STAUNCH Holding Plan Objections for Castle Manor Farm

EXECUTIVE SUMMARY OF THE CAMPAIGN GROUP STAUNCH’S FORMAL OBJECTIONS AND REASONS FOR REFUSAL IN RESPECT OF PLANNING APPLICATION NE/22/00151/FUL, HUNTINGDON ROAD, THRAPSTON. THE SITE IS KNOWN LOCALLY AS CASTLE MANOR FARM, OFF ISLINGTON LANE,THRAPSTON

The context of our consideration of this application has been against the approved policy background of the approved Joint Core Strategy for North Northamptonshire (JCS) which was adopted in July 2016. The law requires that the application be determined in accordance with the approved Development Plan unless there are ‘material considerations which indicate otherwise’. It is also clear from case law, notably ‘Peel Investments(North) Ltd v Secretary of State July 2020 ‘ and the judges reference to the analysis carried out by Lindblom J in Bloor Homes with reference to para 11(d) of the NPPF . That it is the policies most important to the determination of the planning application that must be shown to be out of date or no longer relevant not a single policy taken in isolation.

The applicant has failed to provide a compelling case that the approved policies ‘most important’ to the determination of this application are out of date or no longer relevant. It would not therefore be justified to apply a tilted balance (para 11(d)of the NPPF)in favour of the proposal which is in fundamental conflict with several policies in the approved Joint Core Strategy.

It would be apposite to keep in mind the simple but clear Vision of the JCS as applied to EAST NORTHAMPTONSHIRE ‘ .. will be the heartland of small and medium sized enterprises based on regenerated and thriving market towns with an enhanced role for Rushden as the Districts growth town’.

The strategic and physical scale of this proposal is massive. Completely at odds with the Vision of the JCS which is of course translated into the Plans overall Growth Strategy. These, as well as several other policies, are important to the determination of the application and are clearly not out of date, still relevant, and deserve the Councils full support. Except for policy 23, they are not challenged directly by the applicants.

The applicant’s key reasons for a major, strategic departure from the approved Development Plan are set out in their submitted Planning Statement. Our criticism of their key reasons are set out below;

1.Economic, Environmental and Social Credentials

  • We expect the alleged scale of economic benefits to be fully tested by the Council. Notwithstanding, it is true to say that the alleged benefits could be equally delivered from a sustainable site within the A14 corridor, which would be compliant with policy, in proximity to a growth town and are not therefore uniquely deliverable from this non-compliant and unsustainable site which conflicts with National and Local Policies. The alleged economic benefits do not therefore provide a compelling reason to set aside approved policy and cause significant environmental harm to the intrinsic value, beauty, open and landscape character in this location. It is noted that the applicants have failed to give any consideration to alternative sites in the growth areas and have significantly not demonstrated that such sites do not exist.
  • The alleged environmental benefits pale in comparison to the loss of some 75h of beautiful gently undulating open countryside providing essential character to the open countryside setting of the MARKET TOWN of Thrapston and village of Titchmarsh and the range of well-established habitats. The scale of earthworks proposed to create a build platform some 10m below the existing road level of Islington Lane and then the creation of bunding to heights of 7/10m are in themselves so substantial will cause irreversible damage to this environment. Even within a period of 15 years would fail to mitigate such an impact. The proposal would result in the significant loss of natural habitats putting protected species of birds, mammals, and invertebrates at risk including disturbance of their feeding/foraging routes and breeding areas. Significant biodiversity attributes of this site within both the working areas and built footprint. At best the applicants claim of a biodiversity net gain of 10% appears very weak with little evidence. In real terms what we have is the loss of some 70 hectares of well-established biodiverse open countryside, the loss of important historic hedgerows, mature trees, and well evidenced habitats. The provision of 3 hectares of what is nothing more than modified, compensatory, green space is insignificant in comparison. The term modified is used specifically because the applicants are only changing from a farmland habitat graded good and already a priority habitat to mixed scrub and grassland which the applicants claim will be more diverse.
  • That this proposal will have a significant visual intrusion from many vantage points cannot be disputed. The applicant’s analysis of this impact is limited and fails to examine impacts from several important viewpoints.
  • The social benefits advanced would be available from any such more compliant site and are aspirational rather than guaranteed deliverable. Thrapston has no levels of deprivation and certainly no high levels of unemployment to make a specific compelling case to justify a departure.
  1. The JCS is out of date and no longer relevant
  • The applicant argues that the employment land supply policies in the JCS are out of date and that the niche market areas of East Northamptonshire (EN) and Thrapston have fallen behind in the supply of employment land elsewhere in North Northamptonshire (NN).
  • This argument is confirmation of the success of the JCS in delivering a constant stream of sites in sustainable locations well located to the strategic road network and major urban areas. Thrapston was never supposed to match the growth areas for a range of well evidenced reasons.
  • There are serious weaknesses in this assessment. The market assessment has a flawed methodology as it focusses on Thrapston and East Northamptonshire rather than the strategic market area of NN. It also proposes a new forecasting model that is unproven, untested at inquiry, and not recommended for use by Councils in plan preparation.
  • Their market assessment confirms 6 years plus supply of well-located sustainable sites all close to large urban areas allocated for development. Plus, two other sites in Wellingborough that may have a longer lead in time. Such a supply chain is sufficient to meet short to medium term demand and indicates no urgency for additional sites certainly in conflict with the fundamental strategy and policies.
  • At para 6.19 their assessment shows a possible need for c 424000 sqm of logistics floorspace in NN by 2040 some 106h of land. They state that the EN share (NB: not just Thrapston) would be some 10%. Simply put some c 43000sqm and 10h of land in the whole of EN. Not 200,000sqm or 75h of land on a site in Thrapston alone. There is no evidenced, compelling case that the employment land supply policies are out of date. As such the exception provided for in NPPF policy 11(d) does not apply.
  • It is interesting to note that in the conclusions to their Market assessment they rely heavily on the economic case not the out-of-date land supply policies in the JCS.
  • Their arguments that this is the only site that can be developed for very large units is unproven given the six years supply of land available some of which could be reconfigured if Policy 24 of the JCS, re mix of unit sizes, can be overcome. Furthermore, they advance no compelling reason to set aside policy 24 of the JCS.
  1. Peel Investments v Secretary of State. July 2020
  • The applicants appear to rely upon this judgement in their submission. Their interpretation appears to be flawed.
  • The consideration of the judges found that it was ‘the most important policies of the Plan for the determination of the application that had to be overtaken’ by national policy or events. Not just a single policy alone but the Plan as a whole. The applicants do not argue that the growth strategy policies are out of date nor the raft of environmental policies. Their proposal remains in fundamental conflict with all these policies, and in any event has failed to demonstrate a compelling case that land supply policies are out of date.
  1. Sustainable development
  • The site conflicting with the JCS spatial strategy is by default unsustainable.
  • The site is well outside any growth area and therefore is not close to a large supply of local labour thereby encouraging long journey to work times. and the bussing in of labour from further afield. The applicants evidence relating to labour supply is weak at best ,fails to recognise the current inability of the logistics sector to fill jobs with local labour reverting to bussing in staff, higher wages, other benefits and even on site accommodation.
  • Thrapston has a modest population of some 6500 with Titchmarsh village of about 600, Thrapston has a very low unemployment rate of some 3.3% and even considering nearby villages and market towns, the predicted new jobs of 2700 simply will not and cannot be taken up locally. The proposal is strategic it needs a location with a strategic supply of labour.
  • The proposal causes substantial irreversible damage to valued open countryside and habitats that cannot because of its sheer scale be successfully mitigated. Such impacts alone are not sustainable. The absence of any urgent compelling need nor evidence that a raft of approved Plan policies are out of date makes the environmental damage unacceptable.
  1. Direct connection to the strategic highway network
  • The site is accessed off a field gate from a rural lane. Through a modest industrial estate, a limited mini roundabout, then another roundabout serving the town of Thrapston and the A605 which is frequently congested, then onto the roundabout serving the A14 via a single carriageway which experiences severe queuing causing blockages back to the Thrapston roundabout.
  • The range of highway improvements is inadequate and fails to provide a solution to the inherent limitations of existing junctions which were not designed to accommodate strategic growth. These junctions did not benefit from planned infrastructure investment through the Plan process as this is not a strategic location.
  • It has proven difficult to fully assess the highway impacts due to the unknown pre application discussions between the Highway Authority and the two known developers for strategic sites in Thrapston. Both these strategic proposals demonstrate all to well the need for a Plan led strategic approach which would allow for all cumulative highway impacts to be considered. Any other approach taken by the Council would prejudice the interests of the local communities who will bear the brunt of the impacts. Further openness and transparency is required by the Highway Authority to allow for a proper consultation.
  • The cumulative impact on the strategic network needs a strategic overview from National Highways which cannot be achieved through the ad hoc consideration of a single application when a further major application is to be submitted in April. Probably well before the current application can even be considered. A further demonstration of the essential need for such proposals to be considered by the plan process which is already under review.
  • It appears that all highway improvement works have been contained within the bounds of the existing highway (not within red line). That questions whether the highway improvements required cumulatively have been purposefully constrained to the current limits of the highway?
  • STAUNCH’s key objection to this application are set out above and in the reasons for refusal below. They are also underpinned by a series of Appendices (to follow) that set out in greater technical detail our objections and a range of factual errors, omissions, flawed methodology in survey work, and illustrate the weakness of their evidence base.

CONCLUSIONS

THE CASE FOR AN EXCEPTION TO THE NPPF and APPROVED DEVELOPMENT PLANS HAS NOT BEEN MADE AND THE EXCEPTION PROVIDED FOR IN POICLY 11(D) OF THE NNPF SHOULD NOT BE APPLIED. THE APPLICATION MUST THEREFORE BE DETERMINED IN ACCORDANCE WITH APPROVED NATIONAL AND LOCAL POLICIES.

REASONS FOR REFUSAL

  • The proposal conflicts with the NPPF in that applications should be determined in accordance with approved Development Plans unless material considerations indicate otherwise. No such compelling case has been made.
  • The proposal conflicts with NPPF in that it is not sustainable and fails to conserve or enhance the natural environment.
  • The proposal conflicts with policies in the approved Joint Core Strategy namely, but not exclusively.

Policy 1 presumption in favour of sustainable development
Policy 3 landscape character
Policy 4 biodiversity and geodiversity
Policy 10 provision of infrastructure
Policy 11 the network of urban and rural areas
Policy 13 rural exceptions
Policy 18 HGV parking
Policy 23 distribution of jobs
Policy 24 logistics
Policy 25 rural economic development and diversification

The proposal would be significantly damaging to the environment, its ecology, habitats, local heritage assets and the basic quality and character of the open countryside which creates an intrinsic setting for the town of Thrapston and village of Titchmarsh. Such damage would be irreversible, unjustifiable, and incapable of mitigation.

The proposal is so substantial it would undermine the Plan making process by predetermining decisions about the scale and location of new development in particular elevating the market town of Thrapston to a Growth Town without due consideration through the Plan process of more sustainable and less environmentally damaging options which are central to an emerging, or a review of a Plan. This proposal because of its scale and non-compliant location would also be similarly prejudicial to the emerging Oxford to Cambridge ARC Strategic Framework (ARC SF) which when approved will have the status of National Policy.

The proposal would be damaging to the local highway network as it makes inadequate provision for increased traffic generation which will create further congestion and queuing. (NB: to date we understand that National Highways have not been consulted so we await their comments. Given the imminent prospect of another strategic proposal nearby we would fully expect the cumulative impacts to openly considered.)

The proposal would increase the risk of flooding to downstream areas including highways and properties.

STAUNCH reserve the right to make/add to these objections in the light of additional submissions by the applicants, representations from consultees and the submission of similar strategic logistic applications nearby.

APPENDICES TO FOLLOW

A. Appraisal of applicants Planning Statement
B. Appraisal of applicants Thrapston Economic + Market Assessment
C. Appraisal of Environmental submissions
D. Appraisal of visual impact and heritage assets.
E. Appraisal of Ecological submissions.
F. Appraisal of Highway submissions
G. Appraisal of flooding issue and proposed mitigation.

This list is not necessarily exhaustive.

Objections collated and prepared on behalf of STAUNCH by:
David Bailey BSc. Dip TP, MRTPI (retd) March 2022

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