Why we object
The fundemental objection is that the application site does not meet the requirements of any reasonable definition of ‘sustainability’ and that many of the Economic, Social and Environmental issues arising from the current proposals for this site, are in conflict with many of the core principles set out in the National Planning Policy Guidance (NPPF) as well as in conflict with existing NBC saved policies.
The relevant Core Principles are contained in section 17 of the NPPF, are set out below together with examples of how the applications fail to meet them.:
‘Planning proposals should be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area’.
Ø The current applications are ‘developer led’ and in advance of an adopted Strategic Plan. They were put forward as a speculative proposal in 2006 and subsequently ’cut and paste’ by the WNJPU into the Emerging Joint Core Strategy. There has been no input from ‘local people’ and at every public consultation; the plans have been overwhelmingly rejected. They have been consistently opposed by the two affected Parish Councils, the relevant local Borough and County Councillors and the Constituency Member of Parliament.
‘Plans should be kept up‑to‑date, and be based on joint working and co‑operation to address larger than local issues. They should provide a practical framework within which decisions on planning applications can be decided with a high degree of predictability and efficiency’.
Ø There is no currently up to date ‘agreed plan and joint working and co-operation’ is visibly absent. The Northampton Borough members of the WNJPC have voted against the JCS which has only progressed on the casting vote of the Chair (from Daventry) The current Chair is now from South Northants DC and the Vice Chair is from Daventry – a departure from precedent.
‘Plans 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.
Ø The proposed site does not contribute to the ‘sustainable economic development’ of Northampton. Large scale housing developments on the south side of the borough have become dormitories for commuters and retail activity gravitates south to Milton Keynes. This is a view supported by Northamptonshire County Council who maintain that growth is better located to the north of the town where infrastructure can cope more easily.
‘Plans should always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings’.
Ø It is difficult to reconcile this principle with the fact that the applicant has proposed that the houses nearest to the M1 will have triple glazing on windows and assisted ventilation systems, so that windows need not be opened. The proposed layout of straight access roads will encourage speeding and make traffic calming difficult.
‘Plans should take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it’.
Ø This site is largely good quality farmland together with a golf course originally designed to be an elite facility in keeping with the landscaped parkland laid out in Victorian times. It adjoins a conservation village and forms a green open space between the built up area of the town and the open countryside beyond. In Saved Policy E9 of the not yet replaced NBC Local Plan, the site is designated as ‘important local landscape’.
‘Plans should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy)’.
Ø It would be difficult to find another site more likely to encourage the use of the car. It is encircled by physical barriers on three sides with the only access via a congested suburban road. Bus service provision will be limited. There is no significant additional road management infrastructure proposed and massive traffic overload will only be avoided if there is a 25% shift from using cars to other forms of transport (modal shift). This is a most unlikely outcome and a ludicrous expectation.
‘Plans should contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework’.
Ø The site already experiences overall pollution levels that exceed World Health Organisation (WHO) limits and Nitrogen Dioxide levels that exceed both WHO and UK limits. The site adjoins an AQMA. Noise levels also currently exceed WHO and UK limits. This situation can only be worsened by the attraction to the site of up 7,000 vehicle movements a day linked to the 1,000 houses proposed.
‘Plans should encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value’.
Ø None of this site is brownfield. It is greenfield and farmland. It is relevant that despite all the changes that have taken place in occupancy of the central areas of Northampton, there has not been a thorough Urban Capacity Study of available urban space, since 2003.
‘Plans should promote mixed use developments, and encourage multiple benefits from the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production)’.
Ø The proposed site currently contributes to all the functions listed by the NPPF, particularly flood risk mitigation. The whole site is in the Wootton Brook Flood Plain and historically has always flooded every 2/3 years. The level of flood risk is the subject of intense concern and conflict over realistic assessments and serious issues have been raised by the Nene Valley Flood Prevention Alliance and local residents. The fact that the Environment Agency has asked for a large number of planning conditions highlights the question marks over the sustainability of the site for large scale development. The Phase 1 site is on land that slopes steeply and drains into Wootton Brook.
‘Plans should conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations’.
Ø In addition to the agricultural value of the site (at a time when there is growing concern over lack of self sufficiency in food) the site includes historic parkland together with mature specimen trees. It provides an attractive recreational complex in a river setting. Northampton is not over blessed with these features.
‘Plans should 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’.
Ø The proposed development is currently unsustainable in transport terms and there is no certainty it can be made so in the future. Proposals by the applicant to divert bus services would result in other local communities becoming unsustainable. The A45 is already severely congested and although the Highways Agency hopes to make improvements, they have neither the funding nor a timetable. In any case, improvements would not take place until a high proportion of the proposed development has been completed. As the applicant anticipated that the 1,000 houses would be built at a rate of 50 a year it would be over a decade before funding might be available.
‘Plans should take account of and support local strategies to improve health, social and
cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local need’.
Ø The location of this site means that its residents will be effectively ‘kettled’ within a contained area with limited access to Collingtree Village and a lengthy walk or drive to Hunsbury. There will be little social cohesion and at best, residents will be dependent on ‘estate’ type retail services. No indication has been given as to how medical services and cultural facilities will be provided.
HCRA Says -
is a developer led, commercially driven proposal that is being ‘shoehorned’ in
an effort to meet the requirements of a Sustainable Urban Extension. The site
proposed is not sustainable for this size of development. – it is not urban – it is not even an extension. It fails on almost every core principle set
out in the NPPF and if thorough and objective Sequential and Exception Tests
were applied, it would surely fail these also".