This form has two parts:
Part A contact details
Part B your representation
Please fill in a separate sheet for each representation you wish to make.
Part A
1. Personal Details*
2. Agent’s Details (if applicable)
* If an agent is appointed, please complete only the Title, Name and Organisation boxes
below but complete the full contact details of the agent in column 2.
Title
Mr
First name
R
Last name
Hammond
Job title (where
relevant)
Organisation
(where relevant)
Canton Ltd
Woods Hardwick Planning Ltd
Address line 1
c/o agent
Fort Dunlop
Line 2
Fort Parkway
Line 3
City/Town
Birmingham
County
Postcode
B24 9FE
Telephone number
07741 144986
Email (if provided
we will always
contact you this
way)
r.hammond@woodshardwick.com
Ref:
(for official use)
only)
(for
PS079
Part B: Please use a separate sheet for each representation
Please note all comments will be made publically available. If you do not have sufficient space in
the box please continue on a separate sheet or expand the box.
Paragraph
number
Policy number
Policies Maps
1.4, 3.1.02,
5.1.02, 5.105
RA2
4. Do you consider the Local Plan is:
(please tick in the box below as appropriate and then provide details in the space below)
Yes
No
Yes
No
?
Yes
No
4 (1) Please give details of why you consider the Local Plan is not legally compliant, be as
precise as possible.
N/A
4 (2) Please give details of why you consider the Local Plan does not comply with the duty to
co-operate, be as precise as possible.
It is anticipated that Daventry District along with South Northants and Northampton Borough Council will
undergo local government reorganisation within the next 3 years, with the expectation that the three
councils will merge into a unitary authority. There is no acknowledgement or reference to this in the
Regulation 19 plan, when the reorganisation will likely take place very early on in the life of the Part 2
Plan. There is consequently no commentary on the implications for plan making and review, including the
potential for review of the Part 2 Plan earlier than would otherwise be the case. The absence of reference
to the expected reorganisation does not appear to be in the spirit of the duty to co-operate.
PS079
4 (3) Please give details of why you consider the Local Plan is not sound, referring to the tests
of soundness as appropriate, be as precise as possible.
The plan does not place enough emphasis on the Government’s objective of boosting significantly the
supply of housing.
The housing targets set out in the submission plan, including for the rural area, are based on the West
Northamptonshire Joint Core Strategy (JCS). This plan is nearing the end of the NPPF 5-year review period
with the expectation that a review will not be completed within 5 years from adoption.
The Government acknowledges that the standard methodology for calculating housing need will likely
have to be revisited to increase housing need following the reduced projections in the latest ONS 2016
household projections data; this has the potential to increase housing need including in the rural area.
The absence of a completed review of the JCS within the required five-year time period, coupled with the
uncertainty around the standard methodology for calculating housing need, potentially casts doubt over
housing delivery within Daventry District’s rural area.
Policy RA2 is effectively a policy of restraint for new development in the villages within the District. The
strong potential for an aging and stagnating population in the rural areas, compounded by an effective
policy of restraint in the villages, and potential impact on demand for services, including school places,
conflicts with para 83 of the NPPF which seeks the retention and development of accessible local services
and undermines the social objective of para 8 of the NPPF.
Moreover, the policy of restraint is at odds with para 78 in not identifying opportunities for villages to
grow and thrive.
5. Please set out what modification(s) you consider necessary to make the Local Plan legally
compliant or sound, having regard to the matter you have identified at part 4(1) or 4(3) above
where this relates to soundness. (NB Please note that any non-compliance with the duty to co-
operate is incapable of modification at examination). You will need to say why this
modification will make the Local Plan legally compliant or sound.
It will be helpful if you are able to put forward your suggested revised wording of any policy or
text. Please be as precise as possible.
Consider establishing specific housing targets/land allocations for a sustainable level of limited growth in
appropriate villages, such as Creaton, to allow growth and to enhance the vitality of rural communities
including through support for and retention of local services and facilities.
Woods Hardwick Planning Ltd acts on behalf a local landowner in Creaton whose land has already been
brought to the attention of Council through previous “call for sites” exercises. A copy of the previously
submitted “call for sites” form and site plan identifying the land is attached to this form. The whole or
part of the land remains available and developable.
Please note your representation should cover succinctly all the information, evidence and
supporting information necessary to support/justify the representation and the suggested
modification, as there will not normally be a subsequent opportunity to make further
representations based on the original representation at publication stage.
PS079
After this stage, further submissions will be only at the request of the Inspector, based on the
matter and issues he/she identifies for examination.
6. If your representation is seeking a modification, do you consider it necessary to participate
at the oral part of the examination? (please tick as appropriate)
Yes, I wish to participate at
the oral examination
7. If you wish to participate at the oral part of the examination, please outline why you consider
this to be necessary.
Please note the Inspector will determine the most appropriate procedure to adopt to hear those
who have indicated that they wish to participate at the oral part of the examination.
8. Please tick the box if you wish to be notified of further
progress of the Local Plan.
9. Signature
Date
5/10/2018
Thank you for taking the time to complete the form.
Please return it to the Local Strategy Service at Daventry District Council
by 4.30pm on Friday 5
th
October 2018.
Responses received after this time will not be accepted.
PS079
3
Call for Sites: Site submission form
Closing date for responses – 11th March 2016
Please read the accompanying Guidance Notes before completing this form.
Contact Details
Title
Name
Organisation
(where relevant)
Address
Postcode
Telephone
Email address
Agent Details
Title
Name
Organisation
(where relevant)
Address
Postcode
Telephone
Email address
PS079
Canton Ltd
c/o Agent
Mr
Russell Gray
Woods Hardwick Planning Ltd
15-17 Goldington Road
Bedford
MK40 3NH
01234 268862
r.gray@woodshardwick.com
4
Site Interest
1.
What is your interest in the site?
Owner (whole site)
Developer contracted to buy the land
Owner (part of site)
Developer speculative
Town or Parish Council
Local
Resident
Amenity/community group
Registered social landlord
Other (please specify):
2.
Are there other owners/agents of this site?
Yes
No
If yes, please provide details below:
If there are more than two other owners, please complete their details on a separate sheet and attach
to this form.
Title
Name
Organisation
(where relevant)
Address
Postcode
Telephone
Email address
Does this owner support your proposal for the site?
Yes
N
o
Title
Name
Organisation
(where relevant)
PS079
Gosford Ltd
5
Address
Postcode
Telephone
Email address
Does this owner support your proposal for the site?
Yes
No
Site Information
3.
Site name
Site addr
ess
Grid reference (if known)
Site area in hectares
(gross)
Developable site area in
hectares (net)
Current land use (eg.
Agriculture, employment,
unused/vacant etc.)
Type of site (eg. Green
field, previously
developed land)
Relevant planning history
(if known – please include
relevant planning
application numbers)
I have included an Ordnance Survey plan outlining the extent of the site
PS079
Land at Welford Road, Creaton
Land at Welford Road, Creaton
2.76 ha
2 ha
Unused grassland
Green field
No relevant planning history
6
3
4.
Adjacent
land use (eg. Housing, employment, retail, leisure
etc.)
North:
South:
East:
West:
Proposed Use
& Capacity
5.
Please indicate the proposed preferred use for the site and provide further information as
requested.
If the site is proposed for mixed use, please tick a
ll that apply
Use
Yes
Basic information
eg. Area/number of
units/proposed floorspace/number of pitches
- If residential then please include a brief
explanation of how density has been
arrived at
Residential (market housing)
Residential (self
-
build
)
Residential (affordable housing)
Residential (starter homes)
PS079
The north west of the site abuts existing residential development off Teeton Lane and
Welford Road, which forms the current south western edge of the built development in
Creaton.
The land to the south of the site is comprised of agricultural fields.
The land to the east is paddock land and agricultural buildings.
The land to the west of the site is comprised of agricultural fields.
28 dwellings (based on current affordable
requirement in Daventry District)comprising a mix of
types and sizes.
14 dph. A low density of development is
considered appropriate given the character of the
surrounding area.
11 dwellings (based on current affordable
requirement in Daventry District) comprising a mix
of types and sizes.
A proportion of the affordable units would be starter
home in line with the Government requirement
7
Office, research and development, light
industrial (B1)
General industrial (B2)/ Warehousing (B8)
Gypsy and travellers
pitch(es)
Travelling showpeople
Gypsy and trave
ller emergency stopping
place
Retail (please
which use class
)
Community facilities
eg. Community hall
(please specify)
Sports/leisure (please specify)
Open space
Energy generation
eg. Wind turbine, solar
farm
Other (please specify)
PS079
0.76 ha of open space/informal recreational area
8
1
Rural exception sites: Small sites used for affordable housing in perpetuity where sites would not
normally be used for housing. Rural exception sites seek to address the needs of the local
community by accommodating households who are either current residents or have an existing
family or employment connection. Small numbers of market homes may be allowed at the local
authority’s discretion, for example where essential to enable the delivery of affordable units without
grant funding.
6.
Is the site
an expansion of an existing business?
Yes
No
If yes, please provide details of existing site and its development:
7. Are you promoting your site as a rural exception site?
1
Yes
No
8.
Would you be
agreeab
le to
only
part of your site be
ing
considered?
Yes
No
9.
Have you liaised with the town/parish Council regarding your proposal?
Yes
No
PS079
9
Suitability
10.
Is the site within a flood zone?
The Environment Agency website includes a flood map that can be used to determine if your site is
within a flood zone and if so, what level of flood zone this is. This can be found here:
http://apps.environment-agency.gov.uk/wiyby/37837.aspx
Yes
No
Don’t know
If yes, is this…?
Flood zone 1
Flood zone 2
Flood zone 3
Yes
No
Don’t
know
11.
Is the land classified as best and most versatile agricultural land?
12.
Are there any ecological features e.g. nature reserves, Sit
es of Special Scientific
Interest (SSSIs), local wildlife sites in close proximity to the site?
13.
Are there any geological features of significance that could affect the
development of the site?
14.
Are there any existing trees /hedgerow/woodlands on the
site?
15.
Are there any landscape features that could affect the site?
16.
Are there any public rights of way that cross or adjoin the site?
17.
Is there any contaminated land that would affect the development of the site?
18.
Are there any uses which cou
ld affect the development of the site eg. Power
lines, railway lines, major highways, heavy industry, sewage treatment works
19.
Are there any topographical features that could affect the development of the
site?
20.
Are there any watercourses or water fea
tures in close proximity to the site?
21.
Are there any heritage assets within or adjacent to the site eg. Listed buildings,
conservation areas, scheduled monuments?
22.
Please list any features listed above:
PS079
14. Existing trees and hedgerows form the boundaries of the site and would be maintained and augmented
wherever possible.
10
23.
Please provide any relevant information
of likely measures to address any of the above that you have
answered ‘YES’ to and refer to question number:
Utilities and facilities
Please tell us which of the following are available to the site
Yes
No
Don’t
know
24.
Mains water supply
25.
Mains
sewerage
26.
Electrical supply
27.
Gas supply
28.
Landline telephone/broadband internet
29.
Is
the site safely and directly accessible from an existing (adopted) highway?
Yes
No
If not, can a new access be provided?
Yes
No
If yes, ple
ase indicate this on a scaled plan and attach it to this form. Please tick to confirm such a plan
is attached.
Plan attached
30.
Does the landowner/developer have control over the access?
Yes
No
PS079
14. A Tree Report would be undertaken at the application stage.
11
32.
Please indicate the distances of the following services and facilities from your site
?
Use/facility
Indicative distance (metres)
Primary school
Secondary school
GP surgery
General food store
Post office
Village hall/Community centre
Public transport (please provide detail
s
of the
frequency
of the service)
Public house/restaurant
Small shops/takeaways
Libraries/outreach centres
Pre
-
school provision
Play area
Sports ground
Allotments
Residential use
Local employment provision
Other, please advise:
31.
Is the site safely and realistically acce
ssible by public transport?
Yes
No
If so, how?
If not, how will your proposal achieve this?
PS079
Regular bus service from bus stop on Welford Road to Northampton Town Centre.
240m
515m
515m
200m
208m
208m
515m
Mobile Library Service
240m
60m
12
33.
Are you aware of any other constraints which may aff
ect the suitability of the site?
Availability
34.
Ar
e there any ownership or title constraints which you are aware of?
Yes
No
If yes, please provide details below:
35.
Are there any
restrictive covenants on the land which might affect the deliverability of the site?
Yes
No
If y
es, please provide details below:
36.
Must any land in other ownership be acquired to develop the site?
Yes
No
If yes, please provide details below:
PS079
No
13
37.
Is the site…?
Vacant
Occupied
Partly occupied
If the site is cons
idered to be suitable for development, would all or part of the existing use remain in
occupation?
(a)
Yes
(b)
Yes, part
(c)
No
If (a) or (b) do any of these require relocation before the site could be developed?
Yes
No
If (c) what would be the time
table for the existing use to cease?
38.
Is the site available for development now
(in 0
-
5 years)
?
Yes
No
If ‘No’, when will the site be available?
6
-
10 years
11
-
15 years
16+ years
Achievability
39.
Has the site been marketed for
sale for the use proposed
in
your answer to question 5?
Yes
No
Don’t know
If yes,
how long has the site been marketed for, and
what level of interest has been received?
PS079
14
40.
In your opinion, are there any market factors or financial im
plications that could restrict potential
delivery on site within:
a)
0
-
5 years?
Yes
No
b)
6
-
10 years
Yes
No
c)
11
-
15 years
Yes
No
d)
16+ years
Yes
No
Market factors include: economic viability of existing, proposed and
/or alternative uses, level of
potential market demand and projected rate of sales etc.
41. Please give details of market issues that have been considered and how any issues can be
overcome.
PS079
15
42.
If possible, based on current in
formation please provide an estimate of the scale of
development
to be built on site per annum (April 1
st
to March 31
st
).
Year
Residential
-
estimated no. of units
Commercial
-
estimated flo
orspace m
2
2016/17
2017/18
2018/19
2019/20
2020/21
2021/22
2022
-
2027
2028+
TOTAL
Once commenced how many years is it expected to fully develop the site?
If known, how many developers would be involved in delivering the site?
If housing, at what density would the site be built (dwellings per hectare)?
43.
Please supply any additional information that may help assessment of the site.
PS079
39
1
1
The proposal is for a residential development of 39 dwellings, comprising a mix of private and affordable
units of a range of types and sizes.
An indicative layout has been included in support of this submission to illustrate that a suitable form of
residential development can be achieved.
The proposal indicates a range of dwelling types within the site area, including cottage style dwellings
through the main access road, leading to larger dwellings to the southern edge. The principle and range of
dwelling types and sizes is in keeping with the existing properties within the High Street and the peripheral
areas within the existing village curtilage. A central green area has been formed within the development to
create a feature area similar to that of the existing green within the village. Vehicular access to the site is
proposed via a new priority junction off Welford Road.
Consultation was undertaken on the Creaton Neighbourhood Plan in 2012. The consultation revealed
support for some housing in the village. Two sites have been provisionally identified, one of which lies
adjacent to the west of the proposed site. The layout shows an undeveloped area at the southern quarter
of the site. It is considered that this undeveloped area could provide open space/informal recreational area
and would create an attractive development edge to the site and to this end of the village.
The site is located within walking distance of a range of amenities within the village, including a primary
school, post office and convenience store, public house, village hall, playing fields and a church. There is a
regular bus service in the village to Northampton town centre. Consequently, the site is considered to be in
a sustainable location for the moderate and appropriate level of growth proposed.
The site is in private ownership and no constraints have been identified that would prevent development
from coming forward. The site provides an excellent opportunity to bring forward a development that is well
related to the existing settlement providing new homes.
PS079
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