Northamptonshire County Council NORTHAMPTON NORTH WEST RELIEF ROAD Appendix 5.4 EIA Scoping Response
- JUNE 2019 PUBLIC Summary of Scoping Opinion Responses
Consultees Response received Northamptonshire County Council 16/08/2018
Daventry District Council 04/09/2018
Boughton Parish Council 18/09/2018
Highways England 4/9/2018
Northampton Borough Council 17/9/2018
Wildlife Trust for Bedfordshire, Cambridge and 30/09/2018 Northamptonshire Historic England 28/09/2018
Network Rail 02/10/2018
Environment Agency 04/09/2018
Northamptonshire County Council
FAO Daniel Patterson Please ask for: Peter Moor Tel: 01604 367019 WSP Our ref: 18/00002/SCO 1 Capital Quarter Your ref: 70021598 Tyndall Street Date: 18 September 2018 Cardiff CF10 4BZ
Dear Sir/Madam,
TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS 2017: REGULATION 1 SCOPING OPINION Proposal for the Scope and Content of an Environmental Impact Assessment for the North West Relief Road
Thank you for your e-mail and attachments received on 7 August requesting a scoping opinion in respect of the proposed North West Relief Road (NWRR). The scoping report has been the subject of consultation in accordance with the Environmental Impact Assessment (EIA) Regulations and copies of the responses received are attached for your information.
In accordance with the Town & Country Planning (Environmental Impact Assessment) Regulations 2017, the Environmental Statement means a statement:
a) that includes such of the information referred to in Part 1 of Schedule 4 as is reasonably required to assess the environmental effects of the development and which the applicant can, having regard in particular to current knowledge and methods of assessment, reasonably be required to compile, but
b) that includes at least the information referred to in Part 2 of Schedule 4;
The submitted environmental statement is therefore required to be in accordance with these Regulations.
Topics proposed to be scoped into Environmental Statement
. Air Quality; . Climate Change; . Cultural Heritage (including Archaeology); . Ecology and Biodiversity; Planning Services One Angel Square Angel Street Northampton, NN1 1ED w. www.northamptonshire.gov.uk t. 01604 367019 e. [email protected]
This information can be provided in an alternative language or format such as large print or audio cd. Contact 01604 366014
. Geology and Soils; . Landscape and Visual; . Materials and Waste; . Noise and Vibration; . People and Communities; and . Road Drainage and the Water Environment.
Overall I can confirm that the approach that you are advocating in the scoping report is considered to be generally acceptable and appropriate and this is reflected in the nature of the consultation responses which have already been forwarded onto you for information. These specific points are set out in this Scoping Opinion and you are required to have regard to them. In particular I would draw your attention to the following:
Air Quality
Please refer to the attached comments made by Northampton Borough Council’s Environmental Health Officer, in particular the reference to using the Northampton Low Emission Strategy, Highways England and Daventry District Council.
Climate Change
Please refer to the attached comments made by the Northamptonshire Wildlife Trust
Cultural Heritage (including Archaeology)
Detailed comments regarding cultural heritage and archaeology have been provided by Historic England, the County Archaeology Advisor, Northampton Borough Council and Daventry District Council’s Conservation Officer.
Ecology and Biodiversity
Detailed comments regarding ecological surveys and information have been provided by the Northampton Wildlife Trust and the Council’s Senior Environmental Planner.
Geology and Soils
Please refer to the attached detailed comments made by the Environment Agency and Daventry District Council.
Landscape and Visual
Please refer to the attached comments from Northampton Borough Council, Daventry District Council and Boughton Parish Council. In particular you should ensure that the
Landscape and Visual Impact Assessment should be undertaken using the most up-to- date published guidelines available.
Materials and Waste
The Planning Policy team commented that Para 10.4.5 of the Materials & Waste Chapter could be deleted (especially as it’s a bit confusing referencing the East Midlands as a whole but only referencing the Northants MWLP in relation to where information will be sourced). It might be better to add at end of 10.4.6 that up to date information regarding supply and demand for waste will be utilised.
Noise and Vibration
Please refer to the attached comments made by Northampton Borough Council’s Environmental Health Officer, Daventry District Council, Highways England and Boughton Parish Council.
People and Communities
Please refer to the attached comments made by Daventry District Council
Road Drainage and the Water Environment
Please refer to the attached detailed comments made by the Environment Agency, the Lead Local Flood Authority and Boughton Parish Council.
Traffic and Transportation
Detailed comments regarding traffic, transportation and access have been provided by Northamptonshire Highways and Highways England.
Cumulative Impacts
In assessing the likely effects of the development in respect of the various topics which are scoped in for Environmental Assessment consideration should be given to any cumulative impacts. In particular if there are other permitted developments nearby which if developed could give rise to significant environmental and amenity impacts. In particular you should refer to the comments from Northampton Borough Council and Daventry District Council. The Environmental Statement should address this possibility and the associated potential impacts.
Alternatives
An outline of the main alternatives considered should be addressed in accordance with the requirements of Schedule 4 of the EIA Regulations 2017.
The ES should also include a statement of relevant expertise or qualifications as required by Regulation 18 (5) (b). Should you wish to seek further clarification and assistance on the contents of this opinion please let me know.
Yours faithfully,
Peter Moor Principal Development Control Officer
Enc.
Environment Agency Highways England Daventry District Council (Environmental Health) Daventry District Council (Planning) Daventry District Council (Conservation) Northampton Borough Council (Environmental Health) Northampton Borough Council (Planning) NCC Senior Environmental Planner NCC County Archaeological Advisor Historic England Lead Local Flood Authority Northamptonshire Wildlife Trust Boughton Parish Council
Northamptonshire County Council
memo To: Peter Moor From: Lesley-Ann Mather Ref: 18/00002/SCO Date: 3rd September 2018 cc:
TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2017 SCOPING REQUEST CONSULTATION - REGULATION 15 PROPOSED DEVELOPMENT: Scoping Opinion for proposed North-West Relief Road (NWRR)
Peter
Thank you for your consultation regarding the content of the EIA Scoping Report.
Chapter 6 Cultural Heritage- I would expect the Desk based Assessment to include a full HER consultation with the HER not just a look at the online Heritage Gateway. The suggested search area of 300m is too narrow for undesignated assets. I would expect at least 500m or an area suggested by the Historic Environment Record officer. It is accepted within the EIA Scoping Report that a desk based assessment is insufficient to allow a full assessment of the archaeological potential along the route. I note however that the scoping document only suggests the undertaking of a geophysical survey Paragraph 6.4.6 to inform the Cultural Heritage chapter.
Paragraph 6.4.12- without the undertaking of intrusive evaluation in the form of trial trenching it will not be possible to understand the nature, extent and preservation of the archaeological resource within the route. It will also not be possible to outline suitable mitigation measures without the results of the geophysical survey and trial trenching.
It is expected that WSP 6.4.9 will consult with the County Archaeological Advisor with regard to all aspects of cultural heritage.
I look forward to discussing the methodology for both the geophysical survey and the trial trenching with WSP and the archaeological contractor who will be undertaking the works.
Regards
Planning Services One Angel Square w. www.northamptonshire.gov.uk t. 01604 367909 e. [email protected]
Lesley-Ann Mather County Archaeological Advisor
Peter Moor Our ref: AN/2018/127879/01-L01 Northamptonshire County Council Your ref: 18/00002/SCO One Angel Square Angel Street Date: 04 September 2018 Northampton NN1 1ED
Dear Peter
Scoping opinion for proposed North-West Relief Road (NWRR) North-West Relief Road (NWRR) Northampton
Thank you for referring the Scoping Opinion for the North-West Relief Road which was received on 4 August 2018.
The submitted report shows appropriate consideration of the environmental constraints within our remit. Therefore, we have no specific comments on the scope of the report but can offer the following advice that can be considered as part of the Environmental Statement.
Flood Risk Management We have reviewed the Road Drainage and The Water Environment chapter of the WSP EIA Scoping Report (70045931_SR1 July 2018) and would like the following to be considered in the Environmental Statement (ES):
The proposed route is on land located within Flood Zone 3 and defined by the Environment Agency Flood Map as having a high and medium probability of flooding. Paragraph 163, footnote 50 of the National Planning Policy Framework (NPPF) requires applicants for planning permission to submit an Flood Risk Assessment (FRA) when development is proposed in such locations.
Following the significant flooding to Northampton town centre in Easter 1998 improvements were made to the defences along the River Nene. In order to secure the level of protection afforded by the new defence we have agreed with the West Northants Joint Planning Unit that the standards set for new development should also be improved, beyond industry standards.
Therefore all new development in the Upper Nene catchment will be designed for a flood with a 0.5% probability(1 in 200 chance) occurring in any year, including an appropriate allowance for climate change. This includes design of mitigation for main river flooding and any surface water attenuation. This applies across the whole of the Upper Nene catchment including all branches and arms of the Nene, upstream of Billing Environment Agency Customer services line: 03708 506 506 Nene House (Pytchley Lodge Industrial Estate), Weekday daytime calls to 0370 numbers cost 8p plus up to Pytchley Lodge Road, Kettering, Northants, NN15 6JQ 6p per minute from BT Weekend Unlimited. Email: [email protected] Mobile and other providers’ charges may vary. www.gov.uk/environment-agency
Cont/d..
Aquadrome, and all tributaries such as Wootton Brook, Dallington Brook and Bugbrooke Brook.
This is supported by a document we produced ‘Strategic Review of development and flood risk, Nene catchment Northampton and upstream’ and reinforced more recently in the West Northamptonshire Strategic Flood Risk Assessment (SFRA) Level 1 (February 2009). http://www.westnorthamptonshirejpu.org/gf2.ti/f/278178/6412997.1/pdf/-/sfra_l1_v1.pdf
It is recommended that any main river crossings are clear span (no piers in the river). If the road is classified as essential infrastructure it should not flood in the 0.1% (1 in 1000) plus climate event.
The soffit of the structures should be a minimum of 600mm above the 0.5% (1in 200) plus climate change flood level and no lower than 300 mm above either of the upstream banktops.
The structures should provide a minimum of 8m flat working area either side for (maintenance) vehicular access along banks. With a 3m headroom.
The road should cross the floodplain in the most direct route possible to reduce the impact on flood levels and flows. The road within the floodplain may require flood relief culverts.
The majority of the proposed road appears to be located in flood zone 3. And parallel to the Brampton Branch of the River Nene, this means the floodplain of the river will be restricted. The road should not block flood water flowing into its natural floodplain. There should be no loss of floodplain as a result of the proposed road and the FRA should provide further details on any raising or lowering of land within the floodplain. Any loss of floodplain should be compensated for on a level for level, volume for volume basis (i.e. re-grade the land at the same level as that taken up by the development) therefore providing a direct replacement for the lost storage volume. Within the FRA, detailed information must be provided to demonstrate how this can be achieved. For further advice and guidance on the provision of floodplain compensation, please refer to direct replacement of flood storage within Section A3.3.10 Compensatory Flood Storage of CIRIA Guide C624: Development and Flood Risk, guidance for the construction industry.
The Upper Nene 2016 model is now available. The main purpose of this model update was to refine the operation of specific structures. The opportunity was taken to include reruns for the latest climate change allowances, however the model was not updated for this purpose and is not capable of performing beyond the 0.1% with 25% increase in flows.
Please request Flood Risk Assessment Data Information, by writing to Customers and Engagement, Ceres House, Searby Road, Lincoln, LN2 4DW or by email at [email protected] . Details of what the Flood Risk Assessment Data information products contain is available at https://www.gov.uk/guidance/flood-risk- assessment-for-planning-applications ‘Get information to complete an assessment’.
We would wish to agree the scope of the modelling work prior to any work taking place. Please submit a model scope in which you set out how you intend to update the model to demonstrate that there is no increase in flood risk either upstream or downstream and no loss of floodplain storage or channel capacity as a result of the proposed works.
Cont/d.. 2
Once this scope has been submitted, we can ask our Modelling team to review this. Updated guidance on how climate change could affect flood risk to new development - ‘Flood risk assessments: climate change allowances’ was published on gov.uk on 19 February 2016. Any modelling should include hydraulic modelling and sensitivity testing to take account of this. At this stage a meeting or teleconference can be arranged if our Modelling team deem it necessary.
Please note The Brampton Brook, in the report is labelled by the Environment Agency, as the Church Brampton Arm.
Flood Risk Activity Permit This development may require a permit under the Environmental Permitting (England and Wales) Regulations 2010 from the Environment Agency for any proposed works or structures, in, under, over or within eight metres of the top of the bank of a watercourse designated a ‘main river’. This was formerly called a Flood Defence Consent. Some activities are also now excluded or exempt. A permit is separate to and in addition to any planning permission granted. Further details and guidance are available on the GOV.UK website: https://www.gov.uk/guidance/flood-risk-activities-environmental- permits.
Groundwater & Contaminated Land We have reviewed the relevant sections of the Scoping Report and we have no additional comments to make.
Water Quality and the Water Framework Directive (WFD) We welcome the inclusion of a WFD assessment within the scope (13.4.19) with findings to be reported in the ES.
The current WFD assessment for the waterbodies within scope for this scheme are given below. The table shows the elements where the waterbodies are failing.
WFD Element Brampton Branch - Church Brampton Arm Lower GB105032045380 GB105032045390 Overall Water Body Status Poor Moderate Ecological Potential/Status Poor Moderate Biological Quality elements Poor Moderate Poor Moderate Macrophytes/Phytobenthos Physico-Chemical Quality Moderate Moderate elements Phosphate Poor Poor
Principally much of failures are attributed to diffuse pollution resulting from poor nutrient and land management.
We would like the ES to consider how appropriate measures could be undertaken during construction and operation that not only prevents deterioration of WFD classification but seeks to improve the status of these waterbodies.
The Brampton Branch catchment has suffered from channel straightening historically and there are straightened sections within the red line plan (Figure 2) that details the Cont/d.. 3
site boundary. There is also a disconnected meander at Grid Reference SP7340164770 where there could be the potential to reconnect. This would bring benefits of slowing flows, make the channel more sustainable in term of maintenance and increase habitat quality and could be considered as an opportunity to mitigate any habitat loss that results from the scheme.
Should the applicant wish for us to undertake a detailed assessment of the development proposal, review any technical documents or want further advice to address the environmental issues, we can do this as part of our charged-for service. Further engagement with us is likely to speed up and smooth the formal planning application process, reducing the likelihood of us raising an objection to the planning application and result in a better quality, more environmentally sensitive development. As part of our charged-for service we will provide a dedicated project manager to act as a single point of contact to coordinate our response and to help resolve any problems.
Our charge is £100 per hour plus VAT. The terms and conditions of our charged-for service are available here.
Please note: This response is based on the information you have provided at this time. It is also relevant to current national policy, associated legislation and environmental data / information. If any of these elements changes in the future then we may need to reconsider our position.
We trust that the above information is of assistance. If you’d like more detailed advice, please don’t hesitate to contact me using the details below.
Yours faithfully
Kerrie Ginns Sustainable Places - Planning Specialist Direct dial 02030253304 Direct e-mail [email protected]
End 4
EAST MIDLANDS OFFICE
Mr Peter Moor Direct Dial: 01604 735460 Northamptonshire County Council Planning Services, Floor 3 Our ref: PL00471268 Guildhall Road Block County Hall Northampton NN1 1DN 28 August 2018
Dear Mr Moor
TOWN AND COUNTRY PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2017 SCOPING REQUEST CONSULTATION -REGULATION15
PROPOSED DEVELOPMENT: Scoping Opinion for proposed north-west relief road (NWRR)
Thank you for contacting us on August 14, 2018 regarding a scoping opinion in relation to the above site. The proposed development is for the construction of north- west relief road linking the A5199 to the A428 to the north-west of Dallington.
Historic England has reviewed the information submitted in the scoping report from the applicant and our own records for the proposed development area. In our view, development is likely to have an impact upon a number of designated and non- designated heritage assets and their settings. We therefore consider it essential that the EIA process in this case is sufficiently detailed for it to assist in identifying how the proposed north-west relief road can be delivered sustainably without it having serious adverse effects on designated heritage assets.
General Advice In accordance with the advice in the National Planning Policy Framework (NPPF), we would expect the Environmental Impact Assessment (EIA) documentation to contain a thorough assessment of the likely effects which development might have upon those elements which contribute to the significance of heritage assets. In this way it should be possible to identify (and where possible avoid, minimise or if appropriate mitigate) what may be substantial direct and indirect impacts on assets of local, regional and national importance.
In general terms, Historic England advises that a number of considerations will need to be taken into account when proposals of this nature are being assessed. In order for the determining body to understand the potential impacts of the proposals on the significance of both designated and non-designated heritage assets of all types, we
2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk
Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.
EAST MIDLANDS OFFICE would recommend that you ensure that the Environmental Impact Assessment (EIA) conducted takes the following issues into account. This includes consideration of the impact of any associated ancillary infrastructure:
The potential impact upon the landscape, especially if a site falls within an area of historic landscape; Direct impacts on historic/archaeological fabric (buildings, sites or areas), whether statutorily protected or not; Other impacts, particularly the setting of listed buildings, scheduled monuments, registered parks and gardens, conservation areas etc., including long views and any specific designed views and vistas within historic designed landscapes. All grades of listed buildings should be identified. In some cases, intervisibility between historic sites may be a significant issue; The potential for buried archaeological remains; Effects on landscape amenity from public and private land; Cumulative impacts.
The level of carefully considered information required under the EIA process will need to be proportional to the severity of the potential issues which may arise from any proposed scheme, and directly related to the need to assess the overall sustainability of the development proposals.
Our initial assessment shows the attached list of designated heritage assets within 3km of the proposed development:
2 Scheduled Monument 6 Grade I & II* Listed Buildings 108 Grade II Listed Buildings 8 Conservation Areas 1 Grade II Registered Park &Garden
In addition we draw your attention to the importance of assessing the impact upon the non-designated but nationally important archaeological remains of a Neolithic causewayed enclosure to the northern area of the development site, and the Dallington Grange landscape, which is known to be archaeologically rich. You should therefore be guided by the expert advice of the County archaeological adviser who is best placed to advise on: local historic environment issues and priorities; how the proposal can be tailored to avoid and minimise potential adverse impacts on the historic environment; the nature and design of any required mitigation measures; and opportunities for securing wider benefits for the future conservation and management of heritage assets.
We advise that the determining body must ensure that the EIA process provides a
2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk
Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.
EAST MIDLANDS OFFICE sufficient understanding of the significance of all the heritage assets potentially affected both individually and as part of the development of the wider historic landscape. The EIA must provide a clear understanding of any e.g. historic and spatial relationships between assets whether designated or non-designated, as well as the specific contribution which the development site makes to the significance of any designated assets affected.
Archaeological impacts and impacts upon the built historic environment should be the subject of consultation with the heritage teams and Historic Environment Records at Northamptonshire County.
A structured and science based approach to archaeological deposit modelling and preservation assessment should developed in accordance with our published specialist advice using staff with appropriate expertise and experience.
We advise that the determining body must ensure that the EIA will provide a robust assessment of the impact of development on the setting of designated heritage assets including, but not limited to visual impacts. Heritage Assets are key visual receptors and any impact upon them would need to be considered in depth. This should also include an appropriate selection of viewpoints/photomontages relevant to the significance of the assets in question, to demonstrate the likely impacts of the development upon them and/or their settings. We would recommend the inclusion of long views and any specific designed or historically relevant views and vistas within the surrounding landscape.
Comments on Content of Scoping Report Historic England welcomes the inclusion of Cultural Heritage Chapter in the proposed scope of the Environmental Impact Assessment. In general we recommend that there should be a close relationship between the Landscape and Visual Impact Assessment and the Heritage Assessment.
We recommend that the extent of the study area is defined appropriately and in relation to the results of the Landscape and Visual Impact assessment with specific reference to a Zone of Theoretical Visibility. We recommend that you are also guided
2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk
Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.
EAST MIDLANDS OFFICE by the advice of the specialist, County archaeological advisor in relation to the definition of a study area for non-designated archaeological remains.
We would also recommend that the Good Practice Advice Note (2) on Managing Significance in Decision Taking in the Historic Environment is also consulted by the applicant in producing the Environmental Impact Assessment: https://historicengland.org.uk/images-books/publications/gpa2-managing-significance- in-decision-taking/
Historic Environment Good Practice Advice in Planning Note 3: The Setting of Heritage Assets (2015) http://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage- assets/
We also welcome the commitment of the applicant to embark upon a geophysical survey at the earliest opportunity in consultation with the County Archaeological Advisor.
Yours sincerely,
Neville Doe Assistant Inspector of Historic Buildings and Areas [email protected]
2nd Floor, WINDSOR HOUSE, CLIFTONVILLE, NORTHAMPTON, NN1 5BE Telephone 01604 735460 HistoricEngland.org.uk
Historic England is subject to both the Freedom of Information Act (2000) and Environmental Information Regulations (2004). Any Information held by the organisation can be requested for release under this legislation.
Our ref: Martin Seldon Your ref: 18/00002/SCO Assistant Spatial Planning & Economic Development Manager Floor 9 Peter Moor The Cube Northamptonshire County Council 199 Wharfside Street One Angel Square Birmingham B1 1RN Angel Street Northampton Direct Line: 0300 470 3345 4 September 2018
Dear Peter
NORTH-WEST RELIEF ROAD: REQUEST FOR ENVIRONMENTAL IMPACT ASSESSMENT (EIA) SCOPING OPINION
Thank you for inviting Highways England to provide comments on the scope of an Environmental Impact Assessment (EIA) prepared by WSP in support for the proposed Scoping Opinion for proposed North-West Relief Road (NWRR) to be located on land approximately 1.2 km south-east of Church Brampton, Northampton.
The EIA Scoping Report submitted by the applicant outlines in broad terms the likely impact of the construction, operation and decommissioning of the NWRR on the surrounding environment.
Comments relating to the local road network should be sought from the appropriate local highway authority.
General aspects to be addressed in all cases include:
An assessment of transport related impacts of the proposal should be carried out and reported as described in the Department for Transport (DfT) ‘Guidance on Transport Assessment (GTA)’ and in accordance with Circular 02/2013. It is noted that this guidance has been archived, however still provides a good practice guide in preparing a Transport Statement (TS) or Transport Assessment (TA). In addition, the Department for Communities and Local Government (DCLG) also provide guidance on preparing Transport Assessment.
Environmental impact arising from any disruption during construction, traffic volume, composition or routing change and transport infrastructure modification should be fully assessed and reported.
Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363
Adverse change to noise and air quality should be particularly considered, including in relation to compliance with the European air quality limit values and/or in local authority designated Air Quality Management Areas (AQMAs). With regard to environmental matters in relation to the strategic road network, paragraphs 45 to 48 of DfT Circular 02/2013 ‘The Strategic Road Network and the Delivery of Sustainable Development’ are pertinent.
Highways England recommends the following site specific considerations should inform the final EIA:
We note that the proposed relief road is located approximately 7 Km away from the M1 Junction 23, therefore there is no shared boundary to be considered.
Whilst the proposed Relief Road will not in itself generate traffic movements, it will result in the re-distribution of traffic movements. We therefore advise you to assess the likelihood and effect of the re-distribution of traffic resulting from the relief road. At this stage, we consider that this assessment will need to include the potential impact of the proposals on the M1, in particular Junction 16.
Furthermore, we advise the applicant to provide details regarding the potential impact of traffic on the M1 and A45 during the construction phases of the relief road. This should include details of HGV trips during the construction period and the routing to and from the site.
These comments are only advisory, as the responsibility for determining the final scope of the Environmental Statement would rest with the Local Planning Authority.
These comments imply no pre-determined view as to the acceptability of the proposed development in traffic, environmental or highway terms. Should the applicant wish to discuss the merits of the proposal in terms of the likely impact on the SRN please contact me on 0300 470 3345 or [email protected].
Yours sincerely
Martin Seldon OD Midlands Spatial Planning & Economic Development Team Email: [email protected]
Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ Highways England Company Limited registered in England and Wales number 09346363
Planning Service Planning Department The Guildhall St Giles Square Northampton. NN1 1DE
Tel: 0300 330 7000 Minicom: (01604) 838970 E-Mail: [email protected]
Northamptonshire County Council Our Ref: N/2018/1196 Mr Peter Moor Contact: Nicky Toon Planning Services (Development Control) One Angel Square Telephone No: 01604 837692 Angel Street Email: [email protected] Northampton Date: 17 September 2018 NN1 1ED
Dear Peter
PROPOSAL: SCOPING OPINION FOR PROPOSED NORTH WEST RELIEF ROAD (NWRR) LOCATION: NORTH WEST RELIEF ROAD (NWRR)
I refer to your letter dated 14th August 2018 regarding the above and request for comments on the proposed scope of the Environmental Statement for the above development.
The Council’s comments are as follows:
Section 4 - Air Quality
Section 4.4 states that the exact scope of the air quality assessment for the Proposed Scheme will be confirmed through consultation with Northampton Borough Council. It also provides a list of various documents to be referred to and I would suggest adding the Northampton Low Emission Strategy to this list.
Section 6 – Cultural Heritage
With regard to Figure 3, there is a combination of 3 ‘buffer zones’ shown, in a collection of circles. It would be prudent to seek clarity regarding where the 1km is to be measured from, if the identified buffer zone on figure 3 includes all of the circles and how the centre points for each circle has been determined as this will directly influence which heritage assets, both designated and non-designated, will need to be considered as part of the assessment.
This will then need to be reflected in the narrative which currently states that there are no conservation areas within a 1km study area. It is also likely to increase the number of listed buildings within the study area. The study should include both designated and non-designated assets. There are the remains of Upper Mill (corn) within/close to the site and some surviving Ridge & Furrow.
The Kingsthorpe Conservation Area Appraisal and Management plan identifies the location on sloping land on the edge of Northampton, overlooking the northern arm of the River Nene,
General Letter allowing open views across the valley, reinforcing the semi-rural character of the area, part of the conservation areas special interest.
Section 9 – Landscape and Visual
The broad approach is acceptable in principle. Proposed viewpoints should be agreed in advance with both the County Council Planning Services and Northampton Borough Council Planning.
Section 11 - Noise and Vibration
Section 11.3.11 states ‘in terms of future dwellings and development, it is understood these have been, or are being, designed with the Proposed Scheme in mind. Hence, no scheme- related effects are anticipated for proposed development and so these receptors are scoped- out of the assessment’.
The supporting evidence for this statement should be detailed for the avoidance of doubt.
General
An outline application is currently under consideration for the development of the land to the south, Northampton Kings Heath SUE (Dallington Grange), reference N/2014/1429. The Environmental Statement should give appropriate consideration to these development proposals particularly in regard to the alignment of the proposed road, areas of proposed sustainable urban drainage as indicated on the submitted Masterplan, and the impacts of the proposed road, on potential future residential development particularly in relation to noise and dust during construction and impacts during the operational phase, and visual impacts.
To note: Paragraph 2.1.5 – Watford is in Hertfordshire, not London.
Yours sincerely
Peter Baguley Head of Planning Planning Services
Gallie, Rebecca
From: Alex Gratrix
Good morning Development Control
Thank you for consulting me on this Scoping Opinion. I have two comments to make:
Section 4 Air Quality
Section 4.4 states that the exact scope of the air quality assessment for the Proposed Scheme will be confirmed through consultation with Northampton Borough Council. It also provides a list of various documents to be referred to and I would suggest adding the Northampton Low Emission Strategy to this list.
Section 11 Noise and Vibration
Section 11.3.11 states ‘in terms of future dwellings and development, it is understood these have been, or are being, designed with the Proposed Scheme in mind. Hence, no scheme-related effects are anticipated for proposed development and so these receptors are scoped-out of the assessment’.
The supporting evidence for this statement should be detailed for the avoidance of doubt.
Should you wish to discuss this further, please contact me.
Kind regards
Alex Gratrix
Mrs. Alex Gratrix Senior Environmental Health Officer
Customers & Communities (Regulatory Services) Tel: (01604) 837772 [email protected]
Please note I am in office on Mondays and Thursdays only.
Northampton Borough Council The Guildhall (1st Floor) St Giles Square, Northampton NN1 1DE
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1 Gallie, Rebecca
From: Rachel Booth
Hi Steve
I’ve only had chance to do an initial skip read through this.
Chapter 6 relates to cultural heritage. 6.2.1 - baseline conditions – refers to Northampton Borough Council but not DDC; 6.2.2 - The conservation areas for Harlestone, Boughton & Chapel Brampton, and Boughton’s registered park, should be included in the list (they are picked up in the LVIA chapter, but the cultural heritage chapter draws the boundary of the study area too narrowly. Only listed buildings in Harlestone are identified, but those in the other surrounding villages may also be affected by the proposals. They may need to consider the potential impact on the setting of more distant assets and elements of the historic landscape. 6.3.3 - also need to consider impact on any undesignated heritage assets that are identified by the heritage assessment 6.4.1 - I know you’ll pick this up in your response, but needs to have regard to changes in the new/updated NPPF - Planning practice guidance relating to conserving and enhancing the historic environment was updated February 2018 - refer to DDC planning policy & guidance, instead/in addition to Northampton Borough Council - refer to Harlestone conservation area appraisal and management plan (can be downloaded from the Council’s website at: https://www.daventrydc.gov.uk/living/planning-policy/conservation-areas/).
Happy to discuss further next week.
Thanks Rachel
From: Steve Ellis Sent: 14 August 2018 15:55 To: Katherine Daniels; Rebecca Grant; Bob Ham; Rachel Booth; Michael Venton; Richard Wood; Tom James Cc: Keith Thursfield Subject: FW: 18/00002/SCO Northampton North West Relief Road
Dear all,
Please see below and attached.
I am happy to co-ordinate a DDC Officer response. With that in mind, please let me have any comments by 28 August.
Thanks.
Steve
-----Original Message----- From: Keith Thursfield Sent: 14 August 2018 15:44
1 Patterson, Daniel
From: Chilver, Verity
Dear Peter
Thank you for providing Northamptonshire Highways Development Management with the opportunity to provide comment upon the proposed Scoping Note made in respect of the above mentioned development. We have the following observations to make by way of a response:
· The EIA scoping report does not include a ‘Transport’ Chapter in order to consider the proposed methodology of the EIA assessment required from a transport perspective. In the ‘Other Supporting documents’ section it references the provision of a ‘Transport Statement’ which is a lesser general document, rather than a ‘Transport Assessment’ which as you are aware is very detailed, the report then goes on to list the criteria necessary for a ‘Transport Assessment’. There is clearly some confusion in the document as to the transportation requirements of an EIA. To clarify, the LHA expects a full Transport Assessment (TA) to be produced, which would normally form the ‘Transport Chapter’ of the EIA. · The LHA expect the TA to be Scoped out with NH Development Management. · The transport modelling will require the use of the NSTM to assess the wider implications of the proposed scheme. · The traffic flows taken from the NSTM will need to be agreed with NH Development Management before any detailed design work is undertaken. · NH Development Management will need to check if the distribution and reassigned trips across the local highway network are likely to be accurate & realistic assumptions. · The impacts of the proposed development in this north western area of the town as a result of the road scheme being implemented will inevitably require mitigation; particularly on Boughton Lane; where dualling may be necessary, & also on the A508 Harborough Road mitigation will be sought. A scheme will also need to be developed to manage the traffic eastwards beyond the A508. · The design of the proposed road and junctions will need to comply with NCC Development Management Standards, please ask the applicant to refer to Development Management for the advice. · The TA will also need to consider the impact of construction traffic on the local highway network; to that end an agreed with DM Routing Agreement will need to form part of the necessary Construction Traffic Management Plan, this document will be sought by way of a planning Condition, however early discussion and agreement would be welcomed by this authority.
With kind regards
Verity
Verity Chilver Development Management Engineer Northamptonshire Highways One Angel Square Angel Street NORTHAMPTON NN1 1ED DDI: +44(0) 1604 364332 e-mail: [email protected] web: www.kierwsp.co.uk
1 Patterson, Daniel
From: Alan Smith
Dear Peter,
Hello there once again. Hope that you are keeping well, are doing just fine, at the present time.
Please now see, as immediately here below, The Wildlife Trust’s reply to this above consultation contact exercise and site area location.
RE: Planning Application submission No. 18/00002/SCO; seeking a Request for an EIA Scoping Opinion in respect of the proposed North-West Relief Road ( NWRR ); along the Brampton Arm of the River Nene, at Boughton.
COMMENT.
Thank you very much indeed for consulting The Wildlife Trust concerning the above current proposal to construct a new North-West Relief Road ( NWRR ) highway, in order to connect through from the “Dallington Grange S.U.E.” development site area to the existing A5199 Welford Road highway, and, in this instance, regarding the above request for a Scoping Opinion Request submitted by WSP, on behalf of Northamptonshire County Council.
We refer here now to your own Consultation Covering Letter, dated 14th August 2018, as received here vi email, about this same matter, and also to the relevant documentation associated with this same current matter as held on NCC’s own website; that is the report document entitled “North West Relief Road : Environmental Impact Assessment Scoping Report”, Ref. No. 70045931_SR1, dated July 2018, as produced by the consultancy WSP themselves.
First-of-all, please note that The Wildlife Trust is also of the opinion that, for a project of this scale and nature, an Environmental Impact Assessment would indeed be required.
New developments, as stated in National and Local planning policy, should both protect and enhance local biodiversity as an integral part of any proposal. Alongside an assessment of the existing ecological value of the site, we would therefore expect to see the identification of opportunities for such enhancements.
We advise that a survey for wildlife should indeed be carried out in advance of the determination of this, assumed, forthcoming actual Planning Application. If evidence of any species, such as bats or birds for example, is indeed found, then further steps will need to be taken since you are then dealing with a situation involving protected species that is a Material Consideration within the realms of the planning process.
Ecological surveys and information.
Adequate baseline surveys should be completed to assess the value of this particular site and its surrounding areas. We recommend that, at least, an Extended Phase 1 Habitat Survey be carried out, and that all
1 Statutory and Non-Statutory sites, protected species and other relevant species and habitats be fully investigated and evaluated. Information on wildlife records for the area should be obtained as part of this from the Northamptonshire Biodiversity Records Centre ( NBRC ); contact details below. A list of some possible additional local contacts for Northamptonshire is also enclosed below.
For information, with reference to Drawing No. Figure 2, entitled “Site Boundary and Current Route Alignment”, Rev. A, dated 03/07/18, as included at the very back of this same WSP report document, the proposed overall red-line footprint for this construction’s Site Boundary has the following features :
· There are several instances of existing site designations, of varying categories, lying inside an assumed zone of approximately 2 kilometres around it. These are a Local Nature Reserve ( LNR ), a Nature Reserve, Local Wildlife Sites ( LWS ), Local Geological Sites ( LGS ), Potential Wildlife Sites (PWS), and also Pocket Parks too.
· The Site lies wholly inside an ‘arm’ of the Nene Valley Nature Improvement Area ( NIA ) zone.
· We are aware of a good number of historical records of sightings of ‘protected species matters’ within a distance of 2 kilometres away from the outline boundary of this overall proposed development area.
In addition, consideration may well need to be given to the issue of whether or not there is going to be any significant degree of increased artificial lighting levels occurring as a result of the delivery of this proposed combined development scheme, and if so, the ways in which it might have an impact upon the local biodiversity – such as bat species, for example.
The developer and his / her advisers share responsibility for ensuring the satisfactory and accurate assessment of the Application Site. The Planning Authority is responsible for advising Applicants on protected species issues and for ensuring that the proposal is properly investigated. If the Applicant does not adequately consider the issue of protected species, including a survey if appropriate, the Planning Authority should seriously consider determining the Application as ‘refused’.
If a survey produces evidence of any kind of protected species, then adequate mitigation measures must be agreed prior to the granting of planning permission. In the event that protected species or their habitats are discovered once building works have commenced, then work must cease immediately and Natural England must be informed.
The Wildlife Trust would wish to bring to your attention the fact that various statutory instruments – such as the NPPF, the CRoW Act ( 2000 ) and the NERC Act ( 2006 ), for example – all place a duty upon LPAs to ensure the protection and enhancement of wildlife, and the promotion of Biodiversity Action Plan targets, through the exercising of their normal functions.
Through the principle of the nett planning gain approach, and mindful of both the revised, July 2018, NPPF document, and the NERC Act ( 2006 ) guidance, we would actually recommend that biodiversity enhancements to the local area are delivered as an outcome of this project.
Please note that there may well indeed be an opportunity for any soft landscaping associated with this development to incorporate the planting of appropriate native species, of trees and shrubs, for example, in order to provide food sources and habitat for native species of birds and animals.
In our opinion, it is important to not introduce any non-native or invasive species into either terrestrial or aquatic environments. Therefore, any soft landscaping elements that it is intended to include within this development proposal should be provided for by the use of native species ( of plants, shrubs and trees ) only. Ideally, these species should be chosen as ones that are typical of that part of the county and they should all only be sourced from a local and a known provenance. These areas should then be managed to the benefit of wildlife.
2 Enhancement of biodiversity and Green Infrastructure.
Opportunities for the enhancement of biodiversity include linking and buffering existing wildlife sites and habitats through habitat creation and incorporation of Green Infrastructure ( GI ). Reinforcement of this is found in the NPPF, NERC Act ( 2006 ) and Local Development Plans. The EIA should include proposals for ecological mitigation linked to the during- and post-construction impacts and should suggest the content of Planning Conditions and ecological sections of S106 Agreements, if applicable.
Northamptonshire’s Local Biodiversity Action Plan ( BAP ) gives details and targets on locally important species and habitats; http://www3.northamptonshire.gov.uk/councilservices/environment-and- planning/planning/planning-policy/archaeology-biodiversity-and- landscape/documents/PDF%20Documents/Northamptonshire%20BAP%202015-2020.pdf
In addition, we would draw the Applicant’s attention to the ‘recently-produced’ and revised “Biodiversity SPD” document ( 2015 ) which has been ratified by the North Northamptonshire Joint Planning Unit ( NNJPU ), Daventry District Council, and by other individual Authorities too.
We strongly recommend that a GI approach be followed here. This process should be incorporated as an integral part of the EIA analysis. The key ecological aspect of GI that we would expect to see is the linking of existing and / or potential wildlife habitat within the site and connections out of the site to create more sustainable ecosystems.
The Wildlife Trust strongly recommends that Green Infrastructure be afforded its own separate Chapter within the supporting E.S. / E.I.A. documentation.
The construction of such a development scheme in this location has the potential to contribute towards the opportunities for re-connecting habitats areas in the swathe of countryside around the north-western side of the existing settlement of Northampton in the future. Increasing connectivity of habitats should be a top priority for all areas of the county in order to provide for both sustainable and robust areas of the countryside under suitable ecological management and for a joined-up ‘Living Landscape’ that will allow species and habitats to better adapt to the effects of climate change.
It is the highly strategic location, context and setting of this particular site area that is one of the most important and significant things here.
Therefore, this new proposed highway route corridor, for the NWRR scheme, offers the real and excellent potential to provide a valuable addition to both a local GI network and also other, wider, existing, GI Corridors too, in terms of biodiversity along with the nearby existing designated sites.
We are of the view that, in line with the policy and guidance given within national documents, mitigation measures to address any potential negative impacts upon established biodiversity assets must be brought forward, and Conditioned as necessary.
Analysis of cumulative effects.
The Wildlife Trust strongly recommends that, in addition to addressing any potential direct / indirect impacts as a sole result of their own development scheme, the Applicant here should also be required to include, in the appropriate section(s) of the supporting documentation, a comprehensive review of just what the likely effects of the provision of this new NWRR highway corridor route is going to be upon the existing biodiversity at this location in combination with all of the other relevant encroaching development pressures in this area of the County / District(s).
Feedback in respect of Applicant’s “EIA Scoping Report” document.
3 With reference to the content of the “North West Relief Road : Environmental Impact Assessment Scoping Report”, Ref. No. 70045931_SR1, dated July 2018, as produced by the consultancy WSP, please note our own specific points of observation, as follows :
· With reference to the particular section of this same report document which is sub-headed as “Structure of the Environmental Statement ( ES )”, in Paragraph 3.5.2, on Page 12, as has already been mentioned elsewhere here above, please note that The Wildlife Trust strongly recommends that the topic of Green Infrastructure ( GI ) be given its own separate, individual, treatment, consideration and reporting within the supporting paperwork to this forthcoming Planning Application. Therefore, in-line with our previous comments, please note the repeated assertion that we are strongly of the view that this development proposal needs to consider the topic of GI as a fully-integrated, front-loaded and cross-cutting theme, both throughout, beyond and underpinning the whole site area, and that, in point-of-fact, the subject of GI, and indeed ‘Blue Infrastructure’ too, should be given the treatment of its own separate Chapter within the E.S. documentation.
· In a similar vein to the comment made immediately here above, and with reference to the Chapter headed as “Landscape and Visual”, Chapter 9, on Pages 51 to 55, inclusive, within this same report document, please note that we are also strongly of the view that the Planning Application for this NWRR development site area must clearly demonstrate how its own biodiversity enhancements, habitat retention / creation areas and GI provision are all going to knit with, and be entirely complementary to, the delivery / pre-existence of the other relevant qualifying areas all around it.
· With reference to the content of Chapter 5, “Climate Change”, on Pages 21 to 27, inclusive, The Wildlife Trust would wish to make the recommendation that the cross-cutting theme and subject- matter of the proposed development’s possible impacts upon, and contributions to, the adaptation to climate change effects would indeed be important to be included within this same EIA documentation too.
· In-line with our previous comments, made elsewhere here above, and with reference to the relevant heading of “Cumulative Assessment”, on Page 11, please note our repeated assertion that we are strongly of the view that this development proposal needs to consider the cumulative effects that its delivery would have upon the local biodiversity and Green Infrastructure as well. ( This is in addition to the ‘typically considered’ receptors of traffic and noise, for example. )
· Please note that, in addition to the proposed overall red-line Site Boundary footprint for this NWRR development scheme being located wholly inside an ‘arm’ of the Nene Valley Nature Improvement Area ( NIA ) zone itself, it is also sited in a highly strategic location in respect of established Green Infrastructure ( GI ) Corridor routes too - since it has an interaction with all of a major Sub-Regional GI Corridor route, a Local GI Corridor route, and also a Disused Railway Line GI Corridor route too.
· With reference to both the content and the intention of Paragraph 7.4.2, on Page 41, please note that, as the on-going, and long-standing, land managers of the Local Nature Reserve ( LNR ) site area at “Kingsthorpe Meadows”, The Wildlife Trust is somewhat disappointed and surprised not to have been individually identified herein as a member of one of the group of primary stakeholders.
We do hope that the above comments are of interest, and are useful to you.
Please do not hesitate to contact The Wildlife Trust again if you have any questions about the above points.
4 I would very much welcome any further, and early, opportunities to both review and comment upon any quantity of ecological work which has already been produced on behalf of the Applicant here, and also to meet with / discuss the emerging proposals with the Applicant’s wider team of advisers.
I look forward to reviewing the relevant sections of any Environmental Statement that might eventually be submitted.
Yours sincerely, Alan.
The Northamptonshire Biodiversity Records Centre (NBRC);
Ø Lings House, Billing Lings, Northampton, NN3 8BE; Tel: 01604 400448; Email: [email protected].
Other potential local consultees;
Ø The Northamptonshire bat group (Phil Richardson, [email protected]) Ø The North Northamptonshire Badger group (Wellingborough, Kettering, Corby, East Northants) (Peter Edwards, [email protected]) Ø The West Northamptonshire Badger Group (Northampton, Daventry, South Northants) (Steven Jackson, [email protected]) Ø The Northamptonshire Barn Owl Group (Paddy Jackson, [email protected]) Ø The Hawk and Owl Trust (http://www.hawkandowl.org/) Ø The British Trust for Ornithology (BTO, http://www.bto.org/index.htm) Ø The RSPB (Colin Wilkinson, [email protected]) Ø Northamptonshire Moth Recorder (John Ward, [email protected])
Alan Smith Planning and Biodiversity Officer Direct line: 01604 774046
The Wildlife Trust for Bedfordshire, Cambridgeshire & Northamptonshire Lings House, off Lings Way, Billing Lings, Northampton, NN3 8BE Office: 01604 405285
We work to make our three counties a place where nature can flourish and enrich the lives of the people who live here. With your help we care for local wildlife and more than 100 nature reserves. Volunteering your time or donating money to us will directly benefit local wildlife.
Tweet: @wildlifebcn Like: /wildlifebcn Visit: www.wildlifebcn.org
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6 Gallie, Rebecca
From: Steve Ellis
Dear Peter,
Thank you for consulting DDC on this scoping request. Subject to the following points, the WSP scoping report would appear to cover generally what is necessary. However, the report appears not to appreciate (see e.g. paragraph 4.4.1) that a significant part of the site is in the administrative area of DDC, which has implications for (a) what the relevant planning, and other, policy considerations are; and (b) who should be consulted as part of the EIA work being undertaken. By reference to the various topic headings, I would also offer the following detailed comments:
Proposed Scheme (paragraph 2.1.5) – part of the Site has Green Wedge designation (Daventry District Local Plan saved policy EN10). Air quality: o 4.2.1 – the DDC EHO should be able to provide any relevant DDC baseline information. There is no objection to the proposed methodology. o 4.2.18 – the receptors need to also include (a) the JCS Policy N8: Northampton North of Whitehills SUE (aka Buckton Fields) development (as partly constructed and proposed – see DA/2011/0666); and (b) an approved (on appeal) residential site on the west side of Welford Road. (See DA/2014/0521 and DA/2017/0551). o 4.4.1 – as part of the site is in the administrative area of DDC, there should be consultation with the DDC EHO, as well as with NBC. Cultural heritage – please see attached, the comments of the DDC Conservation Officer. Ecology and biodiversity (7.4.2) – the local Wildlife Trust (which has a service level agreement with DDC) should be consulted, along with local specialist groups for e.g. badgers and bats. Geology and Soils: o 8.2.10 – as 7.4.2. o 8.2.11/12 – the DDC EHO may be able to provide relevant information. There is no objection to the proposed methodology. Landscape and Visual – the DDC Landscaper Officer should be involved in the establishment of the methodology, including the identification of viewpoints. 4.2.18, above, is also relevant. Noise and Vibration – there is no objection to the proposed methodology. People and Communities: o 12.2.5 – please see 2.1.5, above. o 12.2.6 – a primary school is proposed as part of the JCS Policy N8 allocation. o 12.2.13 – please see 4.2.18, above. o Is it considered that ‘human health’ (per Regulation 4. (2) (a)) is covered sufficiently via other topic areas? o Other supporting documents (14.1.1) – ‘Planning Policy Statements’ no longer exist, of course – it is the National Planning Policy Framework (2018) + the related NPP Guidance. The planning statement needs to consider relevant saved Daventry District local plan policies and emerging DDC Part 2 Local Plan policies.
1 Gallie, Rebecca
From: Heather Webb
Hi Pete,
I think the proposed scope for the ecology section is broadly fine. One thing they haven’t specifically mentioned is important arable plants. I know they’re not statutory – although some are in the s.41 list – but given the surroundings I’d ask that they keep an eye out for them when they’re out doing the field work. The fields might be too intensively farmed for anything to thrive but I think it’s worth having a look. Other than that I think what they’re proposing makes sense.
Let me know if you need anything else.
Cheers, Heather
Heather Webb MSc MCIEEM Principal Project Officer Planning Services Northamptonshire County Council One Angel Square 4 Angel Street Northampton NN1 1ED
Tel: 01604 361210
1 Gallie, Rebecca
From: Clerk Boughton PC
Importance: High
Dear Peter
Further to our recent telephone conversation I apologise for the delay in responding to you on behalf of the Parish Council. I was unexpectedly on a week’s compassionate leave last week and was unable to attend the full council meeting on the 10th September 2018. You had very kindly agreed an extension of time for the Parish Council to respond to the above consultation so I hope that due to my absence this response is not too late.
The consultation was discussed by councillors and they have requested the matters below be considered for inclusion in the Scoping Opinion: -
A 24-hour noise assessment Landscape and visual impact assessment to look at limiting the impact of the road on the landscape character Drainage assessment as the road crosses flood plain Air quality as the proposed road is near to the AQMA in Kingsthorpe Assessment of the road levels so they do not impact on the landscape.
Best wishes.
Jayne
Jayne Bunting Clerk and Responsible Financial Officer Boughton Parish Council T: 01604 882527 E: [email protected]
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