significant on-site infrastructure. To ensure the comprehensive master planning of the site and ultimately a properly planned development, it is considered that any planning application on the site should be supported by a comprehensive masterplan, illustrating a disposition of land uses and infrastructure.

2.87 To ensure the infrastructure costs are equalised between landowners and appropriately phased an Infrastructure Delivery Plan (IDP) should be provided ahead of any application being approved.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

SEVERAL TECHNICAL DOCUMENTS APPENDED TO REP 1. Site boundary plan 2. Flood risk review 3. Access Feasibility Report 4. Heritage Appraisal 5. Technical Note Rv1: Ground Conditions and Utilities (ED139b) 6. High Level Summary: Ecology-Constraints and Opportunities (ED139B) 7. Air Quality DMRB Constraints Assessment (ED139B) 8. Landscape and Visual Appraisal: Technical Note (ED139B-ED139D) 9. Residential Constraints Sketches – Noise (ED139E) 10. Education Technical Note (ED139E) 11. Population Forecasting Study 2014 (ED139E)

12 March 2018 Page 192 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO1 - HO3 ED142B James Yeoman

Organisation: Representing: Savills Christ Church Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Housing Growth

Paragraph 6.1.12 of the LP2 acknowledges the landscape and topography constraints to the growth of Daventry. However, it is noted that the Council seeks for a sizeable allocation (800+ units) in order to support infrastructure to serve future communities and thereby create a sustainable extension to the town. Through the site evaluation process, the Council reports that only a single site, proposed by way of allocation HO1 (Daventry South West), is able to provide this scale of delivery. HO1 is currently located within a Special Landscape Area. Three additional sites, up to a capacity of 180 dwellings are also proposed for allocation at Daventry.

Middlemore Farm has been assessed under site reference 321 in the Council’s Site Selection Background Paper (November 2017). The Stage 3 assessment of that Paper reported:

12 March 2018 Page 193 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Daventry – Micklewell Park Extension (Policy HO2) 16. The combination of the proposed extension and the existing permitted Micklewell Park site is such that a second highway access from the A361 will be required, and the highway network of the extension should be connected to the existing allocation as a loop so that the whole development can (if necessary) have access to either exit from the site. Such connectivity would also facilitate the routing of pedestrians, cyclists and buses within and through the development.

12 March 2018 Page 194 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 ED109 Toby Haselwood

Organisation: Representing: Sworders Mr P Noden

Support/Object:

Supporting Documents: Attached - Indicative Masterplan

Comment:

HO2 – Daventry – Micklewell Park Extension has been included within the Local Plan to help address objectives 3, 4 and 9, set out in Chapter 3: Vision and Objectives, and we agree that this will help to deliver policies S1, S3 and D1 of the West Northamptonshire Joint Core Strategy.

A - Any proposal for this site would be informed by a masterplan, (following the principles included in the indicative concept masterplan submitted with these representations), informed by the third party assessments that are being undertaken, agreed by the LPA

B – The development will provide at least 180 dwellings, structural green space and wildlife corridors and include appropriate landscape buffers, retain an area of green wedge to the North and East of the site and provide reasonable necessary contributions to infrastructure.

C – Any proposal that comes forward on this land will be informed by appropriate surveys and assessments that will also set out appropriate mitigation measures covering and relating to Archaeology, Heritage Landscape and Visual, Ecological, Highways and Transport, Flood risk and Water Infrastructure and Noise and Air Quality Impact.

These works will include and are currently being progressed: - Topographical Survey of the site - An Archaeological desk based heritage assessment - Landscape and Visual Impact Assessment - Phase One Ecological Survey - Initial Highways and Transport Assessment - Flood Risk and Water Infrastructure Survey and Report - Noise and Air Quality Survey and Report

The intention is for these works to be available to the LPA prior to the proposed submission stage consultation, currently proposed to be in August and October 2018, and help to inform the viability and deliverability of the site.

12 March 2018 Page 195 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 ED115 Ed Hanson

Organisation: Representing: Barton Willmore Landform Daventry Ltd.

Support/Object: Support

Supporting Documents:

Comment:

Draft Policy HO2 - Daventry Mickle Well Park Extension Site H02 is allocated for residential development (approximately 180 units). The draft policy explains that proposals for this site must be informed by a masterplan, agreed by the Council as local planning authority, that must demonstrate how the site will come forward comprehensively with the site to the south which has an extant permission.

Landform supports the requirement for comprehensive master planning in light of the permitted MWP site. However, Phase II Mickle Well Park has been omitted from the emerging Plan and should be included moving forward, and in advance of development of further land north of Mickle Well Park and adjoin the A361.

The infrastructure required to meet the additional development at Phase 2 has been fully tested and the supporting Development Brief confirms the site is deliverable in the short term.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 ED128 Douglas McNab

Organisation: Representing: Education & Skills Funding Agency

Support/Object:

Supporting Documents:

Comment:

9. The ESFA notes that the plan also refers to a 2FE primary school being delivered at Daventry - Micklewell Park Extension . However, this forms part of an outline approval for a development that includes 450 homes and policy H02 relates only to an extension of this site to provide an additional 180 homes. The update to the Infrastructure Schedule should take into account this proposed extension to the site and any impact on the level of need and size of school required

12 March 2018 Page 196 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 ED138L Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy HO2 – This policy proposes a northern expansion of Micklewell Park which is located to the south and benefits from outline planning approval for 450 dwellings issued in July 2015. Along with the 450 dwellings the site includes land for a local centre, a site for a 2 form of entry primary school along with a network of open space and important landscaping measures. The development will also be served by improved bus connections to Daventry town centre. While the Town Council acknowledges that this location is a significant distance from the Town Centre it considers that it would be more sustainable and efficient in infrastructure terms to locate further growth in this area, if additional housing numbers are required, rather than expanding a new area to the south-west. This would accord more with Option b of the Sustainability Appraisal rather than the hybrid approach that the Council is adopting.

Either site HO2 could be expanded or further housing could be provided to the West of the A361 and to the North- West of Middlemore Park (as suggested in our response to HO1). This would have the benefit of supporting the growth that is already being delivered in this area. A combination of the existing development areas of Lang Farm, Monksmoor Park, Middlemore and those that have consent, Mickelwell Park together with further development in appropriate places (including HO2) will enable development to the North of Daventry to become a sustainable urban extension of several thousand dwellings. This will support planned infrastructure provision such as upgraded road, support the provision of neighbourhood primary schools and sustain local bus services which could have direct access to the town centre via the A361 and Ashby Road.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO2 and ED34 Paul Biggins DA/2014/0869

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Plans to build 450 homes, plus an option for a further 180 homes, on this site should not go ahead until considerable work is completed to improve the A361 and specifically the stretch which runs alongside the reservoir from Middlemore to the Hotel roundabout. This must be one of the most dangerous roads in the UK. If houses are constructed on the Micklewell proposed site even more strain will be placed on this stretch of highway adding to the danger for motorists, pedestrians and other road users. It is only a matter of time before we witness a major accident in this area.

12 March 2018 Page 197 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO3 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Daventry Land at Middlemore (Policy HO3) 17. We note that this site would not, at present, be connected to any adopted highway, and therefore until such time as adjoining highways are adopted, the highways within this site could not be adopted.

12 March 2018 Page 198 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO3 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of housing development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy H03 includes reference to the above requirement. Therefore it suggested that Policy HO3 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

There are a number of sewers and water mains in Anglian Water’s ownership within the boundary of the site. It is therefore suggested that the following text should be included in the supporting text: Existing water mains and sewers cross the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing water mains and sewers should be located in public highway or public open space. If this is not possible a formal application to divert Anglian Water’s assets may be required.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. It is therefore suggested that Policy H03 should include the following wording: that suitable access is safeguarded for the maintenance of water supply and foul drainage infrastructure; and

12 March 2018 Page 199 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO3 ED138M Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy HO3 – This policy allocates infill sites within Middlemore for residential development. The two sites are relatively small and is proposed to make provision for at least 100 houses. The larger site has a planning application (DA/2016/1180) for a mixed tenure Continuing Care Retirement Community (CCRC) for over 55's comprising of an 83 bed Care Home and an Extra-Care building which has yet to be determined. The Town Council considers that this allocation is sensible given the surrounding development; this would complete the housing development in this area. The Council is also supportive of the delivery of a retirement community and accommodation for people over 55. However, if additional housing is to be accommodated in this area it is more imperative that additional facilities for day to day needs are provided as part of either the Mickelwell Park development or any additional growth to the north which would complement the existing Londis and public house already located on Middlemore Farm. This would prevent additional vehicle movements as convenience goods and services could be accessed on foot.

The Council is also supportive of contributions towards the Daventry to Braunston Cycle Link as this will enable existing and future residents to access the countryside and to link through to the Grand Union Canal for wider leisure walks.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO4 ED95 Susan Green

Organisation: Representing: Home Builders Federation

Support/Object:

Supporting Documents:

Comment:

Policy HO4 – Self build & custom housebuilding The HBF supports custom build in principle for its potential contribution to overall housing supply. The Council’s approach to self / custom build should be positively undertaken to increase the total amount of new housing developed rather than by a restrictive policy requirement for inclusion of such housing on allocated sites. Such positive policy responses include supporting development on small windfall sites as well as allocating more small sites. The HBF is not supportive of a policy approach that only changes the house building delivery mechanism from one form of house building company to another without any consequential additional contribution to boosting housing supply.

12 March 2018 Page 200 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO4 ED137 Mr & Mrs J Townsend

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

The principle of self-building is welcomed and is widely employed in other countries. It brings opportunities for people to have an affordable solution to their specific needs whilst contemporaneously delivering diversity in the styles and appearance of the housing stock and street scenes. This is not necessarily the case with volume developments. Self build principles clearly work for first time buyers and growing families alike but it can be an opportunity also for those at the other end of the spectrum. The accessibility and flexible layouts are brought into even sharper focus at this time of life. We feel sure that given the right circumstances people will be induced to sell their existing homes in favour for bespoke solution to their changing needs. Similar to the earlier point, this ability to embody this progression in specific designs is rather curtailed by the definition in the ‘Restricted Villages’. These villages have families where people have strong ties and may not be able to move to another location. After the village survey of housing need in Guilsborough and the responses to the GNP surveys it became clear that a majority would welcome specific and measured limited development. As we currently understand the situation, for self- building. The supply and demand is looked at across the district as a whole not with a local perspective.

Taking into account our comments so far, may we propose that a more localized view of the demand and availability of supply for self-build is applied. The content of HO7 and the preceding clause 6.5.01 = 10 (viewed as positive and progressive) are an even greater driver for a more localized approach when attempting to avoid unnecessary dislocation through ageing. Needless to say any such amendments would need to meet your other policy tests, which you are rightly, in our opinion, proposing (i.e. heritage asset protection).

12 March 2018 Page 201 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED32A, ED32B Meghan Rossiter

Organisation: Representing: Tetlow King Planning Rentplus UK Ltd.

Support/Object:

Supporting Documents: ED32B Affordable Housing Statement

Comment:

We represent Rentplus UK Ltd, an innovative company providing affordable rent to buy housing for working people aspiring to home ownership with an accessible route to achieve their dream though the rent-save-own model. We have previously responded to consultations on the Council's Housing SPD and the Issues and Options consultation on this Part 2 Local Plan, submitting responses together with an Affordable Housing Statement which sets out the model's compliance with the current NPPF definition of affordable housing. That document is enclosed with this response once more so that the practical details of the Rentplus model may be better understood and taken into account in forming the final version of this Plan.

Policy HO7: Housing Mix and Type As set out in our previous responses, the Rentplus affordable rent to buy model addresses the primary barrier to home ownership - the lack of a mortgage deposit - through a combination of a secure rented period at an affordable rent, giving time to save, and a 10% gifted deposit to enable tenants to buy their own home in 5, 10, 15 or 20 years. In this way it extends the opportunity of home ownership to families who are otherwise unable to afford it and to do so within a timeframe to suit their circumstances. The aim of the model is to help those hard working families unable to access shared ownership, starter homes or the open market overcome the mortgage deposit 'gap' by enabling real savings to be built while renting at an affordable rent - 80% of open market rent (including any service charge) or Local Housing Allowance (whichever is the lower). This also meets a gap in the affordable housing tenure mix, helping with the Prime Minister Theresa May's: "personal mission to built the homes this country needs so we can restore the dream of home ownership for people up and down the UK. In the Autumn we set out ambitious plans to fix the broken housing market and make sure young people have the same opportunities as their parents' generation to own their own home. This has an immediate impact, with thousands of people already making savings thanks to our stamp duty cut, and over a million first time buyers over the next 5 years are expected to save money that they can put towards a deposit, solicitors' fees or furniture. We are building a Britain that is fit for the future and our message to the next generation is this - getting on - and climbing up - the housing ladder is not just a dream of your parents' past, but a reality for your future."

The Government is now expected to publish a draft update to the NPPF in late February, bringing forward more specific proposals to widen the definition of affordable housing, as set out in last year's housing White Paper, Fixing our Broken Housing Market which included specific praise of affordable rent to buy (as overleaf): "Rent to Buy homes…..will enable thousands of households to access home ownership through a product that fits their circumstances. Rent to Buy will help hard-working households to benefit from a discounted rent set flexibly at levels to make it locally affordable so they can save for deposit to purchase their home." (Paragraph 4.28)

The definitions contained within Box 4 of that consultation included reference to rent to buy, albeit under the description of intermediate affordable housing which does not reflect the practical nature of the tenure which is occupied by tenants at an affordable rent, under a 20 year full repairing lease through partner housing associations, prior to purchase.

Whilst affordable rent to buy is not yet formally recognised within national planning policy, the next few weeks to provide the Council with an opportunity to further review the policies in this Plan, and to recognise the wide range of affordable housing tenures now being delivered across England. Affordable rent to buy diversifies local housing options and extends the opportunity of home ownership to a greater number of local people, supporting this Government's policy direction. Unlike shared ownership and starter homes, affordable rent to buy does not require an upfront mortgage deposit; those and other intermediate affordable housing tenures fall short of helping those

12 March 2018 Page 202 of 399 people who have the ability to save while renting an affordable home to realise their dreams of home ownership.

In light of those forthcoming changes to the NPPF, we recommend the below addition to Part A of the policy: A. Housing needs will be met by development providing a mix of dwelling type and size to cater for current and forecast accommodation needs. This will also contribute to the creation of sustainable mixed and inclusive communities. (i) Housing mix will include tenures to rent and buy, including starter homes and affordable rent to buy, to accord with the definitions set out in the NPPF and to boost opportunities for home ownership.

That addition will ensure the policy is suitably flexible over the Plan's lifetime, enabling it to be implemented effectively by the Council in advising developers and negotiating with applicants on individual development proposals. This will also future-proof the policy, helping to ensure that the planned changes to the NPPF do not require a rapid review of the Local Plan following adoption.

The inclusion of parts B and C of this policy of specific tenure mix expectations can be problematic as this can reduce the flexibility of both developers and the Council in responding to individual development proposals which may best meet local housing needs. This can create difficulties in determining applications as such a policy approach can be interpreted too rigidly - such expectations may be better described as indicative ranges, and more flexible wording than currently set out in parts (ii) of the Policy.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED55 John O'Neill

Organisation: Representing: Environment Agency

Support/Object: Support

Supporting Documents:

Comment:

We support the Emerging Draft Local Plan. We welcome and fully support the inclusion of the water efficiency standard for new housing (HO7 – Housing Mix and Type Part D iv).

12 March 2018 Page 203 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED75C Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents:

Comment:

Policy HO7 seeks to provide a mix of dwelling types and sizes to cater for current and future accommodation needs. Whilst we do not object to the principle of the policy, Policy HO7 is currently extremely prescriptive in terms of the mix of market housing that would be supported, identifying an exact percentage for the proportion of each bedroom size of dwelling to be provided in all proposals for residential development, regardless of their size or location within the District. Only allowing exceptions to this mix where proposals are supported by a robust assessment of needs at local level is unduly onerous.

Whilst the NPPF provides for local planning authorities to identify the size, type, tenure and range of housing that is required in particular locations, refection local demand, it is very clear that this relates to a range of housing and does not promote the application of an explicit percentage to property size. It is also noted that the NPPF is very clear in that any policy on dwellings should reflect local demand and not need.

The PPG states that when considering future need for different types of housing, plan makers will need to consider whether they plan to attract a different age profile and should also look at the household types, tenure and size in the current stock and in recent supply and to assess whether continuation of these trends would meet future needs (paragraph 021 ref ID: 2A-021-20160401).

The evidence base on which the housing mix and type is prescribed under Policy HO7 is the West Northamptonshire Joint Planning Unit Housing Market Evidence of 2017. Figure 32 on page 60 of this report sets out a purported housing mix based on bedroom sizes for both market and affordable housing. This appears to be based on the housing mix needed by households of each household type and age and apparently uses the ORS Housing Model, but no details are provided as to how this has been undertaken to derive a property size requirement figure. It is not clear that any assessment has been made of the existing housing stock, as advised by the PPG.

Further, it is clear that the ORS Housing Market Evidence Report of 2017 is based on need, whereas the NPPF states that policies on dwellings should reflect local demand.

Policy HO7 also seeks to prescribe housing standards. The PPG includes section entitled ‘Housing: Optional Technical Standards’, and provides the options for LPAs to set additional technical requirements exceeding minimum standards required by Building Regulations in respect of access and water, and also as an option to set nationally described space standard. The PPG identifies that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and to also justify setting appropriate policies in their Local Plans.

Policy HO7 seeks to provide for half of all market dwellings to be delivered to higher standards than Building Regulations – 45% to the effective lifetime homes standard and 5% to be designed for wheelchair access. This policy is purportedly based on the Housing Market Evidence of 2017 that identifies a third of the increased households will include someone aged 65 or over, and that this suggests that there is a need for 50% of all new dwellings to meet Category 2 (Lifetime Homes Standard) Requirements.

The Housing Market Evidence report of 2017 identifies that whilst half of the overall population growth will be in people aged 65 or over, it notes that most of these will already live in the area and many will not move from their current homes. The Study at paragraph 5.33 then notes that a third of the increase in households are likely to have someone aged 65 or over. It is therefore surprising that the conclusion is reached that at least 50% of all new dwellings should meet the Category 2 (Lifetime Homes) Requirement. No evidence is presented to demonstrate that

12 March 2018 Page 204 of 399 all people aged 65 and over require properties built to Lifetime Homes standards. It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified.

The Written Ministerial Statement dated 25th March 2015 confirms that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG” (emphasis ours). The NPPG sets out that “Where a need for internal spaces standards is identified, local planning authorities should provide justification for requiring internal space policies. Local Planning authorities should take account of the following areas: need, viability and timing” (ID: 56-020): • Need – it is incumbent on the Council to provide a local assessment evidencing the specific case for Daventry which justifies the inclusion of the specified accessibility standards in Policy HOU7. If it had been the Government’s intention that generic statements justified adoption of the NDSS then the logical solution would have been to incorporate the standards as mandatory via the Building Regulations which the Government has not done. The NDSS should only be introduced on a “need to have” rather than a “nice to have” basis. The identification of a need for the NDSS must be more than simply stating that in some cases the standards has not been met it should identify the harm caused or may be caused in the future. • Viability – there is a direct relationship between unit size, cost per square metre, selling price per metre and affordability. The Council cannot expect home buyers to absorb extra costs in a Local Plan area where there exists severe affordability pressures. There is also an impact of larger dwellings on land supply. The requirement for the NDSS would reduce site yields or the number of units on a site. Therefore, the amount of land needed to achieve the same number of units must be increased. The efficient use of land is less because development densities have been decreased. At the same time, the infrastructure and regulatory burden on fewer units per site intensifies the challenge of meeting residual land values which determines whether or not land is released for development by a willing landowner, especially in lower value areas and on brownfield sites. It may also undermine delivery of affordable housing at the same time as pushing additional families into affordable housing need because they can no longer afford to buy NDSS compliant home. The Council should undertake an assessment of these impacts. • Timing – the Council should take into consideration any adverse effects on delivery rates of sites including in the housing trajectory. The delivery rates on may sites will be predicted on market affordability at relevant price point of units and maximising absorption rates. An adverse impact on the affordability of starter homes/first time buyer products may translate into reduced or slower delivery rates.

Policy HO7 (Housing Standards) also seek to apply a water efficiency measure limit of 110 limits per day for all new dwellings. Again, the PPG provides for such a water efficiency measure to be applied where the LPA is able to establish a clear need for it. It is not considered that the Local Plan nor the supporting evidence base demonstrates such a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy HO7 is not justified and therefore fails the test of soundness.

Policy HO7 needs to be applied flexibly, taking account of the particular circumstances of development sites. The policy should be amended to make clear that site specific circumstances will be taken into account in determining site specific requirements. It is important that Policy HO7 is applied with sufficient flexibility to ensure that appropriate developments are not unnecessarily hindered or fettered.

Proposed changes to Policy HO7 In order for the Part 2 Plan to be effective and deliverable, and in accordance with National Policy, it is considered that Policy HO7 requires either deletion or significant modification in respect of the housing mix for market housing.

An alternative approach would be to set the percentage figures for each dwelling size as a target but to also identify a more flexible range which would be acceptable. For example, a target for 2 bedroom dwellings is 14%, but an acceptable range could be from 10% to 20%. This approach is also entirely appropriate for the affordable housing mix.

It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified. It is, therefore, concluded that this element of Policy HO7 fails the tests of soundness. As such it should be deleted from the policy.

It is not considered that the Local Plan nor the supporting evidence base demonstrates a clear local need for a water efficiency to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy

12 March 2018 Page 205 of 399 HO7 is not justified and therefore fails the test of soundness. As such it should be deleted from the policy.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Reference is made to all new dwellings being required to incorporate water efficiency to comply with a limit of 110 litres per day. We understand that the Environment Agency considers that Daventry District is located in a area of serious water stress as defined in the Environment Agency’s map (Water Stressed Areas – final classification). Therefore we would fully support the optional water efficiency standard being applied within the Daventry District Local Plan area. However for clarity it would be helpful to make it clear that the standard relates to water use per person as set out in Part G of the Building Regulations. Therefore it is suggested that Policy HO7 is amended as follows: ‘iv) All new dwellings shall include water efficiency measures to comply with a limit of 110 litres per person per day

12 March 2018 Page 206 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED89 Rob White

Organisation: Representing: White Peak Planning Bloor Homes South Midlands

Support/Object: Object

Supporting Documents:

Comment:

Section B Paragraph B(i) of the policy states that 'Proposals for market housing will be supported where they provide a mix that reflects the following…..'

The percentages shown are very specific and in some cases it may not be possible for the development proposals to suitably reflect those shown in the policy, due to numbers of dwellings and proposed mix.

To avoid potential non-compliance with the policy due to its specific wording, can the policy be revised as follows to introduce greater flexibility: 'Proposals for market housing will be supported where they provide a mix of that broadly reflects the following…'

Section D Paragraph D(i) of the policy requires 45% of market dwellings and 40% of affordable dwellings to meet Part M4(2) of the Building Regulations. We recommend that the wording of the policy is amended to '50% of all dwellings will be built to accessibility standards as follows, where practical and viable.'

Paragraph D(i) of the policy also requires 5% of market dwellings an d10% of affordable dwellings to meet Part M4(3) of the Building Regulations.

Paragraph 6.5.09 refers to the need to for 'wheelchair accessible' properties only rather than 'wheelchair adaptable' and therefore, it is inferred that the 5%^ and 10% requirements relate to 'wheelchair accessible' dwellings.

Paragraph 56-009-20150327 of the National Planning Practice Guidance states that: 'Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.'

To comply with planning guidance and ensure the delivery of 'wheelchair accessible' dwellings that meet Part M4(3), we recommend amending the wording of the policy to remove the requirement for 5% of market housing to meet Part M4(3) and increase the percentage of affordable dwellings to 15%

12 March 2018 Page 207 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED91C Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents:

Comment:

Policy HO7 - Housing Mix and Types Policy HO7 seeks to provide a mix of dwelling types and sizes to cater for current and future accommodation needs. Whilst we do not object to the principle of the policy, Policy HO7 is currently very prescriptive in terms of the mix of market housing that would be supported, identifying the exact percentage for the proportion of each bedroom size of dwelling to be provided in all proposals for residential development, regardless of their size or location within the District. Only allowing exceptions to this mix where proposals are supported by a robust assessment of needs at local levels is unduly onerous.

Whilst the NPPF provides for local planning authorities to identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand, it is very clear that this relates to a range of housing and does not promote the application of an explicit percentage to property size. It is also noted that the NPPF is very clear in that any policy on dwellings should reflect local demand and not need.

The evidence base on which the housing mix and type is prescribed under Policy HO7 is that West Northamptonshire Joint Planning Unit Housing Market Evidence of 2017. Figure 32 on page 60 of this report sets out a purported housing mix based on bedroom sizes for both market and affordable housing. This appears to be based on the housing mix needed by households of each household type and age and apparently uses the ORS Housing Model, but no details are provided as to how this has been undertaken to derive a property size requirement figure. It is not clear that any assessment has been made of the existing housing stock, as advised by the PPG.

Further, it is clear that the ORS Housing Market Evidence of 2017 is based on need, whereas the NPPF states that policies on dwellings should reflect local demand.

Policy HO7 also seeks to prescribe housing standards. The PPG includes a section entitled 'Housing: Optional Technical Standards', and provides the option for LPAs to set additional technical requirements exceeding minimum standards required by Building Regulations in respect of access and water, and also as an option to set nationally described space standard. The PPG identifies that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and to also justify setting appropriate policies in their Local Plans.

Policy HO7 seeks to provide for half of all market dwellings to be delivered to higher standards than Building Regulations - 45% to the effective lifetime homes standard and 5% to be designed for wheelchair access. This policy is purportedly based on the Housing Market Evidence of 2017 that identifies a third of the increased households will include someone aged 65 or over, and that this suggests there is a need for 50% of all new dwellings to meet Category 2 (Lifetime Homes Standard) Requirements.

12 March 2018 Page 208 of 399 dwellings should meet the Category 2 (Lifetime Homes Standard) Requirements. No evidence is presented to demonstrate that all people aged 65 and over require properties built to Lifetime Homes standards. It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified.

The Written Ministerial Statement dated 25th March 2015 confirms that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG" (emphasis ours). The NPPG sets out that "Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local Planning Authorities should take account of the following areas: need, viability and timing" (ID: 56-020): - Need - it is incumbent on the Council to provide a local assessment evidencing the specific case for Daventry which justifies the inclusion of the specified accessibility standards in Policy HOU7. If it had been the Government's intention that generic statements justified adoption of the NDDS then the logical solution would have been to incorporate the standards as mandatory via the Building Regulations which the Government has not done. The NDSS should only be introduced on a "need to have" rather than a "nice to have" basis. The identification of a need for the NDSS must be more than simply stating that in some cases the standard has not been met it should identify the harm caused or may be caused in the future. Viability - there is a direct relationship between unit size, cost per square metre, selling price per metre and affordability. The Council cannot expect home buyers to absorb extra costs in a Local Plan where there exists severe affordability pressures. There is also an impact of larger dwellings on land supply. The requirement for the NDSS would reduce site yields or the number of units on a site. Therefore, the amount of land needed to achieve the same number of units must be increased. The efficient use of land is less because development densities have been decreased. At the same time, the infrastructure and regulatory burden on fewer units per site intensifies the challenge of meeting residual land values which determines whether or not land is released for development by a willing landowner, especially in low value areas and on brownfield sites. It may also undermine delivery of affordable housing at the same time as pushing additional families into affordable housing need because they can no longer afford to buy a NDSS compliant home. The Council should undertake an assessment of these impacts. Timing - the Council should take into account consideration any adverse effects on delivery rates of sites included in the housing trajectory. The delivery rates on many sites will be predicated on market affordability at relevant prices points of units and maximising absorption rates. An adverse impact on the affordability of starter homes/first time buyer produces may translate into reduced or slower delivery rates.

Policy HO7 (Housing Standards) also seeks to apply a water efficiency measure limit of 110 litres per day for all new dwellings. Again, the PPG provides for such a water efficiency measure to be applied where the LPA is able to establish a clear need for it. It is not considered that the Local Plan not the supporting evidence base demonstrates such a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy HO7 is not justified and therefore fails the test of soundness.

Proposed changes of Policy HO7 In order for the Part 2 Plan to be effective and deliverable, and in accordance with National Policy, it is considered that Policy HO7 requires either deletion or significant modification in respect of the housing mix for market housing.

An alternative approach would be to set the percentage figures for each dwelling size as a target but to also identify a more flexible range which would be acceptable. For example, the target for 2 bedroom dwellings is 14%, but an acceptable range could be from 10% to 20%. This approach is also entirely appropriate for the affordable housing mix.

It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified. It is, therefore, concluded that this element of Policy HO7 fails the test of soundness. As such it should be deleted from the policy.

12 March 2018 Page 209 of 399 It is not considered that the Local Plan nor the supporting evidence base demonstrates a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy HO7 is not justified and, therefore, fails the test of soundness. As such it should be deleted from the policy.

12 March 2018 Page 210 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED92 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents:

Comment:

The policy is extremely prescriptive in the mix of market housing that would be supported identifying an exact percentage for the proportion of each bedroom size of dwelling to be provided in all proposals for residential development, regardless of their size or location within the District. Only allowing exceptions to this mix where proposals are supported by a robust assessment of needs at local level is unduly onerous.

Whilst the NPPF provides for local planning authorities to identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand, it is very clear that this relates to the range of housing and does not promote the application of an explicit percentage to property size. It is also noted that the NPPF is very clear in that any policy on dwellings should reflect local demand and not need. The Council has not provided sufficient evidence to justify the policy and as a result the plan is likely to found unsound.

The PPG states that when considering future need for different types of housing, plan makers will need to consider whether they plan to attract a different age profile and should also look at the household types, tenure and size in the current housing stock and in recent supply and to assess whether continuation of these trends would meet future needs. (para 021 ref ID: 2A-021-20160401).

Further, it is clear that the ORS Housing Market Evidence Report of 2017 is based on need, whereas the NPPF states that policies on dwelling should reflect local demand.

Proposed changes In order for the Part 2 Plan to be effective and deliverable, and in accordance with National Policy, it is considered that Policy HO7 requires either deletion or significant modification in respect of the housing mix for market housing. One approach would be to set the percentage figures for each dwelling size as a target but to also identify a more flexible range which would be acceptable. For example, the target for 2 bedroom dwellings is 14%, but an acceptable range could be from 10% to 20%. This approach is also entirely appropriate for the affordable housing mix.

Policy HO7 also seeks to prescribe housing standards. The PPG includes a section entitled ‘Housing: Optional Technical Standards’, and provides the option for LPAs to set additional technical requirements exceeding minimum standards required by Building Regulations in respect of access and water, and also as an option to set nationally described space standard. The PPG identifies that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and to also justify setting appropriate policies in their Local Plans.

12 March 2018 Page 211 of 399 Policy HO7 seeks to provide for half of all market dwellings to be delivered to higher standards than Building Regulations - 45% to the effective lifetime homes standard and 5% to be designed for wheelchair access. This policy is purportedly based on the Housing Market Evidence of 2017 that identifies a third of the increased households will include someone aged 65 or over, and that this suggests there is a need for 50% of all new dwellings to meet Category 2 (Lifetime Homes Standard) Requirements.

The Housing Market Evidence report of 2017 identifies that whilst half of the overall population growth will be in people aged 65 or over, it notes that most of these will already live in the area and many will not move from their current homes. The Study at paragraph 5.33 then notes that a third of the increase in households are likely to have someone aged 65 or over. It is therefore surprising that the conclusion is reached that at least 50% of all new dwellings should meet the Category 2 (Lifetime Homes Standard) Requirement. No evidence is presented to demonstrate that all people aged 65 and over require properties built to Lifetime Homes standards. It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified.

A further Housing Standard Requirement that the internal floor area of new build dwellings must meet the National Space Standards as a minimum. Whilst the PPG provides the option for LPAs to require an internal space standard, it is clear that this requires justification based on the identification of a need for internal space standards to be applied. It is not considered that this has been substantiated in Daventry District and is therefore not considered to be justified in relation to the test of soundness.

Policy HO7 (Housing Standards) also seeks to apply a water efficiency measure limit of 110 litres per day for all new dwellings. Again, the PPG provides for such a water efficiency measure to be applied but only where the LPA is able to establish a clear need for it. It is not considered that the Local Plan not the supporting evidence base demonstrates such a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy HO7 is not justified and therefore fails the test of soundness.

12 March 2018 Page 212 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED94 Guy Longley

Organisation: Representing: Pegasus Group Davidsons Developments Limited

Support/Object: Object

Supporting Documents: Attached - Land at Policeman's Field, Naseby Note on Heritage

Comment:

This Policy is extremely prescriptive in the mix of market housing that would be supported identifying an exact percentage for the proportion of each bedroom size of dwelling to be provided in all proposals for residential development, regardless of their size or location within the District. Only allowing exceptions to this mix where proposals are supported by a robust assessment of needs at local level is unduly onerous.

Further, it is clear that the ORS Housing Market Evidence Report of 2017 is based on need, whereas the NPPF states that policies on dwellings should reflect local demand.

Proposed Changes In order for the Part 2 Plan to be effective and deliverable, and in accordance with National Policy, it is considered that Policy HO7 requires either deletion or significant modification in respect of the housing mix for market housing. One approach would be to set the percentage figures for each dwelling size as a target but to also identify a more flexible range which would be acceptable. For example, the target for 2-bedroom dwellings is 14%, but an acceptable range could be from 10% to 20%.

The Written Ministerial Statement dated 25th March 2015 confirms that ‘the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG’. The NPPG advises that where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies taking account of need, viability and timing.

12 March 2018 Page 213 of 399 Policy HO7 seeks to provide for half of all market dwellings to be delivered to higher standards than Building Regulations – 45% to the effective lifetime homes standard and 5% to be designed for wheelchair access. This policy is purportedly based on the Housing Market Evidence of 2017 that identifies a third of the increased households will include someone aged 65 or over, and that this suggests there is a need for 50% of all new dwellings to meet Category 2 (Lifetime Homes Standard) Requirements.

The Housing Market Evidence report of 2017 identifies that whilst half of the overall population growth will be in people aged 65 or over, it notes that most of these will already live in the area and many will not move from their current homes. The Study at Paragraph 5.33 then notes that a third of the increase in households are likely to have someone aged 65 or over. It is therefore surprising that the conclusion is reached that at least 50% of all new dwellings should meet the Category 2 (Lifetime Homes) Requirement. No evidence is presented to demonstrate that all people aged 65 and over require properties built to Lifetime Homes standards. It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified.

A further Housing Standard Requirement is that the internal floor area of new build dwellings must meet the National Space Standards as a minimum. Whilst the PPG provides the option for LPAs to require an internal space standard, it is clear that this requires justification based on the identification of a need for internal space standards to be applied. It is not considered that this has been substantiated in Daventry District and is therefore not considered to be justified in relation to the test of soundness.

Policy HO7 Housing Standards also seeks to apply a water efficiency measure limit of 110 litres per day for all new dwellings. Again, the PPG provides for such a water efficiency measure to be applied but only where the LPA is able to establish a clear need for it. It is not considered that the Local Plan nor the supporting evidence base demonstrates such a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulations. It is concluded that this element of Policy HO7 is not justified and therefore fails the test of soundness.

12 March 2018 Page 214 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED95 Susan Green

Organisation: Representing: Home Builders Federation

Support/Object:

Supporting Documents:

Comment:

Policy HO7 – Housing Mix & Type The HBF recognise that all households should have access to different types of dwellings to meet their housing needs. Therefore planning for a mix of housing needs should focus on ensuring that there are appropriate sites allocated to meet the needs of specifically identified groups of households without seeking a specific housing mix on individual sites as proposed in Policy HO7 Bullet Points B & C. Moreover the housing needs of older people is a diverse sector so the Local Plan Part 2 should be ensuring that suitable sites are available for a wide range of developments across a wide choice of appropriate locations. The Council should justify its requirement for specialist accommodation on SUEs. It is suggested that the Council reconsiders these Bullet Points.

Policy HO7 Bullet Point D(i) also proposes that 50% of all dwellings are accessible & adaptable compliant homes for market homes 45% M4(2) and5% M4(3) and for affordable homes 40% M4(2) and 10% M4(3). The Written Ministerial Statement dated 25th March 2015 stated that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. If the Council wishes to adopt the higher optional standards for accessible & adaptable homes the Council should only do so by applying the criteria set out in the NPPG (ID 56-005 to 56-011). All new homes are built to Building Regulation Part M standards so it is incumbent on the Council to provide a local assessment evidencing the specific case for Daventry which justifies the inclusion of M4(2) & M4(3) optional higher standards in its Local Plan policy. If it had been the Government’s intention that evidence of an ageing population justified adoption of the higher standards then the logical solution would have been to incorporate such standards as mandatory via the Building Regulations which the Government has not done. The Council is also reminded that the requirement for M4(3) should only be required for dwellings over which the Council has housing nomination rights as set out in the NPPG (ID 56-008). It is suggested that the Council re-considers this Bullet Point.

Policy HO7 Bullet Point D(iii) proposes adoption of the Nationally Described Space Standard (NDSS). The Written Ministerial Statement dated 25th March 2015 confirms that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. If the Council wishes to adopt the NDSS this should only be done by applying the criteria set out in the NPPG. The NPPG sets out that “Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local Planning Authorities should take account of the following areas need, viability and timing” (ID: 56-020) :- • Need - It is incumbent on the Council to provide a local assessment evidencing the specific case for Daventry which justifies the adoption of the NDSS in the Local Plan Part 2. If it had been the Government’s intention that generic statements justified adoption of the NDSS then the logical solution would have been to incorporate the standards as mandatory via the Building Regulations which the Government has not done. The NDSS should only be introduced on a “need to have” rather than a “nice to have” basis. The identification of a need for the NDSS must be more than simply stating that in some cases the standard has not been met it should identify the harm caused or may be caused in the future. Indeed the Council’s evidence identifies that average house sizes are exceeding standards so there is no systemic problem to resolve. • Viability - The impact on viability should be considered in particular an assessment of the cumulative impact of policy burdens. There is a direct relationship between unit size, cost per square metre, selling price per metre and affordability. The Council cannot simply expect home buyers to absorb extra costs in a Local Plan area where there exists severe affordability pressures. There is also an impact of larger dwellings on land supply. The requirement for the NDSS would reduce site yields or the number of units on a site. Therefore the amount of land needed to achieve

12 March 2018 Page 215 of 399 the same number of units must be increased. The efficient use of land is less because development densities have been decreased. At the same time the infrastructure and regulatory burden on fewer units per site intensifies the challenge of meeting residual land values which determines whether or not land is released for development by a willing landowner especially in lower value areas and on brownfield sites. It may also undermine delivery of affordable housing at the same time as pushing additional families into affordable housing need because they can no longer afford to buy a NDSS compliant home. The Council should undertake an assessment of these impacts. • Timing - The Councils should take into consideration any adverse effects on delivery rates of sites included in the housing trajectory. The delivery rates on many sites will be predicated on market affordability at relevant price points of units and maximising absorption rates. An adverse impact on the affordability of starter home / first time buyer products may translate into reduced or slower delivery rates. As a consequence the Council should put forward proposals for transitional arrangements. The land deals underpinning the majority of identified sites will have been secured prior to any proposed introduction of NDSS. These sites should be allowed to move through the planning system before any proposed policy requirements are enforced. The NDSS should not be applied to any outline or detailed approval prior to the specified date and any reserved matters applications should not be subject to the nationally described space standards.

It is suggested that the Council re-considers this Bullet Point.

Policy HO7 Bullet Point D(iv) proposes adoption of the higher optional water efficiency standard. The Written Ministerial Statement dated 25th March 2015 confirms that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. If the Council wishes to adopt the higher optional standard for water efficiency the Council should only do so by applying the criteria set out in the NPPG. The Housing Standards Review was explicit that reduced water consumption was solely applicable to water stressed areas. The NPPG (ID 56-013 to 56-017) refers to “helping to use natural resources prudently ... to adopt proactive strategies to … take full account of water supply and demand considerations ... whether a tighter water efficiency requirement for new homes is justified to help manage demand”. It is suggested that the Council re-considers this Bullet Point.

Conclusion For the Daventry Local Plan Part 2 to be found sound under the four tests of soundness as defined by the NPPF (para 182), the Plan should be positively prepared, justified, effective and consistent with national policy. It is suggested that the Council gives due consideration to the above mentioned matters in order to produce a sound Local Plan. We hope that these representations are helpful in informing the next stages of the Local Plan Part2. In the meantime if you require any further assistance or information please contact the undersigned.

12 March 2018 Page 216 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Policy HO7 – Housing Mix and Type Policy HO7 states that housing needs will be met by development providing a mix of dwelling type and size to cater for current and forecast accommodation needs. This will contribute to the creation of sustainable mixed and inclusive communities. Policy HO7 sets out a detailed mix of dwelling sizes that development proposals will be supported by the Council in relation to both market and affordable housing. Exceptions to these mixes identified under the policy will be supported where they are evidenced by a robust assessment of needs at an appropriate local level.

We recognise the importance of delivering a mix of housing types and sizes to meet current and future housing needs to ensure social diversity and mobility. However, we consider that the required housing mix for developments in different locations across the District needs to reflect the market in these locations and the local housing need. We consider that the provision of high quality housing, suitable to the needs and aspirations of an area is strongly supported. Notwithstanding this, the practicalities of housing provision needs to be carefully considered to ensure that unnecessary delays in housing delivery are not experienced. It is important to remember that development cannot only provide for existing demand, it can also address the aspirations of an area. For example, young families could be attracted to an area through the provision of family accommodation whereas the elderly would have different housing requirements.

My client strongly objects to the detailed mix of dwellings sizes required under Policy HO7. The prescriptive detailed mix has the potential to result in housing developments becoming unviable and therefore, cannot be delivered. The required mix of dwellings sizes will need to be based upon local evidence and also on market demand.

Policy HO7 also states that, to meet needs of the District’s residents and to deliver dwellings which are capable of meeting peoples’ changing circumstances over their lifetime, a set out requirements as set out under the policy will need to be met. These include: i. A requirement for 50% of all dwellings to be built to accessibility standards as follows: Market dwellings – 45% to M4(2) and a further 5% to M4(3); and affordable dwellings – 40% to M4(2) and a further 10% to M4(3). ii. An expectation that these standards will be implemented proportionately across the housing sizes identified in parts B and C of this policy. iii. The internal floor area of all new build dwellings must meet the National Space Standards as a minimum. iv. All new dwellings shall include water efficiency measures to comply with a limit of 110 litres per day.

We consider that the detailed reference to the mix of housing types and sizes and the reference to Building Regulations and other housing standards identified under the policy is too prescriptive. The policy must be sufficiently flexible to adapt to changing circumstances as required by paragraph 14 and paragraph 50 of the NPPF. Regarding the specific levels proposed to Building Regulations within the policy, we consider that it is too rigid to specify percentages of dwellings to meet Building Regulations and we consider that this should relate to the identified need. Viability testing will be considered on a case by case basis here. In any event, we consider that it is not necessary to require adherence to Building Regulations within a development plan policy and therefore this reference should be omitted.

We consider that Policy HO7 is unsound as the policy is unjustified in terms of its evidence and inconsistent with national policy.

12 March 2018 Page 217 of 399 Object to Policy HO7: The reference to the detailed mix of housing types and sizes and the reference to Building Regulations and other housing standards identified should be omitted. The percentage requirements are not justified and should be targets, not a fixed requirement, linked to identified need.

12 March 2018 Page 218 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED108 Paige McCarthy

Organisation: Representing: Persimmon Homes

Support/Object: objecting

Supporting Documents:

Comment:

Persimmon Homes Midlands are glad to have the opportunity to review this stage of the Settlements and Countryside Local Plan (Part 2) for Daventry District Council. The development industry should be heavily involved in the preparation process of the emerging plan. This response covers the entire document and where no comment is made this should be taken as acceptance of the wording and the policy as drafted. The key concern to the documents as drafted is the imposition of both Space Standards and Accessible and Adaptable Housing as part of policy HO7.

Policy HO7 – National Context In 2013, The Housing Standards Review (the Review) was launched which sought to simplify and rationalise the raft of housing standards which local authorities applied to development. At the heart of the Review was a desire to reduce developer costs and create attractive conditions to significantly boost housing delivery. The industry has been intrinsically involved nationally in preparation of amendments to Building Regulations and incorporation of National space Standards.

The outcome of the Review was the establishment via Building Regulations of mandatory baseline standards which apply nationwide to all developments. The Code for Sustainable Homes was also withdrawn. Additionally, the Government created a series of enhanced Optional Standards relating to access and water, along with a new optional national standard on internal space.

Initially the industry had concerns that the enhanced standards would be applied by Local Authorities as their starting point. Application of the enhanced standards has the potential to have significant implications in terms of product range, build cost, affordability, cumulative policy burden, viability and ultimately housing delivery.

In response, the government confirmed that the enhanced standards were intended to be optional and that they would only be needed and viable in certain local circumstances. Otherwise, they would have been made mandatory in Building Regulations across the country.

The enhanced standards were introduced on a ‘need to have’ not a ‘nice to have’ basis and policy safeguards were put in place. The new enhanced standards could only be introduced via a new Local Plan which is a suitable forum to discuss local need, viability and timing, clear evidence of need had to be demonstrated and the consequential impact upon viability had to be considered.

New Regime and Policy The new regime was launched by a Ministerial Statement dated 25th March 2015 and the creation of a new section on optional technical standards in the National Planning Practice Guidance (NPPG). This was also underpinned by existing policy within the National Planning Policy Framework (NPPF). Paragraphs 174 and 177 of the NPPF make it clear that via a local plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new ministerial statement stated the following: “The optional new technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning guidance.”

Accompanying this, paragraph 001 reference ID: 56-001-20150327 of the NPPG made it clear that LPAs will need to

12 March 2018 Page 219 of 399 gather evidence to determine whether there is need for additional standards in their area and justify setting appropriate policies in their Local Plans, Paragraph 002 ID 56-002-20160519 of the NPPG confirms the LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

Daventry District Council’s Emerging Policy HO7 Daventry District Council through the inclusion of policy HO7 are seeking to include both national optional (NDSS) and increased accessibility standards M4(2) and M4(3) elements as set out in National Planning Practice Guidance (NPPG).

Accessible Housing The Council have made an assessment of the aging nature of their population across the plan period and concluded that some 50% of all new dwellings will be compliant to accessibility standards to meet this growing need. It is the view of Persimmon Homes that the following additional considerations need to be made for this to be considered a robust assessment;

The specific levels of accessibility standards proposed of which 45% of market dwellings to M4(2) and a further 5% to M4(3), 40% of affordable dwellings to M4(2) and a further 10% to M4(3). We consider that it is too rigid to specify percentages of dwellings to meet Building Regulations and we consider that this should relate to identified need, viability testing will be considered on a case by case basis here. • The 50% figure is crude – It is derived from housing population projections which are simply a starting point and need to be further considered and understood in the context of the housing market – it certainly does not identify a need of 50% of new build properties to have enhanced accessibility. • No assessment of the suitability of the existing housing stock has been undertaken to determine the number of existing dwellings that are currently complying with or can otherwise meet the requirements of this policy or need generated by the aging population across the plan period. • Planned new specialist housing projects across the plan period also need to be considered and factored in as these reduce the need for new dwellings to accommodate the total need. • Consideration of the lifestyle choice of people wanting to stay in their own homes. This is highly material, as the evidence is suggesting meeting a need for the plan period for newly forming families who will not form part of the 50% figure within this plan period.

On the basis of the above Persimmon Homes object on the grounds that the policy evidence of incomplete and does not form a robust assessment or consideration of the issues.

Nationally Described Space Standards National Planning Practice Guidance is clear as to process by which a local authority seeking to adopt optional increased space standards (over and above that required by building regulations) must undertake. It is clear that the NDSS is being applied as a policy aspiration rather than being on a need evidence gathered. 1. Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. 2. Viability – the impact of adopting space standard should be considered as part of a plan’s viability assessment with account taken of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. 3. Timing – there may be a reasonable transitional period following adoption of a new policy on space standards to enable developer to factor the cast of space standards into future land acquisitions.

Persimmon Homes object strongly on the grounds that insufficient evidence has been presented to justify or consider the policy as drafted and that more work is needed to demonstrate any need and implications of adoption. Only after justification of need has been established can the considerations of viability and timing be truly considered. Based on the above, we consider that policy HO7 is unsound and the policy is unjustified in terms of its evidence base and is inconsistent with national policy.

Market Housing Mix Persimmon Homes support the proposal that the majority of dwellings should be 3 bedrooms, however we feel the number of 4 bedroom dwellings proposed is too high. There should be a greater percentage of 2 bedroom dwellings and a reduction in the 4 and 5 bedrooms dwellings. 2 and 3 bedroom homes are where the greatest need lies and are

12 March 2018 Page 220 of 399 most affordable, unlike the larger dwellings where only a small proportion of the market can afford to purchase them. Smaller dwellings are popular products and are often an important first step on the ladder as many are starter homes.

12 March 2018 Page 221 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED110 Gary Stephen

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

HO7 - Housing Mix and Type Housing Mix Whilst the housing market mix for both affordable and market housing is based upon the Council’s latest evidence of need, this is likely to be subject to change over time. It is therefore more appropriate to word a policy that states the housing mix will be in accordance with the latest evidence rather than express the percentages within the policy itself. Whilst there is an exception criterion, this is tightly constrained at the moment to relate to the proposed mix in the policy, with the onus on the applicant to demonstrate a deviation.

If the percentages do remain, as expressed, additional flexibility is necessary that recognises that each figure is an approximation and that not all schemes will be suitable to deliver all of the range. For instance, this may be for reasons of local need, design, market signals, or viability.

Housing Standards D (i) Accessibility The requirements set out in the policy for 50% of all dwellings to be category M4(2) and M4(3) is a significant amount that is not justified by the evidence cited, which recognises that not all of the housing needs derived from over 65s will be met through new development. In addition, the Council should ensure that it is not double counting any requirement with that for specialist housing accommodation.

The Council will be aware that the Written Ministerial Statement (25th March 2015) stressed that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. Therefore, the Council must test this by applying the criteria set out in the NPPG (ID 56-005 to 56-011) before formulating policy. On its own, general evidence of an ageing population is not sufficient to justify the adoption of the higher standards.

The Council’s attention must also be drawn specifically to National Planning Practice Guidance in respect of category M4(3) which states: “Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.”

The requirement for market dwellings to be built in accordance with M4(3) is not consistent with the Guidance.

D (iii) Space Standards Similar to the proposed accessibility standards, the proposed adoption of the Nationally Described Space Standard (NDSS) needs to be considered in light of the Written Ministerial Statement (25th March 2015) which instructs Local Plan policies address evidenced need and that impact on viability has been tested in accordance with the criteria set out in the NPPG. Principally, the NPPG requires the Council to account of need, viability and timing.

Concerning need, this must be based on specific and local evidence, which justifies the adoption of the NDSS. This must include consideration of actual and specific negative effects of the standards not being met in certain circumstances.

The cumulative impact of policy requirements on viability should be assessed. There is a direct relationship between

12 March 2018 Page 222 of 399 floor space, land take and sales prices, which will ultimately harm affordability of market housing’; increase demand for affordable housing and reduce housing land supply (the units yielded from any given site). The Council should therefore undertake an assessment of these impacts, both at a site-specific level and plan wide.

In terms of timing, the Council’s housing trajectory and the assumed delivery rates of sites are predicated on current policy requirements, in particular for those that already benefit from planning permission. As noted above, the introduction of NDSS would have a knock on effect on affordability, which may in turn harm the identified delivery of affordable and smaller units especially. On this basis, if the Council can demonstrate there is a need for a space standards policy, and it is viable, consideration should be given to a transitional approach so as not to undermine the delivery of the Local Plan allocations and commitments.

Finally, the Council must ensure that its Plan is consistent with paragraphs 173 and 174 of the Framework as far as the implications of imposing all the requirements of Policy HO7 (along with other proposed policies and existing development plan policies) have been tested to ensure the viability and deliverability of development. This requirement therefore needs to be tested.

12 March 2018 Page 223 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.9 HO7 - Housing Mix and Type 4.9.1 Policy HO7 includes the proposed introduction of a fixed approach to identifying the housing mix for open market housing and affordable housing. It is essential that a flexible approach is brought forward in this regard, allowing housing schemes to respond to new evidence, circumstances specific to individual sites, demand within the market and viability.

4.9.2 Policy HO7 also outlines that the Council is seeking to introduce optional housing requirements. In this regard, Gladman refer to the PPG which provides the national guidance on this matter. The PPG states: “Where a local planning authority adopts a policy to provide enhanced accessibility or adaptability they should do so only by reference to the Requirement M4(2) and/or M4(3) of the optional requirements in the Building Regulations and should not impose any additional information requirements (for instance provision of furnished layouts) or seek to determine compliance with these requirements, which is the role of the Building Control Body. They should clearly state in their Local Plan what proportion of new dwellings should comply with the requirements…” (PPG ID:56-008-20160519)

4.9.3 The Council need to be able to demonstrate through robust evidence the justification and rationale for the percentage requirements that they are proposing through this policy.

4.9.4 The provision of specialist housing to meet the needs of older people is of increasing importance and the Council needs to ensure that this is reflected through a positive policy approach within the Local Plan. The Council needs to establish a robust understanding of the scale of this element of need across the district. Specialist housing with care for older people is a type of housing that provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally accessible communal facilities including residents’ lounge, library, dining room, guest suite, quiet lounge, ICT suite, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.

4.9.5 Gladman refer the Council to a recent piece of research (conducted by Irwin Mitchell) regarding local plan policies for the elderly (https://www.irwinmitchell.com/newsandmedia/2017/july/two-thirds-of-local-authorities- failing-to-prioritise-housing-for-older-people-jq-25948)This research graded local planning authorities depending on the policies in place in their recently adopted or emerging local plans. The grading identified through this are as follows: A: clear policy and allocation, B: clear policy but no specific allocations, C: site allocation but no policy and D: neither a clear policy nor specific site allocations. Following this research, the head of planning at Irwin Mitchell stated: ‘‘Properly providing for the housing needs of the ageing and the elderly therefore represents a land efficient way for local planning authorities to also address general housing needs.’’

12 March 2018 Page 224 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED141A, ED141B, ED141C Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents: Attached - Extract from Leeds Core Strategy of November 2014 under Policy H4

Comment:

Housing Mix

This Policy is extremely prescription in the mix of market housing that would be supported – identifying an exact percentage for the proportion of each bedroom size of dwelling to be provided in all proposals or residential development, regardless of their size or location within the District. Only allowing exceptions to this mix where proposals are supported by a robust assessment of needs at local level is unduly onerous and contrary to NPPF.

The evidence base on which the housing mix and type is prescribed under Policy HO7 is the West Northamptonshire Joint Planning Unity Housing Market Evidence of 2017. Figure 32 on page 60 of this report sets out a purported housing mix based on bedroom sizes for both market and affordable housing. This appears to be based on the housing mix needed by households of each household type and age and apparently uses the ORS Housing Model, but no details are provided as to how this has been undertaken to derive a property size requirement figure. It is not clear that any assessment has been made of the existing housing stock as advised by the PPG.

Further it is clear that the ORS Housing Market Evidence Report of 2017, is based on need, whereas the NPPF states that policies on dwellings should reflect local demand.

In order for the Part 2 Plan to be effective and deliverable and in accordance with National Policy, it is considered that Policy HO7 requires either deletion or significant modification in respect of the housing mix for market housing. One approach would be to set the percentage figures for each dwelling size as a target but to also identify a more flexible range which would be acceptable. For example the target for 2-bedroom dwellings is 14% but an acceptable range could be from 10% to 20%. Such as approach has been adopted in Leeds Core Strategy of November 2014 under Policy H4 (extract attached).

This approach is also entirely appropriate for the affordable housing mix.

Housing Standards

Policy HO7 also seeks to prescribe housing standards. The PPG includes a section entitled ‘Housing: Optional Technical Standards’ and provides the option for LPAs to set additional technical requirements exceeding minimum standards required by Building Regulations in respect of access and water, and as an option to set nationally described space standard. The PPG identified that LPAs will need for additional standards in their area and to also justify setting appropriate policies in their Local Plans.

12 March 2018 Page 225 of 399 Policy HO7 seeks to provide for half of all market dwellings to be delivered to higher standards than Building Regulations – 45% to the effective lifetime homes standard and 5% to be designed for wheelchair access. This policy is purportedly based on the Housing Market Evidence of 2017 that identifies a third of the increased households will include someone aged 665 or over and that this suggests there is a need for 50% of all new dwellings to meet Category 2 (Lifetime Homes Standard) Requirements.

The Housing Market Evidence report of 2017 identifies is that whilst half of the overall population growth will be in people aged 65 and over, it notes that most of these will already live in the area and many will not move from their current homes. The Study at Paragraph 5.33 then notes that a third of the increase in households is likely to have someone aged 65 or over. It is therefore surprising that the conclusion is reached that at least 50% of all new dwellings should meet the Category 2 (Lifetime Homes) Requirement. No evidence is presented to demonstrate that all people aged 65 and over require properties built to Lifetime Homes Standards. It is not considered that the evidence seeking to support Policy HO7 in respect of the proposed accessibility standards is justified and therefore fails the test of soundness. Such rigorous application of these standards will also impact on viability.

Space Standards

A further Housing Standard Requirement is that the internal floor area of new build dwellings must meet the National Space Standards as a minimum. Whilst the PPG provides the option for LPAS to require an internal space standard, it is clear that this requires justification based on the identification of a need for internal space standards to be applied. It is not considered that this has been substantiated in Daventry and is therefore not considered to be justified in relation to the test of soundness.

Water Efficiency

Policy HO7 Housing Standards also seeks to apply a water efficiency measure limit of 110 litres per day for all new dwellings. Again, the PPG provides for such a water efficiency measure to be applied but only where the LPA can establish a clear need for it. It is not considered that the Local Plan nor the supporting evidence base demonstrates such a clear local need for a water efficiency requirement to be applied in Daventry over and above Building Regulation. It is concluded that this element of Policy HO7 is not justified and therefore fails the test of soundness. ED141 C Attachment of Leeds Core Strategy of Housing Mix

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Policy HO7 – Housing Mix and Type

2.88 Policy HO7 should be amended to acknowledge an alternative approach to housing mix is appropriate for Daventry South West. This would ensure no conflict arises between policies HO1 and HO7. For more detail please refer to our detailed comments in response to Policy HO1 regarding housing mix.

12 March 2018 Page 226 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy HO7 ED79B Paul Jackson

Organisation: Representing: Francis Jackson Homes

Support/Object: Object

Supporting Documents:

Comment:

The aspiration of securing a mix of housing types is supported in principle, however, as drafted Policy HO7 B) and C) seem the be rather prescriptive.

It would make more sense to refer to the percentage figures from the evidence base about need in the supporting text, rather as part of the policy, where they would be a guide, because as it stands they look like a prescriptive part of the policy itself and seek these actual figures.

How would a 5 house scheme seek to provide 3% 1 -2 bed apartments and 6% 5-bed housing for example?

Also, the mix will also partly be driven by and responsive to the local context, so this should also be a consideration.

With regards HO7 D), we consider that there should be a threshold where these requirements apply – smaller sites are complex enough to deliver and often constrained by matters of scale, topography, etc. and it is not simply a case that dwellings can readily be made bigger as on a SUE without other significant implications for what can be delivered. Again, on a site for 3 houses, how would 5% M4(3) compliance be met?

12 March 2018 Page 227 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Policy RA2 ED44A, ED44B Brian Flynn

Organisation: Representing: Carter Jonas JA Knight & Son (Farmers) Ltd

Support/Object: Object

Supporting Documents: ED44C Map

Comment:

This representation has been submitted on behalf of JA Knight & Son (Farmers) Ltd, who operate JA Knight Farms in Walgrave. Our client owns land off Old Road in Walgrave. A larger site off Old Road was promoted through the ‘call for site’s process – Ref. 154. This representation relates to a smaller site off Old Road currently used as a paddock – see attached location plan.

In summary, we object to Policy RA2 (Secondary Service Villages) because it only seeks to retain the existing services and facilities in villages, but does not appear to support new services and facilities to make villages, such as Walgrave, more sustainable. We have requested a minor change to the text of Policy RA2, which reflects national guidance relating to rural areas and the rural policies contained in the adopted West Northamptonshire Joint Core Strategy.

We consider that land off Old Road in Walgrave – as identified on the attached location plan – is suitable for a small farm and community shop, in conjunction with a small number of affordable and market housing to enable the delivery of the shop. There is no village shop in Walgrave, and it would be beneficial for residents and the sustainability of the village if a small shop selling convenience goods could be provided. The farm shop would be compatible with our client’s farm business.

There are two objectives in the emerging Draft Settlements & Countryside Local Plan which are relevant to Policy RA2 and these representations. Objective 10 - Protecting and Supporting Rural Communities states: “To protect and support rural communities to ensure they thrive and remain vital”, and Objective 11 - Rural Diversification and Employment states: “To support rural diversification and rural employment opportunities, in particular those related to agriculture, horticulture and forestry”.

Policy RA2 identifies the secondary service villages, permits development within the confines of the villages, allows development outside the confines of the villages in exceptional circumstances or where a local need can be demonstrated, includes criteria which supports development that is appropriate in scale to the role of a village, does not lead to the loss of services and facilities, and is accessible to the services and facilities in a village, and supports development provided for in a neighbourhood plan. However, the policy, as currently drafted does not appear to support the provision of new services and facilities.

We agree with the classification of Walgrave as a secondary service village in the settlement hierarchy because of the range of services and facilities it contains. The village contains a primary school, village hall, public house serving food, post office, recreation area and allotments. The village is served by a daily bus service to Northampton and Kettering. However, Walgrave currently lacks a small convenience shop, which is a facility that would normally be provided in a secondary service village.

As set out below, we consider that Policy RA2 does not comply with national guidance relating to rural areas in the NPPF and the rural policies contained in the adopted West Northamptonshire Joint Core Strategy.

Section 3 of the NPPF seeks to support a prosperous rural economy. Paragraph 28 encourages sustainable new development in rural areas, supports the development and diversification of agricultural and rural businesses, and promotes the retention and development of local services and community facilities in villages including local shops. Paragraphs 54 and 55 of the NPPF relate to housing, and provides support for some market housing in rural areas to deliver additional affordable housing, and acknowledges the role of additional housing to enhance or maintain the

12 March 2018 Page 228 of 399 vitality of rural communities. Paragraph 70 of the NPPF seeks to encourage the delivery of the social facilities and services needed by communities, including planning positively for facilities and services such as local shops which enhance the sustainability of those communities.

Policy R1 of the adopted West Northamptonshire Joint Core Strategy (December 2014) sets out the spatial strategy for the rural areas. The emerging Draft Settlements & Countryside Local Plan (Part 2) proposes no allocations for residential development in the rural area of Daventry because the housing target for the rural area derived from the Joint Core Strategy has already been met in the district. In our opinion, this proposed approach will lead to negative outcomes for the future supply of housing and affordable housing in the villages, and in the context of Policy R1 it will not support existing services and facilities or encourage investment in new services and facilities which would make the villages more sustainable. Policy R1 does permit development outside the confines of a village in certain circumstances, including where it will enhance or maintain the vitality of rural communities or would contribute towards or improve the local economy. Policy R1 goes on to set out the circumstance where additional housing will be allowed once the rural housing target has been met (as has happened) including where housing would support the retention or improvement of local services. Policy R2 seeks to support development that sustains and enhances the rural economy, including farm diversification schemes involving small-scale business and commercial development.

In addition, we note that Policy R1 of the Joint Core Strategy and Policy RA2 of the emerging Draft Settlements & Countryside Local Plan offers support for development permitted through a neighbourhood plan. However, there are no intentions to prepare a neighbourhood plan for Walgrave Parish, which means that future improvements to services and facilities in the village, such as a new village shop, will not be delivered through this method.

Therefore, we acknowledge that Policy RA2 seeks to protect existing services and facilities in the villages, but it appears to provide no support for the delivery of additional services and facilities, such as a small convenience shop, that would improve the sustainability and vitality of villages. Paragraphs 28 and 70 of the NPPF support the development of new local shops in rural areas. Polices R1 and R2 of the Joint Core Strategy support new development that would maintain or enhance the vitality of villages and the rural economy. We request that Policy RA2 is amended to reflect the support for development providing additional services and facilities in the rural area, and is more positively expressed in the guidance for rural area within the NPPF and the rural area policies of the Joint Core Strategy. The amendments would also deliver Objectives 10 and 11 of the emerging Draft Settlements & Countryside Local Plan. As currently drafted, it is not clear whether development that would deliver additional services and facilities in rural areas would be supported through Policy RA2. It is likely that additional services and facilities, such as a small convenience shop, would be occur on land outside the confines of existing villages, on the basis that there will be few infill opportunities within the village boundary and any that do exist would be brought forward solely for housing.

We request the following underlined changes to Criteria C of Policy RA2, as follows: C. To ensure that the role of these villages is maintained, all development at the Secondary Service Villages shall meet the following criteria: i. Be of an appropriate scale relative to its role as a Secondary Service village; and ii. Not result in the loss of existing services and facilities important to the sustainability of the settlement and its role as a Secondary Service Village; or iii. Provide a new service or facility important to the sustainability of a settlement, including in particular a small convenience/farm shop appropriate to the scale of the village. If enabling development is required to support the delivery of the new service or facility then evidence should be submitted to justify that approach; and iv. Protect the form, character and setting of the village and areas of historic or environmental importance including those identified in conservation area appraisals and village design statements; and v. Protect the integrity of garden or other open land that makes an important contribution to the form, character and setting of the settlement; and vi. Be accessible by walking and cycling to the majority of services and facilities within the settlement; and vii. Protect the amenity of existing residents.

We do not comment specifically on the outcome of the Sustainability Appraisal for Policy RA2. However, we do consider that the assessment of Policy RA2 against Sustainability Appraisal Objective 11: Population and Social Deprivation could be improved with our requested changes i.e. ensure good access to services. The conclusions of the SA assessment for Policy RA2 is provided in SA Report Part 3B - Annex A: Matrices (see pg.21-22). We note that

12 March 2018 Page 229 of 399 for most sustainability objectives Policy RA2 scores ‘green - minor positive benefit’. We consider that clear and positive support for the delivery of additional services and facilities in the villages, as requested in our changes to Policy RA2, would have a ‘green - major positive benefit’ for the residents of the secondary service villages in terms of improving access to services.

12 March 2018 Page 230 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Section 6.1 ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments Ltd

Support/Object: Object

Supporting Documents: Attached - Planning Promotional Document Land off Lilbourne Road, Yelvertoft, site location plan

Comment:

Daventry Town Housing We note that the Draft LPP2 identifies Daventry town as the focus for housing growth within the District as a sub- regional centre across West Northamptonshire. Policy S3 of the WNJCS identifies the need to deliver about 12,730 dwellings in Daventry District (during the period 2011 to 2029) and that Daventry town will deliver about 4,620 dwellings from this requirement. The Council consider that as at 1st April 2017, a total of 1,933 dwellings had been delivered against the WNJCS requirement of 1,784 dwellings for the period between 2011-2017. However, the majority of this has been delivered in the rural areas.

The Draft LPP2 sets out the current position in terms of delivery for the main sites in Daventry town. We note the Council acknowledge that the Daventry North East Sustainable Urban Extension (SUE) allocation in the WNJCS is unlikely to deliver 2,600 dwellings as envisaged over the plan period and this has been revised to 1,570 dwellings as set out in the 2017 Housing Land Availability report. The Council identified a residual requirement of 511 dwellings to be allocated in the LPP2. However, taking into account the slippage in delivery of Daventry North East SUE, and other updates, this requirement has now increased as stated at paragraph 6.1.09 of the Draft LPP2.

Table 4 of the Draft LPP2 identifies the existing commitments for Daventry town as 3,480 dwellings and remaining requirement as 1,140 dwellings (as at 1st April 2017). Table 4 identifies proposed allocations for 1,200 dwellings, which equates to 60 dwellings supply in excess of WNJCS requirement as of 1st April 2017 and 317 dwellings supply in excess of WNJCS requirement as of 1st October 2017.

My client objects to the Council’s approach to only allocating additional housing growth in Daventry town in order to meet the District’s housing needs. Allocating additional housing growth through large allocations at Daventry at other parts of the town is unlikely to help meet the District’s shortfall in the short-term. It is likely that these allocations will be reliant on significant infrastructure coming forward in order for them to be delivered. It is therefore not a sustainable approach to identify additional housing growth over and above the Daventry North East SUE as this does not comply with the WNJCS and an alternative approach to meeting the District’s short-term housing need must be taken.

As discussed previously in this representation, the Council should allocate smaller, more deliverable sites in the District’s as this will help resolve housing need and delivery in the short-term. Smaller sites in sustainable villages in the rural area should be allocated for development as they are much less reliant on significant infrastructure and will contribute towards continued housing delivery across the District as a whole and ensuring the Council can maintain a five-year housing land supply position as the requirement to review and adopt the WNJCS approaches. Housing allocations in the rural area assist with sustaining rural amenities and services, which is increasingly important for settlements that have an ageing and/or declining population.

We reiterate that the approach taken by the Council to identifying additional housing growth at Daventry town and no housing at the District’s rural area is not a positive approach to plan-making based on a strategy which seeks to meet the objectively assessed need of the WNJCS, is not justified by a robust evidence base and is inconsistent with the requirements of the NPPF.

Object to the Council’s approach to identifying additional housing growth at Daventry town to meet the District’s Housing Needs: The Council should allocate smaller sites in sustainable villages in the District’s rural area as they can

12 March 2018 Page 231 of 399 meet housing need in the short term, are not reliant on significant infrastructure in order for them to come forward and assist with sustaining rural amenities and services.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Section 6.4 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 6.4 Rural Exception Sites. Policy H3 of the WNJCS is applicable to the development in Harlestone Parish. HPC would like to see this guidance in the SCLP surrounding this policy include a requirement to design and build sympathetically (using local materials where possible) and to keep housing-density lower than in urban areas. It would add that local services in Rural Exception Sites should be reflect the rural character of the area by providing informal/natural looking space for leisure and recreation.

12 March 2018 Page 232 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Section 6.6 ED129 Simon Richardson

Organisation: Representing: Kettering Borough Council

Support/Object: Object

Supporting Documents:

Comment:

Kettering Borough Council was consulted in the preparation of the West Northamptonshire Travellers Accommodation Needs Study January 2017, at which concern was expressed over Daventry District Council’s interpretation of sustainability in determining appropriate locations for gypsy and traveller site provision. The Council highlighted that more could be done collaboratively between the three Councils of Daventry, Harborough, and Kettering to address the concentration around the district borders.

It is noted that the 2017 study identified that no gypsy or traveller households met the planning definition, and that there were 24 unknown households that may have met the definition, 22 are located on one site. Only 2 households at this site were surveyed. This results in an assumption being made for the remaining 22 households (or 87.5%) on this site. Statistically, it is suggested that there’s a strong risk of inaccuracy in the assumption being made in this Study. In addition, given that the conclusion is that the need is 0, then there is no margin for error, or provision of pitches should there be any need at all.

The supporting policy text within the Plan then considers that of the 24 unknown households that could meet the definition, 6 pitches could be needed up to 2029, based on household formation rates. It then reports that the Study says there’s a high degree of uncertainty that this ‘need’ would meet the definition. It then applies a discount based on a 10% national average of unknown households that actually meet the definition, which reduces the potential need from 6 to 1 pitch. Kettering Borough Council is concerned that the methodology adopted in this Study, and the assumptions relied upon, have the strong potential of underestimating need for residential pitches in Daventry District.

By way of example, Kettering Borough Council is currently determining a planning application for an additional 2 pitches at a gypsy and traveller site at Broughton, near Kettering. The applicant, who informs us he currently lives at a site in Daventry District, has indicated through the application that he needs extra pitches through new household formation, as his children become more independent. In addition, records indicate that an application at Golden Stables in Daventry District for 3 mobile homes is still pending, this would suggest there is further need emanating from Daventry District.

On the basis of the scenarios provided, the Council has concerns that the assumptions made in preparing the Study, and concluding the need for 1 residential pitch in the period to 2029 is flawed and should be properly addressed through policy considerations.

12 March 2018 Page 233 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Site Selection Background ED139A Roger Tustain Paper

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Site Selection Background Paper Version 1 – November 2017

2.40 The Site Selection Background Paper Version 1 – November 2017 brings together the findings of a range of technical reports to clearly illustrate the reasons why sites have been selected to be allocated in the Part 2 Local Plan.

2.41 Commentary on the specific technical assessments that informed this paper are set out below. However, in respect of Daventry South West, it is helpful to note that the Site Selection Background Paper identities that the site “is one of the least constrained sites of those assessed” (page 40). Furthermore, a summary of the OPUN Report is provided (also at page 40) detailing that:

“land at Daventry South West presents a promising opportunity to add much needed new housing to the town.”

2.42 In the final assessment stage identified in the Site Selection Paper (Stage 4b), the paper acknowledges the landscape constraints of the site (as it appears all other alternatives around Daventry equally suffer from) but then goes on to concludes that it “represents the most sustainable option for significant expansion at Daventry” and that the ability to deliver strong pedestrian / cycleway connections to Daventry town centre (including the Daventry Campus of Northampton College) “is a significant strength of the site compared to the alternatives at Daventry North and Daventry South East” (page 40). We wholly support these conclusions and agree that the location of the allocation, in combination with its infrastructure provision will enable the delivery of a highly successful “sustainable community” (page 40 of the Site Selection Background Paper).

12 March 2018 Page 234 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED109 Toby Haselwood

Organisation: Representing: Sworders Mr P Noden

Support/Object: Support

Supporting Documents:

Comment:

In order for the Plan to be sound it needs to be in accordance with paragraph 182 of the NPPF which in turn is interpreted in paragraph: 021 Reference ID: 3-20140306 of the NPPG.

We acknowledge that the land, (Site 134 – Call for Sites/Sustainability Assessment) as illustrated in Table 4 on page 46 of the Plan now forms part of the 1,200 dwellings proposed in table 4-B. Policy HO2 – Daventry Mickle Well Park Extension has been allocated to provide 180 dwellings over the Plan period.

We support the fact that the proposed allocations as a whole, (1200 dwellings) assuming that all of the allocation sites are deliverable, will allow for a degree of flexibility over the plan period. We therefore believe that the plan can be considered sound.

The above helps to demonstrate that, in terms of proposed housing allocations, this element of the Local Plan has been prepared in a positive way. However, it should be noted that the West Northamptonshire Joint Core Strategy is likely to be reviewed within the next 18 – 24 months and as such the numbers that Daventry have to provide over the Plan period may well increase.

This increase could be significant since Northampton Borough have an existing shortfall that is likely to worsen over the Plan period.

The current WNJCS allocations for Daventry are about 12,730 dwellings to be provided over the Plan period. These are distributed as follows; Daventry Town – about 4,620 dwellings Daventry Rural Areas – about 2,360 dwellings and the Northampton Related Development area – about 5,750 dwellings. The lack of a greater number of smaller sites across the District will inevitably lead to an over reliance on the larger allocations, which in turn is likely to lead to delivery issues.

In addition, the Government’s proposed standardised methodology for calculating housing need (subject to consultation last year) could see the housing requirement for the District, or indeed the wider joint planning unit, rise.

In order to incorporate as much in-built flexibility as possible the plan should therefore increase its allocations with a greater range of sites.

We believe that the inclusion of HO2 – Daventry Mickle Well Park Extension, helps to illustrate that the plan is justified, since it is clear that the site has been considered in the Sustainability Report against alternative sites.

The Plan should be flexible to be effective in terms of deliverability, although it should be noted that the current levels of flexibility in the Plan will be tested by large scale allocations, such as the proposed South West allocation for 800 dwellings, which generally tend to come forward slower than anticipated.

We also believe that this element of the plan is consistent with National Policy as its objective is to enable the

12 March 2018 Page 235 of 399 delivery of sustainable development in accordance with the policies in the framework.

The proposed Policy HO2 – Daventry Mickle Well Park Extension would be consistent with the direction of growth established by the permission of 450 dwellings at the site that also provides for a new 2FE primary school and neighbourhood centre.

NPPG Paragraph: 021 Reference ID: 3-021-20140306 is clear that a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time. This is essentially a judgement about the economic viability of a site, and the capacity of the developer to complete and let or sell the development over a certain time period. It is considered that allocation of the larger urban extension sites, due predominantly to their scale, may not lead to the dwelling numbers set out in the trajectory.

To ensure that the Plan is sound and remains so the number of allocations should be increased to a higher percentage of the total trajectory over the Plan period. This will help to ensure that there is a greater flexibility in supply, a wider choice of housing tenure and, most importantly, a greater likelihood of deliverability enabling Daventry to avoid falling into a five year housing supply shortfall.

Even so, although we do have delivery concerns, that could be reduced by additional appropriate residential allocations such as this site. We also believe that this element of the plan has been prepared to be consistent with National Policy as its objective is to enable the delivery of sustainable development in accordance with the policies in the framework.

12 March 2018 Page 236 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED113 Toby Haselwood

Organisation: Representing: Sworders Michael Thompson

Support/Object: Object

Supporting Documents: Attached - site plan

Comment:

Chapter 6, pages 42-46, Table 4 In order for the Plan to be sound it needs to be in accordance with paragraph 182 of the NPPF which in turn is interpreted in paragraph: 021 Reference ID: 3-20140306 of the NPPG.

Whilst we are in general support of the emerging draft we consider the numbers currently provided by the proposed emerging draft Local Plan may well result, if there are delays in delivery, in an undersupply of housing over the Plan period.

The addition of a number of smaller scale allocations that could include this site would assist in delivering further dwellings and as such would increase the flexibility of the Plan in terms of supply, this making it more robust and reducing the chance of the District falling into shortfall.

We support the fact that the proposed allocations as a whole (1,200 dwellings – an oversupply of 312), assuming that all of the allocation sites are deliverable, will allow for a certain degree of flexibility over the Plan period. We therefore believe that in relation to the above table and proposed allocations, specifically the supply of 312 dwellings in excess of 1,200 dwellings over the Plan period, that the plan can be considered sound.

However, although the above oversupply helps to demonstrate that in terms of proposed housing allocations this element of the Local Plan has been prepared in a positive way, it should be noted that the WNJCS is likely to be reviewed within the next 18 – 24 months and that the numbers Daventry have to provide over the Plan period may well increase.

This increase could be significant since Northampton Borough have an existing shortfall that is likely to worsen over the Plan period.

We therefore believe that the inclusion of further, smaller scale residential development allocations would help to illustrate that the Plan has been positively prepared and is therefore justified. As such it is suggested that the proposed numbers for the rural areas are increased and more sites allocated to increase flexibility and ensure delivery.

The addition of further smaller scale sites would strengthen the Plan’s soundness whilst also ensuring variety and diversity in the market. The inclusion of further smaller scale sites would also be consistent with the research carried out by the Federation of Master Builders and the Local Government Information Unit which has challenged the big site approach. It is clear that a larger number of smaller sites are more likely to be deliverable in the first five years of an adopted Plan period than a small number of larger sites.

Again, based on the proposed over supply during the Plan period, the Plan has a degree of flexibility that should allow it to be effective in terms of deliverability. However it is also important to note that the current levels of flexibility in the Plan, in terms of oversupply, will be tested by over reliance on large scale allocations that generally tend to come forward slower than anticipated. For example, the proposed South West allocation for 800 dwellings.

Figures The current WNJCS allocations for Daventry are about 12,730 dwellings to be provided over the Plan period. These are distributed as follows; Daventry Town – about 4,620 dwellings, Daventry Rural Areas – about 2,360 dwellings and Northampton Related Development area – about 5,750 dwellings. The lack of a greater number of smaller sites

12 March 2018 Page 237 of 399 across the District will inevitably lead to an over reliance on the larger allocations, which in turn is likely to lead to delivery issues.

In order to incorporate as much in-built flexibility as possible the Plan should therefore increase its Daventry Rural Areas – about 2,360 dwellings, to be a greater percentage of the whole.

Deliverability It is important there is variation in the portfolio of land available for residential development because; this increases the flexibility in supply, attracts smaller house building companies who will not be present upon larger strategic sites, ensures there is variation in the timescales over which sites can be delivered and provides the consumer (i.e. the future resident) with a choice about where they can live.

NPPG Paragraph: 021 Reference ID: 3-021-20140306 is clear a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time. This is essentially a judgement about the economic viability of a site, and the capacity of the developer to complete and let or sell the development over a certain period. It is considered that allocation of the larger urban extension sites, due predominantly to their scale, may not lead to the dwelling numbers set out in the trajectory.

To ensure the Plan is sound and remains sound the number of rural allocations should be increased to be a higher percentage of the total trajectory over the Plan period. This will help to ensure that there is a greater flexibility in supply, a wider choice of housing tenure and most importantly ensuring a greater likelihood of deliverability enabling Daventry to avoid falling into a five year housing supply shortfall.

Even so, although we do have delivery concerns that could be reduced by additional appropriate residential allocations such as this site, we also believe that this element of the Plan has been prepared to be consistent with National Policy as its objective is to enable the delivery of sustainable development in accordance with the policies in the framework.

The development will provide up to ten dwellings and could provide reasonable necessary contributions to infrastructure, both on site as part of a masterplan and off site financial contributions.

Any proposal that comes forward on this land will be informed by appropriate surveys and assessments that will also set out appropriate mitigation measures covering and relating to archaeology, heritage, landscape and visual, ecological, highways and transport, flood risk and water infrastructure.

These works are being progressed: • Topographical survey of the site • An archaeological desk based heritage assessment • Landscape and visual impact assessment

12 March 2018 Page 238 of 399 • Phase One Ecological Survey • Initial highways and transport assessment • Flood risk and water infrastructure survey and report

The intention is for these works to be available to the LPA prior to the proposed submission stage consultation, currently proposed to be between August and October 2018, and help to inform the viability and deliverability of the site as a residential allocation for up to ten dwellings during the Plan period.

12 March 2018 Page 239 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED114 Toby Haselwood

Organisation: Representing: Sworders The Baker Family

Support/Object:

Supporting Documents: Attached - Indicative masterplan

Comment:

Local Plan Representations BAK1737 216016 – Land West of Ashby Road, Daventry. See attached Indicative Masterplan – drawing number BAK1737 216016 DWG100

In order for the Plan to be sound it needs to be in accordance with paragraph 182 of the NPPF which in turn is interpreted in paragraph: 021 Reference ID: 3-20140306 of the NPPG.

We support the fact that the proposed allocations as a whole, (1200 dwellings) assuming that all of the allocation sites are deliverable, will allow for a certain degree of flexibility over the plan period. We therefore believe the plan can be considered sound.

The above helps to demonstrate that, in terms of proposed housing allocations, this element of the Local Plan has been prepared in a positive way. However, it should be noted that the West Northamptonshire Joint Core Strategy is likely to be reviewed within the next 18 – 24 months and the numbers that Daventry have to provide over the Plan period may well increase. This increase could be significant since Northampton Borough have an existing shortfall that is likely to worsen over the plan period.

Again, based on the proposed supply over the plan period, the plan has a degree of flexibility that should allow it to be effective in terms of deliverability, but it is important to note that the current levels of flexibility in the plan in terms of over supply will be tested by over reliance on large scale allocations, such as the proposed South West allocation for 800 dwellings, that generally tend to come forward slower than is anticipated.

12 March 2018 Page 240 of 399 across the District will inevitably lead to an over reliance on the larger allocations, which in turn is likely to lead to delivery issues.

In order to incorporate as much in-built flexibility as possible the plan should therefore increase its allocations, at the most sustainable locations, namely Daventry.

The development could easily provide further dwellings and could provide reasonable necessary contributions to infrastructure, both on site as part of a masterplan and off site financial contributions.

These works will include and are being progressed: • Topographical Survey of the site • An Archaeological desk based heritage assessment • Landscape and visual impact Assessment

12 March 2018 Page 241 of 399 • Phase One Ecological Survey • Initial Highways and transport Assessment • Flood risk and water infrastructure Survey and Report • Noise and air quality Survey and Report

12 March 2018 Page 242 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED143A, ED143B, ED143C Toby Haselwood

Organisation: Representing: Sworders The Morton Family Trust

Support/Object: Support

Supporting Documents: Attached - Indicative Masterplan

Comment:

Local plan site representations. BUR1755 215413– Land to the East of Daventry. See attached Indicative Masterplan – drawing number BUR1755 215413 DWG103 submitted alongside these representations.

In order for the Plan to be sound it needs to be in accordance with paragraph 182 of the NPPF which in turn is interpreted in paragraph: 021 Reference ID: 3-20140306 of the NPPG.

Whilst we are in general support of the emerging draft Local Plan we consider the numbers currently provided by the proposed emerging draft, may well result, if there are delays in delivery, in an under supply of housing over the plan period.

We support the fact that the proposed allocations as a whole, (1200 dwelling) assuming that all of the allocation sites are deliverable, will allow for a certain degree of flexibility over the plan period. We therefore believe that the plan can be considered sound.

We therefore believe that the inclusion of further, residential development allocations, would help to illustrate that the plan has been positively prepared and is therefore justified. The subject site at Burnt walls

The addition of the Burnt walls site would strengthen the plan’s soundness whilst also ensuring variety and diversity in the market. The inclusion of further smaller scale sites would also be consistent with the research carried out by the Federation of Master Builders and the Local Government Information Unit which has challenged the big site approach. It is clear that increasing the number of sites gives greater likelihood of significant delivery in the first five years of an adopted plan period.

Figures

The current WNJCS allocations for Daventry are about 12,730 dwellings to be provided over the plan period. These are distributed as follows; Daventry Town – about 4,620 dwellings Daventry Rural Areas – about 2,360 dwellings Northampton Related Development area – about 5,750 dwellings. The lack of a greater number of smaller sites will inevitably lead to an over reliance on the larger allocations, which in turn is likely to lead to delivery issues.

12 March 2018 Page 243 of 399 In addition, the Government’s proposed standardised methodology for calculating housing need (subject to consultation last year) could see the housing requirement for the District or indeed the wider joint planning unit rise.

In order to incorporate as much in-built flexibility as possible the plan should therefore increase its allocations, at the most sustainable locations, namely Daventry.

Deliverability

It is important that there is variation in the portfolio of land available for residential development because; this increases the flexibility in supply, attracts smaller house building companies who will not be present upon larger strategic sites, ensures that there is variation in the timescales over which sites can be delivered and provides the consumer (i.e. the future resident) with choice about where they live.

NPPG Paragraph: 021 Reference ID: 3-021-20140306 is clear that a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in time. This is essentially a judgement about the economic viability of a site, and the capacity of the developer to complete and let or sell the development over a certain period. It is considered that with allocation of just the few urban extension sites, due predominantly to their scale, may not lead to the dwelling numbers set out in the trajectory.

Furthermore, it should be noted that the proposed allocation of 800 dwellings to the South West of Daventry is only at emerging draft stage and has not been tested at Examination and adopted in the plan. As such, the preference of the council to allocate this land should not affect the assessment of other potential sites. The Burnt walls site is available, suitable and deliverable and has had considerable political support in (conjunction with the commercial allocation to the south of the A45) for providing the opportunity to improve what is the main gateway to Daventry. Concerns raised regarding the neighbouring Scheduled Ancient Monument are recognised and it is accepted that the capacity of the site would be reduced by the mitigation measures likely to be necessary. However, this was the Council’s preferred site for delivering the biggest proportion of the numbers intended for Daventry and just because those numbers have been increased and the Council has decided to bring in the proposed South West allocation for 800 dwellings, does not mean that it is appropriate to remove the Burnt walls site from the emerging Local Plan.

To ensure that the plan is sound and remains sound the number of allocations should be increased to ensure that housing requirements are met over the plan period. This will help to ensure that there is a greater flexibility in supply, a wider choice of housing tenure and most importantly ensuring a greater likelihood of deliverability enabling Daventry to avoid falling into a five year housing supply shortfall.

Even so, although we do have delivery concerns, that could be reduced by additional appropriate and potentially sustainable residential allocations such as this site, we also believe that this element of the plan has been prepared to be consistent with National Policy as its objective is to enable the delivery of sustainable development in accordance with the policies in the framework.

The development of this site could easily provide at least 250 further dwellings at Daventry, (either as a standalone site or as part of a wider urban extension) and contribute to delivery within the first five years of the Local plan as well as providing reasonable and necessary contributions to infrastructure, both on site as part of a masterplan and off site financial contributions.

The revised proposal for this land will be informed by appropriate surveys and assessments that will also set out appropriate mitigation measure covering and relating to Archaeology, Heritage Landscape and visual, Ecological,

12 March 2018 Page 244 of 399 Highways and transport, Flood risk and water infrastructure and Noise and air quality impact, with a view to preparing a masterplan led scheme that will facilitate a South East Gateway to Daventry.

These works will include: Topographical Survey of the site An Archaeological desk based Heritage Assessment Landscape and Visual Impact Assessment Phase One Ecological Survey Initial Highways and Transport Assessment Flood Risk and Water Infrastructure Survey Report Noise and Air Quality Survey and Report

We believe that 250 dwellings is a conservative estimate of what might be deliverable on the areas of the site in our control, based on the 375 units that the Opun report suggest could be delivered over the various areas of the site that they deemed developable at a rate of 30 dwellings/ha having allowed for mitigation measures in relation to the SAMs.

Chapter 6; Meeting the District’s Housing Needs, Pages 42-46, Table 4

During the preparation of the Emerging Draft Local Plan the LPA looked at a number of sites, one of which was Land to the South East of Daventry, (The above land is part thereof) as a possible location for a sustainable urban extension to accommodate a large proportion of the residual requirement to be provided for at Daventry.

A South East of Daventry SUE has been discussed as an aspiration of the town for some time. The Daventry Masterplan 2012 advocated a predominantly residential development to the South Eastern periphery of Daventry around the A45, and thus in a highly accessible location. It was proposed that this should create an attractive gateway to the town.

However, a series of workshops were carried out by Opun, on behalf of the council, designed to establish which of three potential residential allocations options, set out at Issues and Options - Part 2a Settlements and Countryside Local Plan Consultation Document, would be the most appropriate location for circa 800 dwellings.

Following this process, the LPA chose option C – Land to the South West of Daventry of the Issues and Options Consultation as their preferred site for a proposed allocation of 800 dwellings.

The key purpose of the workshops was to; identify key constraints and opportunities that inform the suitability of the site, to agree a set of design principles in an illustrative form and to produce a proving layout to indicate the potential housing numbers that could be accommodated on the site.

In summary the report suggested that the land at Daventry South East presents significant challenges that might limit its capacity for new development and goes on to state that managing the tensions between the landscape, particularly Historic England’s concerns regarding the setting and location of scheduled monuments, and the topography would mean much of the site is unlikely to be suitable for development. It does not look at how the two SAM’s could be enhanced and access to them and between them be increased by a well developed scheme in this area.

The report went on to urge the Council to careful consider the balance of benefits before releasing sites in this location for development due to the various constraints on site, and to be mindful of the wider aspirations within Council policy to create sustainable new extensions to Daventry.

The report does acknowledge that should development be allowed in this area, then it should be done so after a strong design case has been made which demonstrates that it adds to rather than detracts from what is a special and sensitive location and that development here can provide an over-riding public benefit.

12 March 2018 Page 245 of 399 It should be noted, specifically in terms of public benefit, and as stated above, that a South East Gateway to Daventry from the A45 has been a long term aspiration of the town and this could be facilitated by the development of this area. The Opun report does not give any significant weight to this.

In addition to the above it should be noted that we have concerns as to the validity of the Opun Report and its methodology since the general tone of the report seems to be constraint rather than opportunity based.

Whist it is acknowledged that potential site constraints should be looked at in depth there should be a positive approach to plan making that can be informed by a strong design case, aided by and informed by appropriate surveys and assessments which will be carried out. Whilst we acknowledge that the site is unlikely to provide 800 dwellings due to the potential constraints we do feel that this area of Daventry should be looked at again in terms of the South East approach to the town with a view to creating a gateway entrance and enhancement and increase in public access to and between the two SAM’s where possible.

We therefore suggest that this site be added to the residential allocations illustrated in Table 4 – Existing Commitments and Proposed Allocations at Daventry Town (Housing) with a view to providing the desired gateway in this area.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Table 4 – Existing Commitments and Proposed Allocations at Daventry Town (Housing)

2.35 Table 4 identifies that some 1,200 dwellings are allocated at Daventry Town to meet the residual requirement identified within the WNJCS, of which 800 dwellings will be provided by Daventry South West. However, and as referenced in more detail within our representations to Policy HO1, it is considered that the capacity of the site could be increased to approximately 1200 dwellings, making a more efficient and effective use of greenfield land and optimising development potential, in accordance with paragraph 58 of the NPPF. Not only would this further boost the supply of housing and therefore deliver a key theme of the NPPF, it would also provide greater resilience against the under or non-delivery of housing sites, an issue which Daventry has experienced previously.

Changes sought:

2.36 The quantum of housing allocated at Daventry South West should be increased to approximately 1,200 dwellings, which would make a more efficient use of the site. This increased housing number would supporting a more vibrant local centre and 2 form entry primary school which is proposed as part of Policy HO1.

12 March 2018 Page 246 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 Table 4 ED114 Toby Haselwood Chapter 6, p 42-46, Table 4

Organisation: Representing: Sworders The Baker Family

Support/Object:

Supporting Documents: Attached - indicative masterplan

Comment:

During the preparation of the Emerging Draft Local Plan the LPA looked at a number of sites, one of which was Daventry North, (The above land is part thereof) as a possible location for a sustainable urban extension to accommodate a large proportion of the residual requirement to be provided for at Daventry.

A series of workshops were carried out by Opun, on behalf of the council, designed to establish which of three potential residential allocations options, set out at Issues and Options - Part 2a Settlements and Countryside Local Plan Consultation Document.

In summary the report suggested that Daventry North would present significant design challenges that limit its capacity for new development, whilst going on to acknowledge that there was also potential for development on the eastern edge of the site, next to the proposed development at Mickle Well Park. This is the most suitable location for facilities that can be shared by residents from Middlemore, Mickle Well Park and any development on this site.

It should be noted that The Workshop and subsequent Report make no reference to the proposed allocation HO2 – Daventry Mickle Well Park Extension in relation to Daventry North and specifically the northern part of it, (see attached Indicative Masterplan – drawing number BAK1737 216016 DWG100).

It is clear from the Indicative Masterplan that this part of the Daventry North option should have been assessed alongside HO2 and did not suffer from some of the other issues raised about the site as a whole in the report. Had this been the case it is likely that it would have been seen as a more obvious allocation site for additional housing because of its potential connectivity to HO2.

We therefore suggest that this site be added to the residential allocations illustrated in Table 4 – Existing Commitments and Proposed Allocations at Daventry Town (Housing).

12 March 2018 Page 247 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 & 07 General ED36A Jon Colbourne

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

All of it as I am unable to download the plan from your site; specific reasons include it is out of date and fails to take account of present day, including your wrong assumptions over parking, shopping and the outdated (6+ years in some cases) housing assessments. A 2004 Vision requires assessment in light of the current economic climate. No reassessment has been completed. Please refer to your own documentation, all 94 documents with respect housing alone, not withstanding the inaccessibility of your online documents as detailed previously. I also find it disappointing that you are so reliant on online consultation.

12 March 2018 Page 248 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 & 07 Policy HO1, HO2, HO3, EC3 ED21 Martin Seldon

Organisation: Representing: Highways England

Support/Object:

Supporting Documents:

Comment:

Highways England welcomes the opportunity to comment on the Emerging Draft Daventry District Settlements and Countryside Local Plan Part 2 (LPP2), which covers the period up to 2029 and builds upon the Issues and Options consultation undertaken in early 2016. We note that the LPP2 will sit alongside the West Northamptonshire Joint Core Strategy (WNJCS) and made Neighbourhood Development Plans which will collectively help shape development across the District.

Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth. In relation to the Daventry District LPP2 our principal interest is safeguarding the operation of the M1, M45, A5 and A14 which all route through the District.

We note that, as the sub-regional centre, Daventry town is the focus for housing growth within the District. Policy S3 of the WNJCS sets out that during the period 2011-2029, 12,730 dwellings will be delivered in Daventry District and that Daventry town will be the focus for 4,620 dwellings. We note that the remaining residual housing requirement to be considered in the LPP2 has increased from 511 dwellings (as previously set out in the Issues and Options document) to 1,140 dwellings.

This is primarily due to delays in the delivery of the Daventry North East Sustainable Urban Extension which will not only deliver 1,570 dwellings over the Plan period as opposed to 2,600 dwellings previously expected. There have also been a number of updates made to allocations which have subsequently increased the number of dwellings that need to be allocated within the LPP2.

The key sites proposed in the LPP2 to meet this residual requirement are Land at Daventry South West (HO1; 800 dwellings), Daventry Micklewell Park (HO2; 180 dwellings), Daventry Land at Middlemore (HO3; 100 dwellings) and Land to the North and West of Daventry Town Centre (EC3; 120 dwellings). In total, 1200 dwellings are proposed to be delivered across these four sites. Considering the increased level of growth now proposed we would expect these new sites to be accompanied by a Transport Assessment to assess the implications of this growth on the SRN. We would also expect the cumulative impact of growth across the District to be considered through the Development Management process.

We have no further comments to provide at this time but wish to remain engaged with Daventry District Council as the LPP2 progresses.

12 March 2018 Page 249 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 & 09 ED133C, ED133D, ED133E Peter Frampton

Organisation: Representing: Framptons Barry Howard Homes

Support/Object:

Supporting Documents: Attached - site plan ED133E

Comment:

Land Known as Harris Land – Plot B

Introduction

1) The following submissions are made on behalf of Barry Howard Homes (BHH) in relation to Land known Harris Land – Plot B.

2) It is submitted the land identified at APPENDIX 1 is included within the Part II Plan as an allocation for the purposes of Enabling Development only, specifically in relation to the restoration of Overstone Hall. Overstone Hall is a part derelict and part substantially dilapidated Grade II Listed Building. As the Local Planning Authority (LPA) is aware the building suffered a disastrous fire in 2001.

3) BHH is working extensively with Daventry District Council (DDC) to prepare a scheme (s) which secures the full restoration of Overstone Hall together with a new viable use of this vast building. Evidence has been presented to DDC to demonstrate that the restoration of the Hall from within the 4 corners of the building is not financially feasible. Enabling development is required to secure the future conservation of this important heritage asset.

12 March 2018 Page 250 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 06 & 09 Paras 6.1.3, 6.1.4-6.1.24, ED131A, ED131B, ED131C Nigel Ozier 9.1.08-9.1.14, 9.2.01-9.2.03; Policies HO1, ENV2 & ENV3, Policies and Inset Maps South Quadrant

Organisation: Representing: Aitchison Rafferty Owners of Tollgate Cottage

Support/Object: Object

Supporting Documents:

Comment:

This representation is made on behalf of the owners of Tollgate Cottage, Staverton Road, Daventry NN11 4NN and seeks amendments to the proposed residential development site under Policy HO1. In addition, this representation seeks the delegation of the land at Tollgate Cottage, shown edged red on the attached image, from the proposed Green Wedge and Special Landscape Area.

The site forms an integral part of the existing residential use and the cottage lies between the built development and identified Local Green Space. Development of the proposed allocation HO1 would change the character and setting of both the existing cottage and the land. Essentially, the land identified on this representation already relates to open space/sports use and the existing dwelling and it considered the boundary to the Green Wedge should be revised and repositioned west of Tollgate Cottage.

In addition, it is considered development of the proposed allocation HO1 will completely alter the character and development of the land. Tollgate Cottage will relate to this built development, associated infrastructure and setting. It will not relate to the wider SLA or Green Wedge to the west of the Cottage and brook and south of the A45.

This representation therefore seeks the removal of the land at Tollgate Cottage from the SLA and Green Wedge in order for the development to be considered as part of an extended HO1 area or in association with the existing Cottage. It is considered that the boundary of the Green Wedge and SLA should follow the stream which runs at the bottom of a steep valley on the land at Tollgate Cottage. The character of the site, current adjacent Green Space and proposed allocation HO1 will alter the character of the area and it is considered this relatively small area of land should be excluded from the designated Green Wedge and SLA.

Development of the land will relate to HO1 but will also be acceptable as part of a smaller scale development in association with the associated residential use.

12 March 2018 Page 251 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 ED36A Jon Colbourne

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

The town centre is slowly dying through the lack of shops, the poor quality of those there and the vast number of coffee houses and charity shops. With the loss of the Natwest will only speed up the death of the town centre and that’s before you start out-of-town shops which will further take away from the town centre as they have everywhere else such methods have been completed. Look at the death of Northampton town centre and learn from it. Don’t waste public (DDC funds) money propping up a dated vision of the canal arm when the business industry have already shown it is an unviable project.

12 March 2018 Page 252 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 ED102 Rob Wells

Organisation: Representing: Savills SGC

Support/Object:

Supporting Documents:

Comment:

Representations on behalf of SGC regarding land at Crick Savills is instructed by SGC to submit these representations on the Daventry Settlements and Countryside Local Plan (Part 2) (DSCLP) through which they object to the plan in its present form as being unsound as being neither: • justified – the most appropriate strategy, when considered against reasonable alternatives, based on proportionate evidence; nor • effective – deliverable over its period and based on effective joint working on cross boundary strategic priorities as required by para 182 of the National Planning Policy Framework.

SGC remain willing to work proactively and constructively with Daventry District Council (DDC) to overcome these objections as preparation of the plan continues.

Background SGC are promoters of two parcels of land at Crick for employment use. These include: A. 43.5ha to the west of M1 J18 to the south of the A45 B. 11.6ha to the east of M1 J18 to the north of Crick

SGC have been engaged in dialogue with DDC throughout the plan preparation process and are disappointed that the DSCLP does not propose to allocate sites A and B for employment use.

The PBA Report The report provides a study of the district’s employment market, current supply of employment land and premises and their quality noting at 3.27 that two of the key estates (Marches Industrial Estate and Royal Oak) contain dated premises coming to the end of their economic life. The report is a key part of the evidence base for the local plan.

The report is clear at para 2.14 that it is a striking observation that development of new industrial buildings over recent years has been for buildings of over 10,000sqm and that an insignificant level of the annual floorspace is attributable to smaller units.

Para 3.11 states: “There is a shortage of space across the whole area [Northamptonshire], with occupiers generally finding it difficult to find appropriate space” and in para 3.13 that “Daventry is attractive to smaller scale industrial users…”

Para 3.33 continues “Demand for industrial space in the district is strong for units below 10,000sqm…..take up is low not due to a lack of demand but due to a lack of supply” This is reinforced in para 3.34. Para 3.35 suggests this is particularly prevalent for units within the 80,000sqft range. Where new development has taken place, take up has been strong providing evidence of demand (para 3.55).

PBA provide examples of unsatisfied requirements at paras 3.56 and 3.57 including one of the major town employers who eventually relocated part of its business to Kent partly because of lack of suitable space within the town. It also makes the point that the lack of space means that the district is not attracting new businesses to the area. Similarly at paras 3.41-3.43, the report highlights the need for land suitable for smaller scale and non-strategic industrial/warehousing units to serve the major distribution operators at DIRFT. Demand for such units in Crick is “likely to increase in future as the next phase of DIRFT is built out and occupied”.

12 March 2018 Page 253 of 399 SGC consider that the failure of the DSCLP to allocate additional land at Crick to meet this demand is a fundamental flaw of the plan and will result in it not being effective or justified. 55ha of land to the east and west of J18 of the M1 at Crick is ideally placed to help meet this on-going future demand and DDC is requested to reconsider their proposed allocations to include land at Crick before issuing the next version of the plan.

The PBA report concludes that: • the Council should consider allocating additional land for development; most in Daventry but that there is potential demand at Crick • land should be identified in more than one location to allow competition • sites should be free of physical constraint

Housing and Economic Land Availability Assessment Potential sites have been assessed through the HELAA. SGC sites are identified as ref 116 and 117. Both sites have, effectively, not been proposed for further consideration as a consequence of it being considered that there is no further need for employment land. As such, they were not progressed into the latter stages of the site selection process. However, under this criteria, none of the proposed employment sites should have progressed beyond the initial assessment.

Furthermore, the HELAA was carried out after the receipt of the PBA report which demonstrates a need for employment land and identifies potential demand at Crick. It is unclear therefore whether the HELAA has factored in the recommendations of the PBA report.

Daventry Settlements and Countryside Local Plan (Part 2) SGC acknowledge that the DSCLP forms the Part 2 Local Plan which, when adopted, will sit alongside the West Northamptonshire Joint Core Strategy (2014) (JCS) and the form the main elements of the Development Plan for the Council. The JCS identified the following as part of its overall objectives: • Objective 8 – Economic Advantage - To strengthen and diversify West Northamptonshire's economy by taking advantage of our internationally well-placed location, strategic transport network and proximity to London and Birmingham

It is acknowledged that the overall spatial strategy for the distribution of development seeks to concentrate new development on the main urban areas within the sub-region (Policy S1). Policy S7 seeks to provide a minimum net increase in jobs of 28,500 across the JCS during the plan period. It is appropriate to note that the proposed increase is expressed as a minimum not as a ceiling to job creation and therefore potential development.

The majority of these jobs are proposed to be concentrated within the Northampton Principal Urban Area through redevelopment of existing sites; the Enterprise Zone, Sustainable Urban Extensions and a new strategic allocation at M1 J16. Other key employment sites are identified as DIRFT at M1 J18 and the Silverstone Site.

The Daventry economy is proposed to be supported, through Policy S8, by enabling regeneration of existing employment sites, focussing office development into the town centre, expansion of DIRFT and local opportunities in the proposed urban extension at Daventry North East.

The DSCLP repeats Objective 8 of the JCS in a slightly amended form but it remains one of the key objectives of the Plan: • Objective 6 – Economic Advantage - To strengthen and diversify the local economy by taking advantage of our internationally well-placed location, strategic transport network and proximity to London and Birmingham

Chapter 7 of the DSCLP is titled Vibrant Economy and includes consideration of employment issues. It notes at paras 7.2.03 and 7.2.04 that most of the land allocated for employment has been for large scale B8 use and that there has been short supply of suitable units to accommodate growth for smaller scale enterprises. This position is derived from the outcome of the study ( Employment Land in Daventry District – The Demand for Small and Medium Units – PBA Oct 2017) commissioned by the Council which gives strength to the Council position on the need to protect existing employment areas but also highlights the need to make additional allocations at a non strategic scale. It notes that the study concluded there is need for 1.8 – 3.5ha of land to be provided per annum. For the remaining plan period, this would mean that 11 years land supply needs to be identified (i.e. 19.8ha – 38.5ha) This has been translated into the DSCLP proposing to allocate 13ha of land for employment however the plan states that this is to

12 March 2018 Page 254 of 399 only meet 7 years worth of supply (i.e. to 2025 and at the lowest of the proposed range of required provision) instead of providing land for the whole of the remaining plan period (i.e. to 2029).

Through only proposing to meet part of the identified demand, the plan is failing to be robust, would not be effective or justified and would therefore be unsound.

In order to meet the employment needs, four additional sites are proposed to be allocated. These include: • EC5 - Newnham Drive • EC6 – The Knoll • EC7 - Land North West of Nasmyth Road • EC9 – Daventry South East Gateway

No sites other than these within or on the edge of Daventry are proposed. For this approach to be successful, the sites must be able to be delivered within the plan period, be free from constraint and comply with the recommendations of the PBA report.

It is SGC view that proposed allocations will not all be deliverable or meet the recommendations of the PBA report and that additional land should be allocated including that at Crick.

An analysis of the proposed sites show that: EC5 already partially committed. Remainder of area is small and will provide limited contribution for additional development EC6 significantly constrained. Even DDC do not consider that it will be able to contribute to meeting early development requirements within the 7 years proposed. As such the allocation should be deleted. EC7 large site under option to a large developer which is likely to deliver larger buildings thereby not likely to contribute to meeting needs of wider market EC9 significantly constrained and reliant upon relocation of existing use. Although criteria is provided for the relocation, no site is specifically identified and relocation cannot therefore be guaranteed. The area of the site presently occupied is not new employment land and should not therefore count towards the requirement for new land.

SGC recognise that Daventry is the main urban centre in the district and that the JCS seeks to concentrate development within or on the edge of the town however, the PBA report is clear that potential demand exists at Crick. The failure of the DSCLP to allocate additional land at Crick will constrain companies who are seeking to support DIRFT operations, as set out the PBA report (paras 3.40 and 3.41), and will result in less sustainable patterns of development as they will be forced to locate away from DIRFT requiring more journeys.

Benefits of the land at Crick SGC would advise that their land proposals for Crick have the following benefits: • meets the on-going and future demand from service suppliers to DIRFT as set out in the PBA report as well as providing opportunity for other commercial operators • provide logical extensions to existing employment sites – both DIRFT and G Park, Crick • are best placed to take advantage of the strategic highway network – some of the allocated sites are less well placed to benefit • provide opportunity to deliver benefits for DIRFT and address existing local concerns e.g.: lorry park, roadside facilities, possible hotel • provides a suitable location for relocation of uses from the proposed EC9 • can achieve appropriate landscape/visual mitigation • sites are immediately available and deliverable In addition, the proposals will help meet the recommendation in the PBA report that land should be allocated in more than one location. There is no reason for DDC to have interpreted this as being different sites around Daventry as opposed to different settlements where such allocations would have direct benefits and meet demand.

Conclusion DDC has established that there is need for additional employment land to be provided during the plan period, but is not proposing to allocate land to meet the full identified need. This is likely to result in the plan being found unsound on the basis of not being either justified or effective.

12 March 2018 Page 255 of 399 The evidence base being relied upon by the Council identifies the need for additional employment land and makes recommendations on how land should be identified and locations where it may be appropriate to make allocations. The proposed allocations in the DSCLP do not reflect these recommendations especially through the omission of any new allocations in Crick where demand has been identified by the PBA Report. SGC land is ideally placed, available, suitable and capable of delivering on the requirement.

The suitability/deliverability of some of the proposed allocations, especially EC6 and part of EC9 is doubtful and they should not be counted toward the employment land requirement. This will mean that additional land is needed. SGC land at Crick is available, suitable and deliverable

SGC therefore raise objection to the plan in its present form as being unsound by reason of being neither effective nor justified. Allocation of land at Crick would overcome these objections.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.10 Vibrant Economy 4.10.1 Gladman are concerned that the DLPP2 does not currently seek to introduce a pro-active approach to maintaining and enhancing the rural economy. Paragraph 28 of the Framework identifies that planning policies should support economic growth and promote a strong rural economy. This includes the need to promote the retention and development of local services and community facilities in villages. In order to achieve this, it is essential that the plan provides the sustainable development, including market and affordable housing, which communities will need to achieve this goal.

12 March 2018 Page 256 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 ED133A, ED133B Peter Frampton

Organisation: Representing: Framptons Barry Howard Homes

Support/Object:

Supporting Documents: Attached - Site location plan

Comment:

Introduction

1) The following submissions are made on behalf of Barry Howard Homes (BHH) in relation to Land known as Deer Park, West Haddon Road, Crick, Northamptonshire. A Site Location Plan is attached as APPENDIX 1.

2) The Part II Local Plan identifies that the minimum net increase of 28,500 jobs to be created during in the plan period 2008-2029 (Policy S7 of the WNJCS) has already been met through the various large sale existing planning permissions within the District.

3) However, at Paragraphs 7.2.03 – 7.2.04, the Part II Plan recognises that it is important to support employment uses that are non-strategic in scale but which play an important role in supporting the District’s economy. It has been recognised that there has been a short supply of units to accommodate growth within modern manufacturing, including advanced engineering and automotive industries.

4) Daventry District Council commissioned a Study in July 2017 titled ‘Employment Land in Daventry District: The Demand for Small and Medium Unit’ completed by Peter Brett Associated and Aspinall Verdi (published October 2017) which found that there is demand for units less than 10,000sq.m.

5) In the conclusions of the Study it is stated at:

Paragraph 4.1: “...for small-to-medium industrial units there is substantial demand, currently and probably in the future; so if development sites were allocated they would likely be developed and occupied”

Paragraph 4.3: “The obvious implication is that the Council should consider allocating land for small-to-medium industrial units in the Part 2 Local Plan”

Paragraph 4.4: “Most land identified for development should be in Daventry town, where there is the most demand for space. But there is also potential demand in Crick, including from suppliers and services providers who support the large-scale occupiers at DIRFT. This demand is likely to increase in the future, as the latest phase of DIRFT is built and occupied.

Paragraph 4.5: “Ideally Land should be identified in more than one location, to allow competition, so that no individual landowner is in a position to restrict supply”

6) It is submitted that the Land know as Deer Park should be allocated within the Part II Plan to help meet the Districts requirement for smaller scale employment sites.

7) The Framework states at paragraphs 19 and 20:

Paragraph 19: “The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.”

12 March 2018 Page 257 of 399 Paragraph 20: “To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support and economy fit for the 21st century.”

8) Paragraph 21 states that “Planning policies should recognise and seek to address potential barriers to investment….. “. A potential barrier to investment by local companies is the limited choice of high quality buildings on terms that suit their occupational requirements.

9) Land known as Deer Park is out with the settlement boundary of Crick, however the Framework at Paragraph 28 recognises to importance of supporting economic growth within rural areas, stating:

“Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development. To promote a strong rural economy, local and neighbourhood plans should: • Support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well‐designed new buildings; • promote the development and diversification of agricultural and other land‐based rural businesses; • Support sustainable rural tourism and leisure developments that benefit businesses in rural areas, communities and visitors, and which respect the character of the countryside. This should include supporting the provision and expansion of tourist and visitor facilities in appropriate locations where identified needs are not met by existing facilities in rural service centres; and • Promote the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.”

10) It is considered that land known as Deer Park would be a suitable site to assist Daventry District Council in meeting the growing need for small-to-medium sized units within the District.

APPENDIX 1: SITE LOCATION PLAN Dwg No: PF/9956.01 Our Ref: PJF/bp/PF/9956 Land known as Deer Park, West Haddon Road, Crick Site Location Plan

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Chapter 7 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

No observations.

12 March 2018 Page 258 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 EC4 - Strategic Employment ED41A, ED41B Catherine Camp Areas

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

Wording needs to include something to ensure that villages located adjacent to Strategic Employment Areas are not disadvantaged by additional development. A states that expansion will be supported provided it promotes and supports the role and performance of the employment area and does not harm the amenity of surrounding residential properties. Very often the real negative impact caused by an increase in size of an Employment Area on the neighbouring villages is reflected by increased traffic and noise. This policy should ensure that infrastructure of the surrounding area is also taken into consideration.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.1 ED9 Anthony Hawkey

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

Site 3 potential for 120 dwellings. I would be concerned that this number of additional dwellings would impinge upon the plans for a terminal canal basin for the canal.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.1.12 ED9 Anthony Hawkey

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I would like to see the canal basin to be built on the Eastern Way playing fields, become a centre of entertainment, to include a cinema/theatre, social club, canal side plaza with covered and alfresco eating areas. The plaza could be used as an exhibition area, for entertainment events.

12 March 2018 Page 259 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.1.13 ED74 Sue Halkett

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

Eastern Way Development (formerly site 3) page 71: 7.1.13 This item mentions opportunity for high quality development alongside proposed canal route. Would these be large executive housing with shops, restaurants etc., which would take businesses away from the current centre of Daventry Town (to the detriment of businesses there)? We would ask whether the District Council has really achieved the 'duty to co-operate' (as specified in the Localism Act 2011) with all parties involved, including the electorate, on this particular aspect of the Masterplan? There are many vital unanswered questions related to the project, including cost, source of finance, and known private contributions to date. From what source is the water for the canal arm to be drawn? What is the method by which boats will be lowered into the marina basin? What is the cost, and what is the visual impact likely to be? What is proposed in relation to the funding of ongoing maintenance costs?

We feel there are more pressing long and short term projects that require both attention and financial resources including: The regeneration of Southbrook, and other housing areas within Daventry Town Better sports facilities provision, both in the town and rural areas, promoting health and wellbeing, especially in the rural areas, saving travel to Daventry or Northampton for these services, and thus providing higher levels of usage Regarding the "Learning Quarter" (Site 6), how much is the proposed closure of the UTC for four years likely to cost the taxpayers over that period Are there long term plans for the proposed modern college? Is there a proposal to increase the availability of smaller business units to encourage new businesses, thereby creating an increase in employment opportunities?

12 March 2018 Page 260 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.2.05, policy EC4, ED70 Gemma Hiden Policies and Inset Maps North West quadrant

Organisation: Representing: GVA Mr & Mrs Lewis

Support/Object: Object

Supporting Documents: Map

Comment:

GVA is instructed by Mr and Mrs Lewis to make representations to Daventry District Council's Settlements and Countryside Local Plan (Part 2) ("LPP2") 'Emerging Draft Consultation'.

The Lewis family owns 4.5 hectares of land at Crick Covert, located to the west of the M1 and to the east of Danes Way, in Daventry. The land is located with Daventry International Rail Freight Terminal (DIRFT), a strategic employment site (see location p an attached).

The land is suitable and available for employment development, but the LPP2 makes no obvious provision for this. In the paragraph that follows, we provide some important background information and then describe i) why we object to the LPP2 as currently drafted and ii) the modifications sought in advance of it being examined.

Current planning position The Development Plan for the District comprises the West Northamptonshire Joint Core Strategy (2014) (WNJCS), as well as the 'saved' elements of the Daventry District Local Plan (1997), the latter of which will be replaced upon adoption of the LPP2.

Within the WNJCS, Policy S7: 'Provision of jobs' sets out that provision will be made for a minimum net increase of 28,500 jobs in the period 2008 to 2029. Policy S8 goes on to set out how such new job growth is anticipated to be distributed. In respect of Daventry, the Policy includes support for the growth of DIRFT, as set out within Policy E4. This states that: "Further rail connected storage and distribution uses and associated rail and road infrastructure is support in principle at DIRFT. A high standard of layout, landscaping, building design and materials will be required."

The supporting text to the policy recognises that DIRFT has a national and regional context as a strategic logistics interchange.

In addition, the National Planning Policy Framework (NPPF) provides policy support for local authorities and transport providers to work together to provide for viable infrastructure to support sustainable development, including rail freight interchanges.

Our client's land has the potential to make a positive contribution to the range of buildings/facilities available within DIRFT and its development should be actively encouraged.

The LPP2 position Within the Local Plan Part 2, DIRFT is referred to as an "internationally significant centre for rail connected strategic distribution." It goes on to say that "It will be exemplary in the field of sustainable logistics with links to the University of Northampton. It will be well connected by public and sustainable transport to the surrounding workforce."

Policy EC4 covers 'Strategic Employment Areas', providing support for B1(b, c), B2 and B8 employment uses at these locations. The District's Strategic Employment Areas are listed at paragraph 7.2.05 and defined on the relevant Inset Maps. However, whilst DIRFT clearly is a Strategic Employment Site, it is not included in the list at paragraph 7.2.05. Moreover, it is not defined as an existing employment site/allocation and its boundaries is not shown on any of the

12 March 2018 Page 261 of 399 LPP2's Policy or Inset Maps.

Accordingly, despite being with DIRFT, it is unclear as to whether Policy EC4 of the LPP2 applies to our Client's site. The LPA has confirmed that it does not have a defined boundary for DIRFT and that in practice it refers to the boundaries specified in various planning permissions. This lack of clarity is inappropriate and leads to ambiguity in the decision making process. As such, our Client seeks modifications to the Plan, as set out below.

Modifications required The NPPF states that plans should "enable the delivery of sustainable development in accordance with the policies in the Framework." It also states that local planning authorities should "take account of the need for strategic infrastructure including nationally significant infrastructure within their area."

Having regard to the WJNCS, the LPP2 and its evidence base, we consider that in its current format, the LPP2 is not prepared in accordance with national policy. Our client therefore objects to the LPP2 as currently drafted. We request the following modifications: • Policy EC4 should list the District’s Strategic Employment Areas (in addition to cross-referencing to Inset Maps); • Policy EC4 should include DIRFT within its list of Strategic Employment Areas; • The Policies Map and Inset Map ‘Policies Map Quadrant (North West)’ should clearly define the DIRFT boundary for Policy EC4 purposes; • DIRFT, as defined on the Inset Maps, should include our client’s land at Crick Covert.

The presumption in favour of sustainable development is a ‘golden thread’ which is seen to run through plan-making and the decision making process. Making specific provision for the development of our client’s site, through defining the DIRFT boundary to include the site, or allocating it for development separately, will deliver sustainable development that helps satisfy the Plan’s vision and objectives.

12 March 2018 Page 262 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.2.10, Policy EC4, Crick ED15 Kevin Webster inset map

Organisation: Representing: ANCER SPA Ltd Butchers Pet Care

Support/Object: Object

Supporting Documents:

Comment:

Policy EC4 Strategic Employment Areas states that: To ensure a vibrant economy, proposals for B1 (b, c), B2 and B8 uses will be supported. The expansion of any existing businesses within these use classes will be supported, provided it promotes and supports the role and performance of the employment area and does not harm the amenity of surrounding residential properties.

This recognition of the need to allow expansion of existing businesses in Strategic Employment Areas (SEA) is supported. However, paragraph 7.2.10 states that: Within the District, the WNJCS seeks to focus new development at Daventry town in order to encourage the regeneration of this sub regional centre. This Plan seeks to further this ambition and place a focus on supporting job creation and the economy of Daventry town…..In order to allow for choice in the market, support the growth of local business and to enhance the economy of the town, this plan is making allocations for employment use at a non-strategic scale at Daventry town.

This suggests that the expansion of businesses at SEAs other than Daventry Town will be resisted. However, many businesses in these other SEAs are dynamic and important to a growing economy of the District and the County. They should be allowed to develop and expand their existing businesses and not be forced to relocate elsewhere.

The boundary of the SEA at Crick is drawn tightly around the existing industrial estates at Eldon Way and Dockham Way. There are businesses there such as Butchers Pet Care that wish to expand on to adjoining land which is outside the drawn SEA boundary. The Local Plan should not, either by intentional policy or otherwise unintentionally, deny the opportunity for these businesses to expand.

The wording of policy EC4 or the supporting text should confirm that expansions of businesses at SEAs such as Crick would be allowed on land outside but alongside the boundary, subject to no significant conflict with other Local Plan policies.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Para 7.2.14 ED24 Simon Barber

Organisation: Representing: English Regional Transport Association

Support/Object:

Supporting Documents:

Comment:

Land NW of Nasmyth Road Daventry - currently a greenfield site, and the existing hedgerows should be straightened. It is close to a residential area which is separated by a railway cutting which must be protected for possible future use as a railway.

12 March 2018 Page 263 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 paras 7.2.01, 7.2.03, 7.2.04, ED98A, ED98B Steve Harley 7.2.11, Policy EC4, Policies and Inset Map 2 (EC4d)

Organisation: Representing: Oxalis Planning Pendrix Ltd.

Support/Object:

Supporting Documents:

Comment:

A Vibrant Economy 1.25 The emerging Plan is clear that the majority of new employment creation over the plan period is expected at DIRFT adjacent to Junction 18 of the M1 motorway in the north-west of Daventry District. The implication is that the level of job creation at this single nationally significant site means there is no need to plan for further job growth elsewhere in the District over the plan period. This strategy underplays the opportunities for appropriate local economic development elsewhere, and fails to plan to deliver sites and accommodation to meet a range of employment types – we object to this approach. It is highly questionable in terms of environmental, social and economic sustainability, and would clearly fail to support delivery of the Plan’s strategic Objectives relating to: reducing the need to travel (Objectives 1 and 3) • economic diversification and growth (Objectives 6, 7 and 11).

1.26 However, the references to the ‘niche sectors’, and the associated need for additional ‘non-strategic’ employment sites (paragraphs 7.2.03 and 7.204) are welcome and supported, as is the context provided with reference to the opportunities to support key growing sectors and industries across the District. The explicit identification of the Brixworth Strategic Employment Area (at EC4d) is also supported.

1.27 The emerging Plan refers directly to the shortage in employment land, but the text underplays the significance of this shortage – Pedrix object to this, and suggest that the text should be strengthened (at paragraph 7.2.04) to refer to the “severe” or “significant” shortage identified by the Council’s evidence base. The brief summary of the recent report for the Council into the demand for small and medium sized employment units (at paragraph 7.2.04) is challenged and queried, in particular the reference to “the majority of this demand is indicated to be at Daventry town.” The report identifies strong demand in the District as a whole, and also identifies a range of market signals to indicate the severity of the shortage, and the extent to which this is directly influencing the relative unaffordability of employment space, and the inability of local companies to expand and grow efficiently.

1.28 The report prepared for the Council is clear that additional land, if allocated, would be quickly brought forward by ‘the market’ to meet occupier needs, and is explicit about the extremely ‘tight’ (constrained) supply. We therefore object to the conclusions reached about where additional development land should be located – they appear to be more directly geared around the Council’s preferred spatial strategy and settlement hierarchy than around the evidence of where the market is demanding additional non-strategic sites. A fuller and more rounded summary of the evidence base should be provided, and should inform a revised approach to employment land policies and allocations.

1.29 The emerging Part 2 Plan includes a specific policy regarding Strategic Employment Areas (policy EC4). The emerging policy seeks to provide a positive and enabling context for the continued expansion and growth of businesses in these areas. While welcome, it is unclear how effectively this might be delivered in practice where Strategic Employment Areas are already complete (i.e. developed or built-out in full), and have tightly drawn boundaries. The majority of policy EC4 as drafted refers to the protection of, rather than expansion or growth of, the Strategic Employment Areas – this protectionist rather than proactive and positive approach falls short of the requirements and expectations of the NPPF. It is also at odds with the recognised need for additional non-strategic employment land in Daventry District.

12 March 2018 Page 264 of 399 1.30 The reliance on sites only in Daventry is not a sustainable approach to economic development and job creation, nor consistent with the Strategic Economic Plan of the SEMLEP which is encouraging and planning for continued economic growth, including in key sectors, across the South East Midlands.

1.31 Additional allocations would represent a sound response to the evidence base, and a more sustainable alternative to the proposed strategy in the emerging Part 2 Plan. Changes to the plan should be introduced to ensure a more flexible employment land supply.

1.32 The principle of focusing additional employment development at established and Strategic Employment Areas is sound, but the approach to the potential for future growth should be revisited and amended. The potential for appropriate physical expansion of the Employment Areas should be explicitly allowed for, and the policy might also make direct cross-reference to the support for key business sectors (as planned for in draft plan Objective 7, described above). Suggested additional wording and amendments are proposed below (underlined text):

EC4 Strategic Employment Areas A. To ensure a vibrant economy proposals for B1 (b, c), B2 and B8 uses will be supported. The expansion of any existing business within these use classes will be supported, provided it promotes and supports the role and performance of the employment area and does not harm the amenity of surrounding residential properties. Suitable proposals for the extension of the Strategic Employment Areas will be supported where: • They relate to land directly adjoining the existing employment area; • They are appropriate in terms of the scale and types of uses proposed; • Where they relate to the continued success of existing employers and/or specialist business sectors or clusters; • Where they do not conflict with other policies of this plan relating to housing or other allocations, access, landscape assets, flood-risk or heritage.

1.33 More could and should be done to better reflect strategic Objective 7 of the Part 2 Plan through draft policies – the above proposed changes would help to ensure that this Objective has a more direct expression through policy.

Employment land north of Brixworth 1.34 A site to the immediate north of the existing Strategic Employment Area in Brixworth was submitted in response to the Council’s earlier ‘Call for Sites’ exercise. The site is very close to the physical extent of Brixworth, and to the immediate north of the existing Mercedes AMG Powertrain facility. The site is within a few minutes’ walk of local retail facilities, and well located for existing bus services on the A508 which runs immediately past the site and which provide connections to Daventry and Northampton.

1.35 The site is available now and could deliver a sustainable and appropriate extension to the Strategic Employment Area. It is well placed to deliver small and/or medium sized units to meet a range of business needs, and would be ‘non-strategic’ in scale.

1.36 Emerging landscape led masterplanning shows a strong and generous landscape buffer would be maintained within the site, enabling the retention and protection of local ecological features of interest, and helping ensure a sympathetic and sensitive visual relationship with the remainder of the village. Changes are required to ensure that the Part 2 Local Plan provides a suitably positive, proactive, and sustainable strategy for Daventry District.

Summary of objections and suggested amendments: In summary, Pedrix’s representations are based around the following: • Support for recognition of the shortage of small and medium employment sites and premises across the District; • Objection to the implication that DIRFT will largely meet the job creation needs of the District and most of the West Northamptonshire area as a whole – relying on one large strategic site remote from most of the population is not sustainable and will not deliver widespread social or economic benefits; • Objection to the use and interpretation of the evidence regarding the shortage of ‘non-strategic’ employment land, and the apparent lack of consideration of an alternative strategy with a suitable employment land allocations at the Primary Service Villages, including Brixworth; • Objection to Policy EC4 which emphasises protection of existing employment land but fails to plan for appropriate growth or expansion of Strategic Employment Areas.

12 March 2018 Page 265 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC1 ED58A Paul Everard

Organisation: Representing: Northampton Borough Council

Support/Object:

Supporting Documents:

Comment:

In Point A, bullet point iv, this policy states that development proposals for main town centre uses will be supported where they do not result in insufficient car parking or car parking of poor quality. This part of the policy is justified in para 7.1.05 of the Plan. However, it is unclear as to whether a separate policy on car parking is required for Daventry's Central Area or whether the County Council's Parking Standards (adopted September 2016) is applicable. If it is the former, then there are no measurable criteria to guide applicants on the quantum and/or quality other than where there is a loss of space(s) that requires mitigation.

Point B, bullet point i) relates to the defined Primary Shopping Area and the requirement to not result in the over dominance of non-retail use within a frontage. This can be subject to variations in interpretation. Clarity on what constitutes over dominance would assist in addressing this matter.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC1 ED138A Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Object

Supporting Documents:

Comment:

Policy EC1 supports development proposals for main town centre uses and makes this location the focus and preferred location for these uses. Daventry Town Council supports the principle of this policy, however, the policy goes on to seek to control the over-dominance of non-retail use within a frontage within the Primary Shopping Area.

While this is a legitimate aim in supporting and maintaining a vital and vibrant town centre with a fast-moving retail sector and environment it is also important to have flexibility so that the Town’s principle shopping streets do not become areas of empty shops. Daventry Town Council considers it is preferable to have active streets with cafes or other A3 and A4 uses rather than empty and boarded up shops.

The policy does not define the over dominance of non-retail uses and therefore this part of the policy is unclear, unworkable and must be altered.

12 March 2018 Page 266 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC2 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

As set out in Daventry Water and Wastewater infrastructure Assessment provided by Anglian Water this employment site is expected to require improvements to the water supply and foul sewerage network to enable this site come forward.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC2 includes reference to the above requirement. Therefore it suggested that Policy EC2 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC2 ED138B Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Daventry Town Council supports the ambition of policy EC2 to provide a mix of town centre uses including the retention of a library facility, community uses, leisure, retail and business uses. Any development proposals will need to balance a requirement to increase the density of development within the site with the retention of sufficient car parking for these additional uses to make the scheme commercially viable. There are a high level of uses which are potentially unattractive for the market to deliver and careful consideration needs to be given as to how various elements could be funded.

As the owner of the site, DDC has the opportunity to work with its commercial partner to undertake viability work on a range of scenarios to indicate whether these could be delivered purely through commercial returns or whether elements of subsidy would be required. In the present financial situation, of most of the public sector, it is unlikely that funding partners will be readily available to support the less commercially viable elements of any scheme. Therefore, Daventry Town Council urges Daventry District Council to delay or reject any proposals that would dilute the ambition of the mix of uses for this site until the economic climate is more favourable.

Although the area is largely surface car parking, with a library, this area currently performs a critical function for the town centre. This site must be developed as a whole scheme that would meet all of the deliverable policy aims and be commercially viable and not be developed incrementally in smaller parcels.

12 March 2018 Page 267 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC2 North of High ED9 Anthony Hawkey Street

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I would like to see a proper museum built, principally to highlight Daventry's important position in the development of radio and radar. This would be a great attraction to visitors from all over the world. Such a museum could also highlight that Daventry District has many historic attractions, including Naseby Battlefield, Borough Hill (multi-period hillfort, early development of radio and radar), Burnt Walls Scheduled Monument, Ashby St Ledgers (Catesby and Gunpowder Plot), Grand Union Canal, Weedon Royal Ordnance Depot (section 9.5 Historic Environment).

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC2, Daventry Town ED60C Emilie Carr Inset Map

Organisation: Representing: Historic England

Support/Object: Object

Supporting Documents:

Comment:

Without greater detail it is not possible to comment comprehensively, although the requirement for a masterplan is strongly welcomed. Section 3, criteria ci) should be amended to include all heritage assets and their settings, not just the Conservation Area. Daventry Town Centre has a particular wealth of heritage assets including many highly graded buildings, such as the Grade I Church of the Holy Cross. Historic England would be very happy to agree a change to the wording of criteria ci) by Statement of Common Ground.

12 March 2018 Page 268 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC3 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC3 includes reference to the above requirement. Therefore it suggested that Policy EC3 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC3 EC138C Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy EC3 represents the largest regeneration and redevelopment site that is available to help secure and enhance the economic vitality and viability of Daventry Town Centre. In this respect the Town Council supports the allocation of this site which combines sites 3 and 5 of the Daventry Town Centre Vision 2021.

Daventry Town Council accepts that the economic and commercial position has progressed since 2004, when the Vision was published, and that even at the time the proposals for the town were too ambitious to be deliverable. However, it is considered that the site, being so large, could be given context within the Local Plan part 2 to separate and delineate which uses would be acceptable in specified areas of the site and how this would come together as an overall concept framework. As stated in the text the former Site 5 has planning consent for convenience retail floor space and non-food bulky goods and a petrol filling station and a current application is seeking to alter this mix and layout. A schematic diagram for the whole site is essential to identify the broad location and mix of uses throughout the site.

With the proposals to remove the large roundabout Braunston Rd/Ashby Rd, under the current planning application for site 5, there is an opportunity to realign Eastern Way in order to bring the whole of the former site 3 closer to the town centre and create a much more integrated and permeable development. Eastern Way would need to be downgraded to become a town centre road with multiple crossing places but still retain its capacity for the volume of traffic required. Further land may be required to the north of EC2 to help integrate this site more fully.

12 March 2018 Page 269 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC4 ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC4 ED58B Paul Everard

Organisation: Representing: Northampton Borough Council

Support/Object: Support

Supporting Documents:

Comment:

This policy is supported.

12 March 2018 Page 270 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC4 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

As set out in Daventry Water and Wastewater infrastructure Assessment provided by Anglian Water these employment sites are expected to require improvements to the water supply and foul sewerage network to enable this site come forward.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC4 includes reference to the above requirement. Therefore it suggested that Policy EC4 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

12 March 2018 Page 271 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC4, Policies and Inset ED140C Roy Hammond Maps 50

Organisation: Representing: Howkins & Harrison Mr Bell

Support/Object: Object

Supporting Documents: Attached - Site Plan

Comment:

Howkins and Harrison LLP act on behalf of landowners of multiple sites throughout the villages in the District. This submission is made on their behalf.

Please refer to the attached plan accompanying this representation.

I act on behalf of the owners of the land and have been asked to make representations on their behalf in respect of the economic (B classes) use of the land edged red.

The allocation of the land for economic uses would be a natural extension of the adjacent strategic employment areas in Daventry, and follow the pattern of employment created by the Prologis development on the opposite side of the A45.

The allocation of the land would help meet the obligations under the WNJCS for job creation over the plan period. There are no significant physical constraints to the development of the land and suitable access can be achieved off the A45.

12 March 2018 Page 272 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC5 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC5 includes reference to the above requirement. Therefore it suggested that Policy EC5 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC5 ED138D Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Daventry Town Council supports Policy EC5 which allocates employment uses to an area of brownfield or undeveloped land within the existing Drayton Fields Industrial Estate. It makes sense to utilise this land for further employment opportunities. Sensitive screening should be employed and existing trees and vegetation preserved to ensure that the disused railway footpath is not dominated by industrial premises o this part of the route.

12 March 2018 Page 273 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC6 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC6 includes reference to the above requirement. Therefore it suggested that Policy EC6 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

There are a number of sewers in Anglian Water’s ownership within the boundary of the site. It is therefore suggested that the following text should be included in the supporting text: Existing foul and surface water sewers cross the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing water mains and sewers should be located in public highway or public open space. If this is not possible a formal application to divert Anglian Water’s assets may be required.

It is therefore suggested that Policy H01 should be amended as follows: that suitable access is safeguarded for the maintenance of foul and surface water drainage infrastructure; and

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC6 ED138E Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Daventry Town Council supports Policy EC6 which allocates employment uses at the Knoll, which is within The Marches, an existing industrial and commercial area. The utilisation of all brownfield sites, if appropriate for development, first before allocating greenfield sites is a government priority.

12 March 2018 Page 274 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED26 Steven Rolt

Organisation: Representing: Braunston Parish Council

Support/Object:

Supporting Documents:

Comment:

We are very concerned about Policy EC7. Site EC7 partly occupies the highest land between Braunston and Daventry and has wider significance as the watershed of England. The warehouses built on the first stages of this business park are highly visible from Braunston, the surrounding countryside to the west and to the east of Daventry as well as parts of Warwickshire. One of the buildings on this site was subject to two additional planning applications after the first application was agreed. One of these increased the height of the building, the other added a sign.

In view of the above we insist that the conditions listed in Policy EC7 part B, in particular points iii and iv should be strictly adhered to and that the measures to mitigate the intrusive appearance of any development on site EC7 should include actions to prevent light pollution.

In addition we would like point viii to be specific in including a walking and cycling link from the northern most corner of the site through and along the edge of the neighbouring Green Wedge to link with the Grand Union Canal towpath at the western portal of Braunston Tunnel to provide a sustainable transport option between Braunston and the employment area and onwards to the rest of the town.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Land North West of Nasmyth Road, Daventry (Policy EC7) 18. The description of the footpath/rights of way proposals in paragraph 7.2.17 and Policy EC7 could be helpfully reviewed to make them clearer and to ensure consistency. It is not currently clear whether the proposal is for a new footpath “around the site” (para 7.2.17) or along “the northern perimeter” (Policy EC7 viii). There are some references to ‘footpaths’ or ‘footpath network’ that may more properly refer to rights of way more generally.

12 March 2018 Page 275 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC7 includes reference to the above requirement. Therefore it suggested that Policy EC7 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

12 March 2018 Page 276 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED96 Valerie Coleby

Organisation: Representing: Berrys Prologis

Support/Object: Object

Supporting Documents:

Comment:

We welcome the opportunity to submit representations on the Daventry Settlements and Countryside Local Plan Part 2 on behalf of Prologis Ltd.

In general we support the policy approach to site EC7. We welcome the allocation of the site for B Class uses and look forward to working with the Council in progressing the site.

We understand the desire for the site to deliver smaller to medium sized units and the Council has commissioned evidence base to support the policy provision. The policy identifies a maximum floor space for individual units not to exceed 13,500sqm with at least 50% of units not to exceed 10,000sqm.

The ‘Employment Land in Daventry District – The Demand for Small and Medium Units Background Paper’ makes the case that there is ‘substantial’ demand for small to medium industrial units with potential occupiers being automotive-related industries, smaller-scale distribution and high-end manufacturing. The background paper advises that any allocated sites should be protected from large-scale warehousing.

The emerging plan allocates land at The Knoll, ‘Marches Employment Area, Daventry’ under Policy EC6 for B1 (b, c), B2 or B8 uses to provide a range of sizes. The overall size of this allocated site at 3.3ha will inevitably restrict the size of individual units that can be accommodated to smaller scale units. In addition, land is allocated at, ‘Land off Newnham Drive, Daventry’ under Policy EC5 for B1 (b, c), B2 or B8 uses. Although unit size restrictions are not specified in the policy text the size of the site overall at 2ha will again limit the size and scale of units to the smaller scale type.

The site allocation under Policy EC7 requires at least 50% of the 14.8ha site is reserved for smaller units of up to 10,000sqm for each individual unit.

Overall therefore the plan allocates a minimum of 12.7ha for smaller units leaving a maximum of 7.4ha for medium sized units. The maximum unit size restriction at the Apex Park extension under Policy EC7 is up to 13,500sqm.

Apex Park is identified in the background paper as ‘the highest quality industrial estate’ in Daventry town where stock is of a larger scale and ‘is more suited to B8 strategic distribution’.

Our client would support the evidence base provided by the background paper. Apex Park is a highly sought after location for distribution, although for units of a smaller scale than nearby DIRFT where units sizes for Phase III are predominately between 24,000 sqm and 100,000 sqm. Only 2 of the 12 units currently approved at DIRFT III are below 20,000 sqm.

The strategic warehouse market is continuing to respond to market drivers and units are becoming larger at the strategic scale of the distribution industry. This naturally has an effect on what is considered medium scale.

To ensure Daventry has a broad employment base and attracts the necessary jobs to ensure a good balance of homes and jobs for the town we consider that the maximum unit size attributed in Policy EC7 should be raised from 13,500sqm to 20,000sqm. Our clients currently have interest for in units up to this size.

It is also specified in the background paper at paragraph 3.81 that much of the potential demand identified comes

12 March 2018 Page 277 of 399 from businesses already established in Daventry looking to expand or relocate. Whilst the background paper identifies this with regard to smaller units this is equally true of medium sized units.

In order to ensure that the Daventry Town retains and supports it economic base and its role and function as a secondary growth town in West Northamptonshire, we request that the scope of the policy is broadened to allow for a slightly larger unit size. The retention and creation of jobs for the town is vital to ensure that an appropriate balance of homes and jobs is sustained in order to reduce out-commuting and to support sustainable place-making. The emerging plan proposes housing allocations at Daventry amounting to a further 1,100 dwellings additional to the 2,600 dwellings allocated via the Joint Core Strategy. There is therefore a need to ensure the allocated employment land in the Part 2 Local Plan delivers the necessary jobs to serve the new residents.

We suggest the following minor adjustment to the policy wording below which is consistent with the advice in the background paper. The revised wording will continue to ensure the site is protected from larger scale units such as that found at a DIRFT III whilst also allowing consistency with the commentary in the background paper that Apex Park is suited to B8 strategic distribution. The policy then responds to both the smaller-scale and medium-scale needs identified in the local area.

In addition we suggest a supplementary clause which would allow in exceptional circumstances a larger unit to be considered if the Council consider it is an advantage to retain an existing local employer needing a larger unit. Clearly a case would have to be made by the existing employer and other aspects of the policy would have to be adhered to, however the clause would allow such as scheme to be within the scope of the policy and therefore policy compliant as a justified exception.

EC7 – Land North West of Nasmyth Road, Daventry A) Development proposals for this site must be informed by a masterplan, agreed by the Council as local planning authority. B) Proposals for this site should meet all of the following: i. provide for B1 (b,c), B2 or B8 uses; ii. provide a mix of unit sizes, that individually do not exceed 13,500sqm 20,000sqm and at least 50% of the floorspace to be provided in a range of unit sizes that individually do not exceed 10,000sqm; iii. strengthen existing boundary hedgerows and plant new screening to mitigate impact on the landscape including the provision of a buffer between the built form and the landscape; iv. optimise the design and layout to ensure the development does not result in adverse amenity impacts on neighbouring residents and minimises impact on the landscape beyond including giving careful consideration to the skyline in this location when determining the heights of buildings, as well as the levelling and platforms required; v. provide safe access; vi. integrate with the existing employment area; vii. provide walking and cycling links from the site to the remainder of the employment area and also the neighbouring residential area; and viii. provide an extension to the existing footpath at the northern perimeter of the site connecting to the existing footpath network.

In the event that a local employer comes forward as a relocation requirement for a unit in excess of the limits stated above, the Council will consider the proposal where justified on the balance of issues within the scope of the policy.

12 March 2018 Page 278 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED120 Mark Wesley

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Though this looks like just adding to an industrial area the further encroachment to Middlemore and the subsequent noise is a reason to reconsider but the detrimental effect on current footways and access to the open countryside is unacceptable. The visual environmental impact for Braunston including from Jurassic Way should point to this proposal being shelved.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC7 ED138F Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Daventry Town Council broadly supports Policy EC7 which allocates employment uses as an extension to Drayton Fields Industrial Estate to the North West of the town.

The site area is relatively modest and it adjoins to additional employment floorspace which is currently being built out to the south of the site. The proposals will ‘enclose’ the existing public right of way, which connects with the whole of the western town perimeter footpath, within an industrial estate area.

The policy requires that an extension to the existing footpath at the northern perimeter of the site connecting to the existing footpath network is provided. Daventry Town Council feels that it is essential to ensure that these footpaths are upgraded so that people can gain access to the countryside and that the western footpath around the town can link to a strong pedestrian and cycle route of the old disused railway line. This also needs to be upgraded and provide a viable link to the wider countryside and Braunston.

12 March 2018 Page 279 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC9 ED60B Emilie Carr

Organisation: Representing: Historic England

Support/Object: Object

Supporting Documents:

Comment:

There is a small section of just around 1ha (roughly drafted map attached) immediately to the west of the Burnt Walls Scheduled Monument, harmful to the significance to the Scheduled Monument, the immediate setting and the historic landscape context of the monument, in which there is ridge and furrow. Is this a mapping error give its relatively small size? Historic England would be very happy to agree this change by Statement of Common Ground if this small area can be deleted. Without this change, Historic England would not conclude with the Sustainability Appraisal site assessment.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC9 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Daventry South East Gateway (Policy EC9) 19. Given that the paragraph 7.3.02 refers to the gateway site as comprising the Marches Industrial Estate and associated sites, it is not clear whether site EC9 as marked on the proposals map encompasses the whole of the site being referred to.

20. In addition, reading paragraphs 7.3.02-06 in combination it is not clear how they lead to part B of Policy EC09 – these paragraphs concentrate on the issues and constraints, a further paragraph detailing the proposal would be helpful.

21. There will also be some challenges in delivering a site such as this alongside the A45, particularly where only one side of the road is to be developed. In the absence of more detailed proposals at this stage, we would recommend that a transport or access strategy (comparable to that in policies EC2 and EC3) which would include proposals for pedestrian, cycling, public transport and highway access to the site.

12 March 2018 Page 280 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC9 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Anglian Water has no objection to the principle of employment development on this site.

West Northamptonshire Core Strategy already includes a district wide policy relating to water supply, quality and wastewater infrastructure. It is not considered necessary to duplicate the requirements of Policy BN7A in the Part 2 Local Plan. However we would suggested that Policy EC9 includes reference to the above requirement. Therefore it suggested that Policy EC9 could be strengthened by including reference to both water and wastewater infrastructure and that suitable mitigation will be provided part of this development.

There are a number of water mains in Anglian Water’s ownership within the boundary of the site. It is therefore suggested that the following text should be included in the supporting text: Existing water mains cross the site and the site layout should be designed to take these into account. This existing infrastructure is protected by easements and should not be built over or located in private gardens where access for maintenance and repair could be restricted. The existing water mains and sewers should be located in public highway or public open space. If this is not possible a formal application to divert Anglian Water’s assets may be required.

It is therefore suggested that Policy H01 should be amended as follows: that suitable access is safeguarded for the maintenance of water supply infrastructure; and

12 March 2018 Page 281 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC9 ED138G Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Daventry Town Council broadly supports Policy EC9 which allocates the gateway site on the A45 at the entrance to Daventry for employment uses (B1 b&c, B2, B8). Daventry Town Council considers this site represents a very important gateway to the town and there is significant opportunity for sympathetic redevelopment and commercial regeneration.

Daventry Town Council also considers that the employment uses should not limit office development (B1a). While office development is regarded as a main town centre use and should therefore sequentially be located within or near to the town centre this site represents an opportunity to provide a high-quality office environment with excellent links to the M1.

In order to provide the type of gateway entrance that is envisaged it is essential to require a masterplan to be approved by the planning authority. The Town Council supports the allocation of this site as a gateway however it supports a more flexible approach would potentially allow a number of proposals to come forward which may present a better solution than just light industrial, manufacturing and distribution uses. The production of a development brief by the Council would guide and inform any masterplan which may be submitted for the site in future.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 07 Policy EC9 Daventry SE ED34 Paul Biggins Gateway

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

No reference is made to the derelict hotel and petrol station. Rather than building houses on beautiful green field sites, DDC should implement, as a matter of urgency, the relocation of the car breakers, the cleaning of the land to allow house building and move to convert the hotel into truly affordable council flats.

12 March 2018 Page 282 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 ED24 Simon Barber

Organisation: Representing: English Regional Transport Association

Support/Object:

Supporting Documents:

Comment:

I am a responding to the above consultation as a member of the English Regional Transport Assessment (ERTA), which is a voluntary membership-based, pro-public transport improvement association with its main projects initially in the Bedfordshire and surrounding regional areas but its remit has increased since several of its projects have a nation-wide positive benefits and impact. ERTA website: https://ertarail.com/

I now make the following comments: Access to sustainable transport modes is challenging particularly within rural areas. The current mode share of journey work is based on the car and the share in Daventry District Council is higher than the national average and consequently sustainable modes is lower than the national average.

Grand Union Canal - The tow-path should be upgraded to encourage more walking and cycling.

Welford (secondary village) - The two pedestrian footpaths are of utmost importance.

Weedon (primary village) - A new railway station (could perhaps be named Weedon Parkway/Daventry Parkway) should be built thee on the West Coast Main Line close to Daventry International Rail freight Terminal.

Finally, ERTA calls for the re-opening of the old Great Central Railway which used to run from London Marylebone to Leicester, and used to pass very close to Daventry. Much of the old track-bed survives, and you will find this aspiration mentioned in its web-site given above.

12 March 2018 Page 283 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 ED33 Cliff Cooper

Organisation: Representing: Crick Parish Council

Support/Object:

Supporting Documents:

Comment:

At Chapter 8 there are proposals for strengthening the encouragement of people to cycle particularly to work. Work has been completed to achieve a cycleway from Crick to DRIFT but there is muddled thinking by the various authorities. Attached as an Appendix is a single extract from the recent meeting of the Junction 18 Liaison Forum attended amongst others by Daventry District Council. On the one hand it acknowledges the expenditure to build the new accessway which links with the existing cycle/footway along the A5 but then then accepts that this existing way can be blocked by lorries and no action will be taken. The final sentence of the abstract would appear to suggest that pedestrian/cyclist safety is a very minor consideration.

8.2 notes the problems with lorries but new lorry parks where there is a fee will not stop parking on the footways unless effective action is taken. Daventry District Council should take the lead in addressing this problem and seeking a change by those, whose responsibility it is, to modify the current infrastructure that is currently so attractive to lorries with either signage or bollards. This is also required under the Junction 18 bridge to prevent danger and litter and, also one side of the underpass is required as part of the path/cycleway. Recent action with plastic cones showed how easy it is to deter lorries.

APPENDIX Extract from the Minutes of the Junction 18 Liaison Forum held on the 6th December 2017 Off-site highway works included safety improvements at Lilbourne and Catthorpe and the creation of the foot/cycle path from Crick to DIRFT. With regards to the latter, now the technical approval had been received from Highways England it was intended to start work on 8 January 2018. The scheme would take 3-4 weeks to complete and the work would be done under traffic lights. It had been hoped to start this earlier but this had not been practically possible.

SM asked whether anything would be done to deter HGVs from parking on the roundabout under the M1. MS advised that Tim Callaway from Highways England had met with Crick Parish Council to discuss potential solutions. Funding was available, but the expenditure needed to be justified. No firm conclusion had come from that meeting but Highways England were looking to see what could be done. It was noted that temporary bollards had been in place for a while in that area and had worked.

LC advised that 25+ HGVs continued to park on footpaths in the area. These were the target of organised criminals; the most recent attack was the previous night, on the roundabout under the M1. He added that the first thought was always driver safety, however the Police could only send drivers to authorised truck stops i.e. the Night Owl.

The biggest issue was trying to engage with the companies responsible for the products on the vehicles coming into the UK; there was, generally, a lack of interest. Due to the very limited number of Police Officers, and the time involved, a decision had now been made not to move HGVs from the footpaths. The question had to be asked whether moving HGVs was an appropriate use of Officer time.

12 March 2018 Page 284 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 ED50 Callum Batchelor

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I have recently purchased a home in the town and work for Cummins Power Systems, at the expanding Daventry plant. Many people are thinking about relocating here but are put off by the lack of a rail link. I have looked into the plans the council currently have underway and there looks to be much investment in the town and the international rail freight terminal - why no plans for a rail link at Daventry? A canal link to the GUC would be welcomed somewhat for tourism, leisure and aesthetics; but is redundant for attracting expanding businesses/ commuters. Many colleagues moving from other Cummins sites, such as Kent, choose Rugby or Northampton for this very reason. With the investment that will be undertaken on the UK’s current rail network, rail expansion and high-speed rail in the coming years, Daventry will be left behind without one. It is ideally placed for connecting north and south. It would become very attractive for commuters from both Birmingham and London.

12 March 2018 Page 285 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 ED72 Marianne Follett

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I have lived in Daventry for over forty years so have seen many changes over that time, lots to the good of the town. Daventry needs to grow but keep it’s individual identity and character. Having looked at the plan for the future there are a lot of positive recommendations keeping important green space and not over developing certain areas. We need shops and leisure buildings to support this increase in housing to keep people shopping and finding entertainment in Daventry.

My main concern is the Southern Gateway area as mentioned in the plan( 7.3.02)....what a shambles the entry to Daventry is on the A45...the recycling area has overflown into the derelict hotel next door and car transporters are parked up on side roads and in the hotel area adjoining on the old garage forecourt awaiting space to move into the re cycling area. The area has grown too big for the site and surely needs a more accessible and safer site on an industrial estate not at an entrance to a town. On many occasions it causes a danger to motorists and people getting out of the transporters. I notice the grass verges have no parking signs on them but the whole area is not conducive to welcome people into Daventry. The plan points out this problem and I hope that this will be a matter of great importance in re generating this area.

Two points not covered by the plan that I feel are important local issues are 1. The B4038 road into Daventry needs to restrict large articulated lorries ( I notice learner drivers using Articulated lorries from a depot in Weedon are using this route frequently). There are two very small mini roundabouts, a hospital and zebra crossings and residential areas on this road .....these lorries should be made to use the larger roads into town.

2. Daventry has some wonderful buildings that enhance the town centre but there are some left derelict and empty for years in prominent positions ( opposite the Town Museum and the hotel on the A45 roundabout south ) these spoil the surrounding areas. Hope my views are of interest to those working on the plan for the future of our town.

12 March 2018 Page 286 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Chapter 8 Sustainable ED34 Paul Biggins transport

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

Once again DDC have failed to put forward realistic plans for the improvement of transport links. Whilst it continues to assert that we have excellent transport links, we all know that this is simply not true. The A361, a main route to DIRFT and the M1 and A5 northbound is recognised as one of the most dangerous roads in the UK, yet no mention is made of plans to ensure it's improved. The A45 to Northampton and the A361 south to the M40 are also death traps. If Daventry is really to develop into a town fit for the 21st century we need dual carriageway links to major motorways and A roads, and more importantly we need a rail link into Daventry town centre. We really don't need more cycle routes and walkways and we definitely don't need a canal link! Finally, I would like to add just how difficult it's been to respond to this consultation. Once the process is complete I would like to know just how many residents took part. I wonder how many concluded that, given previous consultations where DDC have completed ignored local views, it was a complete waste of time and effort and so didn't bother?

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Para 8.1.05 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

Badby Parish Neighbourhood Plan Group would very much support the development of rural cycle routes and in the case of Badby, a safe cycle link to our nearest service centre, Daventry, would be very welcome.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Para 8.1.06 ED24 Simon Barber

Organisation: Representing: English Regional Transport Association

Support/Object:

Supporting Documents:

Comment:

Sustainable Transport Infrastructure - protect disused railway lines for possible future use as railways.

12 March 2018 Page 287 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Para 8.3 ED122 Tim Cross

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

Although this is the responsibility of NCC could this section demonstrate a much more determined attitude to continue to press NCC towards progress with these roads. As all the development progresses around the edge of Northampton increasing traffic levels are going to cause major problems on the A428 and associate villages.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Para 8.3.03 ED57 Andy D'Arcy

Organisation: Representing: South Northamptonshire Council

Support/Object:

Supporting Documents:

Comment:

DtC - Connections

We note the plan makes reference to the route of the Northern Bypass/Northampton Orbital Route. This is considered to be 'critical' infrastructure within the WNJCS. SNC is highly concerned by the statement at paragraph 8.3.03 of the consultation document which states:

"The policies emerging in this plan will be relevant considerations for the determination of the most suitable route for the roads"

12 March 2018 Page 288 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Paras 2.5.02, 2.5.03, section ED61 Mark Chant 8.3, para 8.3.03

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Transport 22. Paragraph 2.5.02 refers to the journey time from Long Buckby to London as being 78 minutes. As the journey time varies considerably, either an average figure or a range should be used.

23. Paragraph 2.5.03 refers to “larger villages such as Crick, Long Buckby, Brixworth and Moulton having good access to bus services to Daventry, Northampton and Rugby”. As most of these village have a service only to one of those places a better reference would be to “services to Daventry, Northampton or Rugby.”

24. The A43 Moulton bypass alignment should be shown on the Policies Map.

25. Section 8.3 refers to the Northampton Northern Orbital Road and the Northampton Western Relief Road. The correct names of these schemes are the Northampton Northern Orbital Route and the Northampton North West Relief Road, and these names should be used to avoid confusion.

26. The detailed alignments for the Northampton North West Relief Road, the Northampton Northern Orbital Route and an associated spur to Moulton Park have not yet been determined. However, should the preferred route for any of these schemes be agreed before the adoption of the Part 2 Plan, the routes would need to be safeguarded through policy and shown on the Policies Map. It should also be noted that the statement in paragraph 8.3.03 that the policies emerging in this plan will be relevant considerations for the determination of the most suitable route for the roads is actually incorrect: it will be the policies of the adopted plans (the Part 1 Plan and the 1997 Local Plan) that will do this.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST1 ED26 Steven Rolt

Organisation: Representing: Braunston Parish Council

Support/Object: Support

Supporting Documents:

Comment:

Braunston Parish Council notes the inclusion of policies including Policies RA2 (Secondary Service Villages) and ST1 (Sustainable Transport Infrastructure) that align with the Braunston Neighbourhood Plan and welcomes the support this lends to our objectives.

12 March 2018 Page 289 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST1 ED26 Steven Rolt

Organisation: Representing: Braunston Parish Council

Support/Object:

Supporting Documents:

Comment:

In addition to supporting the cycle route between Daventry and Braunston (Policy ST1) the Parish Council would like to see a similar facility provided between Daventry and Long Buckby as the station there is often used by residents in Braunston Parish and at 7 miles from the village is at a distance that could be reach by bicycle. We believe that a Daventry to Long Buckby cycle route, as well as improvements to the current poor bus service from the town to the station, are more likely to be realised if the development of housing in the North East SUE were prioritised over housing in sites HO1 and HO2.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST1 ED58C Paul Everard

Organisation: Representing: Northampton Borough Council

Support/Object: Support

Supporting Documents:

Comment:

The policy as drafted, in particularly point A and the reference to the provision/retention of walking and cycling connectivity between rural settlements and Northampton, is supported.

12 March 2018 Page 290 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST1 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object:

Supporting Documents:

Comment:

We broadly support the content of policy ST1 but would welcome stronger wording regarding the requirements to deliver the measures identified in the policy. The policy wording does not make it clear that many of these measures will be expected/insisted upon, often using the wording that measures 'will be supported'.

It is not clear therefore that they are an essential requirement of development.

Supporting and enabling active travel is a vital contributor to health and wellbeing (given that over a third of the population of Daventry do not meet minimum recommended physical activity levels) as well as having the potential to reduce congestion and pollution. We therefore propose stronger wording to require that meaningful measures to support walking and cycling are included in new development.

Another example relates to electric vehicle infrastructure. ST1E states that 'Proposals to incorporate appropriate infrastructure to support electric vehicle charging will be supported'. We would suggest that new developments should be expected/required to include electric vehicle charging infrastructure (at a ratio per property to be determined/identified). This would facilitate the take up of electric vehicles in the district, thus contributing to more sustainable transport and making a contribution to maintaining/improving air quality.

12 March 2018 Page 291 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST1 ED138P Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy ST1 is supported by Daventry Town Council however it considers that the policy should be extended to identify further pedestrian and cycle routes within the town. Consideration should be given to creating walking routes on the western perimeter of the town (skirting the industrial estates of Royal Oak and Drayton Fields and the footpaths around Borough Hill).

Further safe provision of cycling routes integrated alongside A-roads within and around Daventry would help residents to access the countryside and use sustainable modes of transport. At the present time, the use of A-roads for cycling is unsafe and discourages cyclists.

The Town Council strongly supports enhanced links to Long Buckby National Rail station for pedestrians, cyclists and bus services and considers this to be a priority to achieve through the proposals for the north east Sustainable Urban Extension.

Daventry Town Council supports the enhancement and upgrading of the pedestrian and cycle link to Braunston on the disused railway line.

Daventry Town Council believes that the electric charging infrastructure should be further promoted, through the local plan. As the transition from carbon-based fuels to electric energy to power vehicles is an inevitability, the Local Plan should be more proactive in implementing these changes. A revised Parking and Charging Standards Supplementary Planning Document should be developed to support the plan and provide guidance as to what is expected in the future.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST2 ED41A Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object: Support

Supporting Documents:

Comment:

There is a huge need for additional lorry parking. Laybys near villages are disgusting with both rubbish and human excrement as drivers park up without any access to necessary facilities. It cannot continue to be ignored and needs stronger legislation.

12 March 2018 Page 292 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST2 ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

The Parish Council strongly supports this policy, but feels that since there is a current need, there should be a stronger emphasis on creation of lorry parks. The park associated with DIRFT 3 will be of insufficient capacity to reduce the current high number of lorries parked overnight in laybys where there are no facilities at all, which leads to litter and human excrement being left. More needs to be done to identify additional lorry parking sites which have toilet and rubbish collection facilities.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST2 ED138Q Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy ST2 promotes the provision of lorry parks in locations that meet an identified need. Daventry Town Council supports this policy aim but the policy must consider the identification of a suitable site which would reduce the number of HGV vehicles parking in laybys and industrial estates, in the Town.

The County Council has been focusing on this issue since 2009 when it produced a report on the need for strategic lorry parking within the County. Five years later in 2014 the first of these had received planning permission at Rothwell on the A14, however, it is believed that this has not yet been built due to commercial considerations.

Strategic thinking is required in relation to HGV parking and the requirements of the distribution sector within the District and facilities need to be provided that will be utilised with potential sanctions for those parking in unauthorised locations. This may require coordination and action from a range of stakeholders and partner organisation. Daventry Town Council supports Policy ST2 but believes it will not be delivered without coordinated action, and the District and/or County Council must take a pro-active lead by acquiring a site and proactively working with a commercial partner to make it happen.

12 March 2018 Page 293 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Policy ST2 – Lorry Parks ED41A, ED41B Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 08 Section 8.1, 8.3 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 8.1 Walking and Cycling. HPC welcome this guidance and appreciate the note in section 8.1.05 which states that it is not desirable to urbanise areas in order to improve walking and cycling routes.

Section 8.3 Northampton Northern Orbital Road and Northampton Western Relief Road. While accepting that the SCLP is unable to provide more detail or indicate its preference for a plan, it may be useful to reference the CPRE’s take on Northampton North Orbital Route (see article: https://www.cprenorthants.org.uk/media/newsletters/Outlook_November_2017_v31.pdf). HPC would encourage the SCLP guidance to be aligned with this information.

12 March 2018 Page 294 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 ED62 Alison Collins

Organisation: Representing: Natural England

Support/Object:

Supporting Documents:

Comment:

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England does not consider that the emerging draft Daventry District Settlements and Countryside Local Plan Part 2 poses any likely risk or opportunity in relation to our statutory purpose, and so does not wish to comment on this consultation. The lack of comment from Natural England should not be interpreted as a statement that there are no impacts on the natural environment. Other bodies and individuals may wish to make comments that might help the Local Planning Authority (LPA) to fully take account of any environmental risks and opportunities relating to this document.

If you disagree with our assessment of this proposal as low risk, or should the proposal be amended in a way which significantly affects its impact on the natural environment, then in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, please consult Natural England again.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

Minerals and Waste Local Plan 27. The Part 2 Plan should acknowledge that the development plan also includes the adopted Minerals and Waste Local Plan.

28. It is noted that the green wedge designation includes a committed (and operational) waste facility at Brampton Lane Boughton. Notwithstanding the comments above about the green wedge, as an existing waste facility and identified as such on the Minerals and Waste Local Plan Policies Map this area should not be in a green wedge.

29. The Minerals and Waste Local Plan identifies mineral safeguarding areas across Daventry district. The planning practice guidance issued by DCLG states that “district councils should show Mineral Safeguarding Areas on their policy maps”. At present these are not shown.

12 March 2018 Page 295 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 ED67 Jonathan Jeyes

Organisation: Representing:

Support/Object:

Supporting Documents: Map

Comment:

I am writing in respect of the current consultation that is taking place on Daventry District Settlements and Countryside (Part 2) Local Plan.

I am a resident within the plan area and co-owner of 60 acres between Moulton and Boughton. As an interested stakeholder within the plan area I find it really disappointing that the Council has not contacted me advising of the consultation on plans that affect my land.

I object to the plans to make the land between Moulton and Boughton a Green Wedge. When looking a map overview of this area it is clear that this land should not have restrictions placed upon it that may prevent future road infrastructure, residential or commercial development of the area. All developments which Northampton needs and would naturally fit between Moulton and Boughton without blighting the natural beauty of other areas of the countryside within the Daventry District boundary.

On the attached map I highlight the area of Green Wedge that I am objecting to.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 ENV 1 – Landscape ED41A, ED41B Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

B. The cumulative impact of development proposals on the quality of the landscape should extend across County boundaries. The impact of huge amounts of urban development on the fringes of Rugby is having a hugely detrimental effect on the parish, and in particular on the highway infrastructure. There needs to be more acknowledgment of this included in the Local Plan.

12 March 2018 Page 296 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 General Historic Environment ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

Barby has an ancient monument consisting of an Iron Age hill fort as depicted on the letter head. This is currently used as pasture land. Can it be included in the Local Plan as a site of interest. It is to the north of “Castle Mound”, Barby. It does fall outside the parish development area, but it is important that it can be protected from ploughing etc. This request also applies to the Mediaeval village to the north of Onley Park.

12 March 2018 Page 297 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Landscape Study ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Daventry Landscape Study

2.58 The Daventry Landscape Study assesses the site in terms of landscape character and provides an assessment of its capacity to accommodate change along with mitigation measures. Part F considers the site specific landscape and visual quality, mitigation measures and the site’s capacity to accommodate change. It identifies that the site forms the lower slopes of a series of interlocking low isolated hills that form the backdrop to southerly views from Daventry. The study highlights that land beyond the site continues to rise to these hills. It goes on to identify that these same hills screen the site from the wider (Ironstone Hills) countryside to the south. The conclusion of this section of the study advises that development would interrupt views to the hills, which would be difficult to mitigate. The assessment continues that the site has a low capacity to accommodate change due to increased urban influence and a lack of ability to screen development.

2.59 Whilst we note that the Council has chosen to allocate Daventry South West, notwithstanding the conclusions of the landscape study (an approach we wholly support), we consider the assessment is flawed as it only considers the site and its immediate environment to receive change, not the Landscape Character Type in which it is located, and as a result is negatively bias in its assessment. The hills to the south/west of the site provide a strong separation to the site’s visibility from the Ironstone Hills landscape beyond and therefore provide a strong mitigation factor.

2.60 When applying the Landscape Strategy as set out in Part A, it is clear that any development which avoids any encroachment onto the upper slopes and summits of the isolated hills, has the ability to accommodate change without undue influence on the character of the Ironstone Hills Landscape Character Type. This character would then achieve higher than the ‘low capacity to accommodate change’ conclusion currently provided in part F of the evidence base.

12 March 2018 Page 298 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Landscape Study ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

2.61 With regards to the Green Wedge designation we have concerns with the methodology used to test the physical requirements of the Green Wedge designation, as identified within Part D of the Landscape Evidence Base. The methodology used by the Council appears to consider the physical boundaries of the ‘Land Unit’ at the desktop stage, reviewing and refining the boundaries as part of the Field Work. However, the desktop does not consider in detail how the settlements of Daventry and Staverton are perceived, and no visual analysis to inform the consideration of the land needed to preserve their identity appears to have taken place. We do not agree that the land unit identified as DA4 is justified as the land required to perform the responsibilities of the Green Wedge. It would appear, for example, that the proposed inner boundary of DA4 is informed by the OPUN study that informed the designation, without any justification. This boundary should be tested in detail, as we do not consider the boundary defines the extent of the Green Wedge that is required between Daventry South West and Staverton. In addition, this boundary is not replicated when considering the analysis of the designation at Part F of the Landscape Evidence Base. Part D identifies that the Land Unit is around 1.5km from Staverton without stating why the distance is justified. While we understand that separation is informed by qualitative and quantitative analysis, this distance far exceeds the other settlements whose identities are protected by the proposed Green Wedge policy, with no explanation for why this is the case.

2.62 In order to overcome our concerns, the Green Wedge needs to be reduced to allow for a greater developable area and reflect the shortcomings in the evidence base as set out above. We recognise that the landscape study confirms the Green Wedge boundaries are not fixed however and we consider this boundary needs more detailed consideration prior to designation.

12 March 2018 Page 299 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Landscape, Ecology and ED142B & ED124D James Yeoman Heritage

Organisation: Representing: Savills Christ Church, Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Landscape, Ecology and Heritage Statement - Prepared by EDP

The Council has since published the Evidence Base associated with the LP2. This includes the:

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.1 ED69 Anne Cowan

Organisation: Representing: Maidwell with Draughton Parish Council

Support/Object: Object

Supporting Documents:

Comment:

2. Paragraph 9.1: Currently the designation of Special Landscape Area covers the land between Maidwell and Draughton and down to Lamport. The new proposal is to set the eastern boundary of the SLA along the Brampton Valley Way. There may be a rationale for this based on underlying geology (which affects landscape) but we feel that the land from the Valley Way up to Draughton, and the land south from Draughton to Lamport should stay in the SLA as this is attractive rolling hillside landscape. Indeed land to the north of Maidwell and south of the A14 should also be considered as part of the wider SLA as it forms part of the most south westerly outcrop in England of the important Lincoln Limestone beds giving a distinctive landscape and flora.

12 March 2018 Page 300 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.1.01 - 9.1.06, policy ED81 Kenneth Morris ENV1

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

Badby Parish Neighbourhood Plan Group would strongly support all elements of the above policy, in particularly the avoidance of "physical and visual coalescence between settlements".

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.1.11, 9.1.12, sections ED87 Sarah Stock 9.2, 9.3 9.5, 9.7

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

HPC broadly welcome this policy which gives appropriate importance to the setting, historic integrity and preservation of the overall character of the district.

Section 9.1.11 Special Landscape Areas. HPC understand that the Daventry District Landscape Study reviewed and now proposes to include four SLAs in the area. Harlestone Parish borders the Brington SLA and would, if given the opportunity, like to propose that Harlestone is included in the SLA to reflect and include those landscape areas that give the parish its distinct settlement areas and open spaces/views. Given that the conservation area status specifically mentions the views and landscape throughout Upper and Lower Harlestone it seems appropriate to make this request.

Section 9.1.12 seems to indicate that settlements classified as ‘other’ and ‘small settlement/hamlet’ are covered by SLA. HPC would appreciate greater clarity in the wording of this section of the SCLP.

Section 9.2 Green Wedge. HPC welcome the introduction of the Green Wedge surrounding Harlestone.

Section 9.3 Green Infrastructure and Biodiversity. HPC welcome these policies but would like them to go further. The SCLP should require developments next to Green Wedges, SLAs or in Rural Exception Sites to include plans for increasing the number of trees in the area. This would be in line with government plans to promote and fund tree planting (https://www.gov.uk/government/collections/countryside-stewardship-woodland-support).

Section 9.5 Historic Environment. HPC very much welcome the emphasis placed on preserving the historic environment.

Section 9.7 Design. HPC welcome the spirit of policy ENV11. However, it notes that recent development applications have fallen short of meeting the high stands of design eluded to in this policy.

12 March 2018 Page 301 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.2, policy ENV3 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

The Badby Neighbourhood Plan Group believes the extension of Daventry to the south of the A45 gives cause for concern as future development to the south of the A45 could compromise the rural setting of Badby village. It is therefore pleasing to see Policy ENV3 supporting the designation of Green Wedge areas to protect the character of settlements close to Daventry. The neighbourhood plan group would be very supportive of the designation of a Green Wedge to protect Badby village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.2.02, 9.2.03, Policy ED103 Andrew Longley ENV3

Organisation: Representing: North Northamptonshire Joint Planning & Delivery Unit Support/Object:

Supporting Documents:

Comment:

We wish to comment on the identification of Green Wedges to protect the identity and setting of villages and to prevent the coalescence of settlements (policy ENV 3. Paras 9.2.02 and 9.2.03).

It will clearly be for the Council to justify this approach and the extent of these Green Wedges through the Examination process, including consideration of the implications for the longer-term growth of Northampton.

The North Northamptonshire JCS refers to post-2029 growth of Northampton at para 1.14, setting out that: “For the period post-2029, options outside of the West Northamptonshire boundary area may need to be tested alongside others for meeting Northampton’s longer term development needs. Through the duty to co-operate and coordination of plan making, the respective local planning authorities will work together to positively address this issue in reviewing future Local Plans”.

It is recognised that the timescale of your emerging Part 2 Local Plan is to 2029. However, it is important that the identification of Green Wedges does not prejudice the assessment of all options in considering the longer term growth of Northampton. It will important that the West Northamptonshire LPAs work collectively to resolve any housing land supply issues that may arise in advance of considering Northampton’s longer term growth through the review of future Local Plans.

12 March 2018 Page 302 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 para 9.3, policy ENV4 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: support

Supporting Documents:

Comment:

We the Badby Parish Neighbourhood Plan Group support policy ENV4.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.3.04 ED76 Alan Smith

Organisation: Representing: The Wildlife Trust

Support/Object:

Supporting Documents:

Comment:

In Paragraph 9.3.04, on Pages 99 and 10: Within this specific paragraph here, in addition to the naming of the various different category types of site designations that are already referenced therein, we also recommend that it would be of benefit to include here too the further categories of “Pocket Parks” and “Protected Wildflower Verges” ( PWV ). { Please note that both Pocket Parks and PWVs are already being individually, and separately, named elsewhere in this overall suite of supporting documentation - within Paragraph 3.30, on Page 11, of the “Natural Environment Background Paper”, Version 1 – November 2017, for example. }

12 March 2018 Page 303 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.5.08 ED112 Peter Frampton

Organisation: Representing: Framptons Barry Howard Homes

Support/Object:

Supporting Documents:

Comment:

Overstone Hall, Daventry, Northamptonshire Introduction 1) The following submissions are made on behalf of Barry Howard Homes (BHH) who have acquired Overstone Hall, a part derelict and part substantially dilapidated Grade II Listed Building. As the Local Planning Authority (LPA) is aware the building suffered a disastrous fire in 2001.

2) BHH is working extensively with Daventry District Council (DDC) to prepare a scheme (s) which secures the full restoration of Overstone Hall together with a new viable use of this vast building. Evidence has been presented to DDC to demonstrate that the restoration of the Hall from within the 4 corners of the building is not financially feasible. Enabling development is required to secure the future conservation of this important heritage asset.

3) The single reference to Overstone Hall in the Local Plan states: ‘The Council has a corporate target to restore, reuse or sustain productive use of the listed buildings in the District with specific emphasis on Weedon Depot and Overstone Hall’. (p105).

4) The West Northamptonshire Joint Core Strategy (WNJCS) states at paragraph 10.36: ‘Whilst protection of designated heritage assets is generally good with relatively few at risk, there are some larger sites that are of some particular importance including Weedon Depot and Delapre Abbey’

5) A specific policy is included within the WNJCS to relate to the unique situation at Weedon Depot. The WNJCS is entirely silent on the circumstances at Overstone Hall which is clearly at risk from further decay. It is submitted that it would be consistent with national planning policy for the Part II Plan to contain a specific policy which relates to the planning circumstances of Overstone Hall.

6) Such an approach within the Part II Plan would be consistent with the approach taken by the Council in formulating a policy for Daventry South East Gateway, where it is a desired planning objective to achieve regeneration and renewal in the wider public interest.

7) It is submitted that a new policy should be introduced into the Part II Plan titled ‘Overstone Hall’. The following text recommends a suggested wording for the supporting explanation to the policy, and suggested policy wording.

8) Supporting Text: ‘The District Council is committed to the restoration, and securing a sustainable new use for Overstone Hall as a designated heritage asset at risk within the District. It is acknowledged that the fire which occurred in 2001 caused extensive damage to the structure. Since then the structure has continued to deteriorate in its physical condition. The restoration of the Hall will require very substantial financial investment.

It is acknowledged that achieving the Council’s corporate target for restoration and securing a sustainable new use will realistically necessitate the identification of ‘Enabling Development’ (Framework 140). In any proposals for the restoration of the Hall the Council will require a comprehensive analysis of the costs of the proposed works and valuation of new development to justify the amount of Enabling Development that may be sought. Enabling Development should follow the guidance set out in the English Heritage (now Historic England) guidance titled ‘Enabling Development and the Conservation of Significant Places’. The amount of enabling development is to be minimised to the extent necessary to achieve restoration and re-use of the Hall.

12 March 2018 Page 304 of 399 Where proposals are presented to the Council for a phased restoration of the Hall, the Council will need to be satisfied that the harm which may be caused by allowing enabling development, including any harm to the significance of designated heritage assets is outweighed by the public benefits to be realised from the individual phase of restoration. (Framework 134/140)

It is acknowledged that the costs of restoration substantially exceed the post development valuation for a range of uses for which the Hall may be suited. As such the so-termed ‘Conservation Deficit’ is very substantial. Correspondingly the restoration and re-use of the Hall is likely to require the release of significant areas of land to provide a new development so as to fulfil its enabling role.

The Council considers that new residential development will realistically provide the form of Enabling Development. Viability and costs have to be given careful attention in plan making and decision taking (Framework 173).The Council acknowledges that land will have to be identified which can accommodate a substantial number of new dwellings in order to achieve the enabling role. The Council believes that the number of new dwellings which may be required may well be circa 200-250. The Council considers that these new dwellings to be specifically released only to secure restoration of the Hall, or in phases of restoration should be identified within the locality of the Hall. The Council will work proactively with the owners of the Hall to identify suitable land that may fulfil the role of enabling development, and of a scale that is sufficient to achieve restoration and a sustainable new use. The Council will consider using its compulsory purchase powers in order to ensure the availability of sufficient land to achieve restoration and reuse of the Hall’.

9) Policy: Overstone Hall ‘Proposals for Overstone Hall will be supported where consistent with the objective to secure restoration of this Grade II Listed Building and a sustainable new use. In submitting any proposal which seeks to secure restoration of the Hall as a single phase or in phases, a Planning Application will need to satisfy the following criteria: 1. All development proposals will need to assess the impact of the development upon the significance of Overstone Hall as a Grade II Listed Building, and other listed buildings where impact may occur to their significance either directly or as a consequence of an impact upon their setting. 2. It will need to be demonstrated that any harm to the significance of a designated heritage asset, whether works to Overstone Hall, or arising from proposals for Enabling Development are outweighed by the public benefits of the proposals. This balanced approach (Framework 134) will be taken in the context of either a single phase of restoration, or in circumstances where phased restoration is proposed. 3. Supporting proposals with robust evidence as to the structural dilapidation of the Hall; the costs of undertaking the restoration works, whether as a single phase or in phases; the valuation following completion of the proposed works; and, the need for the amount of enabling development to support each phase of restoration. 4. All technical and financial information provided in the application will be subject to independent scrutiny to ensure that the amount of any Enabling Development is minimised to an extent that it is justified to achieve restoration of the Hall as a single phase of work or a succession of phases. 5. The imposition of legal mechanisms to ensure that value attributable from allowing any enabling development is expended upon the restoration of the Hall. 6. The imposition of arrangements to closely monitor the progress of restoration, and any change in circumstances which impacts upon the achievement of the restoration and the sustainable re-use of the Hall.’

12 March 2018 Page 305 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.7, ENV11 Design, page ED8 Sharon Henley 112

Organisation: Representing: Northants Police

Support/Object: Support

Supporting Documents:

Comment:

Pleased to note that DDC Local Plan EN42 paragraph D has been included into policy ENV11 point iv.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Para 9.8, policy ENV12 ED81 Kenneth Morris

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

Badby Parish Neighbourhood Plan Group would support the above policy, particularly as there area areas adjacent to the confines where there is a high risk of flooding. This area is clearly defined on the confines map within the Policies and Inset Map section of the Local Plan Part 2.

12 March 2018 Page 306 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Paras 9.2, 9.2.01-9.2.03, ED59 Geoffrey Smith policies ENV1, ENV3 9.2.01 – 9.2.03

Organisation: Representing: Welton Parish Council

Support/Object:

Supporting Documents:

Comment:

3. Chapter 9. The Built and Natural Environment Policy ENV1 – Landscape. Welton Parish Council supports this policy.

9.2 Green Wedge, 9.2.01 – 9.2.03 Welton Parish Council strongly supports the comments in these paragraphs.

Policy ENV3 Green Wedge. Welton Parish Council welcomes this policy. However, the designated area of Green Wedge between Welton and Micklewell Park Extension should also include the area of open countryside bounded by the southern fork from Welton to the A361, the A361 itself, the Micklewell Park Extension northern boundary and the current western boundary of the Green Wedge.

Additionally, an extension of the Green Wedge from its eastern boundary to incorporate fields adjoining the flood zone and Welton Lane should be given very careful consideration. Both of these proposals for extension of the Green Wedge would further protect the setting of the village and are important factors in preventing coalescence. In particular they would strengthen parts Ai and Aii of the policy.

12 March 2018 Page 307 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Paras 9.2-9.2, policy ENV3, ED77D Gerald Willard Policies and Inset Maps

Organisation: Representing: WW Planning Mr & Mrs Krempels

Support/Object: Object

Supporting Documents:

Comment:

I am instructed by my client Mr P Krempels of Moulton Mill to review this emerging draft plan and to comment on it.

Policy ENV3 is proposed to help deliver aims and objectives 12, 13 and 14 of the plan. These objectives seek the following: Objective 12 - Green infrastructure To protect natural species present in the District and enhance the existing strategic green infrastructure network, including biodiversity corridors, by incorporating and designing these into Sustainable Urban Extensions (SUEs) at Northampton and Daventry.

Objective 13 – High quality design To achieve a high quality design in both rural and urban areas that takes account of local character and heritage and provides a safe, healthy and attractive place for residents, visitors and businesses.

Objective 14 – Heritage To conserve and where possible enhance, through carefully managed change, heritage assets and their settings, and to recognise their role in providing a sense of place and local distinctiveness.

My client believes that the allocation of green wedges does not comply with these stated objectives and moreover they cause harm to the longer term planning objectives. They object to the designation of green wedges. They especially wish to object to the designation of a green wedge between Boughton and Moulton. The reasons for their objections are as follows: • The allocation of a green wedge immediately adjoining the existing settlement boundary would in the short and longer term prevent sustainable development on this location from taking place. Green wedges have one advantage over green belts insofar as theoretically they would still allow a development corridor to occur along the urban ‘fingers’ between the green wedges. However in this case given the status of Boughton and Moulton and feelings of local people there is no indication that future development along the ‘fingers’ they lie within would be supported thru the planning process. As such in this particular case the green wedge would not fulfil its purpose and would be inappropriate. • The allocation of a green wedge between Boughton and Moulton would prevent any future sustainable extension to the north of Moulton Park which would be contrary to objective 12 which seeks to provide for sustainable urban extensions. • There is no basis for contesting that green wedge allocation leads to improved design and accordingly the designation does not assist with the delivery of objective 13. • There is no evidence that green wedge designation contributes anything to protecting heritage assets as required by objective 14. Indeed by preventing development in policy terms in this way such designation could choke off any future investment in the very heritage asset it seeks to protect. • It is common practice when reviewing local plans for LPAs to instruct detailed reviews of Green Belt designations to ensure that only land which contributes least to green belt objectives is considered suitable for release from the green belt. Potential releases are then assessed against the core functions of the green belt in order to provide objective basis for potential release. In the same manner it ought to be good practice that the allocation of green wedges which have a similar status to green belts is supported by robust technical appraisal of the value of the draft allocation when measured against the aims of green wedge designation. In this case it would a technical study of existing openness and likelihood of coalescence ought to be undertaken. There does not appear to be such a reasoned study underpinning these green wedge allocations and in the absence of this the allocations cannot be supported and should not go forward. • The provision of green wedges is considered unnecessary. Countryside protection policies in the Part I WNJCS Plan

12 March 2018 Page 308 of 399 and others in the draft DDC Part II Plan provide sufficient planning policy control for the rural areas and a specific green wedge policy is simply unnecessary duplication.

Conclusion At this stage then my client wishes to object to the designation of a green wedge between Boughton and Moulton for these main reasons: • The allocation would fail to perform the function of a green wedge in that whilst constraining development it offers no planned channel or finger for acceptable sustainable development in the future. • The allocation also would prevent any future sustainable extension to Moulton Park which might otherwise naturally come forward as means to make efficient use of the services and infrastructure already present in the area and this would be contrary to objective 12. • There is no basis for contesting that green wedge allocation leads to improved design and accordingly the designation does not assist with the delivery of objective 13. • Green wedge designation would not deliver improved design and does not assist objective q3 and more importantly designation could potentially be harmful to the setting and viability of heritage assets and set out in objective 14. • Additionally it is considered that the proposed allocations not prepared on the basis of a robust technical appraisal.

My client also wishes to preserve their right to add to or amend these objections as further evidence or information comes to light. This is especially so with regard to the provision of a 5 year housing supply. Whilst the plan attest to an adequate supply and cites appeal precedent this respondent has not yet been able to gain sufficient understanding or evidence of housing supply within the district and accordingly they reserve the right to oppose this plan in the future if it considered it fails to provide sufficient housing land or for that matter employment land.

Change requested Omit the designation of a green wedge under policy ENV3 between Boughton and Moulton. Further point It is noted that the draft proposals map does not show the NRDA boundary (an adopted part of the Part I Plan) or land required for the safeguarding of the North West bypass/Northampton orbital route. This is exceptionally odd and should this planned road still be moving forward then clearly and emerging development plan document must give significant weight to it both on the adoption of a policy and indeed the formulation and justification of those polices. Such a significant infrastructure proposal must form part of the plan making process at this stage and this especially so it the work itself is likely to be dependent upon significant financial supporter from new development sites along its length as is understood to be the case in respect of the North West Northampton by-pass.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Paras 9.5.01 - 9.5.12, policy ED81 Kenneth Morris ENV8

Organisation: Representing: Badby Parish Council Neighbourhood Plan Group

Support/Object: Support

Supporting Documents:

Comment:

Badby Parish Neighbourhood Plan Group would support the above policy, but would emphasise that development bordering with, or visible from conservation area should not be detrimental to the character of amenity of the conservation area. Some reinforcement of this policy in that direct would be supported.

12 March 2018 Page 309 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policies & Inset Maps 40 ED18B Jane Austin

Organisation: Representing: Overstone Parish Council

Support/Object:

Supporting Documents:

Comment:

Inset map page 40. The map does not include the whole of the Overstone Parish. The map does not show any listed buildings within the village. The map does not include the following listed buildings, Church, Overstone Hall, Tower Court. It excludes all the properties within Overstone Park. Ass Bank Woods that are within the village Envelope and border Sywell Road should be included in ENV3 and coloured as Parsons Wood, Highlands and Young Spinney are. The designated Green Wedge between Overstone Village and Overstone Leys should be coloured as ENV3.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policies and Inset Map ED6 Kevin Poole Booklet page 2

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

The views to the South West from the Northampton Road at the southern approach to Brixworth and to the west from Froghall in Brixworth are as spectacular and valuable as any in Northamptonshire and need to be preserved for both now and for future generations. To keep the west side of Brampton Brook Valley as part of the Special Landscape Area but take the east side out (thus making it available for development which would destroy the views and change the nature of Brixworth) would suggest that common sense has been ignored in this proposal.

12 March 2018 Page 310 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policies and Inset Map ED7 Emma Poole Booklet page 2

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I am concerned that the stunning views to the south west of the village (around Northampton Road, Stonehill Way, Froxhill Crescent and Shelleycotes Road) and also to the west (around Frog Hall and New Street) would not be protected by this proposal. It seems ludicrous that the west side of the Brampton Brook Valley would be covered but the east side would be left out and so consequently it would be built on and these beautiful views destroyed forever. It seems such a loss to the quality of life for current residents and future generations for the sake of a handful of landowners making a 'quick buck' now.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policies ENV1, ENV2, ENV3, ED56A, ED56B Ann Packett ENV4, ENV5, ENV8

Organisation: Representing:

Support/Object: Support

Supporting Documents:

Comment:

I would like to broadly support the following policies: ENV1, ENV2, ENV3, ENV4, ENV5, ENV8

12 March 2018 Page 311 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policies ENV2, ENV3, ENV4 ED76 Alan Smith

Organisation: Representing: The Wildlife Trust

Support/Object:

Supporting Documents:

Comment:

Thank you very much indeed for consulting The Wildlife Trust concerning the Emerging Draft of the “Settlements and Countryside Local Plan ( Part 2 )” documentation for Daventry District.

So, we are referring here now to your own / DDC’s kind Consultation Covering Email Message, dated 27th November 2017, as here below, about this above same matter, and also to the set of supporting Local Plan ( Part 2 ), and related Evidence Base, paperwork in association with this current consultation exercise as held on your Authority’s own website.

Therefore, having now had the opportunity to review the relevant content of this same appropriate documentation, for us, The Wildlife Trust would wish to make the following observations. ( Please note that this same set of comments, here below, are not being made in any order of priority or importance to our own organisation; instead, they are simply listed in the sequential order in which they appear in the relevant source documents).

For the core “Emerging Draft Consultation Plan” document itself: On Page 99; in the ‘Policy Box’ shown for Policy “ENV4 – Green Infrastructure”: As the final text entry in this particular ‘Policy Box’, just as for the relevant entries made for Policy “ENV2 – Special Landscape Areas”, in the Box on Page 96, and also for Policy “ENV3 – Green Wedge”, in the Box on Page 97, should there not be an additional line which states that “The designated areas of Green Infrastructure Corridors are shown on the Policies and Inset Maps.” {And then, of course, if this amendment was indeed to be accepted and included, there would have to be all of the relevant new illustrations made of the hierarchy of the Green Infrastructure Corridor routes in all of the appropriate places in the separate “Policies and Inset Maps” document itself. }

For the supporting “Natural Environment Background Paper”, Version 1 – November 2017, document : With reference to the relevant content of Paragraph 1.1; on Page 3 : Although it may well perhaps just be due to a typing error, and / or a cut-and-paste mistake, however please note that we are of the view that there would appear to be some apparent confusion / contradiction between calling this particular document the “Natural Environment Background Paper”, on its Title / Front Page, and then these reference here to “heritage assets” and the “historic environment”. Therefore, can we please request that these sorts of conflicting terms ( ? just ? ) occurring in this paragraph are re-visited and checked for relevance and validity.

12 March 2018 Page 312 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV 3 ED57 Andy D'Arcy

Organisation: Representing: South Northamptonshire Council

Support/Object:

Supporting Documents:

Comment:

Duty to Cooperate - Policy ENV3: Green Wedge

The current consultation document appears to suggest the approach favoured for positively addressing issues of delivery within the NRDA by DDC is to impose a blanket restriction on development through Green Wedges on land to the north of Northampton.

"Restrictive policies in the development plan (specific or not) are relevant, but their weight will need to be judged against the needs for development of different kinds (and housing in particular), subject where applicable to the "tilted balance".

In addition, Lord Gill adds at para 79:

"Among the obvious constraints on housing development are development plan policies for the preservation of the greenbelt, and environmental and amenity policies and designations such as those referred to in footnote 9 of paragraph 14. The rigid enforcement of such policies may prevent a planning authority form meeting its requirement to provide a five years supply."

12 March 2018 Page 313 of 399 the social and economic sustainability when carrying out proposed designations. Some parts of the proposed ‘wedges’ may be more appropriate for sensitively designed, small scale development. This should be recognised. • No regard is had within the study to the route of the North-west bypass/Northampton Orbital. This will have a significant impact on the landscape character and quality around the north of Northampton and may mean that sites presently considered as medium sensitivity become more appropriate.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV1 ED105A Nigel Ozier

Organisation: Representing: Aitchison Rafferty Brixworth Parish Council and Brixworth Neighbourhood Plan Steering Group Support/Object:

Supporting Documents: Attached - Landscape Statement, further comments from Neighbourhood Plan Steering Group plus images

Comment:

Comments by the Steering Group I have attached representations prepared by the Neighbourhood Plan Steering Group dealing with those elements considered to be unacceptable which relate to the advice on landscape. It is considered the landscape evidence is not balanced and does not reflect the Neighbourhood Plan and the views on the value of the surrounding landscape, currently part of the SLA.

It is of great concern to the Steering Group that the basis of this study has been led by the consideration of how to achieve development and specifically the implications for the Special Landscape Area. The comments refer to other decisions and importantly, to the ‘made’ Neighbourhood Plan to which insufficient weight has been given. It is considered that the landscape evidence base is significantly undermined and flawed by its own terms of reference.

These comments are prepared by the Steering Group and in order to support views, an independent critique has been commissioned which I refer to next.

We therefore consider that the Local Plan has failed to recognise the landscape character and quality around Brixworth and that the 2017 Landscape Character Assessment is flawed and does not assess the area correctly. This is discussed further in the next section and accompanying report prepared by Huskisson Brown.

While supporting Policy ENV1, it is considered that the basis for maintaining the character and quality of the landscape is flawed due to the inadequacies of the assessment.

Critique of Landscape Evidence Base I enclose a report prepared by Huskisson Brown providing a critique and review of the landscape evidence base. Essentially, this report concludes that the study which forms the evidence base falls short of what is required and is unsound. The boundary of the SLA south and west of the village should be reinstated as part of the Part 2 Local Plan. Therefore, it is concluded that in this respect, the emerging Local Plan is unsound and changes should be made which reflect the independent critique by Huskisson Brown.

We object therefore to the changes proposed to the SLA boundary around Brixworth. The 2017 Landscape Study has failed to recognise the ‘valued’ landscape around the village and Policy ENV2 is based upon a flawed assessment of the existing SLA.

We will welcome the opportunity to discuss these representations further with the Council in the preparation of the next stage of the emerging Local Plan.

12 March 2018 Page 314 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV1 ED110 Gary Stephen

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

ENV1 – Landscape Criterion B states that the Council will take into account the cumulative impact of development proposals on the quality of the landscape. Whilst cumulative assessment is already embedded in plan making and decision-making (for instance through SEA and EIA respectively), it is unclear how this policy would be applied as drafted and further explanation is necessary. It is therefore contrary to paragraph 154 of the framework which states that ‘only policies that provide a clear indication of how decision maker should react should be included’ in a plan.

12 March 2018 Page 315 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV1 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.11 ENV1 – Landscape 4.11.1 Paragraph 9.1.06 includes a statement that suggests that where a proposal would result in landscape harm, there would be a general principle that it should be refused unless there would be an overriding public benefit of the development, for instance, to meet an evidenced local housing need. In such cases, an effective landscape scheme would be crucial to mitigate any harm. This proposed approach is then set out in ENV1(D). This proposition is considered to be a misrepresentation of national policy (NPPF Section 11), which does not set a general principle to refuse development proposals where there is landscape harm.

4.11.2 Paragraph 113 of the Framework refers to the need for criteria based policies in relation to proposals affecting protected wildlife or geodiversity sites or landscape areas, and that that protection should be commensurate with their status and gives the appropriate weight to their importance and contribution to wider networks. As currently drafted Gladman do not believe this landscape policy aligns with the Framework.

4.11.3 Gladman wish to point out that impact on the landscape is one factor that should be considered by the decision maker when determining any planning proposal and ultimately it is a balance of the harm of development against the benefits. It is only where the harm significantly and demonstrably outweighs the benefits that planning permission should be refused.

4.11.4 Reference is made in ENV1(A.iv) to the requirement for development proposals to avoid physical and visual coalescence between settlements. Gladman submit that new development can often be located in countryside gaps without leading to the physical or visual merging of settlements, eroding the sense of separation between them or resulting in the loss of openness and character.

4.11.5 Gladman also wish to question how the Council intends to consider the cumulative impact of development proposals on the quality of the landscape through the development management process.

12 March 2018 Page 316 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV10 ED110 Gary Stephen

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

ENV10 Renewable Energy and Low Carbon Development As currently drafted, paragraph B. places the onus on the applicant to demonstrate that generating energy to serve the development from low carbon technology is not appropriate. With regard to residential development, the Council should be mindful of the Government’s Ministerial Statement of 25 March 2015, which outlined a new approach to the setting of technical housing standards in England which states: “From the date the Deregulation Bill 2015 is given Royal Assent, local planning authorities and qualifying bodies preparing neighbourhood plans should not set in their emerging Local Plans, neighbourhood plans, or supplementary planning documents, any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings.”

It is therefore considered that the policy as drafted is not consistent with national policy.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV11 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object:

Supporting Documents:

Comment:

We support the existing content of policy ENV11 on design. However, we would request that additional reference to health and wellbeing is included in this policy. We suggest the following is added to section B: Promote and enable the take up of a healthy and active lifestyles and minimise any negative wellbeing impacts

12 March 2018 Page 317 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV11 ED108 Paige McCarthy

Organisation: Representing: Persimmon Homes

Support/Object:

Supporting Documents:

Comment:

Design Persimmon homes supports the general principles of the policy, but it needs to be offset by viability. The impact of adopting a higher quality of design should be considered as part of a viability assessment and local authorities will also need to consider impacts on affordability.

Overall conclusion As highlighted Persimmon Homes have significant concerns and objections to the draft policies as presented as well as the evidence provided in the justification of these policies.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV12 ED55 John O'Neill

Organisation: Representing: Environment Agency

Support/Object: Support

Supporting Documents:

Comment:

We support the inclusion of ENV12 Local Flood Risk Management.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV12 ED60A Emilie Carr

Organisation: Representing: Historic England

Support/Object: Object

Supporting Documents:

Comment:

Whilst ENV12 is strongly welcomed, in particular criteria ii) however, it would be helpful to include criteria regarding shopfronts and advertisements, if existing detailed policies are to be superseded. Shopfronts and advertisements are intrinsic to the success of town centres and the protection and enhancement of heritage assets, such as town centre Conservation Areas. Historic England would be very happy to advise on wording and agree these changes by Statement of Common Ground.

12 March 2018 Page 318 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV12 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

Reference is made to development in the district complying with the requirements of the Local Standards and Guidance for Surface Water Drainage in Northamptonshire prepared by the County Council. It is important to note that Anglian Water also has a surface water drainage policy relating to development/re-development within our company area which is available to view at the following address: http://www.anglianwater.co.uk/developers/surface-water-policy.aspx

Therefore we would suggest that Policy ENV12 should be amended as follows: ii) The Local Standards and Guidance for Surface Water Drainage in Northamptonshire. iii) Anglian Water’s Surface Drainage Policy

12 March 2018 Page 319 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED14 Martin Bagshaw

Organisation: Representing: John Martin & Associates Maidwell Hall School

Support/Object: Object

Supporting Documents:

Comment:

ENV2 – Special Landscape Areas – Objection is raised to the inclusion of proposed Policy ENV2 in the draft Local Plan Part 2. Although the draft plan (Paragraph 9.1.07) confirms that the local landscape designation of Special Landscape Areas has been defined since the first Northamptonshire County Structure Plan in 1990, the policy of the Special Landscape Areas designation was not subsequently incorporated into the WNJCS 2014.This would suggest that it was not considered appropriate/necessary or relevant for the policy designation to be retained.

Therefore in the absence of a strategic policy context for the proposed designation the principal justification for the proposed retention of the policy within the Local Plan Part 2 is that the adjacent adopted Stratford on Avon District Core Strategy includes such a Special Landscape Areas policy. However the policy circumstances in Stratford on Avon District are somewhat different in that the Stratford on Avon Core Strategy like the WNJCS provides a strategic policy framework.

Further justification for the proposed policy is also made with regard to the proposed inclusion of the Special Landscape Area policy in the emerging South Northants Local Plan Part 2. However that local plan is not yet adopted having only recently been subject of consultation on its Pre-submission draft and on which there is outstanding objection to the proposed inclusion of the SLA policy.

From consideration of the background report entitled Special Landscape Area Study it is noted that the village of Maidwell is situated adjacent to the Hemplow Hills, Cottesbrooke and Brington SLA. Within the assessment of this SLA it is noted that the following reference is made under Landscape Quality- Localised areas of agricultural intensification such as the edge of the SLA at Maidwell. The landform is the distinctive undulating ridge although lack of hedgerows and copses reduces distinctiveness that is consistent across the rest of the SLA. In this regard whilst it is acknowledged that there has been a proposed change to the eastern boundary of this SLA it is considered that should the SLA designation be retained that in the context of above assessment and the reference to the impact of agricultural intensification on the landscape around Maidwell the eastern boundary of the SLA should be redefined as the A508, therefore excluding all land to the east of that proposed boundary.

12 March 2018 Page 320 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED79D Paul Johnson

Organisation: Representing: Francis Jackson Homes

Support/Object: Object

Supporting Documents:

Comment:

Paragraph 113 of the NPPF states, “Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.”

Whilst Policy ENV1 sets out various specific landscape assessment criteria, policy ENV2 in relation to the elevated status SLA area and to which a higher level of protection is afforded, as drafted lacks any additional or specific criteria against which impact can be assessed.

The policy itself notes simply that if a positive contribution is made to the SLA, development will be supported, but if it is harmful, it will be resisted, but lacks any meaningful assessment methodology or criteria against which to measure and determine the impact in a structured, transparent and repeatable fashion.

Are these the same criteria as in policy ENV1, if so, this needs to be stated, or else different, additional or alternative criteria should be set out as envisaged by the NPPF. As drafted, we consider policy ENV2 in relation to the proposed SLA to be non-NPPF compliant as it lacks a criteria basis for assessment with regards to this specific area.

12 March 2018 Page 321 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED121 Paula Jones

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I object to the change of boundary and the removal of the eastern side of the Brampton Brook between Pitsford and Hanging Houghton and Lamport for the following reasons: 1. It is important that both sides of the Brampton valley are protected. The valley includes the National walking and cycling route known as the Brampton Valley Way and it is important that development of the valley is cohesive.

2. This eastern area represents the edges of the scarps of the Ironstone Uplands which have been defined as Rolling Ironstone Valley slopes in Northamptonshire Current Landscape Assessment. As such they share characteristics with the rest of the defined Special Landscape Area both within their geological structure, rolling aspect and wide vistas.

3. The area includes wide views of the Saxon Church of Brixworth especially as seen from Spratton, Cottesbrooke and Lamport / Hanging Houghton. These views are greatly valued by local residents as shown in local consultations which identified then as of much prized both in the Brixworth Local Plan and the earlier Brixworth Village Design Statement. Daventry DC prepared a Statement of Community Involvement (SCI) in May 2017. The Local Community of Brixworth has been consulted and shown that is values these views and wishes them to be protected. Inclusion in the Special Landscape Area will help this protection.

4. This area includes areas such as Clint Hill and the fields between Hanging Houghton immortalised by the Northamptonshire Poet “BB” (Denys Watkins-Pitsford) and in his writings including “The Story of the Pytchley Fox”. Northamptonshire should be proud of its Heritage and seek to enhance it.

I recommend that the A508 should be eastern boundary of the SLA to include Lamport, Hanging Houghton and Brixworth so that these valued views across the Brampton Valley and the steep valley scarps are within its boundaries.

12 March 2018 Page 322 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.12 ENV2 Special Landscape Areas 4.12.1 Policy ENV2 sets out the intention to designate some 41% of the District as being within ‘Special Landscape Areas’. Gladman would wish to raise concerns regarding the manner in which the Council intends to identify and protect these extensive areas of countryside. Policy ENV2 appears contrary to the Framework’s approach to the consideration of the natural environment within the planning system. Paragraph 113 of the Framework indicates that criteria based policies should be prepared, against which proposals on or affecting landscape areas will be judged. Furthermore, distinctions must be made within such polices between the hierarchy of designations based on their relative importance. The approach set out in ENV2 to identifying and protecting an extensive local landscape designation fails to include a clear criteria based approach to use within decision making or any reference to the special local landscape characteristics that the policy is seeking to manage through the planning system.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED135 Maureen Holliday

Organisation: Representing: Pitsford Parish Council

Support/Object:

Supporting Documents:

Comment:

3. We fully support the Brixworth representations on the SLA Boundary change around Brixworth and include the SLA area within our own Parish in our objections. Pitsford is currently in the process of drawing up a Neighbourhood Plan and the SLA area is a important consideration in this process.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV2 ED155 Gary Taylor

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I would like the areas already designated to continue being protected.

12 March 2018 Page 323 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

We wish to see preservation of a Green Wedge between the parish, and the built up urban areas of Rugby in order to protect the identity, character and setting of the parish, and would like this added to the Local Plan. The Parish Council wish to see this policy wording revised as it is the fringe area with Rugby and the proposed Garden Village at Lodge Farm which threaten the settlements of Barby and Onley. We wish to see some facility for removal of Permitted Development rights and Q class development on Green Wedge land. At the moment Barns can be built under Permitted Development rights, and then converted at a later date to domestic dwellings under Q class legislation which allows development in open countryside by stealth.

12 March 2018 Page 324 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED61 Mark Chant

Organisation: Representing: Northamptonshire County Council

Support/Object:

Supporting Documents:

Comment:

1. The County Council’s representations on the Draft Plan are set out below.

The Council has a concern as to how the Part 2 Plan is addressing issues around the Northampton Related Development Area (NRDA) identified in the adopted Part 1 Local Plan for West Northamptonshire. We also have some concerns about the wording of the proposals for a number of site specific policies, and have proposed amendments to the policy wording in some cases. There are also some further technical comments which are set out in this response.

The Plan and its relationship to the Northampton and the Northampton Related Development Area 2. The issue of providing new houses in the Northampton area is one that was not really resolved through the adoption of the West Northamptonshire Part 1 Local Plan. Questions of whether the NRDA was correctly defined and whether the amount of dwellings to be provided within the area were deliverable have not gone away with the Part 1 adoption and it is now the responsibility of the three Part 2 Local Plans to resolve this on the basis that a review of the Part 1 Plan is not formally timetabled.

3. The Draft Plan does not resolve the issue effectively, assuming instead that everything will come right in the end in respect of the deliverability of Northampton’s urban capacity sites and the NRDA’s Sustainable Urban Extensions. The Daventry Part 2 Draft Plan basically not only ignores the NRDA but also does not seem to want to acknowledge that any NRDA development is taking place. For example the locations of NRDA committed development are not identified on the Policies Map (in sharp contrast to how the Part 2 Plan has treated commitments and Sustainable Urban Extensions (SUEs) around Daventry town). This makes for an inaccurate and thus unsound Policies Map.

The proposed green wedge 4. Despite the known issues and implications around the delivery of the NRDA provision figure (for example the appeal decision at Welford Road in Boughton parish) as well as the accepted need for a review at some stage of the West Northamptonshire Joint Core Strategy (WNJCS), the Part 2 Plan seeks to draw a green wedge corset around all the land on the Northampton fringe in Daventry district that is not within the NRDA. However the explicit and long term purpose of the green wedge designations is not understood other than is it to simply continue the previous green wedge and rural access designations from the 1997 Local Plan to the Part 2 Plan?

5. However far greater areas are now covered to the extent that there would now be a green wedge designation around the whole of the Northampton fringe in Daventry district (other than beyond the Northampton North SUE). This would therefore appear to make this more of a structural designation rather than the continuation of a local designation. Indeed in relation to the Moulton Neighbourhood Plan DDC argued that the green wedge in the adopted 1997 Daventry Local Plan was a strategic overarching policy (and this was for a less extensive designation than is now proposed).

6. This greater than a local designation proposed for inclusion in the Part 2 Plan thus begs the question of whether the principles of this designation should actually have been through the Part 1 Core Strategy process rather than being picked up at the Part 2 stage. The County Council is of the view that because of the extensiveness of the designated area this should have been done. This would also have allowed the West Northamptonshire area as a whole to have considered green wedges. South Northamptonshire are not including green wedges in their own Part 2 Plan and this alone weakens the concept- why are there green wedges in one part of the West Northamptonshire Plan but not in another? The County Council therefore considers that the Part 2 Plan should not include a green

12 March 2018 Page 325 of 399 wedge designation of this scale.

7. Notwithstanding the above, it is also difficult for the County Council to understand what the designation actually seeks to achieve that is not already achieved through the open countryside policy. Paragraph 9.2.03 states that the emphasis for the green wedge policy ENV3 is to ensure that the areas are kept predominantly open and to prevent coalescence but this is achieved through the open countryside policy anyway. This seems to lead to a having a designation that doesn’t actually provide a stronger protection but will nevertheless be seen by those unfamiliar with the planning system as providing that stronger protection and this is therefore not a sound approach to take.

The future growth of Northampton and the green wedge 8. The Part 1 Plan was adopted in 2014. The Part 1 and 2 Plans have plan periods to 2029. Both of this points to the policies of the Part 1 Plan starting to need to be considered for a review under any circumstances. However as a growing location and furthermore one that will be a location for growth within the Oxford-Cambridge Arc, there is an increasing imperative to review the quantum of growth and the housing and employment development needs for Northampton that flow from this. The revision to the policy framework could be through a formal review of the Part 1 Plan, some new non-statutory plan that will need to have a mechanism for then being incorporated into a statutory plan at the district level, or through the proposed Strategic Statutory Spatial Plan/Plans for the central section of the Oxford-Cambridge Arc as recommended by the National Infrastructure Commission.

9. What this growth will mean is that areas will need to be identified for new development around Northampton in the next few years regardless of whether the provision for Northampton as set out in the Part 1 Plan can be delivered in the existing urban area and SUEs, or not. On this basis it is likely that significant parts of the proposed green wedges will not endure unless there will be no long term growth of the Northampton urban area further into Daventry district, which is exceptionally unlikely especially with the proposed Northampton Northern Orbital Route and Moulton Park Spur being proposed in this area.

10. It is noted that the second element of Policy ENV3 states that the Council will support proposals that contribute towards increased public access to, and enjoyment of, the green wedges, particularly from the Sustainable Urban Extensions in the NRDA. It is uncertain about how this encouragement of public access into these open countryside areas would work but if it was achieved, this could also make it more of an issue to allocate such areas in the future to meet the growth needs of Northampton because local residents will have been encouraged to use these areas and would not support their use to accommodate the growth of Northampton. Amendments sought to the Part 2 Plan

11. The Plan should take a more realistic view in relation to the growth of Northampton. It should: - Identify the SUEs allocated through the Part 1 Plan along with committed residential development on the Policies Map. - Abandon either the green wedge designations or at least the blanket approach to it by a more selective drawing of the boundaries but only if a rigorous assessment of why this is needed beyond an open countryside designation and is to endure long term. The designation were it to continue should also not apply in relation to settlements that are already part of the contiguous urban area of Northampton. - Provide clarity on how housing provision linked to the NRDA should be met in the plan area if there was to be a shortfall in the implementation of new housing within the NRDA. This should ideally be through allocating sites for development, even if only as reserve sites.

12 March 2018 Page 326 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED66 Giles Krempels

Organisation: Representing:

Support/Object:

Supporting Documents: Map

Comment:

Re my land on the north side of Boughton Lane, Boughton Green, Northampton - Grid ref 47654E 265464N

It has been brought to my attention by my neighbours that you are endeavouring to restrict the use of my land to some form of greenbelt.

I am wondering why you have not contacted me to advise me of such matters as it would obviously affect the value of my land considerably. I am obviously writing to object to you taking this course of action:

1. This is discriminatory 2. It affects my future use for the land 3. It would immediately down value it 4. There is no explanation as to why any other fields in this vicinity should not be given the same status, i.e. around Boughton or Moulton

Could you please therefore answer the following, am I correct in what I have heard and secondly why are trying to carry out such an action on private property without the knowledge of the owner.

I have asked my planning consultant to write to you professional and he will be putting forward his professional responses to your actions in the next few days.

Is the deadline of Friday 26th January 2018 is an actual requirement? Therefore could you please advise me that you will accept his advices as they will be late to this unbeknown deadline.

12 March 2018 Page 327 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED77A, ED77B Peter & Susan Krempels

Organisation: Representing:

Support/Object:

Supporting Documents: ED77C Map

Comment:

Letter dated 26 January 2018 We have just found out that you are seeking designation as a Green Wedge for 90% of our farm at Moulton Mill. We are very surprised that you have not advised me of such as it is obviously very detrimental to my holding.

We wish to strongly object on the following grounds: 1. It is discriminatory 2. It restricts our land use and devalues it 3. It limits the development around Northampton. Therefore is limiting Northampton's growth in the Daventry District area. This would be at the expense of other areas of Northampton where further expansion would have to take up the slack caused by limitation 4. It appears that Daventry District is requiring to carry out controls of land that is not in the remit of other areas surrounding Northampton. Hence is creating disadvantage to the development of Northampton generally and particularly in the Daventry District area. Therefore, it is disadvantageous to Northampton and its people.

If there is to be green land then it needs to be through out on a countrywide basis and not be selective or disadvantageous to the Daventry District area around Northampton. It is land control that will be a detriment to the county and restrict its proper and formulated expansion which is particularly important between Northampton and Kettering and the Northampton link to the A14 which provides the finest links between east and west of our country. We look forward to receiving your comments regarding the above points. Letter dated 26th January 2018 As stated in my rushed email yesterday, my wife and I as stakeholders of land surrounding Moulton Mill Farm and my son's land nearby were not informed of your intentions to form a Green Wedge which our land would be part of. We have now had the opportunity to discuss the implications of your wishes and now wish to strongly object to them on more formal grounds than was the case in our previous letter (email). We consider your plans completely in conflict with Northamptonshire/Northampton's development are completely in conflict with the strategy sort in part 1 of your plan. And will harm particularly this area of Northampton but also the town's general growth and planned expansion. As you are aware in 2014 the West Northants Core Strategy plan was adopted which prioritised the basis of Part 1 of the development plan in which pointed the way forward to part II of the plan where the local plan would deal with the detail i.e. part II which we are now dealing with. Apparently all part II plans are expected to accord and take account of Part 1, otherwise part 1 should be ? Reviewed. Northampton is a large urban expanding well located area and hence has an immense influence to other areas (authorities) particularly therefore to its housing needs - Northampton is trapped with the tight boundaries that control it. Apparently the solution in Part 1 of the West Northants Core Strategy plan (Part 1) was to identify a Northampton Related Development Area. This specifically identifies the development of a large urban area where it meets the boundaries of its jurisdiction, stating: - that it has a duty of co-operation - refined over ? - formation of flexible plans - to follow such needed expansion Where DDC Part 2 wish to impost stringent solid barriers at its boundaries - through the Green Wedge which conflicts with the strategy of Part 1 Plan, this must therefore be unsound in its conclusions. Apparently these matters were chewed over by inspector Nigel Payne who reviewed the Cherwell District Plan who reviewed the Cherwell District Plan which also has a "green buffer belt" - it was removed as he considered that the plan (WNJCS part 1) provided a "robust rural areas policy framework and that a green buffer would introduce unnecessary constraint and was therefore unjustified. We agree with that summary and feel that policies in part 2 plans are sufficient enough yet flexible enough for rural areas to be well protected. The Green Wedge, being completely unnecessary and a hindrance and we would back the Cherwell's inspector's views. 5 year housing supply - Northampton BC According to what we have read and been told by consultants, NBC has not been able to fulfil its 5 year housing supply needs. Apparently this was confirmed in a cabinet report in October 2016. In fact a shortfall of over 500 houses is calculated.

12 March 2018 Page 328 of 399 Northampton is in the control of a number of restraints - River, motorway, flooding, overloaded highway particularly A43 to A14, large areas of Althorp Estate. As stated in my previous correspondence the Green Wedge will block the entire development of North Northampton where sound growth can be directed without the constraints imposed in other areas. It has also been brought to my attention that the matters we have raised also have been well thought through by South Northants in its local plan (draft 2) whose very flexible policy, taking matters into account as they differ at the time and acting according to these conditions and requirement of the time. A policy that allows for change and ? positive rather than negative approach to planning matters. We may well have missed this but it appears you have not taken note of the North Northampton Orbital Route which we understand is now agreed in principle and the route also. Surely this will change and indeed improve to whole perspective of the area and the view of business and developers to take advantage of the new opportunities that will arise because of its formulation. As we are well aware developers will gladly support a new road development with ? communication if they can develop within the vicinity of these roads. And in this case a natural extension to Northampton creating speedy and much needed housing/industry/business and a free highway orbital route. Of course if the Green Wedge is created then any development would need to go further and further from the town and its services, creating increased transport cars lorries, longer journey to and from work, more congestion - the opposite to what orbital route was trying to lessen. Also it would still harm the villages and communities around Northampton and bring into play further outlying villages, such as Sywell, Holcot, Harlestone etc. etc. We are not advocating all land should have development but development can be of may varieties and if done well can enhance an area. Northampton is in need of some well thought out development and the last area around Moulton/Boughton could provide a natural/?/local site for those wishing to enjoy the countryside. In conclusion 1. The blanket Green Wedge are not prepared positively and do not accord with Part 2. 2. That the Green Wedge would put unnecessary constraints on planning and future development. 3. The report's conclusions leave all surrounding authorities to Northampton open for speculative and unplanned development. 4. The orbital route has not been considered and would change many of the fundamentals that DDC plans state would benefit by these plans 5. The Green Wedge would restrict infrastructure development 6. Would stop/interfere with flexible thought out economical development A more flexible and thought out approach to Northampton and its development would enhance the town and its needs.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED88 Daniel Hatcher

Organisation: Representing: Rosconn Strategic Land

Support/Object:

Supporting Documents:

Comment:

Policy ENV3: Green Wedge is considered unnecessary as there are other policies within the West Northamptonshire Joint Core Strategy Local Plan (Part 1) and Emerging Local Plan Part 2 that protect the countryside from inappropriate development. Paragraph 17 of the NPPF outlines core planning principles which underpin the plan making process. Bullet point 5 requires recognition to be given to the intrinsic character and beauty of the countryside and support thriving rural communities within it. It does not seek to differentiate between different types of countryside that warrant different levels of protection. Notwithstanding, it is noted that policy ENV3 is considered to be overly restrictive more so that the previous Policy EN10 of the Daventry District Local Plan.

12 March 2018 Page 329 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED90 Peter Bateman

Organisation: Representing: Framptons Jeyes Family (The Holly Lodge Farming Partnership)

Support/Object:

Supporting Documents: Appendices include maps, Cherwell Local Plan Examination report, NBC Cabinet report

Comment:

Introduction Framptons act the Holly Lodge Farming Partnership (hereafter referred to as 'the Clients'). Framptons have been instructed to submit the accompanying representation which in short object to DDEC Part II Plan as currently drafted. Specifically, the objection relates to the proposed introduction of the blanket Green Wedge policy advocated by draft Policy ENV5. The proposed green wedge covers the Holly Lodge Farming Partnership land interest and is considered unjustified, unnecessary and in conflict with the strategy advocated by the Part I Plan. For the avoidance of doubt the land in question is identified in red on the map enclosed at the end of this letter (Appendix 1). It forms a holding of around 25 ha.

Policy background and ground of objection The West Northamptonshire Joint Core Strategy (WNJCS) was adopted in December 2014 and forms the Part I Development Plan providing the strategic framework for planning decisions across the administrative areas of Daventry District along with South Northants District and Northampton Borough. At the point that the Part I Plan was adopted there is a clear indication that a number of more detailed planning matters will be dealt with through a series of Part II Local Plans prepared by individual partner Councils of which the DDC Part II Plan subject of this consultation is one such plan.

All Development Plans are expected to accord with paragraph 182 of the Framework which effectively require the Plan to be prepared in accordance with the Tests of Soundness and the relevant legal tests. Paragraph 182 of the Framework sets out four tests that any plan must meet, namely that it is - positively prepared, justified, effective, and consistent with national policy.

Part II Plans which sit under a strategic Part I Plan must also be consistent with the spatial strategy advocated by the Part I Plan otherwise the Part I Plan should be reviewed. This is particularly relevant in a planning situation where a single large urban area (such as Northampton) has a substantial housing need and sphere of influence to neighbouring authority land in its housing market area, but cannot readily extend to meet its needs due to limitations afforded by the administrative boundaries being tightly drawn. The solution in the case of the West Northants Core Strategy (the Part I Plan) was the identification of the Northampton Related Development Area or 'NRDA', which provides a strategic policy framework for development of the larger urban area where it has interface with the surrounding local authorities. It is envisaged by Central Government that precise detail of cross border planning matters be agreed via the Duty to Cooperate and refined over time via review of the plans and formation of flexible policies that are capable of responding, often at short notice, to changes in circumstances.

The current DDC consultation document appears to suggest the approach favoured for addressing issues of delivery within the NRDA by DDC is to impose a blanket restriction on development through Green Wedges on land to the north of Northampton as detailed by draft policy ENV5. It is submitted that such a policy fails to accord with the strategy of the Part I Plan and is therefore unsound.

The WNJCS (the Part I Plan) was inspected by Local Plan Inspector Nigel Payne in 2013 and 2014. The same inspector also reviewed the neighbouring Cherwell District Local Plan context a draft 'green buffer' policy effectively restricted development in the same manner as the DDC's Green Wedge proposes in its Part 1 Plan of June 2014. This policy was subsequently removed as the same Local Plan Inspector considered (see paragraphs 101 to 104 at Appendix 2) that there were sufficient policies in the plan that provided a robust rural areas policy framework and that a Green Buffer would introduce unnecessary constraint and was therefore unjustified. It is submitted that the generic countryside

12 March 2018 Page 330 of 399 protection policies in the Part I WMJCS Plan and others in the draft DDC Part II Plan provide sufficient planning policy control for the rural areas and a specific green wedge policy is simply unnecessary duplication as was the conclusion reached in neighbouring Cherwell.

It is submitted that since 2016 Northampton Borough Council has not been able to demonstrate a satisfactory supply of housing land. This was acknowledged as far back as October 2016 in a cabinet report (Wednesday, 19 October 2016) relating to the 5 year land supply in Northampton Borough. The assessment identified that a 5 year supply for the NRDA cannot be demonstrated. It identifies the capacity to deliver 3.1 years of housing need. This equates to a shortfall of 5,087 dwellings. This can be found at Appendix 3 and nothing fundamental has altered since October 2016, in part due to the constraints surrounding Northampton such as the M1, River Nene Flood Zones, A43 Capacity, the Althorp Estate and so forth. The introduction of a blanket policy around the entirety of the north of Northampton limits where growth can be directed which will not deliver sustainable development.

In an instance where the housing policies of the Development Plan cease to apply due to paragraph 47 being applicable the land it is widely accepted villages in Daventry District (as they are also in South Northamptonshire and Wellingborough) abutting the Northampton Related Area (NRDA) may be vulnerable to appeal. It is submitted that inclusion of a flexible policy, such as that provided by the South Northants Local Plan Draft II Local Plan to support the principle of reviewing the situation and taking action depending on the evidence available at the particular moment in time, is a pragmatic planning policy approach and one which responds to the Framework's requirement for planning authorities to plan positively. It is submitted that the land in control of my clients may provide a more robust strategy for ensuring control is retained over development possibly by being allocated or safeguarded as a site in DDC that could be used to assist meeting the proportion of NBC's housing need met outside the administrative area of the Borough.

My Client also notes that the proposals map does not shown the NRDA boundary (an adopted part of the Part I Plan) or land required for the safeguarding of the north west bypass/Northampton orbital route. The route of the northwest bypass is included at Appendix 4 of these submissions. Delivery of needed infrastructure will in time change the capacity of the northern edge of Northampton for development as well as alter the physical character of the area. Now that the route is set an opportunity exists to utilise the new development capacity and respond to the character of the area by making use of logical infill development which can add much needed housing and employment. Additional housing in the immediate vicinity of the route will aid the viability due to developer contributions.

It is clear under-delivery is being experienced and there is limited opportunity for the DDC areas abutting the NRDA to deliver sustainable patterns of development due to artificial green wedge policy which provides an unjustified and unduly restrictive blanket policy. A blanket restrictive policy is not a positive approach and will direct development to areas beyond the 'protected' arbitrary wedge to locations that are, by their nature, less sustainable. This will increase the length of car journeys, contributing to congestion and pollution.

Conclusion In conclusion, it is submitted that the approach advocated by the draft Part II Local Plan specifically policy ENV5 and its large blanket areas of Green Wedge, are not positively prepared and are considered 'unsound' if not amended in future iterations off the plan. There is a significant shortfall against the housing requirements of the NRDA. This shortfall leaves DDC, SNC and Wellingborough open to speculative development around the edge of Northampton. This position is unlikely to change unless criteria based policy approach is adopted which can flexibly respond to development.

The approach of imposing a blanket 'green wedge' to the north of Northampton restricts options for future housing development, the delivery of critical infrastructure and could create the unsustainable patterns of development. It is recommended a more flexible approach be provide via a suitably worded policy that safeguards land in DDC to come forward in instances where additional land is needed subject to the need being proven by robust evidence.

12 March 2018 Page 331 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED91E Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents: Attached - Heritage Note, Landscape & Visual Constraints and Opportunities Report

Comment:

Policy ENV3 - Green Wedge We note that Policy ENV3 seeks to protect the designated areas of Green Wedge in order to safeguard the identity, character and setting of settlements within the areas that fringe Daventry and Northampton.

Whilst we do not object to principle of the policy, it is currently insufficiently flexible to allow for provision of some level of development adjacent to the existing urban area to meet Northampton’s needs during the Plan period. The policy also fails to take account of the emerging North-west bypass/Northampton Orbital.

In light of the above, we consider that the Part 2 Plan should include a Green Wedge Review to consider the policy designation in the context of the NRDA housing supply shortfall and the route of the Northampton Orbital.

We note that the land which is in our client’s interest, ‘Land South of Moulton Lane, Boughton’ (HELAA ref. 108), is located within an area of Green Wedge as set out in the Daventry Landscape Character Assessment (May 2017). However, this assessment did not consider the implications of either the recognised shortfall in housing provision in the NRDA or the proposed routing of the proposed Northampton North West Bypass on the existing areas of Green Wedge. Areas of Green Wedge are not Green Belt and should be subject to review taking account of identified housing requirements.

As demonstrated by the site masterplan (see attached) there is the opportunity to accommodate development in this location which would safeguard the settlement’s identity whilst allowing for further growth in a sustainable location adjoining Northampton. To support the proposed allocation of ‘Land South of Moulton Lane, Boughton’ an assessment has been undertaken to consider potential landscape and visual impacts, including potential impact upon the Green Wedge (see ‘Landscape and Visual Constraints and Opportunities Report’ attached). The report confirms that, with the implementation of an appropriate landscape strategy, the site can be developed whilst maintaining the aims of the Green Wedge policy.

12 March 2018 Page 332 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED110 Gary Stephen

Organisation: Representing: Marrons Planning Hallam Land Management

Support/Object: Object

Supporting Documents:

Comment:

ENV3 – Green Wedge It is not clear how the Council has arrived at and justified the precise boundaries proposed for the Green Wedge policy. The policy as drafted currently is more restrictive than national Green Belt policy. Green Belt reviews typically look at the form, function and purposes of land within it or land proposed to be Green Belt. A similar approach should be undertaken to examine the suitability of any Green Wedge designation. Furthermore, the stated intentions of the Green Wedge policy are to afford long term protection to the settlements around Daventry and Northampton. Whilst this is a laudable aim to cover so much area with a green wedge, to be secured for the long term, also hinders further potential necessary growth in these areas when it comes to plan review and in the long term.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED124B Val Coleby

Organisation: Representing: Berrys Vanderbilt Strategic Ltd

Support/Object: Support

Supporting Documents:

Comment:

We welcome the opportunity to submit representations on the Daventry Settlements and Countryside Local Plan Part 2 on behalf of Vanderbilt Strategic Ltd.

We are responding in support of the revision to the Green Wedge notation which in particular removes the Green Wedge designation from the site known as Overstone Farm, Sywell Road.

In the supporting text to the policy the purpose of the Green Wedge is defined as a policy tool to protect the identity and setting of villages and preventing the coalescence of settlements by keeping the areas between settlements predominantly open.

In addition the supporting text advises that the proximity of the Green Wedges to the urban areas means that they are also used for informal recreation and as part of the wider green infrastructure network; they also fulfil a biodiversity function.

We support the removal of the Green Wedge notation from the Overstone Farm site which recognises that the site is not required to be retained as predominantly open land for the purposes of; protecting the setting of a village, preventing coalescence of settlements, or as an area of informal recreation or to fulfil a biodiversity function.

The removal of the notation is the appropriate policy response given the location of the site which is surrounded on three sites by the Northampton North SUE and the Northampton Related Development Area. The site is also already partly developed by a range of buildings including residential and offices.

12 March 2018 Page 333 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED126C, ED126D Sebastian Charles

Organisation: Representing: Aardvark Planning Law

Support/Object: Object

Supporting Documents: Map of consented scheme (ED126E) Moulton inset map (ED126F) Access Review (ED126G) Detailed plan (ED126H)

Comment:

Landscape The Council’s own landscape character assessment fails to identify any special character for the Land behind the Nest, which is comprised in Landscape Character Area 4, and only notes that “further development around these settlements should be resisted particularly where fields, hedgerow boundaries and wooded areas contribute to the physical separation and the setting of the settlements.”. However, the hedgerow boundary of the adjacent Hallam Development is weak and performs no such function. There is no justification in landscape terms of the current extent of the extent of ENV 3 green wedge. Whilst the principle of the Green Wedge is supported, the extent of the Green Wedge and including the Nest and Land Behind the Nest is not justified and is objected to. We propose that the boundary of the Green Wedge is redrawn to exclude both the Nest and Land behind the Nest.

We would propose that extensive landscaping to the western boundary of this site would create a defensible future limit for development and provide a transition through better landscape quality further west.

12 March 2018 Page 334 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED78A Justin Gartland

Organisation: Representing: Lichfields Roundhill Northampton Limited

Support/Object:

Supporting Documents: Attached - site plan ED78B - Moulton Heights Design and Access Statement

Comment:

The Part 2 Plan proposes to designate land north of Moulton, west of the A43 as Green Wedge. This is identified on the District-Wide Policies Map and specifically the Northampton Fringe Inset Map. The proposed Green Wedge allocation north of Moulton is not supported by any credible supporting evidence. Contrary to the Green Wedge allocations in the areas to the south of Moulton, which seek to separate the village from Northampton, the proposed allocation to the north performs no function that can be described as remotely consistent with the function of a Green Wedge. The proposed Green Wedge represents an unjustifiably restrictive policy approach and does not constitute positive planning for the much needed development within the area.

Within section 9.2.03 of the emerging Local Plan it states: “the emphasis of Policy ENV3 is to ensure that the areas are kept predominantly open and to prevent coalescence”. For reference, the core principles of Policy ENV3 are as follows:

ENV3 - Green Wedge Draft Daventry District Settlements and Countryside (Part 2) Local Plan, Page 97. A. The Council will protect the designated areas of Green Wedge in order to protect the identity, character and setting of settlements within the areas that fringe Daventry and Northampton. Proposals within the Green Wedges will be required to: i. Maintain the physical and visual separation between settlements; and ii. Maintain the openness around settlements and their settings. iii. Maintain the predominantly open and green character of the Green Wedges; and iv. Preserve or enhance the character, visual amenity and biodiversity value of the Green Wedges; and B. The Council will support proposals that contribute towards increased public access to, and enjoyment of, the Green Wedges, particularly from the Sustainable Urban Extensions in the Northampton Related Development Area, providing they are compatible with i) to iv) above.

With respect to items A and B of the emerging Local Plan GW Policy ENV3, the proposed designation of land north of Moulton is not congruous with the fundamental functions of ENV3. This is because:

A: i. Maintain the physical and visual separation between settlements; and • The proposed Northampton Northern Orbital Route (NNOR) is a highway commitment by the strategic highway authority for an orbital route to north Northampton. The NNOR is supported and endorsed by the County Councils Government bid for Housing Infrastructure Funding in recognition of the role the NNOR will contribute to in unlocking land for housing development. • Two NNOR options (7 & 8), run through the proposed Green Wedge north of Moulton with infrastructure junctions providing access to the A43, Moulton, Moulton Road, Pitsford and a spur to Moulton Park. Construction of either option introduces a significant new highway into the current rural landscape with the strategic aim of improving connectivity and opportunities for development. The significant scale of construction of either option diminishes the physical and visual separation between settlements north of Northampton and undermines this function of the GW.

A: ii. Maintain the openness around settlements and their settings. • To the south of Moulton, the proposed GW ensures that further development is restricted along the west A43 and Northampton Lane to maintain a visual and physical separation between the village and wider conurbation of Northampton. The function of the GW south of Moulton, which is approximately 1km in width at its widest, would be appropriate to maintain the narrow area of open landscape and distinction between settlements. • The Village of Holcot lies approx. 3km to the north and is neither visually or physically connected to Moulton. The GW between these settlements does not extend to the full distance between these villages and will eventually

12 March 2018 Page 335 of 399 contain the NNOR, a strategic highway proposed to connect settlements and facilitate development. In this location the proposed GW has questionable value and integrity to this function of the policy. • In contrast land between Moulton and Overstone is not proposed as GW and forms a strategic development site. Development of this site will significantly reduce the open setting on this arterial route into Northamptonshire, extend the urban footprint in a linear form north and minimise the separation of settlements from one another. Moulton Heights in the context of potential development along the A43 provides a strong opportunity to round off development north of Moulton and the A43 whilst actively addressing the wider impacts of the NNOR. • In consideration of the development land adjacent to the A43 and NNOR the proposed GW north of Moulton fails to address the wider impacts to openness.

A: iii. Maintain the predominantly open and green character of the Green Wedges; and • On review of the proposed GW designation there appears logic to the setting of this policy in a westerly direction from Moulton. In this location the southern boundary of the GW is defined by the northern extents of Northampton and the northern boundary of the GW is defined by a wooded stream corridor. The northern boundary forms a recognisable and defensible edge which contains a distinct landscape character and GW within the wider setting. • The GW boundary surrounding Overstone to the east of Moulton is additionally defined by strong, recognisable and defensible edges within the wider landscape which additionally contain a distinct landscape character of woodland belts, water courses and designed landscapes. • In both the east and westerly areas, the proposed GW seeks to retain and protect recognisable and visually defined areas of landscape with a distinct character. • To the north of Moulton, the proposed GW boundary is defined by the A43, Holcot Road and an arbitrary field boundary to the north. Selection of these boundaries does not follow the precedent of defining the GW edge with recognisable and defensible edges or distinct landscape character within the wider setting. In the GW identified to the north of Moulton there is limited landscape character difference either side of the proposed boundary. The GW extents in this location appear largely more defined by existing highways, which have limited credibility in terms of a landscape character or a significant feature which contributes to the setting of Moulton or Northampton as a whole.

A: iv. Preserve or enhance the character, visual amenity and biodiversity value of the Green Wedges • Land to the north of Moulton proposed for GW is limited in its distinction from other land north of Northampton between Overstone and Pitsford. Land between Overstone and Pitsford consists predominantly of large agricultural fields bounded by hedgerows with some hedgerow trees. There is limited evidence and credibility in landscape character terms that the proposed GW to the north of Moulton has any distinct or unique features requiring preservation or enhancement. The proposed GW fields appear intensively managed for agriculture, therefore will have limited biodiversity or habitat variety. It appears that the proposed GW is defined by highways and arbitrary field boundaries rather than landscape features, character or visual amenity. In reflection of this core policy principle there is limited integrity to the proposed GW north of Moulton or consistency to approach of defining the GW location or extent.

B. The Council will support proposals that contribute towards increased public access to, and enjoyment of, the Green Wedges, particularly from the Sustainable Urban Extensions in the Northampton Related Development Area, providing they are compatible with i) to iv) above. • As detailed above, RNL submitted an application for planning permission on land north of Moulton in December 2014. This application at Moulton Heights (MH) included for a significant area of undeveloped land north of the village. As described above, future applications will adhere to this design philosophy. The MH proposals included significant offers of parkland, woodland, tree planting, aquatic habitat, hedgerow planting and retention. The significant open space contribution provides opportunities for sustainable travel, habitat creation, biodiversity gain in addition to a wider recreation offer and public access to open space. Any MH masterplan will embrace the proposed NNOR and sensitively integrate this major transport infrastructure into the development fabric through woodland, tree and hedgerow planting. Landscape proposals further seek to create a strong and recognisable landscape boundary with an edge defined by landscape features and not transport infrastructure. By introducing a positive green edge MH maintains a physical and visual separation from settlement to the north and a sense of openness to Moulton via the POS. • The Inspectors report on the examination into the West Northamptonshire Joint Core Strategy Local Plan, Issue 9 – Northampton North (policy N3), dated 2nd October 2014, noted the following with regard to land associated with Moulton Heights: ‘The area to the north of Moulton that has been put forward as an alternative SUE location is more detached from the existing urban area and of medium/high landscape sensitivity. It would also result in a greater erosion of the gaps

12 March 2018 Page 336 of 399 between settlements in the area to the overall detriment of the character and appearance of the locality on this side of the town.’

In this instance whilst the Inspector raises concerns about landscape sensitivity and encroachment, this was firstly part of a comparison exercise with the land east of A43 which he ultimately allocated as an extension to the North Northampton SUE under Policy N3 and does not make the proposed GW setting logical or a considered response to existing landscape character or features and more a poor reaction to restrict development. The Inspector’s conclusion was also founded on an unsupportable (in landscape and planning terms) pre-requisite that any NRDA allocation had to physically attach to either an existing or allocated Northampton urban area. Again, it is important to consider the context of the NNOR which will erode landscape quality and perceived gaps. In this location the NNOR is proposed as a strategic catalyst and facilitator of development, MH therefore represents an opportunity to balance housing undersupply with significant landscape enhancements to integrate the NNOR and A43 development within the context of north Northampton.

In summary, there appears an inconsistency of approach to defining the proposed Green Wedge to the north of Moulton. The GW proposals north of Moulton appear not to consider the core ENV3 policy principles, existing landscape character or the wider impacts of the proposed NNOR or potential development east of the A43. Following our initial review of the GW north of Moulton we believe the proposed extension in this location has limited credibility.

The land to the north of Moulton, ‘Moulton Heights’, is an ideal site to bring forward for development and contribute towards the critical housing needs of Northampton as identified above. There is no clear justification to protect the landscape of this site as it is not proposed to be identified as a special landscape area and development of the land would not result in a merge between settlements. The area not should be allocated as Green Wedge due to the lack of credible evidence.

The presence of the Green Wedge designation north of Moulton, inexplicably coincidental with the land in our client’s control, renders the Part 2 Plan unsound in its current form.

Moulton Neighbourhood Development Plan Moulton has an adopted Neighbourhood Development Plan (NDP). There is a lack of consistency between the draft Part 2 Plan and the Moulton Neighbourhood Development Plan.

RNL participated in the consultation process during the preparation of the NDP and had submitted the planning application for the Moulton Heights development as described above as well as having promoted, with the Parish Council’s support, 2000 dwellings as part of the NRDA allocation within the Part 1 Plan (WNJCS). The NDP was prepared with these two development promotions as a context. After extensive consultation during the preparation of the NDP, the development of the land to the north of the village is now anticipated and separation of new development from the existing northern edge of the village’s built form required.

All proposals of RNL at north Moulton include the dedication of land south of proposed development as land to accommodate open space, open recreational land, leisure centre or education development, which is considered to be wholly consistent with the requirements of the adopted NDP.

We object to the designation of the Green Wedge outwith the land identified as Local Green Space within the NDP which seeks to preserve important open spaces and prevent coalescence with Northampton.

Service Provision Within the emerging Part 2 Plan, draft Policy RA1 identifies Moulton as a Primary Service Village. The policy acknowledges that development outside the defined confines will be acceptable where it is demonstrated that it is required to meet an identified local need. While this policy reference is supported, it is clear that no consideration has been given in designating land use allocations in the Part 2 Plan to strategic community infrastructure requirements. There is a clear issue of Education and a Leisure Centre provision for the east of Daventry district associated with the level of existing and planned development for this part of the North Northampton and no opportunity has been taken to identify a site for either of these uses, for example, within the Draft Local Plan. Further, consideration has not been given to the need for other land uses, which would need to be provided to support the level of development already permitted and allocated in this area. This includes: retail, employment,

12 March 2018 Page 337 of 399 strategic transport intermodal facilities and hotel accommodation, for example.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.13 ENV3 Green Wedge 4.13.1 Policy ENV3 proposes an approach to designating areas as ‘green wedges’. The areas that have been identified as being within the proposed green wedge are extensive in nature. It is therefore essential that any associated policies recognise that proposals for sustainable development within these areas can often be accommodated without compromising the overall function and purpose of such designations.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED136 Sebastian & Sgoluppi Jodie

Organisation: Representing:

Support/Object: object

Supporting Documents:

Comment:

We have only just found out today that you are proposing to designation our property as a Green Wedge. We are somewhat surprised that you have not considered it necessary to advise us of this considering it is extremely detrimental to my property and family.

We object in the strongest terms to the proposal on the following grounds: 1. It is discriminatory 2. It devalues and restricts the use of our land 3. It places limits on the development around Northampton, therefore limiting the town’s growth in the area. This would be at the expense of other areas of Northampton where further expansion would have to take up the slack. 4. Daventry District is appears to be requiring to carry out controls of land that is not in the remit of other areas surrounding Northampton therefore creating disadvantage to the development of Northampton generally and particularly in Daventry District area. This would be disadvantageous to the town and its residents.

If there is to be green land it needs to be considered on a country wide basis and not selective or disadvantageous to the Daventry District area surrounding Northampton. This is land control that is detrimental to the county and restricts its proper and formulated expansion which is particular important between the Northampton link to the A14 and between Northampton and Kettering. We look forward to receiving your response regarding these points.

12 March 2018 Page 338 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Policy ENV3 – Green Wedge and supporting text 9.2.01-9.2.03

2.89 As identified within our detailed representations to Policy HO1 we recommend that the Green Wedge boundary as identified within Policy ENV3 and the accompanying supporting text, namely in relation to the identification of part of land to the south west of Daventry South as a Green Wedge is reviewed and adjusted for the reasons set out below.

2.90 A Landscape and Visual Appraisal: Technical Note (see Appendix 8) has been submitted as part of these representations. This technical note considers in detail how the settlements of Daventry and Staverton are perceived and inform the consideration of the land needed to preserve their identity, which is the core objective of the proposed Green Wedge designation DA4/5. This assessment identifies two key movement routes between Staverton and Daventry where both settlements can be perceived at various points along its length.

2.91 The National Trail, to the north of Staverton, is entirely unaffected by any proposed development within the site as defined by the red line, as it is not visible from this route and would not alter the perception of Daventry’s location or the separation between it and Staverton.

2.92 The more relevant movement route for the consideration of Staverton and Daventry’s retained identity is the A425. At present, there is a gap of around 400 metres from which neither the identity of Staverton and Daventry are visible or experienced.

2.93 The reason for the lack of intervisibility between the settlements is a combination of topography (in particular the localised crest of a hill along the A425 that limits views southwards to Daventry) and vegetation.

2.94 Future development of land within the redline will reduce the physical separation between Daventry and Staverton from around 1.8km to around 1km. However, due to the intervening topography and vegetation, the ‘gap’ where neither the identities of Daventry and Staverton are perceived will remain at around 400m.

2.95 As a result, the proposed development of land within the red line will extend the developed edge of Daventry by around 800 metres, and this will be perceived by users of the A425. However, as far as the perceived gap remains the same as it is at present.

2.96 The location of this ‘gap’ that creates the perceived separation between the identities of Daventry and Staverton lies to the west of the proposed Green Wedge allocations DA4/5, from which the identity of Daventry can already be perceived. The more robust, and actual area that protects the identity of the respective settlements is land occupied by Staverton Clump and Big Hill to the south of the A425, and Staverton Golf Course to the north of the A425.

2.97 We therefore strongly recommend that the Green Wedge allocation is adjusted to reflect this finding (it is recognised in paragraph 5.6 of the Landscape Evidence Base Part D that precise boundaries can be refined).

12 March 2018 Page 339 of 399 Suggested change 2.98 Update Policies and Inset Policies map to reflect a reduced area for the Green Wedge around Daventry South West.

12 March 2018 Page 340 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED142B, ED142C and James Yeoman ED142E

Organisation: Representing: Savills Christ Church, Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Landscape Briefing Note – Prepared by EDP

EDP’s Briefing Note undertakes further assessment of the development credentials of Middlemore Farm from a landscape perspective and concludes:

EDP’s Briefing Note also assesses the proposed function of the Green Wedge, as set out by Policy ENV3 of the LP2. This policy relates to land at Drayton Gate Farm. EDP’s assessment concludes:

12 March 2018 Page 341 of 399 In summary, EDP concludes that the strategic location of Drayton Gate Farm, at the edge of the town, requires a cohesive landscape framework to ensure development is appropriately assimilated in to the wider landscape setting. Nevertheless the site is capable of accommodating development to meet future employment growth needs of Daventry.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 ED142B James Yeoman

Organisation: Representing: Savills Christ Church, Oxford

Support/Object:

Supporting Documents: ED142C - Site location plan; ED142D - Landscape, Ecology and Heritage Statement; ED142E - Landscape Briefing Note

Comment:

Employment Development

We trust the enclosed documents are of assistance to the continued plan preparation process and would welcome the opportunity to further engage with Officers as the Plan progresses.

12 March 2018 Page 342 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV3 – Green Wedge ED41A, ED41B Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

The Parish Council wish to see preservation of a Green Wedge between the parish, and the built up urban areas of Rugby in order to protect the identity, character and setting of the parish, and would like this added to the Local Plan.

The Parish Council wish to see this policy wording revised as it is the fringe area with Rugby and the extension to DIRFT and the associated 6200 residential development which threaten the settlement of Kilsby and its surrounding infrastructure.

We also wish to see some facility for removal of Permitted Development rights and Q class development on Green Wedge land. At the moment Barns can be built under Permitted Development rights, and then converted at a later date to domestic dwellings under Q class legislation which allows development in open countryside by stealth.

12 March 2018 Page 343 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV4 ED137 Mr & Mrs J Townsend

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

ENV4, Secondary Service Village confines and Heritage Assets

The subjects above are always going to be very emotive areas in any debate and we recognize the difficult balance you and your colleagues are facing. There must however be some areas abutting the confines of the restricted villages, which are not sensitive visually and of low impact upon the existing developed area than others. So how might the vibrancy, sustainability and changing needs of our smaller restricted villages be given a future within the wider pleasing landscape as a whole? We understand that ENV4 is very important for the district and the county, but this should not surely be viewed in isolation, as with the green environment, but holistically with our picturesque living villages included.

A conundrum: is it possible to have a small local needs provision, to maintain the vitality of a village, whilst protecting the very essence of the locality? Perhaps a weighting for local perspective, along with some stronger design guidance, which accounts for the setting, may be a key to allowing very limited development and breathing space for these rural villages. We note that the areas of SLA and their boundaries, do appear to have some element of flexibility in your policies (although we are not yet aware of the GNP view on this matter). So our proposition for development, on local basis, for your consideration is: • To ensure development only utilizes good design • Of low impact • Restricted massing and quality materials • Limited to five or fewer dwellings • In a location where the existing mature green landscape and screening, at the interface of the village confines, about the SLAs.

Other tests of compliance would also need to be applies as mentioned earlier in this text.

We have attempted throughout this letter to offer suggestions for amendments to the proposed policies without them being wholly personal but viewed from a wider perspective, which we feel probably apply to several villages across the district.

Thank you for the time you have taken to date and your valuable comments following our last meeting, it is very much appreciated.

12 March 2018 Page 344 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV4, paras 7.1.03, ED74 Sue Halkett 10.1.05,

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

Green infrastructure: page 99 ENV4 It is not clear what relevance the canal arm/marina has to health and wellbeing. The green space is already there for healthy outdoor activities, and can readily be used for that purpose. It is unclear what extra contribution the Canal Arm provide. In building it, would it tend to impair and/or eradicate existing green open space?

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV5 ED76 Alan Smith

Organisation: Representing: The Wildlife Trust

Support/Object:

Supporting Documents:

Comment:

On Page 101; in the ‘Policy Box’ shown for Policy “ENV5 – Biodiversity": With reference to the relevant content of the 2nd bullet-pointed item listed under the “A” heading here, please note that, for reasons of uniformity / conformity, we recommend that you make all references to non-statutory geologically-designated site areas as being Local Geological Sites ( LGS ), and not the formerly used nomenclature of either RIGS or RIGGS. { This is in-line with the national change, being adopted as the new approach for several years now, that also saw the move away from referring to the former, non-statutorily-designated, County Wildlife Sites, CWS, and their several other regional / county variants, to standardise the naming as being Local Wildlife Sites, LWS, instead. } [ However, in light of this recommendation, please also be aware that you will always have to make it clear just which type of LGS-designated site area you are referring to in any given situation; since there is the potential for confusion, in certain contexts, with the naming of Local Green Spaces as being LGS too. ]

12 March 2018 Page 345 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV5 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.14 ENV5 Biodiversity 4.14.1 Policy ENV5 should reflect the Framework’s requirement for the planning system to minimise impacts on biodiversity and provide net gains where possible. In doing so, it should be recognised that any harm arising from an individual site should be considered through a planning balance exercise undertaken in accordance with the presumption in favour of sustainable development.

12 March 2018 Page 346 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV6 ED86 Ian Dickinson

Organisation: Representing: Canal and River Trust

Support/Object: support

Supporting Documents:

Comment:

The Canal and River Trust is owner and operator of both Daventry Reservoir and the Grand Union Canal. The Trust supports the aim of incorporating footpath/cycleway connections within the proposed extension to the Country Park to provide a link to the Grand Union Canal. The canal towpath can provide a valuable recreational and leisure resource for future residents of the urban extension, providing a link to the surrounding countryside and ready access to the canal offers opportunities for people to maintain and improve their overall health and wellbeing.

Where the Daventry North East Sustainable Urban Extension creates new linkages to the Grand Union Canal (whether via the Country Park extension or elsewhere) consideration should also be given to the effect that increased footfall will have on the existing canal towpath.

A significant increase in use of the towpath is likely to increase the Trust's maintenance liabilities, and it may be necessary to consider upgrading the towpath to provide a more durable and harder wearing surface in order to minimise our maintenance liabilities and to ensure that the towpath remains in a condition that will encourage its continued use.

Where such increases in towpath use occur as a result of new development near to the canal, the Trust considers that there is a case for the developer to contribute towards the improvement of the towpath in order to offset increases in the Trust's maintenance liabilities. We therefore suggest that Policy ENV67 should also identify a requirement for the Daventry North East Sustainable Urban Extension to address this matter, as well as providing links to facilitate improved/increased access to the canal towpath.

The Trust supports inclusion of a requirement to ensure that the Daventry North East Sustainable Urban Extension does not impede the operation of, or maintenance access to, the reservoir feeder channel and associated infrastructure. The reservoir provides a water supply to the Grand Union Canal, and it is essential that this supply is not adversely affected in any way by new development.

The Trust supports that requirement for future development to protect and enhance the setting of the reservoir and the canal conservation areas. Both the reservoir and the canal are valuable heritage assets, of both historic and ecological interest and importance. It is therefore important that their character and setting is fully taken into account by any new development proposals, and that opportunities to enhance their settings are taken wherever possible.

12 March 2018 Page 347 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV6 ED138H Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy ENV6 - Daventry Country Park seeks to enhance Daventry Country Park’s recreation, leisure, health and wellbeing and cultural assets. Daventry Town Council supports this objective however it considers that the Country Park will change in nature to more of an urban park given the proposed and existing development which will encompass it within the built fabric of the town.

The County Park extension is a very important green corridor for the town to extend to the open countryside and link up with the Grand Union Canal. It is imperative that this green infrastructure properly integrates with the proposals in the masterplan for the North East SUE and that green wedges extend through the development joining up so that wildlife and recreational corridors can be created with sufficient land to achieve multiple objectives.

The Country Park Extension will from the interface between the Monksmoor Park and the proposed North-East SUE and provide a green buffer between the two developments with proposed walking and cycling routes to connect them. Daventry Town Council considers there is an opportunity to link the development by a dedicated public transport route. This has been proposed in the County Council’s Daventry Transport Strategy and would allow better circular connectivity between the new development areas, the northern residential districts and the industrial estates on the north and west of the town. This public transport link should be provided by the developers of the NE SUE and the expanded bus services negotiated with the bus operators before planning permission is granted.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV6 ED141A, ED141B Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents:

Comment:

Whilst no objection is raised to the principle of the Policy, it is noted that one of the requirements for the Country Park extension as part of the Daventry North East Sustainable Urban Extension is to include footpath/cycle connections to the Grand Union Canal and ‘the open countryside’. There is no concern with providing such footpath and cycle links to the Grand Union Canal and to ‘the open countryside’. If it is not intended through the proposed policy to provide such linkages beyond the Grand Union Canal then the policy should be amended to omit the words “and the open countryside” from Criterion I to policy ENV6.

12 March 2018 Page 348 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV7 ED74 Sue Halkett

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

Canal arm: page 103 ENV7 We have reservations, owning to unanswered questions on this proposed 'vision' element which is part of the DDC Masterplan.

It seems the whole cost is coming from "anticipated future" CIL contributions. This proposal has not been put to the electorate. We are concerned that if CIL contributions are not forthcoming the cost will be borne by the community of the District, the majority of whom reside in rural villages. These are areas already squeezed with financial pressures and a lack of resources for infrastructure, i.e. limited bus routes, cuts to bus services, mobile libraries placed at risk, parish councils having to undertake more village services with little or no recompense, and all within a regime where there is pressure to keep precepts low. We therefore question the sustainability and the wisdom of this proposal in the long term.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV7 ED120 Mark Wesley

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

The linear Park/Canal should be designated in this plan as such irrespective of the Canal being built so protecting this green link and the links through the NSUE.

12 March 2018 Page 349 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV7 ED138I Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Object

Supporting Documents:

Comment:

Daventry Town Council strongly objects to the proposals for a Canal Arm stretching from the Grand Union Canal to site EC3.

Daventry Town Council considers that the significant level of investment required for this infrastructure, will far outweigh any perceived or actual benefits in relation to the regeneration of Daventry Town, or the accessibility for users of the waterway to Daventry Town Centre.

Daventry Town Council considers that the cost of delivering the Daventry Canal Arm project, together with the A45 Daventry Development Link Road, will require all of the public-sector infrastructure funding and CIL contributions (from the private sector) beyond the end of the plan period. This would result in no funding for any crucial infrastructure, including highway enhancements and community facilities.

Daventry Canal Arm will have significant implications for the North East SUE, potentially increasing costs, due to design requirements which could make the delivery of the scheme unviable and funding for other requirements such as the undergrounding of electricity cables or enhanced links to Long Buckby Station may not be available.

Daventry Town Council is strongly opposed to this policy and the continuation of the Daventry Canal Arm proposal. Daventry Canal arm will result in additional costs to local residents, forgoing other vital infrastructure which is necessary for the growth of the Town.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV7 ED141A, ED141B Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents:

Comment:

Whilst no objection is raised in principle to proposed Policy ENV7, it is noted that the Policies Map that accompanies the Part 2 Local Plan is inaccurate in how it is identifying the safeguarded route for the proposed Canal Arm. The policies map therefore requires amending to ensure that the route to be protected accords with the route of the canal as secured through planning permission (Ref 11/0052/FULWND).

12 March 2018 Page 350 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV7 Daventry Canal ED9 Anthony Hawkey Arm

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I am pleased to see that the proposed canal arm still forms part of the proposed plan for Daventry, as this will attract tourism to the town, particularly if it includes a novel form of inclined plane boat lift and visitor centre. An inclined plane boat lift will help to conserve valuable water resources, which might otherwise be reduced using pound or staircase locks. (Objective 1 - Climate Change: to minimise demand for resources and mitigate and adapt to climate change).

The canal arm can be integrated into a flood relief system to help drain surface water from surrounding developments (section 9.8: Local flood risk). A canal visitor centre could be sited at the canal basin at Site 3, but might be better situated at the top or bottom of the inclined plane boat lift. Foxton Locks (and abandoned inclined plane) attracts more than 300,000 visitors a year. A working boat lift at Daventry would attract similar numbers, so sufficient visitor parking and access roads would need to be provided.

A hotel/restaurant could be provided alongside the canal at the top of the inclined plane, as part of the Daventry North East SUE (Objective 2 - Infrastructure and development). The canal arm will help to ensure the new Daventry North East SUE effectively supports and links new and existing communities physically and socially (Objective 3 - connections).

Para 7.1.16: the canal arm and associated towpath will provide a clear walking and cycling connection between the town centre and Daventry Country Park, and the Daventry North East SUE (Objective 12 - green infrastructure). The canal arm will also help to mitigate the risk of flooding by acting as a conduit for excess surface water.

12 March 2018 Page 351 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV8 ED60E Emile Carr

Organisation: Representing: Historic England

Support/Object: Object

Supporting Documents:

Comment:

The inclusion of policy ENV8 is strongly welcomed. Whilst Historic England appreciate that criteria iv) partly reflects Historic England's guidance on this issue there is a growing consensus that Enabling Development, which is by definition contrary to the Local Plan, should not be planned for with a supporting policy incorporated into a Local Plan. We are of the view that Local Plans do not require specific enabling development policies and that criteria iv) should therefore be removed.

By definition within the NPPF enabling development is development that is not otherwise in accordance with adopted policy. Paragraph 140 of the NPPF states: "Local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies."

Historic England is therefore of the view that a separate policy/criteria on enabling development is not a necessary component of a local plan document. A local plan should adequately set out a positive strategy for the historic environment without the need to include such a policy. Historic England would be very happy to agree to the deletion of criteria iv) by Statement of Common Ground.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV8 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.15 ENV 8 – Historic Environment 4.15.1 It is essential that any policies relating to the historic environment are consistent with the requirements of the National Planning Policy Framework.

4.15.2 With reference to designated heritage assets, the Council should refer specifically to paragraphs 133 and 134 of the Framework, which set out the need to assess the significance of a designated heritage assets and where there is less than substantial harm, this should be weighed against the public benefits of the proposal. Where there is deemed to be substantial harm, then the proposal would need to achieve substantial public benefits to outweigh that harm.

4.15.3 For non-designated assets, the policy must reflect the guidance set out within paragraph 135 of the Framework. This states that the policy test that should be applied in these cases is that a balanced judgement should be reached having regard to the scale of any harm and the significance of the heritage asset.

12 March 2018 Page 352 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV8 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Policy ENV8 – Historic Environment

2.99 Policy ENV8’s purpose is to conserve and enhance the historic environment of the District, this aligns with the requirements of the NPPF and as such, we support the policy.

2.100 As detailed earlier, Daventry South West does not contain any designated heritage assets however Badby House, a Grade II listed building, is located adjacent to the south west site boundary. However, this listed building will be screened from the development by a woodland buffer, the sites natural topography, a green corridor and landscaped areas. Further, as outlined within the Heritage Appraisal, the reintroduction of a wooded environment to the south of the site would represent a positive reinstatement of the landscape’s historic character, and consequently, would enhance the setting of Badby House, through restoring the original densely wooded and secluded character.

2.101 It is therefore clear that Daventry South West would accord with Policy ENV8 and that heritage considerations would not prevent the delivery of the allocation.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV9 ED60D Emilie Carr

Organisation: Representing: Historic England

Support/Object: Object

Supporting Documents:

Comment:

The inclusion of policy ENV9 is strongly welcomed. However, criteria ii does not provide clarity regarding land to the east of The Marches Strategic Employment Area; Historic England have objected to a small area of allocation EC9. Criteria ii should be reworded to reflect the concerns set out within the responses to EC9. Historic England would be very happy to agree to the wording of criteria ci) by Statement of Common Ground.

12 March 2018 Page 353 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Policy ENV9 ED138J Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Support

Supporting Documents:

Comment:

Policy ENV9 seeks to conserve and enhance the significance of Borough Hill and Burnt Walls Scheduled Monuments.

Daventry Town Council support the aspiration of this policy however any development which is proposed through policy EC9 will need to be sensitively designed in relation to its adjacent boundary with the Burnt Walls Scheduled Ancient Monument.

Daventry Town Council considers that enhanced pedestrian access for and around Borough Hill and the linkages between this SAM and the Burnt Walls SAM, is essential.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Section 9.1, Policies and ED83 Mark Blaber Inset Maps 2

Organisation: Representing: BRANE

Support/Object:

Supporting Documents:

Comment:

b) Issues relating to the environment In para 5.2.01 there is a statement "It is important that the Open Countryside is protected". BRANE fully supports this statement but believes that proposed removal of the status of Special Landscape Area from around Brixworth actually weakens that intent to protect the countryside and that the consultant's report (Daventry Landscape Character Assessment by The Environment Partnership or TEP) conflicts with DDC's aim. Within the TEP report there are specific statements suggesting that land around the south west of Brixworth could be screened by trees - as a "guide to developers"! This is in direct conflict with DDC policy of directing development to the areas around Daventry Town and the Sustainable Urban Extensions (SUEs).

BRANE considers that the TEP report in certain areas is weighted towards potential development rather than an unbiased assessment of the value of the landscape. The area to the south western edge of Brixworth identified in the TEP as "under pressure for new building" is largely within or adjacent to the current Special Landscape Area (SLA), is outside the agreed village confines and therefore in open countryside. This is an area identified by the community as important to the setting of Brixworth. This was defined in the Brixworth Neighbourhood Plan and supported by the Examiner. There is no need to mention this particular area and BRANE believes that the TEP report should be looked on as advisory only and where conflict with DDC aims in protecting the Open Countryside occurs, then those parts of the TEP report should be deleted or at least disregarded.

BRANE does not accept the logic of the argument that the SLA should be reduced in size around Brixworth as that weakens the medium to long term protection for the countryside.

12 March 2018 Page 354 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Section 9.4 ED76 Alan Smith

Organisation: Representing: The Wildlife Trust

Support/Object:

Supporting Documents:

Comment:

With reference to Section 9.4, sub-headed as “Daventry Country Park”, on Pages 101 and 102 : Within this overall Chapter of the core Plan document itself, dealing with the topic of the “Built and Natural Environment”, would it not also be of benefit if, in order to highlight other important and strategic locations within the scope of the overall Daventry District itself, a similar, and separate, consideration and treatment ( with associated Policies, as required ) was also given to the site locations and features of Borough Hill Country Park, Pitsford Reservoir and the Brampton Valley Way too - as all being further, high-profile, examples of the natural environment within Daventry District.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Section 9.8 ED27 Malcolm Ball

Organisation: Representing: Northamptonshire County Council - Flood and Water Management Team Support/Object: Support

Supporting Documents:

Comment:

Thank you for consulting us on the Emerging Daventry Local Plan. Having reviewed the documents we wish to commend the authors for their recognition of flood risk management policies and practices and the role flood risk management undertakes in the development of sustainable places by reducing flood risk. With adaption to climate change and the mitigation of flood risk within Objective 1 of the plan there is then a continuous stream of references to SuDS, the SFRA and the requirement for the assessment of flood risk. The inclusion of section 9.8, Local Flood Risk, is particularly welcome. We have no further comment to make.

12 March 2018 Page 355 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 SFRA ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Strategic Flood Risk Assessment

2.56 The Strategic Flood Risk Assessment (SFRA) Part 1 provides updated Flood Mapping for Surface Water produced by the Environment Agency (EA). This work has been assessed by Brookbanks who are appointed on Flood Risk and Drainage. The study identifies a number of surface water flows over the site however as detailed later on in these representations, these are not considered to present a constraint to the delivery of the allocation.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 09 Water and Wastewater ED139A Roger Tustain Infrastructure Capacity Assessment

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Water and Wastewater Infrastructure Capacity Assessment (November 2017)

2.57 The Water and Wastewater Infrastructure Capacity Assessment identifies that the delivery of the site would require off site network reinforcement due to wastewater network capacity. Initial work undertaken by the Client’s technical team indicates that the Whilton Sewage Treatment Works (STW) has capacity to support initial housing delivery from Daventry South West. This will ensure that sufficient time exists to deliver the enhancements to the STW before capacity is reached, ensuring that the housing trajectory set out later on in these representations can be delivered.

12 March 2018 Page 356 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 ED125 Tom Clarke

Organisation: Representing: Theatres Trust

Support/Object:

Supporting Documents:

Comment:

Daventry has a range of cultural and community facilities such as pubs that contribute to the vibrancy of its town centre and the night time economy and to the wellbeing of the local community. As such the breadth of health and wellbeing currently referred to within the draft plan appears too narrow, focussing predominantly on housing standards, health infrastructure and healthy environments. The draft Plan’s Community Facilities section (Chapter 10) should explicitly support and reference arts and culture for consistency with the NPPF.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 CF3 – Protecting Local retail ED41A, ED41B Catherine Camp services and public houses

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

We would like to ensure that if a business is operating from a property which used to be a private dwelling, that it has to seek and obtain planning permission to revert to domestic use when it wishes to cease trading. Current legislation has allowed shops in Kilsby to revert back to domestic accommodation when they cease trading without full planning permission which means that sometimes the village did not receive advance warning that it was going to lose a local shop.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Para 10.1.04 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

Section 10.1.04 addresses the need for an appropriate mix of recreation facilities. Chapter 10 fails to make the distinction between the requirements in urban and rural areas, so that the recreation facility reflects the character of the area. For example, recent outline application for largescale development in Harlestone Parish indicated inclusion of formal sports pitches whereas informal recreation space (i.e. dog parks or nature walks) would be better suited to this rural area.

12 March 2018 Page 357 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Para 10.1.05 ED74 Sue Halkett

Organisation: Representing: Flore Parish Council

Support/Object:

Supporting Documents:

Comment:

Air quality: 115 Would not fumes emitted from the boat engines pollute the air to the detriment of the air quality, since the canal is to be situated in the proposed location with buildings alongside? These would potentially confine and concentrate the released fumes rather than allowing them to disperse as in the more normal open canalside environment.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Para 10.1.07 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object: Support

Supporting Documents:

Comment:

We support the reference to undertaking health impact assessments to show how potential health impacts of new development have been addressed. Only by doing this in a structured way will the potential health and wellbeing benefits of new development be maximised and any negative effects mitigated. We would welcome clarity in the Local Plan Part 2 about when this will be required and how this requirement should be met. We understand the health impacts could be identified and addressed within a broader assessment of development proposals, such as Environmental Impact Assessment or Sustainability Appraisal.

12 March 2018 Page 358 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Para 10.1.09, policy CF2 ED79C Paul Johnson

Organisation: Representing: Francis Jackson Homes

Support/Object:

Supporting Documents:

Comment:

The policy and supporting text as drafted is very unclear.

We note the aspiration is that new residential developments, in the case of Section A) outside of the NRDA, and over 0.2ha area or for more than 6 dwellings are expected to “meet the following open space standards”.

There then follows a list of typologies and a figure to be provided based on the quantity per 1,000 population.

Detailed supporting methodology is required so that a transparent and meaningful figure is arrived at – how many residents will a 3-bed dwelling generate for example, and how is this transposed into an area required to be provided in each instance.

How is an applicant to know if there is a local shortfall or overprovision (and so a demonstrable need generated as a direct result of the development itself – to be CIL complaint) such as to generate a need for each typology? This is not at all clear from this policy as drafted, nor is it clear if the Policy evidence base for this is the 2009 Open Space, Sport and Recreation Strategy, or an updated version – if so, what is that new version, has it been through examination/adopted?

Developers will also need certainty what the minimum threshold for the provision of on-site POS is in each instance – smaller sites could be rendered totally unviable by the provision of small pockets of POS which are impossible to maintain and have little amenity value due to their restricted size.

What threshold of development requires a LAP, at what point does this become a LEAP and then a NEAP. This policy is very unclear and should ideally refer the reader to a detailed SPD where this is all set out and transparent, including its methodology and trigger points, rather than trying to include all the typologies and details within a development plan policy itself.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Para 10.7.05 ED24 Simon Barber

Organisation: Representing: English Regional Transport Association

Support/Object:

Supporting Documents:

Comment:

Poor Air Quality - extremely important.

12 March 2018 Page 359 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF1 ED85 Stephen Marks

Organisation: Representing: Northamptonshire County Council Public Health Team Support/Object:

Supporting Documents:

Comment:

I am writing to provide a response from Northamptonshire County Council's Public Health Team in relation to Daventry DC's consultation on your Part 2 Local Plan (Daventry District Settlements and Countryside (Part 2) Local Plan). Please find below comments on various aspects of the draft plan.

Firstly we welcome the strong references to Health and Wellbeing within the draft Local Plan Part 2. The way in which new developments are designed and built will have a strong impact on the health and wellbeing of the people who ultimately live, work or visit those new developments/environments, either by facilitating healthier lifestyles or conversely by discouraging them.

Policy CF1 - Health and Wellbeing We welcome the inclusion of a specific policy entitled Health and Wellbeing. However, we do not feel it should be included in a section entitled Community Facilities. The delivery of Health and Wellbeing goes far beyond the provision of community facilities and as such we feel the Health and Wellbeing policy should be moved to a more suitable part of the Local Plan Part 2 document.

12 March 2018 Page 360 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF1 ED125 Tom Clarke

Organisation: Representing: Theatres Trust

Support/Object:

Supporting Documents:

Comment:

Thank you for consulting the Theatres Trust on the Emerging Draft Daventry District Settlements and Countryside (Part 2) Local Plan. Please find our comments outlined below.

To meet National Planning Policy Framework (NPPF) requirements and better support cultural wellbeing, the Trust would strongly advise that the next draft of your new Local Plan should amend Policy CF1 to cover sport and outdoor recreation with Policy CF3 being expanded to cover not just local retail and public houses but also other cultural, arts and community facilities.

Cultural facilities include theatres, public houses (especially where they provide live music and other entertainment), community spaces, museums, cinemas, libraries and other public and performance venues. They are important in supporting the local and visitor economy by attracting people to your district where other businesses then benefit from the flow on effects.

Culture and cultural activity helps develop a sense of place and make communities unique and special. Cultural and community facilities support the day to day needs of local communities and help promote wellbeing and improve quality of life. Participation in cultural events can contribute to social cohesion, reduce isolation and loneliness, encourage learning and the development of skills as well as provide the entertainment and stimulation needed to develop vibrant communities and grow the economy. There is also growing awareness of the role that the arts and culture play in attracting and retaining residents and a skilled workforce.

The NPPF provides clear directions to local planning authorities about the importance of safeguarding and promoting cultural activities and venues in their areas. - One of the 12 core planning principles (Para 17) is the need to plan for culture to support the social wellbeing and sustainable communities. - Paragraph 23 recognises the important role town centres play in supporting communities and notes that cultural venues makes a valuable contribution to the vibrancy and success of these centres. - Paragraph 70 states that in ‘promoting healthy communities’ planning decisions should ‘plan positively for cultural buildings’ and ‘guard against the loss of cultural facilities and services’. - Paragraph 156 directs local planning authorities to ensure their local plan includes cultural policies that reflect the NPPF.

12 March 2018 Page 361 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF2 ED91F Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents: Attached - Landscape & Visual Constraints and Opportunities Report

Comment:

Policy CF2 - Open Space Requirements Whilst no objection is raised in principle to Policy CF2, it is considered appropriate to identify a degree of flexibility in applying the standards, particularly where one typology of open space provision is able to compensate for under- provision in another open space typology. An overall quantum of open space is necessary in all developments but it is perhaps in an all party's interests to provide for some flexibility to be applied and the following additional sentence is proposed to be added to Policy CF2: "Whilst an overall quantum of open space is required in accordance with the above standards, an over provision in one form of open space typology may be acceptable in compensating for an under provision in another form of open space where this is demonstrated to be acceptable having regards to overall provision in the locality."

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF2 ED141A, ED141B Gary Lees

Organisation: Representing: Pegasus Barratt Developments & Davidsons

Support/Object: Object

Supporting Documents:

Comment:

Whilst no objection is raised in principle to Policy CF2, it is considered appropriate to identify a degree of flexibility in applying the standards, particularly where one typology of open space provision is able to compensate for under- provision in another open space typology. An overall quantum of open space is necessary in all developments but it is perhaps in all parties’ interests to provide for some flexibility to be applied and the following additional; sentence is proposed to be added to Policy CF2 to achieve this:

“Whilst an overall quantum of open space is required in accordance with the above standards, an over provision in one form of open space typology may be acceptable in compensating for an under provision in another form of open space where there is demonstrated to be acceptable having regard to overall provision in the locality”

I trust the above objections and comments can be taken in to account and proposed policies updated accordingly prior to the publication of the Regulation 19 consultation version of the Part 2 Plan.

12 March 2018 Page 362 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF2 ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object: Support

Comment:

Policy CF2 – Open Space Requirements

2.102 We support Policy CF2 which establishes the open space standards new residential developments are required to provide. Daventry South West will meet or exceed the open space requirements set out within Policy CF2.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF2 ED18B Jane Austin

Organisation: Representing: Overstone Parish Council

Support/Object:

Supporting Documents:

Comment:

Provide a definition for LEAP and NEAP.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF3 ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

We would like to ensure that if a business is operating from a property that used to be a private dwelling, that it has to seek and obtain planning permission to revert to domestic use when it wishes to cease trading. Current legislation allows shops to revert back to domestic accommodation when they cease trading without full planning permission which means that sometimes the village is not made aware in advance that it is going to lose a local shop.

12 March 2018 Page 363 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF3 ED125 Tom Clarke

Organisation: Representing: Theatres Trust

Support/Object:

Supporting Documents:

Comment:

Thank you for consulting the Theatres Trust on the Emerging Draft Daventry District Settlements and Countryside (Part 2) Local Plan. Please find our comments outlined below. To meet National Planning Policy Framework (NPPF) requirements and better support cultural wellbeing, the Trust would strongly advise that the next draft of your new Local Plan should amend Policy CF1 to cover sport and outdoor recreation with Policy CF3 being expanded to cover not just local retail and public houses but also other cultural, arts and community facilities. Cultural facilities include theatres, public houses (especially where they provide live music and other entertainment), community spaces, museums, cinemas, libraries and other public and performance venues. They are important in supporting the local and visitor economy by attracting people to your district where other businesses then benefit from the flow on effects. Culture and cultural activity helps develop a sense of place and make communities unique and special. Cultural and community facilities support the day to day needs of local communities and help promote wellbeing and improve quality of life. Participation in cultural events can contribute to social cohesion, reduce isolation and loneliness, encourage learning and the development of skills as well as provide the entertainment and stimulation needed to develop vibrant communities and grow the economy. There is also growing awareness of the role that the arts and culture play in attracting and retaining residents and a skilled workforce. The NPPF provides clear directions to local planning authorities about the importance of safeguarding and promoting cultural activities and venues in their areas. - One of the 12 core planning principles (Para 17) is the need to plan for culture to support the social wellbeing and sustainable communities. - Paragraph 23 recognises the important role town centres play in supporting communities and notes that cultural venues makes a valuable contribution to the vibrancy and success of these centres. - Paragraph 70 states that in ‘promoting healthy communities’ planning decisions should ‘plan positively for cultural buildings’ and ‘guard against the loss of cultural facilities and services’. - Paragraph 156 directs local planning authorities to ensure their local plan includes cultural policies that reflect the NPPF.

12 March 2018 Page 364 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 10 Policy CF3 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.16 CF3 – Protecting local retail services and public houses 4.16.1 Chapter 10 provides the context and proposed local policies relating to community facilities across Daventry District. In this regard, Gladman notes the intention of policy CF3 to protect local retail services and public houses. The current policy seeks to protect services in rural areas, however paragraph 28 of the Framework goes further by requiring local policies to promote the retention and development of facilities in villages. Consideration should therefore be given to extending the scope of this policy to ensure that the Plan takes a pro-active and positive approach to meeting this requirement of the Framework across the settlements of the rural area. It is essential that the local plan does not just focus on the enhancement of its urban centres (which are supported extensively through the policies in Chapter 7) by also identifying and responding to the needs of communities in the rural area.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Chapter 11 ED87 Sarah Stock

Organisation: Representing: Harlestone Parish Council

Support/Object:

Supporting Documents:

Comment:

No observations.

12 March 2018 Page 365 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Chapter 11 Parish Annex, ED39 Anonymous Anonymous Policy PA1 Local Green Space, Policies and Inset Maps 23, reference 133

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

I wish to object to the designation of the Allotments 133 Walgrave as a protected area of Green space as the site does not meet all 3 of the criteria set out in paragraph 77 of the National Policy Framework which states: The Local Green Space designation will not be appropriate for most green areas or open space. The designation should only be used: ● where the green space is in reasonably close proximity to the community it serves; ● where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and ● where the green area concerned is local in character and is not an extensive tract of land.

REASONS FOR OBJECTIONS The green space is in reasonably close proximity to the community it serves Objection on the grounds that: The allotments do not serve the local community o The allotments are provided by a private land owner on an individual basis and do not serve the community as a whole. o Walgrave ‘s population was 868 in the 2011 census. Only 7 allotments are let to eight people and not all allotment holders live in Walgrave. This means that percentage wise basing the calculation on 2011 figures the allotments are used by 0.9% of the community if you include all allotment holders even those outside the village. (This is not extensive use as indicated by the Parish Council in their submission to include it as a Local Green Space)

Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife Objection on the grounds that: The allotments are not demonstrably special to the local community as they are not of beauty, historic significance, tranquillity or richness of its wildlife. Objection on the grounds that: The allotments are not used by the local community for recreational value.

The allotments are not let to the community as a whole but on an individual basis Recreational value is not defined in the National Planning Practice Guidance: this document mainly seems to refer to sports grounds/ playing field.

Recreational activity if any is minimal as: o only 7 allotments are held and o the activities that are carried out on the allotments are no different to those that can be carried out in a garden, whether your own or another’s o There are 45 allotments within the Daventry District. Only 13 of these have been nominated as Local Green Space of these only 4 are owned by Private Land Owners (8%).

Where the green area concerned is local in character and is not an extensive tract of land Objection on the grounds that: The allotments are no more local in character than any other garden or the piece of land between the allotments and the village, which was not even been considered for nomination as a Local Green Space Designation.

12 March 2018 Page 366 of 399 OTHER CONSIDERATIONS That existing planning controls are adequate to prevent unsuitable development of the site. This is demonstrated by the fact that the site between the allotments and the village had planning permission refused recently (2016).

The land is being considered for designation as a Local Green Space as it has been used for allotments. Designating this land as a Local Green Space may deter other land owners in the District from allowing their land to be used as allotments in case this strong designation is applied.

There are 45 allotments within the Daventry District. Only 13 of these have been nominated as Local Green Space of these only 4 are owned by Private Land Owners (8%). The other 9 are owned by the Parish or Town Council and to the best of my knowledge these organisations are required by legislation to provide allotments if they are needed.

Allotments have not been provided by Walgrave Parish Council even though the Parish Council’s responsibility is not negated by the fact that a private land owner may provide allotments.

Walgrave Parish Council did not consult me or gain my opinion prior to nominating the land as a Local Green Space.

Walgrave Parish Council originally nominated 16 Local Green Spaces, 11 of which are now being considered for designation as local Green Space.

Consideration has not been given to the future of the land if there is no further demand for allotments. Daventry District Settlements & Countryside Local Plans (Part 2) 11.1.06*.

In the future the land 133 Walgrave may be considered as a suitable location for housing that would suit either the elderly/disable/young persons wishing to live in the village in accordance with the Daventry District Settlements & Countryside Local Plans (Part 2) 1.8*, 2.3.04*, 5.1.05*

Some Parish appear not to have nominated local Green Spaces 11.1.05*

*References Daventry District Settlements & Countryside Local Plans (Part 2) 1.8 Presumption in Favour of Sustainable Development 1.8.01 At the heart of the NPPF is a presumption in favour of sustainable development. For plan making this means that local plans should positively seek opportunities to meet the development needs of the area with sufficient flexibility to adapt to change. For decision taking it means approving planning applications that are in accordance with the development plan without delay. 2.3.04 Within Northamptonshire, Daventry District has the second highest average house prices after South Northamptonshire. However, house prices within the rural parts of the District are much higher than within Daventry town. Affordability is an important issue in the rural parts of the District, an issue raised during the 2012 issues consultation 5.1.05 Due to the progress against the rural requirement it is not considered necessary to make any allocations for development in the rural areas in this plan or to identify specific targets for individual settlements. However further allocations could come forward through neighbourhood development plans or exception sites where supported by appropriate evidence, for example a local housing needs survey. The Council works proactively with local communities to undertake local housing needs surveys16, in particular to support neighbourhood development planning. 11.1.05 Further submissions of Local Green Space are now invited from those parishes that are not currently or are not intending to produce a neighbourhood development plan.

The National Planning Policy Framework The NPPF (para 77) sets out when the Local Green Space designation should be used: • Where the green space is in reasonable proximity to the community that it serves • Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness in its wildlife; and • Where the green area concerned is local in character and is not an extensive tract of land 11.1.06 Paragraph 78 of the NPPF sets out the national approach for managing development within a Local Green

12 March 2018 Page 367 of 399 Space, stating that this should be consistent with the policy for Green Belts. This approach is extremely restrictive. At a local level it is not conducive to the approach that many communities wish to take to protect their local spaces as LGS because it prevents development/uses that would be entirely acceptable.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Inset Map p10 ED47 Catherine Camp

Organisation: Representing: Barby and Onley Parish Council

Support/Object:

Supporting Documents:

Comment:

Barby Sports Field at the top of Longdown Lane is identified as an important Green space within Barby & Onley Neighbourhood Plan, yet it is missing from the Inset Maps within Daventry District Local Plan. – please correct this error.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 PA1 Local Green Space ED41A, ED41B Catherine Camp

Organisation: Representing: Kilsby Parish Council

Support/Object:

Supporting Documents:

Comment:

Kilsby has important Ridge and Furrow on the fringes of the village. These are noted in Kilsby Neighbourhood Development plan and fall outside the village development area, however can they be covered as important features within the District Local Plan?

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Parish Annex ED68B Sue Porter

Organisation: Representing: Staverton Parish Council

Support/Object:

Supporting Documents:

Comment:

We note the paragraph at the beginning of this consultation form and would ask that it be confirmed that the Local Green Space Nominations identified as part of the SNDP process and submitted to DDC will be included within the plan as our plan has yet to be made.

12 March 2018 Page 368 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Parish Annex - Local Green ED2 Nigel Shields Space: Great Brington

Organisation: Representing: Althorp Estate

Support/Object: Support and Object

Supporting Documents:

Comment:

Thank you for your letter of the 24th November 2017. This needs to be read in context with the National Planning Policy Framework (NPPF). I act as Estate Director to the Trustees of the Eighth Earl Family Settlement, who are the Landowners. Firstly the Trustees support the inclusion of 140 allotments next to Grange Farm (the other 140 by the church is not owned). The trustees support the inclusion of 143 and 144 both being playing fields areas let to the Parish Council. The Trustees are committed to this through long term leases to the Parish Council.

On behalf of the Trustees I am objecting to the inclusion of location 141. This is an area of elevated land known as Back Lane. The land in question is protected by being with the designated Great Brington Conservation Area and is used for a range of agricultural purposes entirely appropriate to the quiet rural setting of the village. The land was clearly orchard land for some time, with the remains of some fruit trees and is also part used as pony paddocks. The stone wall that abuts Back lane is attractive and part of the character of the area. Whilst I understand why it might have been identified as a possible candidate for Green Space, I do not believe this aspect has been thought through. Your letter is misleading in drawing attention to just para 77 of the NPPF. The inclusion of Local Green Space areas need to be considered in the context of the sustainability of these local communities, in the longer term. The Bringtons have a village school, a Post Office, village hall, shop and two public houses, clearly sustainable communities in terms of the rural settlement hierarchy and there needs to be space in the long term for this community to organically grow. It may be deemed inappropriate for any form of development to be considered on this area for the extent of the plan period to 2029: however the inference from para 76 is that "Local Green Spaces should only be designated when a plan is prepared or reviewed, and be capable of enduring beyond the end of the Plan Period" - therefore beyond 2029. It is for this reason we believe that area 141 should be reconsidered so that this area in the centre of the village is not entirely precluded from being considered for appropriate development in perhaps 20 to 50 years' time - something for future generations to assess.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED48A, ED48B, ED48C Marion Money

Organisation: Representing: Newnham Parish Council

Support/Object:

Supporting Documents: Maps attached

Comment:

Two sites nominated for designation as Local Green Space: 1. Allotments, Coronation Road, Newnham 2. Playing Field, off Preston Capes Road, Newnham

12 March 2018 Page 369 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED49 Lisa Callan

Organisation: Representing: Holcot Parish Council

Support/Object:

Supporting Documents:

Comment:

Six sites nominated for designation as Local Green Space: 1. Allotments, Moulton Road 2. Playing Field, Back Lane 3. Old School Site, Main Street 4. Churchyard, Main Street and Churchyard Overspill 5. Crossroads Green, Moulton/Brixworth Road 6. Washbrook, Sywell Road

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED91D Kate Thompson

Organisation: Representing: Pegasus Group Gallagher Estates Ltd

Support/Object: Object

Supporting Documents: Attached - Landscape & Visual Constraints and Opportunities Report

Comment:

Policy PA1 - Local Green Space We note that Policy PA1 proposes the allocation of Boughton Green, Moulton Lane (LP Ref. 7) as a ‘Local Green Space’. Our client Gallagher Estates, have interests in land to the south east of Boughton (‘Land South of Moulton Lane, Boughton’ (HELAA ref. 108)), of which the proposed Local Green Space at Moulton Lane forms part. We strongly object to the proposed designation of LP Ref. 7) as a ‘Local Green Space’ as it is, in our view, inappropriate and unjustified. The NPPF is clear that Local Green Space designation will not be appropriate for most green areas or open space.

‘Land South of Moulton Lane, Boughton’ has been promoted for residential development as part of the Local Plan consultation process. As demonstrated by the Indicative Concept Masterplan (see attached) there is an opportunity to accommodate development to the south west of Boughton whilst safeguarding the proposed Local Green Space and providing new areas of green infrastructure alongside enhanced public access. The triangle of land which comprises the proposed Local Green space would be included as part of a strategic landscape buffer to the wider scheme and we consider this to be the appropriate mechanism to ‘protect’ this land.

The site does not currently benefit from any public access and is largely ‘locked’ by the local road network. The land could, if the landowner chose, be used for intensive agriculture and would therefore, not perform as a green space in the way the policy intends. On the contrary were it to be included as part of a wider allocation, the land could be safeguarded as amenity green space with enhanced public access going forward.

12 March 2018 Page 370 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED82 Stewart Patience

Organisation: Representing: Anglian Water

Support/Object:

Supporting Documents:

Comment:

It is proposed to designate land at Church Road, Weedon as a local green space. The land identified in the policies map includes an operational sewage pumping station in the ownership of Anglian Water.

Policy PA1 states that the land designated as Local Green Spaces will be protected from development which would harm the function, openness and permanence of these spaces except in very special circumstances.

However Policy PA1 does not state what would constitute special circumstances in the context of development being brought forward within designated local green spaces.

Our concern is that the policy as drafted does not allow for development to enable continuing operation of existing water recycling infrastructure to serve our customers. We would therefore ask that the land in Anglian Water’s ownership at Church Road, Weedon be removed from the designated local green space.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED64 Kate Thompson

Organisation: Representing: Pegasus Group Miller Homes

Support/Object: Object

Supporting Documents:

Comment:

Chapter 11 Parish Annex It is noted that Policy PA1 – Local Green Space seeks to protect areas of open space as identified on the Inset Maps from development that would harm their function and openness, and that this policy is underpinned by an evidence base which is the Local Green Space Assessment of 2017. Whilst no objection is raised to the areas of Local Green Space proposed to be allocated through Policy PA1, it is noted that the Inset Maps also identify areas of Local Green Spaces that have been identified through the Neighbourhood Planning process.

Objections are raised to the identification of those Local Green Spaces that have been designated through the Neighbourhood Plan process within this Local Plan. Neighbourhood Plans are not subject to the Town and Country Planning (Local Planning) (England) Regulations of 2012 (as amended) and are not subject to the tests of soundness. Whilst Neighbourhood Plans are development plans, they are not Local Plans and are not subject to the same degree of scrutiny. It is thus misleading and inappropriate to identify Neighbourhood Plan designations in a Local Plan. In order for the Plan to be effective and sound, it is necessary to omit the identification of those Local Green Space areas that have been designated through the Neighbourhood Plan process.

12 March 2018 Page 371 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED144B, ED144C, ED144D, Katrina Jones ED144E, ED144F, ED144G, ED144H, ED144I

Organisation: Representing: Creaton Parish Council

Support/Object:

Supporting Documents:

Comment:

Nomination of eight areas for designation as Local Green Space: 1. The Churchyard, Violet Lane, Creaton 2. The School Grounds, Violet Lane/Welford Road, Creaton 3. The Grounds of Creaton Lodge, The Green, Creaton 4. Paddocks and the Central open space of pastureland, Creaton 5. The Village Green, Creaton 6. Little Creaton, Creaton 7. The Playing Field, Brixworth Road, Creaton 8. Orchards, Teeton Lane & behind the Church, Creaton

12 March 2018 Page 372 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED93 Richard Crosthwaite

Organisation: Representing: Gladman Developments Ltd.

Support/Object:

Supporting Documents: Attached - Site submissions for Holly Lodge Drive, Northampton; Land at New Street, Weedon; Land at Brington Road, Long Buckby

Comment:

4.17 PA1 – Local Green Space 4.17.1 Paragraph 77 of the Framework sets out the national policy position in relation to Local Green Space designations and sets out the following tests which need to be met in order to designate Local Green Space. • “Where the green space is in reasonably close proximity to the community it serves; • Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and • Where the green area concerned is local in character and is not an extensive tract of land.” (emphasis added)

4.17.2 As outlined through national policy, the Council need to have clear justification for designating land as Local Green Space, and they should not be using this as a means to arbitrarily protect vast areas of land from development.

4.17.3 The PPG provides further clarity on the designation of Local Green Space, and at paragraph 37-015-20140306 states: “There are no hard and fast rules about how big a Local Green Space can be because places are different and a degree of judgement will inevitably be needed. However, paragraph 77 of the National planning Policy Framework is clear that Local Green Space designation should only be used where the green area concerned is not an extensive tract of land. Consequently blanket designation of open countryside adjacent to settlements will not be appropriate. In particular, designation should not be proposed as a ‘back door’ way to try to achieve what would amount to a new area of Green Belt by another name.” (emphasis added).

4.17.4 The Council needs to ensure that the Local Plan designations align with national policy and that they are able to demonstrate the rationale behind any such designation. This is particularly key as the Council is proposing to designate a significant number of sites as Local Green Spaces. All of these areas of land need to be demonstrably special to a local community and be of local significance in order for them to merit this designation.

12 March 2018 Page 373 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1 ED138O Deborah Jewell

Organisation: Representing: Daventry Town Council

Support/Object: Object

Supporting Documents:

Comment:

Policy PA1 – This policy seeks to protect the Local Green Spaces that have been designated through the Local Plan from development that would harm their function, openness and permanence unless in very special circumstances. Daventry District Council conducted a consultation with regard to what ‘issues’ might be relevant to include within a Parish Annex of the Local Plan and concluded that Local Green Space would be the only element. Out of the 165 green spaces which were nominated by Daventry Town Council and District Parish Councils 99 have been designated in the plan.

Daventry Town Council wish to contest the exclusion of four of their nominated areas, and request they be reassessed and included in the plan, for the following reasons:

Ref 22 Northern Valley Park

The LGS Assessment report states that the reason for not designating this site is that it is ‘Extensive grass verge which is not demonstrably special to the public, therefore it is considered does not meet criteria 2 and 3’. Daventry Town Council considers that the assessment of this site has been possibly made erroneously as the area does not form a grass verge of any description. The piece of land forms a green wedge between the existing outer edge of development of Lang Farm and what will be the proposed and consented development of Micklewell Park. Although the LGS boundary would need to be changed to accommodate the aforementioned development it would still act as an important green ‘lung’ for the town and is and will be a valuable recreational and leisure resource for the residents of these communities. It also provides a setting and protection around the Grand Union Canal Conservation Area, as well as linking through to the Drayton Reservoir providing a green and ecological link for fauna to travel between it and the countryside. While the area is significant, it represents an important element of Green Infrastructure for the town’s future growth and if it is not protected through a Local Green Space designation it should be protected in some other way.

Ref 31 Admirals Way

This piece of land borders between the eastern edge of the built boundary of the town and the Borough Hill Scheduled Ancient Monument. The area is heavily wooded and on sloping ground and is very popular for residents. The wooded area also acts as a buffer to the Scheduled Ancient Monument and provides access through to Borough Hill footpaths and the open countryside. The area is a thin piece of land creating a green corridor which should be protected and retained as local amenity land for residents.

Ref 37 Daventry & District Golf Club

The Golf Club is an area of Green Space which has been in a local amenity and recreational facility for the town since 1907. It represents a well-used facility valued by the town’s residents and is close to the people that it serves. It therefore meets NPPF criterion 1 and 2 and the size of the site is a function of the facility and not excessive in these terms. If the golf club were to close the area would still represent a valued local resource for recreation and leisure, particularly in the context of the setting of the Scheduled Ancient Monument.

Ref 38 Daventry & District Sports Club

Daventry & District Sports Club is an area of green space with running track, sports fields and pavilion buildings. It is a

12 March 2018 Page 374 of 399 valued resource for the community and sits on the southern fringe of the town close to where the community is and the people who use it. The site area is approximately 7.5ha in size which is typical for a sports facility of this type. It is not dissimilar to the allocated Local Green Space in the Earls Barton Neighbourhood Plan for the Sports and Leisure pitches at the Grange. This is approximately 6ha and includes the existing pavilion. While the designation of Local Green Space will provide protection against development it would allow certain development in very special circumstances. Any future redevelopment of the site for sports facilities could be justified on these grounds.

Alternatively, the Local Plan could afford protection of existing open space, sports and recreation buildings through the designation as Local Open Space (NPPF 74) and this could be designated on the Proposals Plan accordingly.

Daventry Town Council strongly objects to these valuable areas of Local Green Space not being designated in the plan and requests that either they be reassessed and included as LGS or the Sports Club and Golf Club be designated as Local Open Space to afford some protection of these facilities and to ensure that they are safeguarded for the existing community and future generations.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies & Inset ED18A Jane Austin Maps 40

Organisation: Representing: Overstone Parish Council

Support/Object: Object

Supporting Documents:

Comment:

OPC strongly oppose the plans for Overstone for the following reasons:

The wooded areas within the Overstone village envelope as agreed by DDC set the character and place of the village. Without trees bordering the stone wall along Sywell Road the character of the village would be lost. Consult any resident of Overstone will tell you that the " tree lined " avenue is one of the most important features of the village.

Local Green Space as defined in the NPPF has no requirement for access for the general public. There is no definition of extensive in the NPPF.

Church Lane and the Beech Avenue is country lane connecting Sywell Road via the church to Overstone Hall. This walk through the Overstone Park to the houses within Overstone Park and Billing Lane was available to all until DDC gated the lane at the cattle grid.

Why can't " agricultural Land " be classified as Local Green Space as it is at the rear of the houses along Sywell Road.

12 March 2018 Page 375 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED17, ED19B James Ellis Maps 26

Organisation: Representing: Northamptonshire County Council Property Strategy & Estates Support/Object: Object

Supporting Documents:

Comment:

Thank you for the attached letter regarding the draft local plan and designation of green open space. Our initial comments are that the school playing field is completely fenced, gated, and is not open to the public. The school playing field forms part of the school site and is used by NCC to delivered statutory school places. Should NCC need to deliver additional school places, it is entirely feasible that an extension or modular building may be required, and that development could be sited on the school playing field. NCC opposes the proposed designation of the school playing field as green open space on the grounds that it is private, and will restrict our ability to deliver a statutory service. We also note that there is a substantial village sports field close by, and the fields neighbouring the school have not been identified as potential green open space.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED12 David Noble Maps 26

Organisation: Representing: Governors of Yelvertoft Primary School

Support/Object: Object

Supporting Documents:

Comment:

The governors of Yelvertoft School met on 4th December and unanimously resolved to oppose the proposed designation of the school playing field as a Local Green Space. The Governing Body have the view that such a designation would be damaging to the long term viability of the school as it would restrict development of the school for future generations of children. The governors consider that the protection offered under Section 77 of the Schools Standards and Framework Act offers adequate protection for the school.

The playing field is not accessible to the public and does not meet the NPPF criteria 2. The assertion contained in the Local Green Space Assessment document that the playing field is 'Regularly used by school and community. Used for village events' is false. To the governors certain knowledge the playing field has not been used either for a community or village event in the last 5 years, and probably much longer. The playing fields are used solely for educational purposes and school events, for example sports day. A small number of times a year parents and friends of the school are invited to such events as part of the children's social education. These are not public events. The playing field is surrounded by fences and is kept locked outside school hours. There is no public access to the playing field.

12 March 2018 Page 376 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED51 William and Wells Maps 30 Diana

Organisation: Representing:

Support/Object:

Supporting Documents: Map attached

Comment:

Parish Annex Local Green Space nomination We have received details of the above regarding our part ownership of The Green, Church Stowe. This is to inform you that the map detailing the area of The Green is incorrect in that the piece of land fronting our property (No 6 The Green) has been included. This is in fact part of our property. Please see attached corrected map. We trust that this correction will be made to all maps relating to The Green, Church Stowe.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED52 Nigel Bright Maps 30

Organisation: Representing: The Green (Church Stowe) Management Company Ltd. Support/Object:

Supporting Documents: Map attached

Comment:

Thank you for your letter Ref L141 dated 24 November 2017 advising of your plan to designate The Green, Church Stowe, as a Local Green Space in the Emerging Draft Local Plan.

The Green is owned by The Green (Church Stowe) Management Company Limited. The Company, in turn, is owned by the residents of the nine houses around The Green, each house owning one share of the nine issued shares. The Company was formed to purchase the land from the original developer of the site in order to both maintain (grass cutting and hedge trimming) and to protect The Green by enforcing the restrictions on any development as included in the covenants in the original purchase documents.

We are therefore happy to support the designation of The Green as a Local Green Space.

There is however one apparent problem arising from the map that accompanied your letter. Your plan appears to include the front garden of No. 6 The Green as part of The Green. The Land Registry Map that I attach clearly shows this not to be the case. I believe that Mr & Mrs Wells of 6 The Green have also written to you regarding this. I would appreciate you acknowledging that the Land Registry Map is the correct interpretation for the designation of the Local Green Space.

12 March 2018 Page 377 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED28 Angela Feltham Maps 39

Organisation: Representing: Parochial Church Council for All Saints Church, Norton Support/Object:

Supporting Documents:

Comment:

I am writing on behalf of the Parochial Church Council (PCC) for All Saints Church, Norton in connection with your letter dated 24th November 2017 regarding the nomination of the Graveyard of All Saints Church, Norton as a Local Green Space. The members of the PCC have discussed the matter and taken into consideration the comments of the Archdeacon of Northampton and the appointed architect to the PCC. There is no objection to this nomination, however, it is considered to be unnecessary. The graveyard provides the community with additional facilities which are compatible with the criteria for Local Green Space. These are over and above that of a burial site. The churchyard is enjoyed by dog walkers and people seeking rest and a place to retreat to. Due to its status in serving the local community and being an open burial site it is unlikely to be an attractive site for development. The PCC would be interested in receiving further communication from the Daventry District Council regarding this nomination.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED25 Andrew Clarke Maps 40

Organisation: Representing: Overstone Playing Field Association

Support/Object: Support

Supporting Documents:

Comment:

OPFA support the plan to designate Overstone Playing Fields as local green space.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED13 Sue Porter Maps 5

Organisation: Representing: Long Buckby Parish Council

Support/Object: Object

Supporting Documents:

Comment:

Further to discussions with the Chairman of the United Charities Trust, could we please ask that Cotton End Park is removed from the Local Plan.

12 March 2018 Page 378 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: 11 Policy PA1, Policies and Inset ED134A, ED134B Fran Rowley Maps 6

Organisation: Representing: Turley Moulton College

Support/Object: Object

Supporting Documents:

Comment:

We write on behalf of our client, Moulton College, in response to the Daventry District Council's emerging draft Local Plan Part 2 (‘Local Plan’). Our client is the landowner of the allotment site on the outskirts of Moulton, which is identified as a proposed ‘Local Green Space’ (number 93) within the Draft Local Plan and Policy and Insert Map Booklet.

Background Moulton College is a Further Education College, based in Moulton. It provides post-16 teaching, training and research opportunities across a wide range of specialist vocational and academic disciplines and its estate amounts to over 485 hectares. College buildings are focused on four sites: the ‘Main Site’, which is integral to Moulton village; and the Holcot Centre, the Pitsford Centre and Lodge Farm to the north of the village.

The allotment site, which forms the subject of this representation lies at the southern edge of the campus on the edge of Moulton Village. Under the draft Local Plan the land has been designated as proposed ‘Local Green Space’ (number 93) and therefore subject to Policy PA1 meaning that:

“The Council will protect the Local Green Spaces identified on the Insert Maps from development that would harm their function, openness and permanence unless in very special circumstances, where any harm is outweighed by other considerations.”

We strongly object to this allocation for the following reasons:

Local Green Space Criteria

The supporting text for Policy PA1, confirms that paragraph 77 of the National Planning Policy Framework (NPPF) applies. The sets the criteria for designation of ‘Local Green Space’ which are:

a) Where the green space is in reasonably close proximity to the community it serves;

b) Where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and

c) Where the green area concerned is local in character and is not an extensive tract of land.

We acknowledge that criteria a) an c) are satisfied insofar as the site is close to Moulton village and can be regarded as relatively small and local. However, we do not accept that criterion b) is satisfied.

Whilst the use of land for allotment purposes can be regarded as an enjoyable and productive pastime (and indeed this experience may be ‘special’ to some members of the community), this does not in itself afford this allotment particular local significance or suggest that it is demonstrably special to the community of Moulton as a whole. We take the view that, if it did, then this would have been acknowledged in the adopted Moulton Neighbourhood Plan.

With reference to the Neighbourhood Plan, we note that there are not references to this specific parcel nor is there

12 March 2018 Page 379 of 399 any suggestion that the existing allotments are either a unique community asset, or of particular significance to the community. Indeed the only reference to allotments is wholly generic (at para 1.21) within the context of an overriding desire to protect and create open spaces across the whole of Moulton. Allotments just listed as one form of open space alongside the variety of other parks, gardens, playing pitches and nature reserves in the area.

It is relevant that this particular parcel of land has no historic significance, is not of any particular beauty in relation to the surrounding open spaces and countryside, nor does it have any particular richness in wildlife, or recreational value. To the contrary, the plot has no special or unique characteristics. It is not prominent, being largely hidden from public view through neighbouring residential property and through private College land to the north and west. This type of allotment space can be regarded as a common and usual aspect of many settlements.

To substantiate this position further, we have reviewed the ‘Local Green Space Assessment’ prepared by the Council to support the Draft Local Plan. This provides wholly inadequate justification for the proposed allocation in our view, simply stating that the allotments are demonstrably special because they are ‘used by village residents for food production’. The production of food by local residents is also possible within their own gardens; yet these are not considered ‘demonstrably special’ to the local community.

In any case, criterion b) requires that sites must be demonstrably special and have a particular local significance. It is not sufficient to rely on just one of these attributes.

Existing protection

It is highly relevant that the subject site is already subject to policies which afford them protection from development. this is confirmed through reference to the Glossary (Appendix B) of the Local Plan which states that allotments are ‘Green infrastructure’ and that under Policy ENV4, the Council ‘will protect, enhance and restore the District’s green infrastructure assets’. Furthermore, Policy CF1 (ii) – ‘Health and Wellbeing’ confirms that the protection, management and enhancement of green infrastructure will be supported.

The Moulton Neighbourhood Development Plan also affords this site some protection from development, through its designation within the Pages Brook Valley ‘Green Space’ and associated Policy E1.

In this context, we can see no justification for imposing a further layer of protection on this site.

Scope for Re-provision

You will be aware that Moulton College has previously identified the subject site as having for residential development, in association with further land to its immediate north. This position was made clear by the College in its response to the Council’s ‘call for sites’ submission in January 2016, where it was highlighted that the land could be regarded as a highly suitable and sustainable site for housing, being well related to the settlement boundary and within very close proximity to a range of amenities and services within Moulton.

With reference to the lease, it could be expected that any future development on this site, resulting in loss of the allotments would necessitate their pre-provision elsewhere in proximity; and, as an extensive landowner, there is significant scope for Moulton College to help facilitate this.

The fact that re-provision of the allotments on an alternative site in Moulton is a realistic and reasonable expectation in respect of any future development proposal, and that this re-provision could be expected to fulfil the community’s needs further confirms that this specific plot does not merit any special protection.

Consultation and engagement

We would take the opportunity to express the College’s serious concern with the absence of engagement with them in relation to this proposed designation, prior to the draft Local Plan being formally published. As a landowner with significant land holdings within the parish boundary of Moulton, and with a vested long term interest in the proper stewardship of its Estate, it is critical that it is informed at the earliest stage of any potential changes, arising from third party interests.

12 March 2018 Page 380 of 399 Conclusion

It is submitted that there is not the requisite justification for the allotment sites to be designated as a Local Green Space. The designation is not necessary nor does it satisfy the criteria for designation under paragraph 77 of the NPPF.

We therefore, respectfully request that the proposed designation is removed from the emerging Draft Local Plan Part 2 and the Policy and Insert Map Booklet.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Appendix B Glossary ED125 Tom Clarke

Organisation: Representing: Theatres Trust

Support/Object:

Supporting Documents:

Comment:

For clarity, and so that guidelines are clear and consistent, we also suggest the Glossary should contain an explanation for the term ‘cultural, arts and community facilities.’ We recommend this succinct all-inclusive description which would obviate the need to provide examples: cultural and community facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Habs Reg Habitats Regulation ED62 Alison Collins Assessment Screening

Organisation: Representing: Natural England

Support/Object:

Supporting Documents:

Comment:

Thank you for your consultation on the above which was received by Natural England on 22 November 2017.

No objection Natural England notes that your authority, as competent authority under the provisions of the Habitats Regulations, has screened the local plan to check for the likelihood of significant effects. Your assessment concludes that the local plan can be screened out from further stages of assessment because significant effects are unlikely to occur, either alone or in combination. On the basis of information provided, Natural England concurs with this view.

12 March 2018 Page 381 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: HELAA HELAA ED99 Gareth Johns

Organisation: Representing: Savills Society of Merchant Venturers (SMV)

Support/Object:

Supporting Documents:

Comment:

Savills is instructed by the Society of Merchant Venturers (SMV) to submit representations in response to the Daventry District Council (‘DDC’) Settlements and Countryside Local Plan (Part 2) Emerging Draft Consultation Document, herein after referred to as the ‘Emerging Draft Paper’.

Background

Specifically, this representation is made in relation to our client’s interest at ‘Land off Northampton Road’ and ‘Land off Station Road’. We have previously submitted the sites to the Council and they are identified within the Council’s Housing and Economic Land Availability Assessment (HELAA) as Site References: 114 and 115 respectively.

The HELAA confirms that the sites are ‘not suitable’ for residential development – although, it is noted that this is due to the sites lying outside the village confines in the open countryside and therefore they do not meet the requirements in the West Northamptonshire Joint Core Strategy (WNJCS) and Brixworth Neighbourhood Plan. Indeed, it is acknowledged in the HELAA that no sites at Brixworth are deemed ‘suitable’ for residential development.

12 March 2018 Page 382 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: HELAA HELAA ED99 Gareth Jones

Organisation: Representing: Savills Society of Merchant Venturers (SMV)

Support/Object:

Supporting Documents:

Comment:

Land off Northampton Road and Land off Station Road

The SMV’s land off Northampton Road and Station Road is immediately adjacent to the built-up area of Brixworth, albeit the Council’s HELAA identifies the site as ‘not suitable’ for development as the sites lies outside of the village confines in the open countryside (where there is a general presumption against new development).

However, we consider that the Council’s HELAA is not an appropriate assessment of the sites because Policy RA1 will support development outside the village confines in ‘exceptional circumstances’ and there is a need to identify reserve sites to make the Plan more robust (see comments above). Accordingly, the HELAA should also assess the suitability of those sites outside of the village confines within the context of the built up area of the settlement.

Furthermore, it was acknowledged that the sites are currently located partly within (Northampton Road) and adjacent (Station Road) the Special Landscape Area (saved Policy EN1 in the Daventry Local Plan (1997)). However, we note that the Daventry Landscape Study (November 2017) includes a review of the Special Landscape Areas (SLAs). This demonstrates that the SMV’s land is no longer within and/or adjacent to the SLAs and, therefore residential development in these locations would be in keeping with the surrounding area.

We consider that the development of the ‘Land off Northampton Road’ for up to 150 dwellings and ‘Land off Station Road’ for 15-20 dwellings are deliverable options for the following reasons:

- Brixworth is capable of accommodating significant levels of growth given the range of services and facilities it currently offers and is therefore a sustainable location for development.

- Residential development in this location would be in keeping with the surrounding area. The site would adjoin the existing built up area and is considered an appropriate extension to Brixworth.

- The site is well related to and within walking distance to the village facilities, including the primary school, pubs, church, convenience store etc. and has access to frequent local bus services. Development on this site may not only assist in supporting such facilities and other business services in the village, but also has the potential to deliver other community benefits to the village.

- Opportunity to deliver new areas of green infrastructure/public open space.

- The site has access to local employment opportunities within Brixworth.

- The scale of dwellings proposed is capable of delivering housing in line with local objectives, such as need for affordable housing.

- There are no planning history or policy constraints which would prevent the site coming forward for housing.

- There are no environmental or physical constraints to the site.

The above clearly demonstrates that both sites are suitable, available and achievable for residential development. Moreover there are no significant constraints which will prevent development on the sites and their allocation as reserve sites.

12 March 2018 Page 383 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: HELAA HELAA ED80 Robert Love

Organisation: Representing: Bidwells Davidsons Developments

Support/Object:

Supporting Documents: Attached - Planning Promotional Document: Land off Lilbourne Road, Yelvertoft

Comment:

Land at Lilbourne Road, Yelvertoft, Northamptonshire

My client wishes to promote their land interest at Land at Lilbourne Road, Yelvertoft for residential allocation through the Settlements and Countryside Local Plan (Part 2) for Daventry District. The site equates to an area of approximately 2.39ha.

The Planning Promotional Document enclosed with this representation to the Draft LPP2 has been prepared in support of the site’s proposed allocation.

Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing by identifying and updating annually a supply of deliverable sites. Footnote 11 of the NPPF states that to be considered deliverable, sites should be available now, offer a sustainable location for development now, and be achievable on the site within five years and in particular that development of the site is viable.

It is considered that the site can accommodate approximately 50 dwellings. Masterplanning can be prepared for the site to show details of proposed layout and design to identify how residential development of the site can be delivered. Proposed residential development of the site will provide significant benefits including contributing towards the housing needs Daventry District by providing a mix of types and sizes of market and affordable housing, contribute to a deliverable supply of housing and contribute towards the local economy.

The proposed development of my client’s site would be supported by a planning application which would be accompanied by a detailed package of technical information to demonstrate that the proposed development will not result in any significant harm to matters of acknowledged importance, such as highway safety, flooding, ecology, arboriculture, heritage, archaeology or landscape and visual amenity.

An outline planning application at the site (reference: DA/2015/0790) for up to 50 dwellings including the allocation of land for additional car parking for Yelvertoft Village Hall was submitted in August 2015. The application was subsequently withdrawn in February 2016. Another outline planning application at the site (reference: DA/2016/0754) for up to 50 dwellings including the allocation of land for additional car parking for Yelvertoft Village Hall (resubmission) was submitted in August 2016. The application was refused in February 2016 for the following reasons:

1. Proposed development within open countryside and outside of the village confines – contrary to Policy R1 (criteria E and G) of the WNJCS. It has not been adequately demonstrated that the proposed development would enhance or maintain the vitality of the rural community or would contribute towards and improve the local economy. The Council can demonstrate that the scale of development for the Daventry Rural Area (Policy S3 of the WNJCS) has now been exceeded and accordingly the provisions of Policy R1 (i) to (v) of the WNJCS are engaged. The proposal would not result in environmental improvements on the site as is required by Policy R1 (i) as it involves the loss of greenfield beyond the village confines; it has not been demonstrated that the development is required to support the retention or improvement to local services that may be under threat as required by Policy R1 (ii). Additional policy considerations.

2. Absence of a full two-week traffic speed survey to agreed parameters around the proposed point of vehicular access onto Lilbourne Road, as advised by the Local Highways Authority.

3. Absence of an archaeological field evaluation.

4. Absence of an up-to-date protected species survey.

We consider that reason for refusal no. 1 is not a technical reason for refusal and is therefore not relevant in the context of the Council’s assessment of the site for a proposed housing allocation in the Draft LPP2. As noted previously, DDL are preparing a formal representation in respect of the consultation to the Draft LPP2. The formal representation

12 March 2018 Page 384 of 399 considers that Council should take a more proactive approach to identifying additional housing in the Local Plan Part 2 based on potential additional housing need from more up-to-date evidence base that will underpin a review of the WNJCS. Therefore, the Council should seek to identify additional housing allocation in the Draft LPP2 in the District’s rural area.

We consider that reason for refusal no. 2 is a technical reason for refusal that can easily be resolved. A full two-week traffic speed survey can be prepared for the proposed development of the site and the parameters around the proposed point of vehicular access onto Lilbourne Road can be agreed with the Local Highways Authority.

We consider that reason for refusal no. 3 is a technical reason for refusal that can easily be resolved. An archaeological field evaluation can be prepared in relation to the proposed development of the site in order to demonstrate that there is no adverse impact on archaeological sites of potential interest. An appropriate mitigation strategy can be agreed with Northamptonshire County Council.

We consider that reason for refusal no. 4 is a technical reason for refusal has been resolved. Up-to-date ecological surveys have been prepared for the site and details are provided within the Planning Promotional Document in support of this representation.

In view of the above, the site represents an achievable, suitable and deliverable allocation to support the necessary housing growth for Daventry District in the context of paragraph 47 and footnote 11 of the NPPF in a sustainable location. Village amenities and services are located along the High Street in Yelvertoft, all within safe walking distance. These include a primary school, local shop, post office, village hall, pub, church, public open space, sports facilities and local bus service. Yelvertoft is served by a regular local bus service with direct links to Northampton, East Haddon, Long Buckby, West Haddon, Crick, DIRFT and Rugby.

The proposed development of the site will contribute towards the Council’s current or future housing requirements. The site can be developed within the forthcoming five-year period, which will contribute significantly towards maintaining a rolling 5-year supply of suitable housing sites throughout the remainder of the plan period and moving forward towards a review of the WNJCS.

The proposed allocation and development of my client’s site will assist with sustaining the local amenities and services of Yelvertoft. This is especially important given that the population of the village has declined from approximately 821 people (2001 Census) to approximately 764 people (2011 Census).

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: HELAA HELAA page 380 ED20 Susan Hicks

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

HELA, rural areas residential page 380, submission 302 land available at Hannington on edge of village for housing. 1. There is a housing shortage in the UK 2. The plot is available at the edge of the village 3. There is access for horsebox weight vehicles 4. There is water to the site 5. We offered a plot for a wellbeing centre where currently there is no GP surgery and an ageing population.

We therefore believe the site to be suitable for housing development. We believe the plot suitable for development.

12 March 2018 Page 385 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies & Inset Maps 8 ED132 Paul Grazier

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Objection

I would like to object to the Policies and inset map for Woodford Halse confines map as indicated on page 8 of the local plan policy maps booklet. The Map does not align with the NDP map which is currently being reviewed by an independent examiner.

My complaint with regard to the Woodford Halse policy map on page 8 stems from the development of the Woodford Halse Neighbourhood development plan (NDP). The map does not follow the DDC guidance for recent planning for built development - it states it should be included in the confines. The new confines now put a recent planning approval out of the confines and a current application out of the village confines, despite these being included in the NDP.

Neighbourhood Development (NDP)

I raised a number of issues with the NDP leading up to this and the Daventry District Council Policy officers were instrumental in resolving my issues regarding the village confines.

• I initially raised issues with the NDP and logged a complaint at regulation 14 stage in Nov 2016, after an initial visit by the NDP I discussed my concerns, but then did not receive any feedback, the only form of feedback I received was in the form of the NDP being submitted to DDC without my objection being included. It had been removed by the NDP prior to submission (The submission to DDC is for the DDC policy officers to review the plan for regulation 16, then submit it to an external examiner).

• I complained to DDC about my objection being removed (The NDP initially told me I would have to submit another objection later).

• The DDC policy officer suspended the start of regulation 16 (in Aug 2017) and asked the Woodford Halse NDP to reinstate my objection. After some lengthy correspondence with the DDC planning policy officer the confines on the NDP map where amended to include my property and the Regulation 16 process started. (The NDP had excluded my property and a number of properties within my area of the village confines).

• I was asked to review the new policy map and signed to say that I agreed to support the NDP due to my property being back within the village confines.

• In Sept 2017, I checked the link on the council Website which allowed the public to view the links. I noticed that the map on page 10 of the NDP, had reverted to the old policy map version, again I was out of the confines. I reported this to the DDC policy officer. Apparently the DDC had requested amendments, but unfortunately the NDP team resubmitted the old copy. DDC policy requested the NDP to reinstate the new map, and worded an issue on the website that there had been a technical issue.

• By Oct 2017 DDC had reviewed the NDP documents and submitted their comments, on page 3 of the DDC comments - it stated the reinstatement of the confines on my property, and suggested other areas of amendment. On page 20 it showed the NDP boundary with the proposed recommendations, my property was still within the confines and my garden retained its length of 34 mts within the confines.

12 March 2018 Page 386 of 399 Local Plan Policy Map Booklet Page 8

My current planning application started at pre planning stage in Jan 2017, I then applied for full planning in Sept 2017. My property at this stage was within the confines of the NDP, and still is at present. A planning decision was due at the beginning of Nov 2017. However the planner asked if it could be postponed until the beginning of Dec 2017, due to waiting for a decision from planning policy. In Jan 2018 I requested an update from the planning officer, I was informed the confines on the new Local plan were different from the confines on the NDP and a decision would be delayed, due to them not being aligned.

On the 23rd of Jan, I received an update from DDC Policy giving an update on the Woodford Halse NDP. In a link in one of the documents it referenced the Local plan. I checked the policy map on page 8 of the booklet, and contacted policy to ask why the confines had moved.

• As I have previously stated the DDC planning policy was instrumental in the NDP confines being amended to their current location, their recommendations also clearly show my property still within the confines.

• The new DDC Local plan has moved the NDP confines line 20mts forward basically putting both my approved planning application and my new planning application out of the village confines.

• I asked for the reason how this could happen, after my lengthy issues with the NDP. It was the same policy team. I requested what process was used. I was eventually told they are defined through site visits (no one has come to my property) and Aerial Photography etc.

• The comment was that “I agree that the boundary is slightly different in the two documents but no decision was taken to deliberately “change” the boundary at this point.

• I checked the scale and compared the two maps (Local Plan and NDP) the only residential garden to be reduced within the area is my garden this coincidently corresponds to the size of the house in my current planning application.

12 March 2018 Page 387 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Map - ED53 DJ and S Wilson Badby

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

For the reasons set out below we cannot agree with and do therefore object to the proposed inclusion within the Village Confines of the outlying dwellings at Nene Side Close and the bungalows at the top of Bunkers Hill.

The main built area of Badby village lies tucked within a valley formed in the southern flank of the Upper Nene Valley which lies to its North. Viewed from every direction other than from the North, the village is well screened from sight by the lie of the surrounding land.

Set apart from the main settlement, the bungalows at the top of Bunkers Hill sit prominently on high ground above the rest of the village with no dedicated footway link to them, whilst the dwellings of Nene Side Close lie entirely to the North of the Nene and are surrounded by open countryside.

Notwithstanding the recent extension of the garden of Bridge House and the new house on Pinfold Green, Nene Side Close remains separated from the village by a succession of small enclosures, mainly pasture land but including also the lower parts of Challis’ Yard, all of which are liable to flooding. These form both a wildlife corridor linked to farmland to the East and a distinctive element of the village setting which adds also to the amenity of neighbouring residents.

Both groups of dwellings spill out beyond the valley setting of the main village and are thus visually and topographically set apart and detached from it. The drawing of a line around a garden on Bunkers Hill and another around the new house on Pinfold Green and the extended garden of Bridge House to link these two areas to the rest of the village cannot change that basic geographical fact.

These two outlying groups of houses have for many years been held to fall outside the Village Confines for planning purposes. Meanwhile there has been no material change in the provisions incorporated in Daventry District Saved Policy HS22 para 4.90 and those set out in the DDC Guidance Note for Defining Village Confines (Version 2 Jan 2017) at Category E of the Principles for Exclusion. Both expressly provide for the exclusion from the Village Confines of these areas precisely on the grounds that they are groups of dwellings that are detached from or peripheral to the main body of the village.

This is the position adopted in the Draft Badby Parish Neighbourhood Plan and this is the position that we do firmly support.

Conclusion The continued exclusion of Nene Side Close and the bungalows at the top of Bunkers Hill from the Village Confines only properly reflects their outlying nature whilst recognising the importance of maintaining the much valued contribution of the encircling unspoilt landscape to the character of the village and all that this means for its residents sense of place and quality of life. With regard to Nene Side Close, it makes sense also to ensure that any future development avoids the risk of flooding or of increasing flood risk elsewhere.

12 March 2018 Page 388 of 399 For the reasons set out above, we ask for a reconsideration as they relate to Badby of the Principles for Exclusion from the Village Confines of dwellings that are detached or peripheral to the main body of the settlement with a view to the exclusion of Nene Side Close and the bungalows at the top of Bunkers Hill from the Confines of the Village.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Map 13 - ED113 Toby Haselwood Byfield

Organisation: Representing: Sworders Michael Thompson

Support/Object: Object

Supporting Documents: Attached - site plan

Comment:

The land off Boddington Road, Byfield is entirely viable and deliverable because, although not currently illustrated within the proposed Byfield Inset map, it benefits from being an obvious infill plot and the proposal map should be altered accordingly. The site benefits from existing road frontage and could deliver up to ten dwellings in a sustainable rural settlement. We therefore suggest that the Byfield Inset Map be amended to include this site.

12 March 2018 Page 389 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Map 14 - ED127 Ben Hall Creaton

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I write as the owner of Berkeley, 15 Teeton Lane, Creaton. My comment on the draft local plan predominantly relates to a drafting mistake on the Council’s draft policies map. In order to successfully reiterate my comments, I have attached the title plan for my property and a snapshot of the Councils proposed policies map for the settlement edge of Creaton.

As you will note, the layout of garden and wider land associated with my property extends to the south west of the building, beyond the southern elevation of the property itself. It does not form what I would consider a normal ‘back garden’ that would extend out to the rear of the property, which in this care would be due east of the property.

I have reviewed the Councils proposed draft policies relating to development in small settlements such as Creaton which I note is a ‘Secondary Service Village’. It suggests that development will be located within the confines of the settlement as defined on the attached map. As such, should I wish to develop my property within the boundary of my own curtilage, using the draft maps, I will currently be against this policy as any building will be located outside of the boundary.

I do not consider this approach to be justified by the Council in the context of a review I have undertaken of other nearby settlements boundaries as shown as part of the draft documents. None of these settlement boundaries simply ‘cut’ gardens in half from the settlement edge as the policy boundary for Creaton and my property. As such, it is considered that this approach the Council has applied specifically to Creaton’s settlement boundary is not consistent with other secondary village envelopes. Further, Point C of the table contained at Paragraph 5.2.23 suggest that any proposals should ‘Protect the integrity of garden or other open land that makes an important contribution to the form, character and setting of the settlement’.

I do not believe that garden of Berkeley relates to open countryside as the policy suggests. It is heavily planted with trees, vegetable garden, orchards and is hemmed in by a building with planning consent for a business and complex of bards and agricultural buildings to the west and two houses to the south. No part of this garden runs out into open countryside.

The Village in recent years has been lacking in any development for family housing and I feel that my efforts to buy a property within the locality which has the potential to accommodate a family subject to a sensitive extension is justified.

I consider my concerns to be valid in this context and likely consider this is a drafting error made by the Council during a desk-based analysis. I would be grateful if you could therefore amend the policy maps to include the curtilage of my property in line with other settlement boundaries throughout the District. Should you need any further information on this, I would be more than happy to discuss and provide this details.

12 March 2018 Page 390 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Map 52 - ED124C Val Coleby Northampton Fringe

Organisation: Representing: Berrys Vanderbilt Strategic Ltd

Support/Object: Object

Supporting Documents: Attached - site map and Northampton Fringe Inset Map with alterations

Comment:

We welcome the opportunity to submit representations on the Daventry Settlements and Countryside Local Plan Part 2 on behalf of Vanderbilt Strategic Ltd.

We object to the omission of the boundaries of the Northampton related Sustainable Urban Extensions (SUEs) and the Northampton Related Development Area (NRDA) on the proposals map.

Whilst the Daventry SUEs are shown the Northampton Related SUEs and NRDA boundary are not. As a consequence the plan lacks clarity and causes confusion as it (wrongly) implies policy RA5 – Open Countryside applies the SUE and NRDA area.

The NRDA boundary and boundaries of the Northampton SUEs should be shown on the proposals map and relevant inset maps.

12 March 2018 Page 391 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Maps ED77C Gerald Willard

Organisation: Representing: WW Planning Mr & Mrs Krempels

Support/Object: Object

Supporting Documents: Site plan attached

Comment:

I am instructed by my client Mr P Krempels of Moulton Mill to review this emerging draft plan and to comment on it.

The draft plan clearly focuses upon Daventry as the principal centre. It is understandable but given the economic, political and sustainability gravity of Northampton the plan cannot disregard from the plan the prospect of growth to Northampton taking place.

The plan and the proposal map especially shows no capacity for any sustainable extension to the north of Northampton. Indeed the suggest of imposing green wedges (ENV3) to the north of Northampton is a constraint in the short, medium and longer term to the future modest sustainable expansion to the edge of Northampton and which might support additional housing and jobs.

In a separate submission there is an objection to the main draft policy constraint in the form of policy ENV3. This submission suggests that as an alternative to adopting a green wedge tightly around Norther Northampton (especially between Boughton and Moulton) the plan should instead allocated land that adjoins the northern boundary for future development needs.

Opportunity should be taken to support limited and sustainable expansion to the north of Northampton and this is especially so on land to the north of Moulton Park. By designating land adjoining Northampton for development in this plan or allocating it as White Land (or some similar designation which protects land for future development needs) the LPA could support mixed housing and/or employment development in sustainable urban fringe locations whether in the short term or by protecting the land by an allocation ensuring it would suitable for development in the future during a future plan making period.

Allowing for additional land for housing would accord with text in the draft plan as follows:

6.1.08 Finally, the WNJCS also allocated land for a total of 4,000 dwellings on the Daventry North East Sustainable Urban Extension. It was assumed within the WNCJCS that 2,600 of these dwellings would come forward during the plan period i.e. up to 2029. However, the site has not progressed at the rate that was anticipated in the WNJCS. At the time of writing a planning application has yet to be submitted for the site, although it is expected to be submitted shortly. Consequently it is unlikely that 2,600 dwellings will come forward over the plan period, and as set out in the 2017 Housing Land Availability 2017 report this has been revised 1,570 dwellings.

6.1.09 The Issues and Options consultation (as at 1st April 2015), taking into account the sites set out above, identified that there was a residential requirement of 511 dwellings for this plan to allocate. However taking into account the slippage in delivery of Daventry North East, and other updates, this requirement has now increased. The current position is summarised in Table 4 and Figure 5 below identifies where the main commitments are located.

Allocating land for housing that is within the suggested growth area to the north of Northampton (between Boughton and Moulton) which is suggested would provide additional land in a sustainable location which could help to meet Daventry District's future housing and or employment needs.

This matter cannot be divorced from proposals also prepared to provide a Northern Orbital Route around Northampton. Whilst the alignment of this proposed road and linkages to it raise a range of planning issues what is highly likely to transpire is that such a road can only be undertaken if it funded by new development close to it and

12 March 2018 Page 392 of 399 dependent upon the road capacity that such a new road would provide. This being the case close and careful scrutiny must be paid to considering development options to the north of Northampton.

Change requested This submission on behalf of Mr Krempells makes the following suggestions for new policies and changes to the proposals map:

1. To include within the plan the land shown in grey on the attached plan as land being suitable for a small sustainable urban extension to accommodate housing and or employment uses. 2. To show that land about 200 metres deep to the north of Northampton between Boughton and Moulton is allocated for development in the short term or to indicate its suitability for sustainable development in the future (a white land designation).

Note: a plan is attached to this submission which shows land to the north of Northampton, between Boughton and Moulton which is available, deliverable and suitable for future development needs either as housing or employment land is in a highly sustainable location.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Maps 10 ED106A Dalton

Organisation: Representing: Howard Sharp and Partners LLP The Executors of VM Knowles Deceased

Support/Object: Object

Supporting Documents: ED106B Map

Comment:

The position of Barby in the settlement hierarchy as a Secondary Service Village is supported and it is agreed that it has an important role in providing services and facilities for the local community.

This objection relates to page 10 of the Policies and Inset Maps Booklet which is the Inset Map for Barby.

The land to the east of Kilsby Road, Barby as shown on the enclosed suggested amendment to the policy map is considered to relate closely to existing built development. It is very well contained by mature trees and vegetation and it is bounded by a watercourse at the eastern edge. These features physically and visually enclose the existing settlement from the countryside to the east. The permanent natural feature of the watercourse would form a logical line for the settlement boundary to follow and the boundary should be amended in line with the attached drawing.

12 March 2018 Page 393 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Maps 19 ED101A Katrina Jones

Organisation: Representing: Naseby Parish Council

Support/Object:

Supporting Documents:

Comment:

The Parish Council agrees with development being restricted in Naseby to the area inside the boundary designated for infill. However, the Parish Council disagrees with the boundary illustrated on the map for Naseby exhibited with the Emerging Draft Local Plan, Part 2. The boundary around the village on the map exhibited does not include a bungalow on Thornby Lane named ‘Southfields’. The Parish Council would ask that the boundary be extended to include the bungalow only and not its garden. Recent development next to and opposite ‘Southfields’, Thornby Lane, has extended the previous village boundary beyond the boundary designated in Naseby’s Village Design Statement (2009). An extension of the boundary to include ‘Southfields’, Thornby Lane would provide consistency. A plan marking ‘Southfields’, Thornby Lane, Naseby is attached.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Maps 52, ED63 William Shearer Policy ENV2

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

Existing policy shows all the land north of Northampton in the area of Church Brampton to be Special Landscape Area, which has now been deleted. This should be reinstated to give the maintain the current high level of protection.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies and Inset Maps page ED43 Tom Benyon 21 Spratton

Organisation: Representing: Oastlodge Limited

Support/Object: Object

Supporting Documents:

Comment:

The Inset Map now does not take into account recent Planning Consent ref DA/2017/0407. This should help remove the rather unusual kink in the plan on this section of Yew Tree Lane.

12 March 2018 Page 394 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: Map Policies Map ED42A Yvonne Dean

Organisation: Representing: Welford Parish Council

Support/Object:

Supporting Documents: ED42B Map

Comment:

The plan was welcomed overall for its support of Neighbourhood Plans and sustainability agenda. There were some concerns recorded in the following order which negated neighbourhood plan objectives. 1.0 The Welford village confines boundary differs from Welford's own Made Neighbourhood Plan. As this was subject to considerable discussion with Daventry, it should be substituted with the 'Made' Neighbourhood Plan Map (see annotated map).

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: SA SA ED31 Anthony Davies

Organisation: Representing:

Support/Object:

Supporting Documents:

Comment:

I lose faith in such analyses when I read under Site 298 and again under Site 301 that these sites are serviced by a bus route. Clearly it is just a desktop exercise with no basis in reality. It is a major bone of contention that no bus routes serve Welton (and therefore that none venture north of the canal on Welton Lane). Buses do travel to the east on A361 and to the south to Monksmoor but none of these get to the above sites.

Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: SA SA EDS3 Jon Colbourne

Organisation: Representing:

Support/Object: Object

Supporting Documents:

Comment:

All of it; so many places it makes "bland" management type statements which don't actually say anything! It states things like 'minor negative effects' or minor positive effects and fails to actually say what the issues or pro's are. How is one supposed to assess the points raised if your not actually saying anything? I also question elements where you state there will be issues around flooding due to the use of flood plain but then the solution is to use environmentally efficient housing insulation??? Did anyone actually read the document before you published such a poorly written and factually incorrect document? See above; the document is of such poor quality and so lacking in detail ad facts that the DDC should be embarrassed you published it, but then you are still clinging to a 2004 'vision'.

12 March 2018 Page 395 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: SA SA part 2, page 72 ED8 Sharon Henley

Organisation: Representing: Northants Police

Support/Object:

Supporting Documents:

Comment:

Further point to note regarding SA report part 2 on page 72 where it states 'it is also important to ensure an increased presence through the provision of new policing facilities in new developments'. Northants Police do not require the provision of new facilities on new developments. We have developed a new policing model based on strategically located hubs across the county and officers are located there or co-located with fire service colleagues in fire service buildings. Other facilities are not required at this time nor in the foreseeable future. Please delete this sentence.

12 March 2018 Page 396 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: SA SA, Part 2, Part 3A including EDS6, ED98A Steve Harley sites information, Part 3B

Organisation: Representing: Oxalis Planning Pendrix Ltd.

Support/Object:

Supporting Documents:

Comment:

It is unclear what alternative approaches were considered in regard to the role of (some or any) of the Primary Service Villages in accommodating additional non-strategic employment sites.

It is unclear how well the emerging policies of the Part 2 Plan relate to the SA Framework and Objectives and how the emerging preferred approach compares to alternative policy approaches.

Sustainability Appraisal, including consideration of alternative policies or strategies 1.37 It is unclear how successfully the approach proposed in the Part 2 Plan, with no proactive or positive planning for additional job creation in these key settlements, will contribute towards delivery of the Plan’s objectives. It is also unclear to what extent the Council has considered allocating appropriate but higher levels of employment development to the Primary Service Villages, and how this approach compares in terms of the Plan’s objectives and in terms of delivering (maximising) sustainable development.

1.38 The Sustainability Appraisal report makes it unclear if an alternative strategy with specific employment land allocations to Primary Service Villages (as well as to Daventry town) was considered, and if it was, on what ground it was rejected. Crucially, it is not clear how an alternative approach with some additional non-strategic employment allocations outside of Daventry town would perform in comparison to the approach proposed in the Part 2 Plan.

1.39 As referred to below, the implication is that with the WNJCS overall jobs ‘monitoring target’ met across the area there is no need to consider additional employment land allocations to enable further job growth. The contribution this makes to sustainability and economic objectives is unclear.

1.40 Other parts of the SA report help to indicate other issues associated with the emerging Plan. For example, Table 4.1 of the Part 2 SA Report describes a ’future baseline’ in a scenario without the Part 2 Plan – with regard to ‘labour market and economy’, and ‘material assets’ respectively this includes “Continued high levels of in commuting and potential out commuting.”

“Land supply, in terms of plots with consent, has been increasing slowly since 2010 but will remain challenging, especially with regard to the delivery of employment uses.”

1.41 The Sustainability Appraisal makes reference to a number of relevant issues and considerations. The SA Framework used to test the Local Plan is intended to help “strengthen” it through an iterative approach to policy development. On review of the various SA reports it is not clear to what extent the proposed approach – with new employment allocations only located in Daventry town – respond to the SA Framework, or the issues raised by the appraisal questions.

1.42 The Part 2 SA report states: “The plan will need to ensure an appropriate provision of housing, including affordable housing, as well as a supply of employment land suited to the requirements of growth sectors in order to maintain economic success……. The plan will need to ensure an appropriate mix of land, premises and infrastructure are developed to meet the requirements of the economy, which is related to an understanding of economic trends.” (page 83). And: “sufficient range of employment sites is vital to the success of an area’s economy and the well-being of its residents.” (page 87)

12 March 2018 Page 397 of 399 1.43 It should be clarified how these details and issues have informed and been reflected by the policies and strategy in the current draft of the emerging Part 2 Plan.

1.44 The Part 3B SA report suggests that only sites in and around Daventry have been assessed as ‘reasonable alternatives’. It has not been possible to find or understand an explanation for this, or how the preferred approach would compare with a selective number of employment allocations to Brixworth as a Primary Service Village. The implication is that the overall WNJCS job requirement having been met is considered justification for only allocating employment land in Daventry town, but the sustainability and relationship with Plan objectives of this response is not clear.

1.45 SA report Part 3B (Table 2.1, page 6) suggests that policy EC4 will have a “neutral effect” on sustainability objectives. This supports the view that more could and should be done to create a policy approach for additional employment land which makes a more positive approach to the overall plan objectives, and to sustainability objectives.

1.46 Primary Service Villages such as Brixworth should be subject to a more proactive and flexible approach to enable them to accommodate further employment development over the plan period, and would make a direct and beneficial contribution to meeting stated economic and sustainability objectives.

Summary of objections and suggested amendments 1.47 Changes are required to ensure that the Part 2 Local Plan provides a suitably positive, proactive, and sustainable strategy for Daventry District. In summary, Pedrix’s representations are based around the following: • Objection to the lack of coherence in the SA - it is unclear how the proposals for new employment land allocations only in Daventry would help to improve or amend the likely ‘future baseline’ compared to alternatives with appropriate allocations to Primary Service Villages. Object to the conclusion that employment policies having a ‘neutral’ impact on most sustainability objectives is an optimal outcome.

12 March 2018 Page 398 of 399 Chapter: Para / Policy / Fig / Map/ SA Representation Reference: First Name: Surname: SA Sustainability Appraisal ED139A Roger Tustain

Organisation: Representing: Nexus Planning High Cross Farm Limited and Drayton Lodge

Support/Object:

Comment:

Sustainability Appraisal

2.47 Detailed comments on the Sustainability Appraisal (SA) are provided in separate representations, however a summary of our comments are provided within these representations for completeness and ease of reference.

2.48 The SA concludes that the site is one of the most appropriate locations for growth based on an assessment of reasonable alternatives. These reasonable alternatives were informed by technical assessments, location, capacity, site visits and workshops with stakeholders, including agents and landowners and then balancing this against identified issues and constraints of the site. Accordingly, Annex B of the Part 3A SA report identifies that Daventry South West (site 202) scores comparatively well, scoring a minor positive effect, or neutral effect on 9 of the 14 objectives (SO4, SO5, SP6, SO7, SO8, SO10, SO11, SO13 and SO14). We welcome the SA conclusions for these objectives.

2.49 It is noted that the site does attract one double negative in respect of its effect on ‘Soils, geology and land use’. This is due to the fact that approximately half of the site is designated as a Mineral Safeguarding Area for Sand and Gravel and the potential adverse economic impacts that might arise. However, in terms of Northamptonshire County as a whole, the site represents a fraction of overall mineral safeguarded areas, meaning its economic importance in the context of County mineral reserves is somewhat limited. Furthermore, Policy 28 of the Adopted Minerals and Local Plan (2017) sets out a number of scenarios in which non-mineral related development can proceed, one of which is if “there is an overriding need for the development”. It is clear that the Council has taken this designation in to consideration when assessing reasonable alternatives within the SA but has ultimately concluded the other significant benefits of developing this site and the general overriding need for housing in the District, would present the circumstances necessary to warrant the loss of part of this safeguarded site a conclusion we wholly support.

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