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 James

Last name Yeoman

Job title (where relevant)

Associate Director

Organisation (where relevant)

Christ Church, Oxford Savills

Address line 1 Wytham Court

Line 2 11 West Way

Line 3

City/Town Oxford

County

Postcode OX2 0QL

Telephone number 01865 269116

Email (if provided we will always contact you this way)

jyeoman@savills.com

Ref:

(for official use) only)

(for

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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.

3. To which part of the Local Plan does this representation relate?

Paragraph number

Policy number

Policies Maps

ENV3

4. Do you consider the Local Plan is: (please tick in the box below as appropriate and then provide details in the space below)

4. (1) Legally compliant?

Yes X No

4. (2) Compliant with the Duty to co-operate?

Yes X No

4. (3) Sound?

Yes No X

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. N/A

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. Please refer to accompanying Savills Correspondence and EDLP Landscape Matters Paper.

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. Please refer to accompanying Savills Correspondence and EDLP Landscape Matters Paper.

Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested

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modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage.

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)

No, I do not wish to participate at the oral examination

Yes, I wish to participate at the oral examination

X

7. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary. In light of our Client’s specific land interest and proposed policy designation (ENV3) to the west of Daventry that relating to such land, our client wishes to participate at the upcoming Examination in Public. We would therefore be grateful to be kept informed of arrangements to this effect.

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.

X

9. Signature

Date 05/10/2018

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 5th October 2018.

Responses received after this time will not be accepted.

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Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East..

Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD

James Yeoman

E: jyeoman@savills.com

DL: +44 (0) 1865 269116

Wytham Court

11 West Way

Oxford OX2 0QL

T: +44 (0) 1865 269 000

F: +44 (0) 1865 269 001

savills.com

5 October 2018 L 181003 RML Local Plan Reg 19 reps - Daventry

Local Strategy Service Daventry District Council Lodge Road Daventry Northamptonshire NN11 4FP Correspondence sent by email to: planningpolicy@daventrydc.gov.uk Dear Sirs Settlements and Countryside Local Plan (Part 2) for Daventry District Council Regulation 19 Submission Draft Public Consultation Response on behalf of Christ Church, Oxford Savills (UK) Limited is instructed by Christ Church, Oxford to submit the following representations in response to the Regulation 19: ‘Settlements and Countryside Local Plan (Part 2)’ consultation document, hereinafter referred to as LPP2. Christ Church, Oxford owns land situated to the north-west of Daventry, namely:

Middlemore Farm: situated immediately to the west of the A361 and promoted for residential use; and

Drayton Gate Farm: situated north of the A45 (Braunston Road) and promoted for employment use.

This submission follows previous representations and inputs in respect of:

The Issues and Options Paper and Call for Sites (March 2016); The Regulation 18 Draft Local Plan - representations included a technical Landscape, Ecology and

Heritage Statement, a Landscape Briefing Note and development proposals in respect of Christ Church’s land interest;

A workshop organised by OPUN on behalf of Daventry District Council in June 2017 – attended by members of our Client’s appointed technical team;

A subsequent written submission to Daventry District Council on 7th July 2017 - this provided a response to a number of issues discussed, including the expansion of development beyond the ‘Daventry Bowl’, impact upon the Conservation Area; coalescence with Braunston and the provision of an adequate landscape strategy.

In addition to the duly completed and enclosed representation form, a Landscape Matters Paper (edp3630_r002b), prepared by EDP, is formally submitted at this Regulation 19 stage. The following Plans and Key Views further support the matters raised herein and are therefore drawn to the readers’ attention:

Plan EDP1 - Site Location and Site Boundaries (edp3630_d009) Plan EDP2 - Landscape Planning Context (edp3630_d010) Plan EDP3 - Visual Assessment (edp3630_d011) Plan EDP4 - Topography Plan (edp3630_d012) Plan EDP5 - Site Appraisal (edp3630_d013a) Key View WGA (edp3630_d014)

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Key View WGB (edp3630_d014) In accordance with the transition arrangement reported at Annex 1 of the new National Planning Policy Framework (2018), we understand that Daventry District Council intends to submit the LPP2 before 24 January 2019. On this basis, Paragraph 214 states the policies of the previous Framework (NPPF 2012) will apply for the purpose of examining Local Plans. The following representations and enclosed submissions are made with reference to NPPF 2012. In line with Paragraph 182 of the NPPF 2012, our client’s general position is that the Local Plan as drafted is not sound. The policy position proposed, specifically by ENV3, is not justified for reasons set out below. Settlement and Countryside Local Plan Part 2 (LPP2) Paragraph 14 of the NPPF reports that Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change. It is important that the LPP2 conforms to the wider spatial strategy of the West Northamptonshire Joint Core Strategy Local Plan (December 2014). Daventry is clearly recognised as a sustainable development location with the northern part of the town having delivered strategic growth in recent years. The delivery of the Daventry North East Sustainable Urban Extension (SUE) will provide further housing growth, again reinforcing the sustainability of the settlement as a location for growth. Our client supports the key focus of development in the District to be on the town of Daventry, as set out by the Vision of the Local Plan (Chapter 3). The Objectives set out from paragraph 3.1.03 are clear in their relationship to the overarching vision for the LPP2. The thrust of Objectives 6 and 7, relating to the strengthening and diversification of the local economy and the development of specialist employment clusters, is supported. Objective 9 relating to housing provision seeks to provide a range of housing in sustainable locations, focused at ‘…the most sustainable location of Daventry”. This is wholly supported by the College. Policy SP1 focuses development at Daventry town. Our client continues to support the direction of growth towards Daventry as the District’s main settlement. This provides for a sound approach. This is particularly relevant in respect of residential development, owing to the Council’s own recognition that the majority of delivery has, to date, been in the rural areas elsewhere across the district. Strategic Employment Areas LPP2 sets out key principles at Policy EC4 to ensure a vibrant economy in the district, including that proposals for B1, B2, and B8 uses will be supported in principle. Criterion A is clear that the expansion of any existing business within these classes be supported, provided it promotes and supports the role and performance of the employment area and does not harm the amenity of surrounding residential properties. The Councils own evidence base identifies a need for employment development during the period of the LPP2. The western extent of Daventry Town provides significant employment uses, evidenced by allocations EC4 and EC7. The College’s earlier representations to the LPP2 identified its land interest, immediately abutting Apex Park, as a logical location for further employment provision at the town. Despite submissions made, the Council has opted not to allocate further employment use at this location. Policy ENV3 In landscape terms, Drayton Gate Farm is not subject to any national or local designations and, based on EDP’s Landscape Matters Paper, there is no reason to conclude that the site is of more than ‘ordinary’ value. In the national context, the site lies towards the lower end of the hierarchy of landscape value afforded consideration under the NPPF, subject only to the ‘recognition’ rather than explicit protection. Therefore the baseline position is such that development in principle should not be precluded at Drayton Gate Farm site for landscape reasons.

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Development of the site would have no material effect on existing landscape fabric of significant value – impacts being restricted to the loss of an area of arable land and, most likely, some section of hedgerows and trees. Policy ENV3 does not constitute the protection of a local space, its implementation is to act as a spatial planning tool. Policy ENV3 (Green Wedges), as drafted, affords protection to the identity, character and setting of settlements within the areas that fringe Daventry and Northampton. The policy requires that proposals within the Green Wedges demonstrate that they would maintain:

(i) the physical and visual separation between settlements; and (ii) the openness around settlements and their settings.

Our client considers this policy approach unjustified. In turn LPP2 should not be found sound in its current form. Our client objects to the principle of Policy ENV3 itself given the development strategy for the District proposed by remaining policies within LPP2. Policy ENV1 aims to ensure that development has regard to landscape character and quality. Specifically:

Criteria A.iv of Policy ENV1 expects development to avoid physical and visual coalescence between settlements;

Criteria C ensures that development proposals include an assessment of likely visual impacts on the local landscape and the site’s immediate and wider setting;

Criteria D requires that any landscape harm be mitigated through appropriate treatment. Policy ENV3 is therefore an onerous requirement that repeats principles established by Policy ENV1. For this reason, and in order to enable LPP2 to be found sound, it is proposed that Policy ENV3 be deleted. Notwithstanding our clients overall objection to the principle of Policy ENV3, we comment further on the specific extent of the Green Wedge proposed to the west of Daventry that directly affects Drayton Gate Farm. The accompanying EDP Landscape Matters Paper is clear that the effects of development on visual amenity, including perceived separation between Daventry and Braunston, would be viewed in a variety of orientations, proximities and wider visual contexts. However, in each case, any development would be viewed in the context of the existing settlement edge of Daventry to the east, including the existing units at Drayton Fields, which are ever-present in views from elevated locations to the north. In a similar manner, whilst views from Braunston towards Daventry would be changed, such change would not be so significant to materially alter the visual perception of the town. As per the College’s Regulation 18 representations, an existing planted boundary along the western edge of Drayton Gate Farm provides a suitable alternative boundary to the proposed Green Wedge whilst still allowing for future employment uses (refer to Plan EDP5). The trees which constitute this boundary were planted in 2009 and provide natural year round cover. Amendment to the proposed ENV3 boundary, recognising both the need to provide a buffer between the settlement and wider countryside, but also balancing the need to provide continued opportunity for enhanced future employment provision at Daventry is therefore required. In light of conclusions set out by the enclosed Landscape Matters Paper, the Green Wedge at Drayton Gate Farm is unduly expansive, extending to circa 83 ha, and is disproportionately restrictive. Based on evidence presented by the enclosed EDP, it is suggested that, if the policy principle of the Green Wedge (ENV3) is retained, its area should be re-drawn as shown on Plan EDP 5. The extent of land identified by ENV3 at this specific location is not required to meet the objective of preventing coalescence. EDP’s assessment concludes that development of this site would not be perceived as a protuberance into open countryside but as a discrete and logical rounding off. The Landscape Representation prepared by EDP ultimately concludes that the change of open land to built form in this location is not, by definition, harmful to the landscape resource (as opposed to the site in isolation). ‘Harm’ to landscape character arises from either: (a) being in an inappropriate place; or (b) through

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inappropriate design and appearance. Neither of these criteria apply to the Drayton Gate Farm site, where development would enable appropriate opportunity to reinforce the structural qualities of the landscape. Summary Further to previous representations, identified by Page 1 of this submission, our client’s interest at Drayton Gate Farm immediately abuts Apex Park. This location provides a logical, deliverable site for the future expansion of employment uses to the town. Notwithstanding this position we recognise that the site is not proposed for allocation, at this point, based on development requirements set out by LPP2. The College objects to principle of Policy ENV3 (Green Wedges). This objection is on the basis of other definitive policies within LPP2 that will guide development both within and outside of the built up area (e.g. Policy ENV1). Policy ENV3 is not therefore justified and should be removed in order that LPP2 can be found sound. In the event that Policy ENV3 is retained, it is respectfully requested that amendment to the Green Wedge boundary, to the west of Daventry, be made in line with EDP5. This seeks alteration to the extent of the Policy ENV3 boundary in order to take account of existing landscape features. In light of our Client’s specific land interest and proposed policy designations to the west of Daventry, our client wishes to participate at the upcoming Examination in Public and would be grateful to be kept informed of arrangements to this effect. In the meantime, please do not hesitate to contact me should you have any queries in respect of the above. Yours sincerely

James Yeoman BA(Hons) DipTP MRTPI Associate Director Cc William Benbow Savills Encs.

Completed consultation response form Landscape Matter Paper (including plans EDP1 to 5 and Key Views) Separate copy of Plan EDP5 - Site Appraisal

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