Representations to Regulation 15 of the Draft Oundle Development Neighbourhood Plan Response on behalf of , Landowners of Millers Field, Benefield Road, Oundle August 2019 Contents 1. Introduction 3 2. Does the draft Oundle Neighbourhood Development Plan meet the specified ‘basic conditions’? 4 Our reference ANNC3002 August 2019 1. Introduction 1.1 This Statement has been prepared by Turley, on behalf of , Landowners of draft allocation O19, Millers Field, Benefield Road, Oundle of the draft Oundle Neighbourhood Development Plan. 1.2 The Landowners have previously submitted representations in response to the Regulation 14 Plan Consultation. 1.3 The Landowners continue to strongly support the inclusion of Site O19 in the draft Plan, but advocate a number of changes to ensure the Plan can meet the basic conditions as set out in paragraph 8(2) of the Schedule 4B of the Town and County Planning Act 1990. In summary, to satisfy these basic conditions and put to a referendum, the Oundle Neighbourhood Development Plan must: • have regard to national policies and advice. • have special regard to the desirability of preserving any listed building or its setting • have special regard to the desirability of preserving or enhancing the character or appearance of any conservation area. • the neighbourhood plan contributes to the achievement of sustainable development. • the neighbourhood plan is in general conformity with the strategic policies contained in the development plan for the area. • the neighbourhood plan does not breach, and is otherwise compatible with, EU obligations. • prescribed conditions are met and prescribed matters have been complied with. 1.4 The Landowners have requested the right to be heard before the examiner at the Neighbourhood Plan Examination if such a hearing is required. 2. Does the draft Oundle Neighbourhood Development Plan meet the specified ‘basic conditions’? 2.1 Overall, the Landowners of site O19, Millers Field consider that the draft Oundle Neighbourhood Development Plan (ONDP) is supportive of the Government’s objective at paragraph 59 of the National Planning Policy Framework to boost the supply of homes. The new National Planning Policy Framework (the ‘Framework’) recognises small and medium sized sites can make an important contribution to meeting the housing requirement of an area due to their ability to be built-out relatively quickly. Site O19 is immediately available, unconstrained and does not require significant upfront infrastructure. For these reasons, the Landowners strongly support the inclusion of their site within the draft Neighbourhood Plan as a housing allocation site, which would make a positive contribution to the Council’s continuous delivery of housing where there is an identified need. 2.2 Notwithstanding this strong support the Landowners have provided some commentary on specific parts of the draft Plan, where it is considered that an alternative approach would better ensure a deliverable strategy that meets the basic conditions so that it can proceed to a referendum. Regard to National Policies and Advice 2.3 Paragraph 13 of the Framework sets out that ‘neighbourhood plans should support the delivery of strategic policies contained in Local Plans or Spatial Development Strategies; and should shape and direct development that is outside of these strategic policies’. 2.4 It goes on in paragraph 69 to encourage ‘Neighbourhood Planning groups to consider the opportunities for allocating small and medium-sized sites (of a size consistent with paragraph 86a) suitable for housing in their area’. 2.5 Paragraph 41 of the Planning Practice Guidance is concerned with how policies in a Neighbourhood Plan should be drafted. It states that: ‘A policy in a neighbourhood plan should be clear and unambiguous. It should be drafted with sufficient clarity that a decision maker can apply it consistently and with confidence when determining planning applications. It should be concise, precise and supported by appropriate evidence. It should be distinct to reflect and respond to the unique characteristics and planning context of the specific neighbourhood area for which it has been prepared’. 2.6 In this context, draft allocation O19, Millers Field is well placed to deliver proportionate housing growth in Oundle, in line with paragraph 69 of the Framework. It has a developable size of less than 1 ha which means that it is of a suitable size and location for the Neighbourhood Plan to allocate and deliver. Paragraph 68 of the Framework calls for Development Plans (including Neighbourhood Plans) to promote a good mix of developable sites including land to accommodate at least 10% of their housing requirements on sites no larger than one hectare. 2.7 Notwithstanding this, and the overall support for the inclusion of the site within the draft ONDP, we would suggest that the wording of Policy O19 is amended to align with Planning Practice Guidance and in turn meet the basic conditions. Policy O19: Millers Field, Benefield Road Land south of Benefield Road, as shown on the Policies Map, is allocated for residential development and open space. The site is expected to deliver high-quality development and shall:- 1. Deliver at least 14 dwellings with particular encouragement given to the provision of dwellings to accommodate small households, including homes to meet the needs of older people; 2. Deliver approximately 0.55ha for allotments and informal, public recreational space; 3. Ensure that views into the open countryside from Benefield Rd are preserved; and 4. Not lead to a net increase in flood risk including fluvial flooding along the course of the Lyveden Brook. 5. The allotment land shall be in a suitable location with its own vehicular access, on-site water supply and adequate off-street parking. 6. Provide structural landscaping incorporating informal recreational space adjacent to the Lyveden Brook with access for maintenance vehicles. 7. Provide a new cycle and pedestrian route between the informal recreational space and Benefield Road. 2.8 Point 2 of draft Policy O19 specifies that the site should deliver approximately 0.55 ha for allotments and informal, public recreational space. The Landowners fully support the provision of open space and allotments on this site and that this will be in the region of half the site. Notwithstanding this, given that the quantity and size of homes on this site are still to be formally determined, there is a need for the policy to be flexible to ensure delivery of the site. 2.9 Draft Policy O5 of the ONDP provides the mechanism for delivering open space on new housing developments and refers back to the guidance (or subsequent guidance) produced by East Northamptonshire District Council which is the correct means for calculating the required amount of open space on new sites. As such, we would request that the quantum is removed and Point 2 is re-worded as follows: 2. In accordance with Policy O5, deliver an appropriate amount of informal, public recreational space, including allotments taking into account site constraints; approximately 0.55ha for allotments and informal, public recreational space; 2.10 Our second point in respect to Policy O19 is point 7. This requires a new cycle and pedestrian route between the informal recreational space and Benefield Road. The Landowners are content to provide a route but questions the likelihood of cyclists using this route given the topography and the fact that it does not lead onto other locations. To ensure that the policy is not too prescriptive, which could affect the deliverability of the site, the Landowners suggest that the policy be reworded so that it provides flexibility e.g. ‘provide a new pedestrian route between the informal recreational space and Benefield Road, with consideration towards any possible future cycle route.’. The Neighbourhood Plan Contributes to the Achievement of Sustainable Development 2.11 In general, the Landowners welcome the importance that the Neighbourhood Plan places on the duty of ‘protecting and enhancing the natural, built and historic environment’ and making ‘efficient use of land’. However, they do regret that the Plan does not make any reference to how future development should reduce greenhouse gas emissions. 2.12 Paragraph 148 of the Framework requires that ‘The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change [footnote: In line with the objectives and provisions of the Climate Change Act 2008]. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure 2.13 In order to ensure that the Neighbourhood Plan accords with the environmental strand of sustainable development, the Landowners urge the Town Council to review the ONDP and consider insertion of a policy which addresses this important matter. Other Policy Responses: Policy O5: The Provision and Enhancement of Open Space Proposals for new housing developments of 15 or more dwellings, or with a site area over 0.42ha, will need to: 1. Include on-site provision of open space and/or, where appropriate, contribute towards the enhancement of existing provision in Oundle in accordance with guidance set out in East Northamptonshire Council’s Open Space Supplementary Planning Document or any subsequent update; and 2. Make provision for the long–term management of open space made necessary by the development. The open space should be overlooked and easily accessible by means of pedestrian connections. Where practicable, the open space should provide other green infrastructure benefits such as tree planting, flood or water storage areas or new habitats. The more significant Open Spaces proposed in new housing developments, as shown on the Policies Map, include the following: 1. New Cricket Facilities off Herne Road 2.