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Person ID   Full Name    Details        Type                   Your view   Reason for comment                                 KBC response
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                                                                                                                              Policy 14 of the CSS and the Kettering
                                                                           9.4 should state that all new housing should
                                                                                                                              Sustainable Design SPD guide all
                                                                           include photovoltaic or similar roofing, so
                                                                                                                              development in relation to sustainability and
                                                                           that roofing structures are utilised in the
                                                                                                                              design. The Sustainable Design SPD
                                                                           production of green electricity. All products in
                                                                                                                              provides guidance and a framework for
                                                                           the building of homes should be British,
                                                                                                                              producing Sustainable Design and Energy
                                                                           organic materials which blend in well with the
                                                                                                                              Statements in order to achieve targets as
                                                                           local environment. Local contractors should
                                                                                                                              outlined in the CSS. Sustainable design
                                                                           be utilised in all aspects. 9.8 should specify
                                                                                                                              techniques vary from property to property
                                                                           that the surrounding existing environment
                                                               Strongly                                                       and the SPD aids in assessing the most
   184804   d'agostino                  document                           takes precedence above all new housing,
                                                               Agree                                                          appropriate techniques.
                                                                           and if new housing is to be built then the
                                                                           surrounding green environment should be
                                                                                                                              Open space will be laid out in accordance
                                                                           invested in and public right of ways
                                                                                                                              with the Kettering Open Space SPD and
                                                                           maintained etc. 9.10 should state that all non
                                                                                                                              preferred policy direction 15 and green
                                                                           recyclable waste should be banned, and if it
                                                                                                                              infrastructure contributions would be
                                                                           is not banned then a local incinerator should
                                                                                                                              required to make provision for the Local
                                                                           be built on the proposed sites so that
                                                                                                                              network as well as the requirement to
                                                                           electricity for local use can be generated
                                                                                                                              improve connectivity between the two towns
                                                                           from this waste.
                                                                                                                              and local facilities.




                                                                                                                                                              1
                                          The Rothwell position is broadly acceptable        Improved connectivity will improve access
                                          and uncontentious so my comments focus             into the town centre. The explanation behind
                                          on Desborough. There is much to commend            site selection is in the sustainability
                                          the proposals but they do contain significant      appraisal. This outlines the constraints to
                                          flaws. My overriding objection to the              developing this site. Although, the Local
                                          proposal is that it extends the town further       Planning Authority recognise that the railway
                                          away from the town centre. The extension           line is a constraint between the town centre
                                          will in effect give rise to two towns, one north   and 'the Grange', development already
                                          of the railway line and one south. Those of        exists to the north of the railway line. Taking
                                          us who live in Desborough already know that        into consideration the existing Pocket Park
                                          the railway line is a constraining factor in       and the need to enhance it (including an
                                          going to Market Harborough or Corby. In one        increase in size proposed by Desborough
                                          case there is a traffic light controlled bridge    West) this would actually separate the
                                          crossing and on the B576 a somewhat                Desborough West proposal further from the
                                          narrow bridge. Access from the B576 to the         town centre than the preferred Desborough
                                          supermarket is difficult either via Gladstone      North. Also, the Desborough West proposal
                                          Street or round a difficult corner at The          would require the construction of a new
         Mr David              Strongly   George. While it is laudable that the aim is to    junction off the A6 and through the Pocket
254448              document
         Larmour               disagree   encourage more cycle and foot traffic this is      Park into the site via Rothwell Road, due to
                                          wholly unrealistic for people who are going to     the existing poor links (mainly congested
                                          do grocery shopping. The macro position            terrace streets) to the town centre, which
                                          The proposals as currently defined expand          currently exist. It is considered that
                                          the town further away from the town centre.        development here would have a greater
                                          The alternative proposal (sometimes known          impact on the town centre and further
                                          as Desborough Central or Desborough                encourage out commuting than Desborough
                                          West) has a more holistic appeal. No               North. Employment land already exists at
                                          explanation has been given why this                Desborough North; there is no further
                                          proposal has been deemed unsuitable. It            requirement to allocate employment land in
                                          more easily feeds into the town centre at one      this AAP in accordance with the findings of
                                          end and out to the A6 bypass at the other. In      the employment background papers, as
                                          addition it results in a more compact              listed in the Position Statement. The plan
                                          community with fewer people out on a limb.         includes a policy direction for Desborough
                                          Employment land could easily be                    Town centre and the next iteration of the
                                          incorporated on the bypass edge of the             document - proposed submission will
                                          extension. There are no arguments                  identify further how the development will
                                          advanced for the statement in 7.0.2                secure improvements to the Town Centre.




                                                                                                                             2
increased self-containment for each town. I      Finally, the Site Specific Proposals LDD will
agree wholeheartedly with the statement set      look at retail offer and town centre
out in 8.0.8 It is important that the urban      boundaries.
extension is integrated into the existing town
and results in the regeneration of the town
however the proposed location will not
contribute to this objective. Town Centre
issues One of the stated objectives for the
review of the AAP was to require the Urban
Extension to support town centre
regeneration, yet nothing in the proposal
shows how Desborough town centre will
benefit from the location of the proposed
extension. The state of the town centre is
recognised locally as a key issue but no
mention is made of the issue in these
proposals. People who end up living on the
new site will find access to Market
Harborough easier than to Desborough town
centre Access issues The development of
The Grange was supposed to be
accompanied by a footbridge across the
railway. The houses are built but the footway
is not. Why should we believe that these new
proposals will result in enhanced foot and
cycle links? Laudable as the ambition set out
in 9.1.1., is it is impossible to see how
extending the town further away from the
town centre can help to meet this ambition.
At least Desborough West (or Central) would
feed into the town centre and lead to a more
compact town. Employment land The original
proposal for 30 hectares in Desborough has
been reduced to 0. How will this help the
town and how can a policy which will ensure
that Desborough becomes a commuter town




                                                                                 3
be said to follow meet sustainable
communities criteria? Summary There is
much to commend this position statement
but the disadvantages far outweigh the
advantages. The plan is to almost create a
satellite town to the north of Desborough
which will effectively be cut off from easy
access to the town centre because of the
railway line. Promised improvements to
linkages between The Grange and the town
centre have not materialised and people who
live in the proposed extension will find
access to Market Harborough easier than to
Desborough town centre.




                                              4
                                                                                            The LPA have been working with
                                                                                            developers of the current Grange
                                                                                            development to provide the best possible
                                                                                            leisure facility in this location. A planning
                                          No infrastructure to cope with the current        application is expected in June and
                                          'The Grange' development - supermarket,           construction of Phase 1 of this facility should
                                          schools, roads, general amenities etc. We         follow shortly after determination. Phase 2 is
                                          should be getting the current village structure   to be brought forward following
                                          fixed first - the roads are terrible, and         commencement of construction of this
                                          transport will get increasingly worse over        planned urban extension. The existing
         Mr David              Strongly
255002              document              time. You have been consulting about a            Desborough Leisure Centre contains
         Buffey                disagree
                                          'new' leisure centre for the last 5 years!!       squash courts which will not be brought
                                          Surely you should be providing for current        forward until Phase 2 of the new leisure
                                          residents and spending our exceedingly high       centre. The Squash Club have been
                                          council tax earnings now! Forget this             informed but the intention is to provide
                                          consultation until the village is in order and    regional competition squash courts with
                                          the infrastructure is sorted!!                    glass backs which are much improved from
                                                                                            the existing. A review of the town centre and
                                                                                            retail provision will be undertaken in the Site
                                                                                            Specific Proposals LDD as well as other
                                                                                            facility provision.




                                                                                                                             5
                                           “Coop saves Desborough” - headlines from
                                           E.T.1909... “Coop destroys Desborough
                                           2009." ...we have lived here all our lives and
                                           have defended this town of ours from jokes
                                           about the coop butchers, coop chemist, coop
                                           toy shop, shoe shop, ladies "fashions”. You
                                           see a theme here!!! ...now what do we have.
                                           a couple of coop "supermarkets" either end
                                           of town selling obviously the same items and
                                           nothing in-between except closed, boarded
                                           up premises, yet another double fronted
                                           shop closed at mass-we heard it was going
                                           to be a cafe/craft shop...that then opened in
                                           Rothwell (boo) we heard that was because          A review of Desborough town centre and
                                           the coop have a clause on the lease that          retail provision will be undertaken during
                                           prevents it being anything but another estate     production of the Kettering Borough Site
                                           agents!! ...is that true? If so I would like to   Specific Proposals LDD. It is however,
         Mrs Jayne              Strongly   point out that my husband is a builder and        considered necessary to improve the public
255163               document
         Hall                   disagree   we would like the council to stop anyone else     realm in the town centre to make it a more
                                           from becoming a builder in Desborough as          attractive place for business to invest. Also,
                                           we want ALL the business.......is that            improved connectivity into the town centre
                                           possible? Somehow I very much doubt               will make it more accessible for local people
                                           it......we don’t want better pavements, street    and increase the levels of trade available.
                                           art and any other titivation......we want shops
                                           for gods sake!!!!!!....yes I shop with Tesco
                                           online...yes I go to Market Harborough M+S
                                           (although not for long)...because there is no
                                           choice...and not just food items...did you
                                           know you cannot buy any
                                           underwear...tights...childrens clothing...you
                                           name it you cant get it here....don’t even
                                           suggest going to Kettering or Corby ...we
                                           WANT to support " artarn " like we used to
                                           be able to...come on give us some pride
                                           back. GIVE US SOME SHOPS
                                           BACK!!!!!!!!!!!!!!!!!




                                                                                                                             6
                                          A laymen's opinion Desborough town centre         The LPA have been working with
                                          lacks life and variety. Many buildings - retail   developers of the current Grange
                                          and industrial are empty and boarded up. It       development to provide the best possible
                                          is a common statement that the "CO-OP"            leisure facility in this location. A planning
                                          own Desborough. Looking around this               application is expected in June and
                                          appears true, most of the grocery stores and      construction of Phase 1 of this facility should
                                          convenience stores are "CO-OP" Some of            follow shortly after determination. Phase 2 is
                                          the old buildings and land belong to the Co-      to be brought forward following
                                          OP are just allowed to sit abandoned              commencement of construction of this
                                          bringing down the image of the town centre        planned urban extension. The proposed
                                          and town in general. Most people I know           urban extensions will help to fund Phase 2
                                          travel out of the town in order to shop as the    making the Leisure Centre larger and
                                          town centre is inadequate. The leisure centre     offering a number of new additional facilities
                                          is too small and offers inadequate services       including competition squash courts.
                                          more in keeping with a village hut. A lot of
                                          the current surrounding open space to the         The urban extension at Desborough will
                                          North currently used by all residents and         actually improve the current open space
         Mr                               children to play and walk will be developed       offer to the north of the town, extending and
255529              document   Disagree
         Capewell                         meaning people will have to travel further in     making more accessible the Country Park.
                                          order to access this open space, meaning          Green Infrastructure contributions will also
                                          that more people will take to driving again       be sought for the provision of an improved
                                          out of town to surrounding areas and points       local network. Preferred policy directions 15
                                          of interest. There is inadequate facilities for   and 16 provide a list of facilities which give
                                          youths and as such they congregate in the         examples of the contributions the developer
                                          town centre. The rail station re-opening          may be expected to provide. Improved and
                                          would supply good travel links in/out of town,    new open space and community facilities
                                          encouraging new business and providing            will be expected for all age ranges to serve
                                          commuter links to London. This would boost        the needs of the new population.
                                          housing demand and provide increased
                                          productivity with existing and new services.      A review of the town centre, retail and
                                          Surely more homes will put further strains on     facility provision will be undertaken in the
                                          the already struggling resources of the town.     Site Specific Proposals LDD, with a view to
                                          Should the town centre not be done first and      improve the current offer for the existing
                                          this will attract new business and peoples        population through land allocation. The re-
                                          desire to reside in Desborough and which          opening of the railway station is
                                          point dwellings can be built to accommodate       unfortunately not a strategic priority and




                                                                                                                             7
the then demand. The current estate "The         would not be something we would expect
Grange" has not sold all of it's houses and      the proposed extension to deliver. However,
some have been half built and then tore          improvements to public transport will be
down again ;leaving ugly open space. This        important to the success of a sustainable
due to insufficient demand in the housing        urban extension.
market in the current climate to interest
developers to continue. How will an extra        The Local Planning Authority is aware of the
10,000 empty homes improve things. Surely        current economic climate and that there has
we should concentrate on the heart of the        been a reduction in the sale of houses.
town first and then build around it once it is   However, this plan is intended to guide the
healthy?                                         delivery of housing until 2021.




                                                                                8
           Mrs Carole                                   Strongly
  254480                            document                       (No further comments made).                        Noted.
           Preen                                        disagree




                                                                   Wm Morrison Supermarkets plc consider that
                                                                   it is important to ensure that the proposed
                                                                   'shops and community facilities' are designed
                                                                   to provide for a local need. In particular it is
                        Wm                                         important to ensure that the scale of any
                        Morrison                                   shop provision is appropriate and will not
261812                              paragraph   8.0.3   Disagree                                                      Noted
                        Supermark                                  result in the diversion of trade away from the
                        ets plc                                    town centre, particularly as one of the aims is
                                                                   to facilitate the regeneration of Rothwell town
                                                                   centre. To that end it would be helpful to
                                                                   indicate a maximum size level appropriate
                                                                   for 'local' shops.




                                                                                                                               9
                                                    Wm Morrison Supermarkets plc consider that
                                                    it is important to ensure that the proposed
                                                    'shops and other community infrastructure'
                                                    are designed to provide for a local need. In
                                                    particular it is important to ensure that the
         Wm
                                                    scale of any shop provision is appropriate
         Morrison
261812               paragraph   8.0.5   Disagree   and will not result in the diversion of trade   Noted
         Supermark
                                                    away from the town centre, particularly as
         ets plc
                                                    one of the aims is to facilitate the
                                                    regeneration of Desborough town centre. To
                                                    that end it would be helpful to indicate a
                                                    maximum size level appropriate for 'local'
                                                    shops.




                                                                                                            10
                                                     I do not see the need for 700 extra homes
                                                     for Rothwell. In the past three years there
                                                                                                       The Local Planning Authority is aware of the
                                                     have been several new developments which
                                                                                                       current economic climate and that there has
                                                     must total in excess of 200, and very little
                                                                                                       been a reduction in the sale of houses.
                                                     social housing amongst these. Who is going
                                                                                                       However, this plan is intended to guide the
                                                     to buy these new homes, I doubt it being
                                                                                                       delivery of housing to 2021. Policy 15 of the
                                                     local people. If these homes are built, the
                                                                                                       CSS identifies the requirement for 30 per
                                                     added population will result in severe
                                                                                                       cent of the proposed urban extension to be
                                                     congestion of Rothwell on its roads, both to
                                                                                                       affordable housing and the relevant HMA
                                                     obtain access to the A14 and to schools
                                                                                                       identifies the specific types and sizes of
                                                     centralised in small restricted streets. As a
                                                                                                       houses required to meet the current need in
                                                     consequence, the whole town will be at a
                                                                                                       both towns. A new junction off the A6 will be
                                                     standstill during peak times. A small number
                                                                                                       required to serve the proposed urban
         Mrs.                                        will probably use the proposed access
                                          Strongly                                                     extension, especially large vehicles and
262660   Sandra       paragraph   1.0.3              footpath, but the majority will use their cars
                                          disagree                                                     lorries. A Public Realm Strategy for Rothwell
         Mcloughlin                                  to get the children to school. The only way to
                                                                                                       is intended to improve the public realm and
                                                     avoid this would be to put on a school bus to
                                                                                                       reduce the amount of on-street car parking
                                                     the infant and junior schools, but I doubt
                                                                                                       in the town centre to prevent traffic 'bottle-
                                                     again many parents opting for their little ones
                                                                                                       necks' and aid the free-flow of traffic through
                                                     being taken to school this way. The other
                                                                                                       the town centre. This AAP is also intended
                                                     new residents, without small children, will
                                                                                                       to help achieve the modal shift as outlined in
                                                     then expected to travel away from the town
                                                                                                       policy 13 of the CSS through improving
                                                     across to the new A6 to get onto the A14. In
                                                                                                       connectivity via walking and cycling as well
                                                     my opinion this will not happen. This is
                                                                                                       as improving public transport. Green Travel
                                                     because extra traffic has been noted coming
                                                                                                       Plans especially for key facilities such as
                                                     through Rothwell as a direct result of the
                                                                                                       schools will aid in the safe delivery of pupils
                                                     new houses in Desborough, as it is a shorter
                                                                                                       to schools and nurseries.
                                                     route to the A14, so I doubt the new
                                                     residents of Rothwell will take a longer route.




                                                                                                                                      11
                                                     I make a further comment in that if these
                                                     houses are built, and we gain another 1400
                                                     residents, what facilities are going to be
                                                     made available for them, particularly the
                                                     young adults? We have enough problems
                                                     with kids not having anything to do in
                                                     Rothwell; I would suggest not just a
                                                                                                       Community facilities will be required to be
                                                     contribution but a rebuild of the community
                                                                                                       provided by the developers. However,
                                                     centre in Well Lane. I see Desborough is
                                                                                                       funding from the urban extension will only
                                                     having a better Leisure Centre and that is
                                                                                                       make provision for the facilities required as
                                                     great for the people of Desborough.
         Mrs.                                                                                          a result of the pressure generated by the
                                          Strongly   However, it is obvious that as our kids are
262660   Sandra       paragraph   1.0.5                                                                increased population. As outlined in
                                          disagree   not now using that facility, would it not be
         Mcloughlin                                                                                    preferred policy direction 1 'some services
                                                     wiser to go to the senior school here and ask
                                                                                                       may be focused on an individual town but
                                                     the young adults of our town what they
                                                                                                       serve both'. Connectivity will be improved
                                                     would like to have in their town. After all, by
                                                                                                       between the towns to ensure that services
                                                     the time this goes ahead and gets built,
                                                                                                       can be easily shared.
                                                     these are the people who will be the future of
                                                     the town and know what's needed to keep
                                                     the young happy and out of trouble. I do feel
                                                     the town does not have anything to offer
                                                     youngsters right now, so to think of greater
                                                     numbers will only result in a loss of the
                                                     town's overall appeal.




                                                                                                                                      12
                                                                                                    This Area Action Plan is to plan primarily for
                                                                                                    urban extensions to Rothwell and
                                                                                                    Desborough. It is recognised that
                                                                                                    improvements are necessary in Desborough
                                                                                                    Town Centre to support the proposed
                                                  Desborough needs a decent town centre             population and a contribution will be
                                                  with decent shops and services. It does not       required through this plan to support the
                                                  need any more houses on the Grange                regeneration of the town, especially for
                                                  estate. The builders on the Grange can’t          improvements to the public realm which may
                                                  even sell the existing homes that they have       act as a catalyst for further regeneration.
                                                  already built. We have a large estate and not     However, a more comprehensive strategy
                                                  one play park in the vicinity. I would consider   for the regeneration of Desborough town
         Mr Mark                       Strongly   the Plens to be unsafe for young children to      centre will be developed and consulted upon
263619             paragraph   3.2.3
         Hope                          disagree   play in. A park with swings and slides and an     during the adoption of the Kettering Site
                                                  area of grass to play ball games on would be      Specific Proposals Local Development
                                                  much more welcome than more tarmac and            Document.
                                                  houses. We have nice countryside around
                                                  Desborough. Why is it that the local council      The Local Planning Authority is aware of the
                                                  always want to build houses on it or erect        current economic climate and that there has
                                                  eyesores like the Great Bear Distribution         been a reduction in the sale of houses.
                                                  building.                                         However, this plan is intended to guide the
                                                                                                    delivery of housing to 2021.

                                                                                                    Open space will be laid out in accordance
                                                                                                    with the Kettering Open Space SPD and
                                                                                                    preferred policy direction 15.




                                                                                                                                  13
                                                 The comment concerning the ability of the
                                                 Rothwell North site to be assimilated into the
                                                 surrounding countryside (as referred to in
                                                 your report) would be laughable, were the
                                                 fate of this beautiful countryside under your
                                                 wicked plan not tragic on a Shakespearean
                                                 scale. What will not be sustained will be the
                                                 woodpeckers, yellowhammers, fieldfare,
                                                 redwings, whitethroats, blackcaps,
                                                 wheatears, snipe, blackbirds, bramblings,
                                                 chiffchaffs, magpies and other birds that it
                                                 has been my privilege to see on this site
                                                 over the past 40 years. No doubt when this
                                                 site is raped by your development the
                                                                                                  The Sustainability Appraisal looks at all
                                                 wonderful hedgerows where I have gathered
                                                                                                  potential environmental impacts of the
                                                 sloes and berries will be torn violently from
                                                                                                  proposed development and weighs these
                                                 the unquiet earth by your mechanical
                                                                                                  against the requirement to provide housing
         Mr Ian                       Strongly   diggers, trees where I have watched
264176            paragraph   8.0.3                                                               in accordance with the CSS. It also
         Foster                       disagree   fledglings leave the nest on balmy early
                                                                                                  suggests mitigation measures which have
                                                 summer evenings will be savagely ripped
                                                                                                  been highlighted within the document to
                                                 down by your hellish machines and the
                                                                                                  protect birds and other ecology as well as
                                                 meadows where I have smelt the sweet
                                                                                                  trees.
                                                 grass of England will be tarred and
                                                 concreted over by your brutish workforce
                                                 who are "merely carrying out orders". In
                                                 short, there is nothing environmentally
                                                 sustainable about this site. By choosing this
                                                 site, you choose on our behalf money over
                                                 morality, houses over heaven and
                                                 extermination over Elysium. Furthermore,
                                                 you choose this without consulting us,
                                                 excepting this token piece of technological
                                                 wizardry which is so confusing as to baffle
                                                 Oxbridge alumni. Therefore I want this
                                                 proposed site preserved as a site of
                                                 outstanding natural beauty in perpetuity. God




                                                                                                                               14
knows, the world is ugly enough without
Kettering Borough Council giving the green
light to yet more ghastly red brick erected
over the spiritually enhancing Rothwell North
heaven haven site. I don't expect you to take
note of my views. Instead, no doubt you'll
plant a token tree or two in the middle of
fields of concrete, plant a few plastic flowers
and slap yourselves on the back whilst telling
yourselves what fine fellows you are, what
impeccable green credentials you have. This
is indeed hell on earth.




                                                  15
                     Deputy
                     Head                                          Thank you for consulting The Coal Authority
                     Planning                                      on the above. Having reviewed your
         Miss        and Local                                     document, I confirm that we have no specific
169659   Rachael     Authority    document            No opinion   sites to add to this consultation at this stage.   Noted
         Bust        Liaison                                       We look forward to receiving your emerging
                     Departmen                                     planning policy related documents;
                     t The Coal                                    preferably in an electronic format.
                     Authority




                                                                                                                      At detailed planning application stage, the
                                                                   As our house is on the boundary line and the       impact of the specific proposals on the
         Mrs Linda                                    Strongly     kitchen window is approx 3ft from the              amenity of existing residents will be
262835                            paragraph   8.0.5
         Tomkins                                      disagree     boundary line I very much object to having         considered in accordance with policy 13 of
                                                                   houses built so close.                             the CSS and other relevant national,
                                                                                                                      regional and local planning policy.




                                                                                                                                                    16
                                                    This representation relates to Desborough
                                                    Central PREFERRED POLICY DIRECTION
                                                    1 Persimmon Homes supports the overall
                                                    approach to the provision of Urban
                                                    Extensions at Desborough and Rothwell
                                                                                                   As outlined in the Sustainability Appraisal it
                                                    based upon the identified role of the two
                                                                                                   is considered that due to the presence of the
                                                    towns. The alternative proposal at
                                                                                                   pocket park, the nature of the connecting
                                                    Desborough Central would have provided a
         Persimmon                                                                                 roads and the requirement for a new
                                         Strongly   far more sustainable location for
268419   Homes       paragraph   7.0.2                                                             junction off the A6 to secure the
                                         disagree   development, especially in terms of its
         Midlands                                                                                  development, Desborough West would
                                                    connectivity than the Councils Preferred
                                                                                                   actually encourage out commuting and fail
                                                    Policy Direction to the north of the Grange.
                                                                                                   to provide sufficient connectivity to the rest
                                                    The alternative proposals at Desborough
                                                                                                   of the town.
                                                    Central would have ensured the
                                                    regeneration of Desborough Town Centre,
                                                    improved connections to and within the town
                                                    and made provision for increased
                                                    employment opportunities.




                                                                                                                                 17
                                                    This representation relates to Desborough
                                                    Central PREFERRED POLICY DIRECTION
                                                    2 Persimmon Homes supports the Councils
                                                    vision to enhance the character and
                                                    individuality of Desborough. However, it is
                                                                                                      Policy direction 5 aims to improve
                                                    considered that this vision cannot be
                                                                                                      connectivity and will ensure better linkages
                                                    achieved through the Councils preferred
                                                                                                      over the railway line. As outlined in the
                                                    location for development at Desborough.
                                                                                                      Sustainability Appraisal the proposal is
         Persimmon                                  The extension to The Grange (the Councils
                                                                                                      actually no further from the town centre than
268419   Homes       paragraph   7.0.4   Disagree   preferred location for growth in Desborough)
                                                                                                      Desborough West and parts of the preferred
         Midlands                                   will result in a large development detached
                                                                                                      extension are closer to the town centre than
                                                    from the town centre due to its position to the
                                                                                                      Desborough West due to the separation
                                                    north of the railway line, poor links across it
                                                                                                      which would exist taking into consideration
                                                    and the circuitous routes between the new
                                                                                                      the existence of the Pocket Park.
                                                    and existing communities. Persimmon
                                                    Homes concerns regarding the Councils
                                                    preferred location for development are set
                                                    out in further detail in Preferred Policy
                                                    Direction 4.




                                                                                                                                    18
                                                    This representation relates to Desborough      The Sustainability Appraisal (SA) and Urban
                                                    Central PREFERRED POLICY DIRECTION             Extension Methodology outline and support
                                                    4 As you are aware Persimmon Homes             the proposed direction for growth. Although,
                                                    Midlands, has previously provided the          this highlighted some areas for improvement
                                                    Borough Council with detailed submissions      it is considered that policies can be put in
                                                    advancing its case for the allocation of the   place to address these issues whilst for the
                                                    land known as Desborough Central which is      proposed Desborough West (or central) the
                                                    located immediately to the west of the town    solutions are not so apparent. The
                                                    centre. The documentation and supporting       opportunities identified above are
                                                    evidence provided to the Council comprises:    opportunities which exist for the preferred
                                                    June 2004 Submission; Desborough West          direction for growth. Policy direction 5 aims
                                                    Development Statement and Supplementary        to improve connectivity and will ensure
                                                    Information; Appendices to the Desborough      better linkages over the railway line. As
                                                    West Development Statement; Desborough         outlined in the SA the proposal is actually no
                                                    West Concept Master plan; Accompanying         further from the town centre than other
                                                    Technical Reports: Requirements of             options and parts of the extension are closer
                                                    Education Provision by JRW Solutions (20       to the town centre than Desborough West
         Persimmon
                                         Strongly   January 2003); LDA Landscape and Visual        due to the separation which would exist
268419   Homes       paragraph   8.0.6
                                         disagree   Impact Assessment; The Robert Stebbings        taking into consideration the Pocket Park.
         Midlands
                                                    Consultancy Limited’s Ecological
                                                    Assessment; Archaeological Desk Based          The SHLAA only looks at the housing and
                                                    Assessment by CgMs Consulting (April           its deliverability not any wider impacts of the
                                                    2002); Agricultural Land Classification and    provision or other uses. The SA looks at all
                                                    Farm Business Impact Assessment by ADAS        the social, economic and environmental
                                                    (October 2003); Flood Risk Assessment by       impacts of any proposed site and along with
                                                    BWB Partnership; Transport Assessment          the Urban Extension Methodology is the
                                                    Scoping Study by BWB; Soiltechnics Desk        most appropriate means of assessing sites
                                                    Study Report Volumes 1 and 2 (June 1999)       and site selection. Also, the SHLAA is a
                                                    December 2007 Submission Additional            technical study of housing potential, working
                                                    information was provided at the request of     on the best available information at a point
                                                    the Borough Council which detailed the         in time; this means it is not necessarily fully
                                                    social and economic benefits of the            inclusive. The SHLAA forms part of the LDF
                                                    development with particular reference to:      evidence base, along with a range of other
                                                    regeneration, connectivity, integration and    technical studies. It does not in any way
                                                    community cohesion; transport; leisure; and    prejudice decisions to be taken by the Joint
                                                    landscape and biodiversity issues.             Planning Committee or by individual




                                                                                                                                  19
November 2008 Submission Additional               district/borough planning authorities, in
information was provided relating to: the         relation to preferred directions of growth,
deletion of any requirement for employment        site identification in Development Plan
land to be provided as part of the urban          Documents (DPDs) or the determination of
extension; the requirement to set out how         planning applications.
the development would assist with the
physical and economic regeneration of the
town centre. Persimmon Homes maintains
its objection to the Councils Preferred Policy
Direction to locate residential development to
the north of Desborough. It is considered
that the land to the north of the Grange will
not provide a sustainable urban extension to
Desborough and that Persimmon Homes€™
alternative proposal at Desborough Central
would secure a more suitable and
sustainable urban extension than the
Preferred Policy Direction. It is considered
that the land to the north of the Grange will
result in a large development detached from
the town centre due to its position to the
north of the railway line, poor links across it
and the circuitous routes between the new
and existing communities. The alternative
proposal at Desborough Central would have
provided an opportunity to create a southern
gateway to the town and initiate the
regeneration of the town centre. The
justification for the alternative proposal at
Desborough Central included: The
Desborough Central proposal would have
been more accessible to the town centre
than the Councils preferred location for
growth to the north of The Grange; The
development at Desborough Central would
have presented the opportunity to make




                                                                               20
numerous links to the existing movement
network of Desborough, as well as being
best placed to take advantage of planned
improvements for pedestrians and cyclists on
the Rothwell Road corridor; The alternative
proposal at Desborough Central site would
have been significantly more accessible to
sustainable transport modes than the
Councils preferred direction of growth; The
Desborough Central site would have
provided a major opportunity to connect
existing residential areas to the south of the
railway line with a major new network of
public open space that would have provided
access to a variety of different environments
nature conservation, amenity, play facilities,
sports and recreation, etc; The alternative
proposal would have provided new homes in
a far more accessible location for
pedestrians and cyclists, closer to the
existing services and facilities within the town
centre. The alternative proposal at
Desborough Central would have connected
with Desboroughs urban fabric, as well as
the towns existing community. In so doing,
Desborough Central would not only have
delivered new homes but would have also
acted as a catalyst for the regeneration of
the town, reinforcing its identity and
improving the quality of life for all its
residents. Since the submission in November
2008, further support for Persimmon Homes
case in respect of the suitability of the land at
Desborough Central in comparison to the
land to the north of The Grange has been
provided in the North Northamptonshire




                                                    21
Strategic Housing Land Availability
Assessment which identifies the Desborough
Central site as a Category 2 site; a site which
performs moderately well against the
assessment criteria and appears to be
achievable/ deliverable. The land to the north
of the Grange is identified as a Category 3
site; a site achieving low overall scores and
performing least well against the assessment
criteria.




                                                  22
                                                 This representation relates to Desborough
                                                 Central PREFERRED POLICY DIRECTION
                                                 5 Improved connections for pedestrians and
                                                 cyclists The Rothwell North development
                                                 proposal will enable the provision of a cycle
                                                 route between Rothwell and Desborough
                                                 alongside the B576. This will enhance the
                                                 route for pedestrians walking between the
                                                 two towns and create a safer environment
                                                 for cycles using the route. Additional
                                                 proposals for achieving the improved
                                                 connectivity between the two towns have
                                                 been discussed with the Rights of Way
                                                 Officer at Northamptonshire County Council,
                                                 who initially advised that the County Council
                                                 wished to upgrade Shotwell Mill Lane to
                                                                                                    The creation of a new access onto the A6
                                                 create an improved connection for cyclists as
         Persimmon                                                                                  for the provision of ease of movement would
                                                 well as pedestrians. These proposals were
268419   Homes       paragraph   9.1.4   Agree                                                      require significant highway works. This level
                                                 prepared as part of the Growth Area Fund
         Midlands                                                                                   of works is not necessary for the preferred
                                                 Round 2 Bid and included rerouting part of
                                                                                                    direction of growth.
                                                 the footpath through a wildlife site and
                                                 providing a surfaced route to accommodate
                                                 wheelchair users, pushchairs and cycles.
                                                 Due to constraints with both the existing and
                                                 revised footpath, including landownership
                                                 and ecological issues, the proposals have
                                                 been put on hold. The Rights of Way Officer
                                                 is however keen to pursue improvements to
                                                 Shotwell Mill Lane to enhance pedestrian
                                                 access between Desborough and Rothwell.
                                                 Persimmon Homes would be willing to make
                                                 a financial contribution towards this scheme,
                                                 if it is resurrected, as part of the alternative
                                                 proposal at Desborough Central. B576/A6
                                                 Link Road Although this requirement applies
                                                 to the proposed urban extension at Rothwell,




                                                                                                                                  23
it is in part sought to enable vehicles to
access Desborough south without passing
through either town. Persimmon Homes
proposals for Rothwell will therefore have
major benefits to the reduction of traffic
congestion in both towns. In addition, the
alternative option at Desborough Central
would have included a similar link road. The
main vehicular access would have been via
a new three arm roundabout on the A6 and a
junction onto Lower Street. This road would
have been available for use by local bus
services and therefore would not just have
provided a high quality route to the strategic
highway network and significant
improvements to the town centres
accessibility, for the benefit of both local
residents and businesses, but would also
have provided a convenient route for public
transport users. Public Transport The
proposed link road, described above, and its
junctions with the surrounding road network
would have provided the opportunity to route
bus services through the site. Further the
alternative proposal at Desborough Central
already benefits from the proximity of the
existing Rothwell Road public transport
corridor. Bus routes pass the site on
Rothwell Road, providing a frequent service
from the existing bus stop on Rothwell Road
to the High Street, to the north and the south
of the town and beyond. Cyclists and
Pedestrians The alternative development
proposal would have included a
comprehensive network of direct and
attractive pedestrian/cycle routes which




                                                 24
would have connected with the existing
facilities in the areas. The site is also well
placed to take advantage of the planned
improvements for pedestrians and cyclists on
the Rothwell Road corridor and particularly
secondary school pupils travelling to
Montsaye College. Links to new and existing
Networks and Facilities The alternative
proposal at Desborough Central site would
have been accessible to the town centre
than the Preferred Policy Direction site to the
north of Desborough by virtue of its direct
pedestrian routes. The Desborough Central
site would have been best placed to take
advantage of planned improvements for
pedestrian and cyclists on the Rothwell Road
corridor. The link road through the
Desborough Central site would have
provided improved access to the town centre
for those living, working and visiting the
town.




                                                  25
                                                     This representation relates to Desborough
                                                     Central PREFERRED POLICY DIRECTION
                                                     7 Persimmon Homes believes that the
                                                     alternative development proposal at
                                                     Desborough Central would have contributed
                                                     to the regeneration of the town centre. As
                                                     stated in the response to Preferred Policy
                                                     Direction 5, the site would have delivered
                                                     connectivity to the town centre through
                                                     existing connections. Improvements would
                                                     also have been made where necessary to
                                                     public transport, cycleways and footpaths in      Similar proposals were contained in the
                                                     order to ensure ease of access to the town        Desborough North submissions in terms of
                                                     centre. The Brief for the existing Grange         access improvements into the town centre.
                                                     Development identified a potential                As previously stated the Desborough Pocket
                                                     pedestrian link from the development, over        Park acts as a physical barrier in between
                                                     the railway line and connecting with              Desborough west and the rest of the town.
         Persimmon
                                                     Gladstone Street. Although, Kettering             Kettering Borough Council has been in
268419   Homes       paragraph   9.2.15   Disagree
                                                     Borough Council has advised that the bridge       regular communication with the developers,
         Midlands
                                                     will be constructed, the S106 Agreement for       landowners, highways authority and the
                                                     the Grange Development only requires the          railway company to secure a footbridge over
                                                     developer to have used all reasonable             the railway line and is continuing to do so. If
                                                     endeavours to construct the bridge by             not brought forward in the short term, it is
                                                     October 2008. This date has now passed            considered that this will be a priority in this
                                                     and the pedestrian footbridge has not been        emerging AAP.
                                                     provided. Therefore, it is questionable
                                                     whether the pedestrian link and footbridge
                                                     will in fact be provided with the Preferred
                                                     Policy Direction location for development.
                                                     Without it there will not be the enhanced
                                                     connectivity to the existing services and
                                                     facilities in the town centre; and hence there
                                                     is a danger of a false perception about the
                                                     connectivity and accessibility of the Preferred
                                                     Policy Direction site. The proposed
                                                     connections at Desborough Central would




                                                                                                                                      26
have been much more deliverable than
those to the north of the Grange, for the
reasons detailed in the previous
submissions.




                                            27
                                                  This representation relates to Desborough
                                                  Central PREFERRED POLICY DIRECTION
         Persimmon                                8 Persimmon Homes would consider
268419   Homes       paragraph   9.2.16   Agree   bringing forward, as part of the Desborough     Noted
         Midlands                                 Central development, a number of live/work
                                                  units which offer flexible living and working
                                                  space for small businesses.




                                                                                                          28
                                                 This representation relates to Desborough
                                                 Central PREFERRED POLICY DIRECTION
                                                 9 The alternative proposal at Desborough
                                                 Central would have provided a local centre
                                                 adjacent to the new Primary School. Given
                                                 the emphasis on regeneration within
                                                 Desboroughs town centre and the ease with
                                                 which residents would have been able to
                                                 walk and cycle to it, Persimmon Homes
                                                 recognised how important it was that the
                                                 local centre did not detract from the services
                                                 and facilities on offer in the town centre. The
                                                 local centre would have been designed to
                                                 provide for the needs of the new
                                                 development only. In terms of composition, it
                                                 was envisaged that the local centre would
                                                 provide a maximum of 600 square metres
         Persimmon
                                                 (sq m) of retail floorspace which could
268419   Homes       paragraph   9.3.2   Agree                                                     Noted
                                                 provide 6 small (100 sq m) units or, more
         Midlands
                                                 likely, 2 or 3 slightly larger units. Although
                                                 described as the retail units, the occupiers of
                                                 these premises might have included the
                                                 following uses: A1 Shops (e.g. Convenience
                                                 Store, hairdresser, etc); A2 Financial and
                                                 Professional; A3 Restaurant and/or Cafe; A5
                                                 Hot Food Takeaway; B1 Business (e.g.
                                                 Offices) which it is anticipated could be
                                                 provided as first floor accommodation; and
                                                 D1 Non-residential institutions (e.g. a
                                                 crèche). In view of the number of public
                                                 houses within the town centre and the
                                                 proximity of them to the alternative proposal
                                                 at Desborough Central, it was not proposed
                                                 to provide a further drinking establishment as
                                                 part of the Desborough Central
                                                 development.




                                                                                                           29
                                                 This representation relates to Desborough
                                                 Central PREFERRED POLICY DIRECTION
                                                 10 Persimmon Homes would be willing and
                                                 able to provide a range of dwelling types and
                                                 sizes, thereby enabling a wide choice of
                                                 properties for those needing or wishing to
                                                 live in the area. Persimmon Homes would
                                                 work with its master planning consultants to
                                                 achieve a mix of densities, resulting in a
         Persimmon                               range of plot sizes and dwelling types that
268419   Homes       paragraph   9.4.2   Agree   respond to the requirements of Preferred         Noted
         Midlands                                Policy Direction 10, as well as national
                                                 planning policy. The location, orientation and
                                                 inter-relationships of the different densities
                                                 (and the housing types that reflect the
                                                 densities) would be given careful
                                                 consideration, to ensure that the built
                                                 development is well laid out, characterful,
                                                 permeable and respectful of the prevailing
                                                 urban form, scale and building types that
                                                 occur in Desborough.




                                                                                                          30
                                                 This representation relates to Desborough
                                                 Central PREFERRED POLICY DIRECTION
                                                 11 As indicated in response to Preferred
                                                 Policy Direction 10, Persimmon Homes is
                                                 willing and able to provide a range of
                                                 dwelling types and sizes. Bungalows and
                                                 other forms of housing designed specifically    Noted - the provision of affordable housing
                                                 for older people and others with special        shall be in accordance with the Core Spatial
         Persimmon
                                                 needs could also be provided. Before the        Strategy and the requirements of the
268419   Homes       paragraph   9.4.4   Agree
                                                 current change in market conditions,            relevant Housing Market Assessment.
         Midlands
                                                 Persimmon Homes would have been willing         Viability testing will inform the next iteration
                                                 and able to consider the provision of one and   of the AAP - Proposed Submission.
                                                 two bed flats as part of the development.
                                                 However in the view of the current adverse
                                                 market conditions, a decision on the
                                                 provision of this size and type of dwelling
                                                 would be deferred until the detailed design
                                                 stage.




                                                                                                                                 31
                                                    This representation relates to Desborough
                                                    Central PREFERRED POLICY DIRECTION
                                                    12 Persimmon Homes is aware of the
                                                    requirements of Policy 15 of the North
                                                    Northamptonshire Core Spatial Strategy
                                                    (NNCSS) which seeks to meet local housing
                                                    need and ensure that a percentage of all
                                                    new development is genuinely affordable
                                                    and in line with the target of 30% for
                                                    Kettering Borough. However, the Inspector
                                                    who held the examination into the East
                                                    Northamptonshire Rural North, Oundle and
                                                    Thrapston AAP has recently advised that he
                                                    is unconvinced that the affordable housing
                                                    policy (which is based on that contained
                                                    within the NNCSS) is supported by an                  Noted - the provision of affordable housing
                                                    adequately robust and credible evidence               shall be in accordance with the Core Spatial
         Persimmon
                                                    base; nor that the viability of the affordable        Strategy and the requirements of the
268419   Homes       paragraph   9.5.3   Disagree
                                                    housing targets accord with government                relevant Housing Market Assessment.
         Midlands
                                                    guidance as set out in PPS3. He continued             Viability testing will inform the next iteration
                                                    by explaining that: The Blythe Valley Court           of the AAP - Proposed Submission.
                                                    judgement has important implications for all
                                                    DPDs in its interpretation of the guidance in
                                                    paragraph 29 of PPS3. The inclusion of
                                                    words within the policy to the effect that
                                                    viability factors will be assessed on an
                                                    individual site basis is not sufficient. It follows
                                                    that the evidence base should demonstrate
                                                    the extent to which the affordable housing
                                                    target for the plan area and the site-size
                                                    thresholds and proportions reflect an
                                                    assessment of the likely economic viability of
                                                    land for housing within the area taking
                                                    account of risks to delivery and the likely
                                                    availability of finance. Such information is not
                                                    evident in the SHMA. The SHMA on which




                                                                                                                                          32
the Borough Council is relying in justification
for the emerging affordable housing target in
the Rothwell and Desborough Urban
Extensions AAP Position Statement is the
same SHMA that was found wanting at the
Rural North, Oundle and Thrapston
Examination. It therefore follows that the
same conclusions in respect of the policys
unsoundness will be reached. In any event it
is essential that the changing market and
economic conditions are taken into account
when formulating any affordable housing
policy.




                                                  33
                                                      This representation relates to Desborough
                                                      Central PREFERRED POLICY DIRECTION
                                                      13 Persimmon Homes is willing and able to
         Persimmon                                    incorporate sustainable drainage (SUDs)
268419   Homes       paragraph   9.6.4   Agree        systems into its proposed development at         Noted
         Midlands                                     Desborough Central. Persimmon Homes will
                                                      seek to ensure that the SUDs have dual
                                                      functionality and that their long term
                                                      maintenance is secured.




                                                      This representation relates to Desborough
                                                      Central PREFERRED POLICY DIRECTION
         Persimmon                                    14 Persimmon Homes is confident that its
268419   Homes       paragraph   9.6.8   No opinion   previous submissions provide sufficient detail   Noted
         Midlands                                     of its approach to the integration of high
                                                      quality design and environmental
                                                      sustainability.




                                                                                                               34
                                                      Desborough Central PREFERRED POLICY
                                                      DIRECTION 15: As detailed in the previous
                                                      submissions to the Council, the alternative
                                                      option at Desborough Central site would
                                                      have provided the following open space:
                                                      New Town Park (9 hectares) 5 ha of
                                                      strategic landscaping; Amenity greenspace
                                                      throughout the development; Play facilities
                                                      within the development; Allotments; Adult
                                                      and Junior football pitches; Linear Park on
                                                      the southern bank of the River Ise; A
                                                      financial contribution to the Grange leisure
                                                      centre; Provision of a site to facilitate the
                                                      relocation of the Desborough Indoor Bowls
                                                      club Persimmon Homes notes the additional
                                                      contributions sought since the publication of
                                                                                                         This Policy has been written taking into
                                                      the Preferred Options Paper which include:
         Persimmon                                                                                       consideration the preferred policy direction.
                                                      Contributions to the provision of facilities for
268419   Homes       paragraph   9.7.6   No opinion                                                      The open space requirements are directly
                                                      young people (e.g. BMX track and one half
         Midlands                                                                                        related to the expected growth associated
                                                      pipe). Contributions to improve the quality of
                                                                                                         with that site.
                                                      existing parks, gardens and open spaces
                                                      which will serve the development.
                                                      Contributions to the refurbishment of
                                                      buildings, pitches and other associated
                                                      infrastructure at Desborough Town Football
                                                      Club. Contributions to the existing outdoor
                                                      bowls green at Dunkirk Ave Recreation
                                                      Ground to improve the facility. Persimmon
                                                      Homes is willing to consider these additional
                                                      contributions. However, before doing so it
                                                      will require full justification from the Council
                                                      for the contributions it is seeking to ensure
                                                      that the need for the contributions arises as
                                                      a direct result of the Desborough Central
                                                      development and in accordance with
                                                      Government guidance.




                                                                                                                                        35
                                         Whereas many of the stated objectives are
                                         generally OK there is a complete lack of
                                         detail in the document, except for the
                                         number of homes to be provided. No
                                         quantifiable objectives for such things as "net
                                         biodiversity gain", "waste reduction", "energy
                                         efficiency", "water saving", "reduced traffic
                                         congestion and Improving road safety" are
                                         given so how are the public supposed to be        Policies in the next iteration of this AAP -
                                         able to judge whether the detailed proposals,     Proposed Submission, will set local targets.
                                         when they are available, will meet these          Detailed evidence with regards to monitoring
         Mr John
254704             document   Disagree   vague objectives? A number of stated              targets will be required in order to review the
         Showers
                                         objectives are potentially contradictory and      application and determine any subsequent
                                         no guidelines are given as to how a balance       planning application as well as evidence of
                                         between them will be achieved. At this level      any proposed mitigation measures.
                                         the document does not provide sufficient
                                         detail to assess whether what will be carried
                                         out will be beneficial to the community as a
                                         whole or to assess the negative impact of
                                         some of the proposals. However I have
                                         added comments on specific areas to
                                         express my concerns about the positioning
                                         statement.




                                                                                                                          36
                                                  The statements made here are laudable but
                                                  seem to be contradicted by the actual
                                                  proposal. I refer only to the Rothwell plan in
                                                  these comments. Why is it proposed to build
                                                  on the land to the East of the B576, which
                                                  contains ridge-and furrow grassland, old         Sites have been assessed in the
                                                  hedges and mature trees, whilst the area         Sustainability Appraisal and chosen to limit
                                                  between Rothwell and the A6 has been             the loss of open space and biodiversity
                                                  reduced since the previous scheme, even          whilst delivering essential housing. The next
                                                  though this contains low grade arable land?      iteration of the AAP - Proposed Submission
         Mr John                                  This will lead to a net reduction in             will propose mitigation measures to limit the
254704             paragraph   6.5.4   Disagree
         Showers                                  biodiversity. What constraints will be put on    impact of the proposal on the Rothwell
                                                  the developers to protect the existing           Gullet and local wildlife. Detailed proposals
                                                  hedgerows and trees? Replacing an old tree       will be assessed at planning application
                                                  with a sapling will reduce biodiversity, not     stage to ensure that land take is limited, as
                                                  improve it. What mitigation is proposed for      are any negative impacts from the
                                                  the impact of developing up to the line of       development.
                                                  Rothwell Gullet Nature Reserve and the old
                                                  gullet running to Shotwell Mill Lane? This
                                                  development will inevitably lead to greater
                                                  environmental and wildlife damage from
                                                  cats, dogs and litter dumping.




                                                                                                                                 37
                                                  I agree that these issues are the correct
                                                  ones to raise but fail to see how the
                                                  proposals will deal with them. Again, lack of
                                                  quantifiable objectives, guidelines for
                                                  balancing contradictory objectives and no
                                                  detail in the proposals make it impossible to
                                                  judge whether or not the plans will in fact
                                                  deal with these issues effectively. For          Policies in the next iteration of the AAP will
                                                  example: "Retaining and building on the          guide development and limit any negative
                                                  identity of the towns" - in the previous         impacts. It is not intended that development
                                                  consultation steps a member of the KBC           will 'fill' the area as outlined in the Position
                                                  stated that "building in the North Rothwell      Statement with development. Land adjacent
                                                  extension would be kept behind the ridge         to the Rothwell Gullet has been outlined in
                                                  line". This was part of the argument that        order for a buffer of planting, screening and
                                                  there would not be a decrease in the             open space to form part of the development
                                                  separate identities of Rothwell and              in order to protect the Gullet.
                                                  Desborough and that the Ise Valley would
         Mr John                       Strongly   retain an open countryside atmosphere. The       A new junction off the A6 will be required to
254704             paragraph   6.4.1
         Showers                       disagree   proposal clearly shows the development           serve the proposed extension, especially for
                                                  extending well over the ridge line as far        large vehicles and lorries. A Public Realm
                                                  down as Rothwell Gullet. “Achieving a net        Strategy for Rothwell is intended to improve
                                                  biodiversity again" - how??? You are             the public realm, reduce the amount of on-
                                                  planning to develop an area of ridge-and         street car parking in the town, prevent traffic
                                                  furrow grassland with old hedges and trees       'bottle-necks' and aid the free-flow of traffic
                                                  whilst reducing the amount of arable land        through the town centre. The AAP will also
                                                  being used between the A6 and Rothwell.          help to achieve the modal shift as outlined in
                                                  "Reducing traffic congestion and improving       policy 13 of the CSS through improving
                                                  road safety" - how?? 700 houses in Rothwell      connectivity via walking and cycling as well
                                                  will increase traffic towards Kettering on the   as improving public transport.
                                                  B576 unless serious measures are taken to
                                                  dissuade road users. Although a link from
                                                  the B576 to the A6 is proposed this will not
                                                  stop the traffic going East onto the A14
                                                  unless other measures are put in place to
                                                  enforce its use. The existing radar speed
                                                  warnings on the Desborough and Kettering




                                                                                                                                   38
Roads are not effective - at least 60% of
vehicles ignore them and no enforcement
seems to take place. Heavy goods vehicles
still use this route to get between the A14
and North Desborough, despite the
restriction signs.




                                              39
                                                  The objectives are fine but again the
                                                  proposal does not provide detail of how they
                                                  will be assessed and success measured. Nor
                                                  does the proposal provide sufficient
                                                  information so that the public can assess
                                                  what the impact might be. For example:
                                                  "Controlling flood risk...." - in the late 1970s
                                                  water run-off from Montsaye School playing
                                                  fields caused flooding to the then A6 and to
                                                  some people's houses at the corner of
                                                                                                     A Flood Risk Assessment would be required
                                                  Nunnery Avenue. Even today after heavy
         Mr John                                                                                     at planning application stage outlining flood
254704             paragraph   6.5.6   Disagree   rainfall the B576 can be covered with flowing
         Showers                                                                                     risk as well as any proposed mitigation
                                                  water and the gardens have standing water
                                                                                                     measures.
                                                  in them. When this area is developed, the
                                                  potential for rapid run-off will be increased -
                                                  what proposals are there to increase drain
                                                  capacity between North Rothwell and the
                                                  Slade? If water is diverted to the Ise (and
                                                  some must be as you are proposing
                                                  development over the ridge line) then what
                                                  mitigation will be provided to protect
                                                  Geddington, for example, from the increased
                                                  flow?




                                                                                                                                   40
                                                                                                 A new purpose built access directly onto the
                                                                                                 A6 is proposed to serve the development at
                                                                                                 Rothwell. Policy direction 24 is aimed at
                                                                                                 improving the public realm in both towns
                                                                                                 and the Local Planning Authority is
                                                                                                 developing a Public Realm Strategy to
                                                                                                 improve the street scene within Rothwell
                                                  The objectives lack details of how their       and create gateways which link the urban
                                                  success will be measured or achieved so are    extension to the town centre. In improving
                                                  effectively meaningless. What specific         the public realm some highway
                                                  proposals are there to reduce the impact of    improvements within Rothwell town centre
         Mr John                                  traffic in town centres? What is the current   will be required including the removal of
254704             paragraph   6.5.7   Disagree
         Showers                                  volume? What is the proposed volume after      some of the on-street car parking. This will
                                                  the 1400 houses and commercial                 aid the free flow of traffic and prevent traffic
                                                  developments have been built? If traffic       'bottle-necks' within the town centre, which
                                                  volumes are to be reduced or their increase    then impact the surrounding highway
                                                  contained how will this be achieved?           network. The access for the current 'Grange'
                                                                                                 development in Desborough has been
                                                                                                 constructed to accommodate the growth
                                                                                                 proposed in this application. Weight
                                                                                                 restrictions would need to be applied to
                                                                                                 roads to prevent large vehicles and lorries,
                                                                                                 advice on this would be taken from the
                                                                                                 highways authority.




                                                                                                                                 41
                                                                                                    Open space provision will be in accordance
                                                                                                    with the requirements outlined in the
                                                  You state quantifiable objectives for
                                                                                                    adopted Kettering Open Space SPD and
                                                  dwellings and employment land but none for
                                                                                                    policy 13 of the CSS. With regards to
                                                  number of shops and community facilities,
                                                                                                    community infrastructure provision and
                                                  open space and green infrastructure or
                                                                                                    shops this will be based on the identified
                                                  associated roads and other infrastructure.
                                                                                                    need at the time of receipt of the planning
                                                  How can we judge the impact of this?
         Mr John                       Strongly                                                     application. Examples of expected
254704             paragraph   8.0.4              Throughout this document there is a
         Showers                       disagree                                                     contributions are outlined in the Position
                                                  complete lack of detail on any mitigating
                                                                                                    Statement and will be updated accordingly
                                                  actions or even quantified objectives that will
                                                                                                    in the next iteration of this AAP - Proposed
                                                  be set to balance the impact of the
                                                                                                    Submission. The development of shops will
                                                  development. I want to see these items
                                                                                                    be market lead but limited to serve the day
                                                  quantified as well as the number of houses
                                                                                                    to day needs of the community so as not to
                                                  etc...
                                                                                                    compete with the vitality and viability of the
                                                                                                    town centres.




                                                                                                                                   42
                                                  Why has the area to the East of the B576
                                                                                                   The employment land allocation has been
                                                  been retained but the area between the A6
                                                                                                   reduced in accordance with the adopted
                                                  and Rothwell reduced since the last plan?
                                                                                                   CSS. Therefore, the site allocation has also
                                                  This seems to contradict the objectives of:
                                                                                                   been reduced. The land closest to the A14
                                                  Increased biodiversity - you are retaining low
                                                                                                   is less suitable for residential use due to the
                                                  biodiversity arable land but developing richer
                                                                                                   potential amenity and noise impacts.
                                                  ridge and furrow land Retention of the
                                                                                                   Therefore, this land has been removed from
                                                  separate identity of the two towns - by
                                                                                                   the allocation with land close to the
         Mr John                       Strongly   developing over the ridge line at North
254704             paragraph   8.0.5                                                               proposed junction with the A6 remaining for
         Showers                       disagree   Rothwell rather than in the space between
                                                                                                   employment land purposes. Community
                                                  the A6 and Rothwell. Reducing traffic
                                                                                                   infrastructure provision will be based on the
                                                  volumes in town in Rothwell by making the
                                                                                                   identified need at the time of receipt of a
                                                  development to A14 access easier on the
                                                                                                   planning application. Examples of expected
                                                  existing B576 than via the A6. Reducing
                                                                                                   contributions to leisure facilities are outlined
                                                  leisure opportunities for Rothwell people by
                                                                                                   in the Position Statement and will be
                                                  building on land that is widely used by local
                                                                                                   updated accordingly in the next iteration of
                                                  people whilst retaining land to which they do
                                                                                                   this AAP - Proposed Submission.
                                                  not have access.




                                                                                                                                   43
                                                  Referring to Rothwell north. The policy is too
                                                  vague although its general sentiments are
                                                  OK. Just adding a link between the B576
                                                  and the A6 will not help with the traffic
                                                  problems on the Rothwell Desborough and
                                                  Kettering Roads unless other measures are
                                                  put in place to discourage their use as a
                                                                                                    Noted, the required junction off the A6 will
                                                  short cut to the East-bound A14. The
         Mr John                                                                                    be designed in accordance with adopted
254704             paragraph   9.1.4   Disagree   junction between Kettering Road Rothwell
         Showers                                                                                    highways standards as outlined by the
                                                  and the A14 is already dangerous and these
                                                                                                    Highways Authority and Agency.
                                                  proposals, as they stand, will not improve it
                                                  and will probably make it worse. There have
                                                  to be additional, enforced, traffic calming or
                                                  re-routing proposals in the scheme. Also,
                                                  heavy goods vehicles will still use this route,
                                                  as they do now, unless specific actions are
                                                  taken to prevent this.




                                                                                                                                   44
                                                  The proposal makes some aspirational
                                                  statements about provision of retail outlets
                                                  but no objectives are set. If 700 dwellings
                                                  are to be built in Rothwell north, how many
                                                  shops should be provided to service their
                                                  needs? What constraints on the nature of the    The development of shops will be market
                                                  retail businesses will be applied? General      lead but limited to serve the day to day
                                                  stores may be welcome, book-keepers would       needs of the community so as not to
         Mr John                                  not be. Given the current rate of closure of    compete with the vitality and viability of the
254704             paragraph   9.3.1   Disagree
         Showers                                  public houses what incentives would be put      town centres. Further clarity to the number,
                                                  in place for a new one to be built? If take-    range and size of units will be given in the
                                                  aways are to be permitted what mitigation for   next iteration of this AAP - Proposed
                                                  litter will be provided? The                    Submission.
                                                  Kettering/Desborough Road already suffers
                                                  from large amounts of litter from these
                                                  outlets, especially on Saturday night /
                                                  Sunday morning but no apparent attempt to
                                                  control or clear it currently exists.




                                                                                                                                 45
                                                  9.6.3 "Improvements to the Rothwell
                                                  systems may also be required” I am
                                                  concerned about the vagueness of this
                                                  statement. Surely if a proper impact
                                                  assessment has be made you should know
                                                  whether or not they will be required. In the
                                                  1970s run-off from the Montsaye School
                                                                                                   Noted, further clarity will be given to the
                                                  playing fields caused flooding down
         Mr John                                                                                   requirement for waste, water and sewerage
254704             paragraph   9.6.3   Disagree   Desborough Road, including some houses.
         Showers                                                                                   systems in the next iteration of the AAP -
                                                  When this area and the area to the East of
                                                                                                   Proposed Submission.
                                                  the B576 are developed this will increase the
                                                  risk of a recurrence. Furthermore as the
                                                  development area extends over the ridge-
                                                  line there will be run-off towards the Ise
                                                  Valley, increasing the risk of flooding there.
                                                  What are the proposals for protection of
                                                  Rothwell north and the Ise Valley?




                                                                                                                                46
                                                  No mention is made of parking facilities to
                                                  support the additional or existing playing
                                                  fields in Rothwell north. Already the Rothwell
                                                  Corinthians football ground causes problems
                                                                                                    The AAP will help to achieve the modal shift
                                                  with traffic; destruction of the road verge and
         Mr John                                                                                    as outlined in policy 13 of the CSS through
254704             paragraph   9.7.5   Disagree   inconvenience to local people because of the
         Showers                                                                                    improving connectivity via walking and
                                                  lack of proper parking places. This
                                                                                                    cycling as well as improving public transport.
                                                  development should make adequate
                                                  provision for parking for the existing football
                                                  ground as well as any proposed new playing
                                                  fields.




                                                                                                                                  47
                                                  There is muddled thinking in the objectives
                                                  here. Improved access and improved
                                                  biodiversity can be incompatible unless a
                                                  great deal of care is taken in protecting
                                                  fragile biotopes. In particular Rothwell Gullet
                                                                                                    Through the identification and protection of
                                                  meadow is very small and increased foot
                                                                                                    green infrastructure corridors, provision can
                                                  traffic would damage the flora, for which the
         Mr John                                                                                    be made for improved access as well as
254704             paragraph   9.8.5   Disagree   reserve was acquired, through trampling and
         Showers                                                                                    protection of species. This delicate balance
                                                  ground compaction. In the Ise Valley there is
                                                                                                    will form part of the justification for planning
                                                  the risk that increased disturbance by people
                                                                                                    permission to be granted.
                                                  and loose dogs could affect the snipe that
                                                  use the meadows. The problem is that the
                                                  proposals are vague and do not show how
                                                  these objectives can be achieved or how
                                                  conflicts of interest would be resolved.




                                                                                                                                    48
                                          ROTHWELL JUNIOR SCHOOL PLAYING
                                          FIELD An area of land which was designated
                                          as a car park on the Junior school playing
                                          fields to the rear of properties on
                                          Desborough Road Rothwell, has not been
                                          mentioned in the latest plan. That plot
                                          however is still shaded as being an area to
                                          be developed. I object to a change of use for
                                          that land on the following grounds. 1. To
                                          reduce the size of the play area when at the
                                                                                           This has been proposed as part of the
                                          same time increasing the number of pupils
                                                                                           Rothwell North planning application and
                                          seems ludicrous. 2. A car park in an isolated
                                                                                           does not form part of the Position
                                          area will be ideal for drug dealing and burnt
                                                                                           Statement. The AAP will not designate land
         Mr Peter              Strongly   out stolen cars and other anti-social
266655              document                                                               within the illustrated preferred direction of
         Brown                 disagree   behaviour. 3. The security of properties
                                                                                           growth but guide development to make
                                          adjacent to the school field has always been
                                                                                           provision for the necessary land uses.
                                          a problem. Most of the homes and out
                                                                                           However, further land may be required to
                                          buildings have been broken into, with the
                                                                                           'future-proof' schools in this location.
                                          culprits using the playing fields to escape.
                                          Putting a car park there would make it very
                                          much easier as they would not have to carry
                                          their haul but just take it away in a van! 4 A
                                          car park with access to the town Football
                                          club would result in noise and disturbance at
                                          evenings and weekends all year round. 5.
                                          Coaches parking at the end of our garden,
                                          whether for the school or Football club would
                                          destroy our privacy




                                                                                                                         49
                                                     This representation refers to Desborough
                                                     Central PREFERRED POLICY DIRECTION
                                                     16 The Desborough Central submission to
                                                     the Council in December 2007 made
                                                     provision for the following developer
                                                     obligations: A two hectare site for a new
                                                     primary school Creating and supporting safe
                                                     routes to schools Public transport
                                                     improvements to serve the development
                                                     Biodiversity improvements A financial
                                                     contribution to the Grange Leisure Centre
                                                     Preferred Policy Direction 16 also seeks to
                                                     secure developer obligations towards
                                                     improvements to the townscape, town
                                                     environment and security, heritage funding,
                                                     public art, furniture and signs. Chapter 3 of
                                                     the December 2007 submission detailed the
         Persimmon
                                                     means by which the development at
268419   Homes       paragraph   9.7.14   Disagree                                                    Noted
                                                     Desborough Central would be able to make
         Midlands
                                                     a positive contribution to the physical and
                                                     economic regeneration of the town centre.
                                                     The more recent, December 2008,
                                                     submission to the Council included a letter
                                                     from Richard Palmi, the General Manager,
                                                     Property Services, of the Midlands Co-op, in
                                                     which he confirmed the company’s
                                                     commitment to bring forward an agreed
                                                     mixed retail based regeneration scheme at
                                                     Key Site 1. Persimmon Homes notes the
                                                     additional developer obligations being
                                                     sought since the publication of the Preferred
                                                     Options paper which include: Contributions
                                                     for the renovation of the Desborough Chapel
                                                     Contributions towards a permanent heritage
                                                     centre for the town Contributions to a central
                                                     community centre for the town Contributions




                                                                                                              50
to a social development worker
Contributions to a Community Fund
Contributions to Borough Wide facilities e.g.
Museum and Gallery Provision for a district
base for the Safer Communities Team
Contribution to Community Safety e.g. CCTV
Contributions to the renovation of the
Desborough Chapel and cemetery grounds
as a public open space. Persimmon Homes
would be willing to consider making
contributions to the additional obligations
being sought by the Council. However, it will
not contribute to anything which is not
directly related to the proposed development
at Desborough Central. As for Preferred
Policy Direction 15, Persimmon Homes
requires full justification from the Council for
the contributions being sought in order to
determine whether the need for the services
and facilities sought directly arises from the
development. It must also be recognised that
with falling land values it may not be possible
to finance the Councils aspirations and an
element of affordable housing from the
development; as a consequence of which it
may be necessary for the Council to prioritise
these contributions.




                                                   51
                                                    This representation relates to Desborough
                                                    Central PREFERRED POLICY DIRECTION
                                                    17 The alternative proposal at Desborough
                                                    Central would have provided a Town Park.
                                                    This would have been formed by extending
                                                    and improving the existing Pocket Park to
                                                    provide 9 hectares of informal open space.
                                                    The park would have provided a varied and
                                                    rich environment with informal paths winding
                                                                                                     The Council agree that the Pocket Park
                                                    through new and existing vegetation,
                                                                                                     would benefit from general enhancements.
                                                    providing new routes and following existing
                                                                                                     However, the surrounding of the pocket park
                                                    desire lines. The layout of the park would
                                                                                                     with development would actually serve to
                                                    have been sensitively designed to avoid
         Persimmon                                                                                   block green infrastructure corridors and
                                                    disturbance to the badgers and other
268419   Homes       paragraph   9.8.5   Disagree                                                    wildlife movement patterns. Also, routes
                                                    protected wildlife which forms an important
         Midlands                                                                                    through the pocket park are unlikely to be
                                                    part of the areas biodiversity. Persimmon
                                                                                                     easily accessible to all including those with
                                                    Homes recognises the value of the Ise
                                                                                                     mobility issues and cyclist due to the
                                                    Valley for the residents of Desborough, not
                                                                                                     unsuitable terrain, uneven surface and
                                                    just as an amenity in itself but through the
                                                                                                     differences in ground levels.
                                                    leisure and recreational opportunities that
                                                    greater access to the riverside could bring to
                                                    the town. The proposals for the alternative
                                                    option at Desborough Central therefore
                                                    included provision for a linear park on the
                                                    southern bank of the River Ise. It was
                                                    considered that the linear park would not
                                                    only enhance the Ise Valley but also improve
                                                    public access to it.




                                                                                                                                   52
                                                  This representation relates to Desborough
                                                  Central PREFERRED POLICY DIRECTION
                                                  18 Persimmon Homes will protect and
                                                  enhance existing feature of biodiversity
                                                  importance through improved management
                                                  regimes and new habitat creation as set out
                                                  in Preferred Policy Direction 18. More
                                                  specifically the Desborough Central
                                                  development would have facilitated
                                                  biodiversity gain by means of: reinstating
                                                  quality ponds, especially those known to
                                                  have Great Crested Newts improving other
         Persimmon
                                                  ponds on the site retaining hedgerows
268419   Homes       paragraph   9.8.10   Agree                                                    Noted
                                                  surrounding the quality ponds to provide
         Midlands
                                                  ˜wildlife corridors, a vital component of the
                                                  habitat for newts retaining existing
                                                  hedgerows particularly those in the northern
                                                  part of the site (where they are already
                                                  diverse and tall/thick) improving poor quality
                                                  hedgerows through better management and
                                                  some further planting, especially of native
                                                  trees careful retention of badger setts within
                                                  the existing Pocket Park provision of grassy
                                                  footpaths from the Pocket Park to the
                                                  southwest, west and north of the site to
                                                  provide corridors for the badgers.




                                                                                                           53
                                                 This representation relates to Desborough
                                                 Central PREFERRED POLICY DIRECTION
                                                 20 Persimmon Homes is willing and able to
                                                 make a site of 2 hectares available for use
         Persimmon
                                                 for a primary school. The master plan
268419   Homes       paragraph   9.9.3   Agree                                                    Noted
                                                 submitted with the December 2007
         Midlands
                                                 submission illustrates the school in a central
                                                 location within the Desborough Central site,
                                                 easily accessible to both new and existing
                                                 residents.




                                                                                                          54
                                                     This representation relates to Desborough
                                                     Central PREFERRED POLICY DIRECTION
                                                     21 Preferred Policy Direction 21 reflects
                                                     Preferred Option (PO20) of the Rothwell and
                                                     Desborough Urban Extensions Area Action
                                                     Plan Preferred Options Paper, September
                                                     2006. At the time of the Preferred Options      The Northamptonshire Waste Local Plan
                                                     Paper this policy was already out of date as    and the SPD on Development and
                                                     the Council had introduced a comprehensive      Implementation Principles give guidance
         Persimmon                                   kerb-side collection service throughout the     with regards to the requirements for waste
268419   Homes       paragraph   9.10.1   Disagree   Borough. It is understood that this service     facilities. The emerging Minerals and Waste
         Midlands                                    results in three separate containers for        Core Strategy may contain further guidance
                                                     different types of waste to be recycled which   with regards to this and if adopted will inform
                                                     can be summarised as paper; glass, tins and     the next iteration of this AAP - Proposed
                                                     plastic; garden waste and other compostable     Submission.
                                                     materials. In the circumstances it is unclear
                                                     exactly what facilities for the separation,
                                                     storage and collection of waste the Council
                                                     will require as part of the development, if
                                                     indeed onsite waste management facilities
                                                     are required at all.




                                                                                                                                    55
                                                       This representation relates to Desborough
                                                       Central PREFERRED POLICY DIRECTION
                                                       22 The master plan submitted with the
                                                       December 2007 Desborough Central
         Persimmon                                     submission sought to address the design
268419   Homes       paragraph   9.12.1   No opinion   headings listed in Preferred Option (PO23)       Noted
         Midlands                                      and reflected in Preferred Policy Direction
                                                       22. Persimmon Homes and its team of
                                                       consultants would welcome the opportunity
                                                       of working with the Council to further develop
                                                       the master plan for Desborough Central.




                                                                                                                56
                                                  This representation relates to Desborough
                                                  Central PREFERRED POLICY DIRECTION
                                                  23 Improved access and connectivity into the
         Persimmon                                town centre would be achieved by the
268419   Homes       paragraph   9.13.2   Agree   provision of the A6 link road through the         Noted
         Midlands                                 Desborough Central site. New and enhanced
                                                  pedestrian/cycle routes would be provided
                                                  which will connect with the existing facilities
                                                  in the town.




                                                                                                            57
                                                       This representation relates to Desborough
                                                       Central PREFERRED POLICY DIRECTION
                                                       24 The Desborough Central development
                                                       would have provided a high quality public
                                                       realm throughout the development, in
                                                       particular at the main entrance to the
         Persimmon                                     development site off the A6 where a gateway
268419   Homes       paragraph   9.14.4   No opinion   entrance to the town will be created. As        Noted
         Midlands                                      stated in the response to Preferred Policy
                                                       Direction 16 and Preferred Policy Direction
                                                       23 the Desborough Central proposal would
                                                       have sought to improve areas within the
                                                       town centre making a positive contribution to
                                                       the physical and economic regeneration of
                                                       the town centre.




                                                                                                               58
                                                  This representation relates to Desborough
                                                  Central PREFERRED POLICY DIRECTION
                                                  25 Persimmon Homes would be willing, in
         Persimmon                                principle, to enter into a planning obligation
268419   Homes       paragraph   10.1.2   Agree   with the Borough Council and others, as          Noted
         Midlands                                 required, to secure the infrastructure and
                                                  other facilities, the need for which arises
                                                  from the development, and would negotiate
                                                  accordingly.




                                                                                                           59
                                                  Before any new development is approved it
                                                  would seem prudent to wait until current
                                                  developments are completed to identify
                                                                                                  Noted. The creation of open space is for
                                                  whether there is any demand for the
                                                                                                  formal and informal open space and
                                                  housing, particularly in the current economic
                                                                                                  contributions will be required for expanding,
         Mrs                           Strongly   climate, and whether the towns can cope
273646             paragraph   3.1.2                                                              improving and management of the Country
         Pateman                       disagree   with the current development particularly the
                                                                                                  Park at Desborough. Policies within the next
                                                  schools and roads. Additionally it is planned
                                                                                                  iteration of this AAP - Proposed Submission
                                                  to create open space as part of the
                                                                                                  will protect and enhance existing footpaths.
                                                  development. As both towns are surrounded
                                                  by open fields with many public footpaths it
                                                  seems illogical to have to create open space.




                                                                                                                                60
                                                      This representation relates to Rothwell North     Policy 1 of the Core Spatial Strategy states
                                                      PREFERRED POLICY DIRECTION 6 The                  that all future development is to be
                                                      suitability of the land north of Rothwell as a    principally directed towards the urban core
                                                      mixed use urban extension has been                with a focus on Kettering. The Kettering
                                                      promoted since 2001 when Kettering                Borough Employment Land Breakdown
                                                      Borough Council decided that the Strategic        Report of 16th September details the Local
                                                      Development Area (SDA) proposals for              Planning Authority’s strategy to achieve a
                                                      Desborough and Rothwell should be taken           job allocation of 2 jobs to every one person
                                                      forward through a process comprising firstly      of working age living in Rothwell by 2021.
                                                      of Issues Papers, followed by Locational          Taking into account the planned housing
                                                      Options and Development Concepts (which           growth, as outlined in the CSS, this would
                                                      would be prepared by developers). The             create the requirement for a further 1652
                                                      Council subsequently produced ˜Guidance           jobs across all employment sectors. Policy
                                                      for the Submission of Development Options         11 of the Core Spatial Strategy outlines that
                                                      in March 2004 inviting landowners and             quantity and quality of existing employment
                                                      developers to provide further technical           sites and allocations will be reviewed
         Persimmon
                                                      information together, with concept schemes,       against the job creation targets set out in
         Homes
                                                      in respect of their individual sites. At this     Table 6. Therefore, the overall job allocation
276721   Midlands -   paragraph   9.2.13   Disagree
                                                      stage the employment land requirement on          figure has been further broken down to
         Rothwell
                                                      site was minimal. However to secure the           reflect the job number split as outlined in
         North
                                                      provision of a mixed use, sustainable urban       Table 6. This gives a figure of 636 jobs out
                                                      extension, Persimmon Homes proposed a             of the overall total if we assume 2:1 jobs in
                                                      total of 6.5 ha of employment land. This was      Rothwell. A Strategy which was agreed my
                                                      included in the proposals for Rothwell North,     members at Planning Policy Committee on
                                                      submitted to the Borough Council in June          16th September 2008. Further works with
                                                      2004. This and other submissions enabled          regard to growth in Rothwell and outside of
                                                      the Borough Council to undertake a                the Urban Extension Area Action Plan will
                                                      sustainability assessment of the alternative      be reviewed within the Site Specific
                                                      proposals against the objectives identified for   Proposals Development Plan Document and
                                                      the SDA. As a result of the introduction of       growth in this area will result in an increase
                                                      the Planning and Compulsory Purchase Act          in jobs across all areas including the service
                                                      2004, it was decided that although the Local      sector. With regard to phasing the
                                                      Plan Review should be put on hold, work           development and incorporating a further 7ha
                                                      should proceed on planning the SDA, which         of employment land, to plan for greater than
                                                      resulted in the publication of the Rothwell       4ha of employment land would mean rolling
                                                      and Desborough Urban Extension Area               the AAP forward and to outside of the plan




                                                                                                                                      61
Action Plan Preferred Options Paper.             period, which is not possible. The AAP must
Rothwell North was identified as the Councils    be in accordance with the CSS and as
Preferred Option in PO3 in respect of which      previously stated the AAP states that the
it was stated that: The site totalling 51        principal focus for development must be on
hectares will accommodate an urban               Kettering and there is no justification in the
extension of: 700 dwellings 11 hectares of       CSS or the Councils Strategy to plan for
employment land Shops and community              further B class development outside of
facilities Open space and green                  Kettering. The CSS is clear that generating
infrastructure (including a minimum of 6         new and better jobs will be the provision of
hectares of structural landscape                 the right kind of land in the right place in the
concentrated along the northern and              right amounts. The over-allocation of
southern boundaries) Associated roads and        employment land at Rothwell would either
other infrastructure; Having been identified     result in a large area of employment land
as the Preferred Option at Rothwell, a           standing empty at Rothwell, a relocation of
significant amount of technical work was         employment uses from other areas within
undertaken to enable the submission of an        the Borough to Rothwell leaving sites empty
application for outline planning permission,     in other locations or of particular concern
accompanied by an Environmental                  employment allocations locating in Rothwell
Statement, in May 2007. Persimmon Homes          over Kettering leaving a low demand for or
planning application for Rothwell North          empty employment sites in Kettering.
provided an employment land allocation of        Subsequent reviews of the CSS or AAP
11 hectares (4 ha B1, 7ha B2) which was in       could result in the requirement for further
conformity with the Rothwell and                 employment land allocation in Rothwell or
Desborough Urban Extensions AAP                  indeed Desborough. However, at this time
Preferred Options Paper, (September 2006).       the contents of the Committee Reports titled
The 11 ha of employment land represented a       Kettering Borough Employment Land
floor space of approximately 35,000 m2           Requirements Update July 2008, 30th July
equally divided between B1 and B2 uses and       2008, the Kettering Borough Employment
in addition service uses of 0.5 ha (1,350 m2).   Land Breakdown and the Kettering Borough
The application, ensured that a range of B       Employment Land Requirements Quantity
units was included to attract a variety of       Update July 2008 employment paper remain
employers and users to provide a wide            the Councils Strategy for employment land
variety of jobs to encourage local               allocation.
opportunities for improving skills levels,
enterprise and innovation. Since the
submission of the planning application, the




                                                                                 62
NNCSS (Policy 11) sets out the net job
growth in all sectors up to 2021 which is
significantly lower than previously proposed.
It is acknowledged that it is in response to
the job numbers set out in the NNCSS that
the Borough Council produced the various
background papers and reports which
provide the context for the revised
employment land allocations currently being
proposed by the Council. Work has however
now commenced on the review of the
NNCSS and a call for sites has been
undertaken as part of the initial stages of the
North Northamptonshire Strategic
Employment Land Assessment. Persimmon
Homes is to amend its current application
proposals in accordance with the Councils
revised employment land requirement of 4
hectares. However, having analysed the
various employment land studies it has been
concluded that there will be an ongoing
requirement at Rothwell for more
employment land than the Council is
currently proposing and as a consequence
objections are made to the proposed loss of
7 hectares of employment land at Rothwell.
Justification for this is set out in the
statement below (submitted to Kettering
Borough Council in November 2008 as part
of the Rothwell North Further Submission).
ROTHWELL NORTH - AN ANALYSIS OF
THE REVISED EMPLOYMENT LAND
REQUIREMENT 1. In view of the long
standing policy requirement to encourage
new employment provision at the smaller
market towns, including Rothwell (which is




                                                  63
reiterated in paragraph 3.91 of the NNCSS)
it is necessary to firstly consider the
background to employment land provision at
Rothwell. 2. This is outlined in the Borough
Councils paper entitled Pre Commencement
Work and Consultation Rothwell and
Desborough Area Action Plan. This
document identifies the regeneration context
for growth at Rothwell and Desborough and
the progression towards sustainable
communities. 3. Policy within the Core
Strategy clearly directs growth to secure
sustainable development and balanced
communities. In particular, employment
growth at Rothwell is encouraged in
paragraph 3.91. Figure 14 indicates that the
policy direction in the Core Strategy does not
seek to identify major service expansion in
Rothwell and Desborough but to maintain a
pleasant town centre environment at
Rothwell. 4. Employment provision set out in
the Rothwell and Desborough Urban
Extensions AAP Preferred Options is based
upon the context set out above and in
accordance with employment land
requirements at that time. (LDF Background
Papers Borough Employment Land
Requirements, Kettering Urban Extensions
Employment and Retail Needs and
Desborough / Rothwell SDA Employment
Land Needs and Availability, June 2006.) 5.
The key change since the adoption of the
NNCSS relates to an overall reduction in the
amount of employment growth in Kettering
Borough following: additional jobs being
allocated to East Northamptonshire




                                                 64
redefinition of Standard Industrial
Classification (SIC) codes and subsequent
translation to its use classes publication of
the Strategic Distribution Study the
publication of the Commercial Property and
Employment Land Availability report
(CoPELA) 2006. 6. The issue at present is
the most sustainable approach to the
redistribution of employment land throughout
Kettering Borough. The Borough Council has
addressed this in the following background
papers and reports; • Kettering Borough
Employment Land Requirements Quantity
Update July 2008, • Rothwell and
Desborough Urban Area Extension Plan
Committee Report September 2008, and •
Kettering Borough Employment Land
Breakdown September 2008. These papers
provide the context for a revised allocation of
4 ha of employment land at Rothwell,
including landscaping and associated
infrastructure (the 11 ha previously referred
to excluded landscaping) and no provision at
Desborough, except at unspecified town
centre locations and existing allocations.
Employment Land allocations elsewhere in
the Borough include 14.1 ha at Kettering
East and 3.8 ha at the Station Quarter of
Kettering Town Centre. 7. Persimmon
Homes has very serious concerns about the
methodology used by Kettering Borough
Council to determine employment land
breakdown within the Borough based upon
the Borough requirement for 6,200 new B
Class jobs and 10,000 other service base
jobs. Persimmon Homes particularly




                                                  65
considers that the assumptions and
conclusions made by the Borough Council
are not sound as they do not demonstrate:
justification in the form of the evidence base
used to explain the decision; any clear
conformity to national and regional guidance;
a clear context of options appraisal required
to ensure the most sustainable approach to
employment land distribution and
subsequent evaluation to ensure the most
appropriate strategy. 8. It is considered that
the background paper entitled Kettering
Borough Employment Land Requirements
(July 2008) is flawed since it contains only
an assumption of employment land losses
based upon potential losses. The
employment land requirements do not
therefore have a sound basis as they are not
consistent with the ODPM Guidance Note on
Employment Land Reviews. The Kettering
Employment Land Study should provide a
district wide appraisal of local demand and
potential sites. However, existing
employment sites were not systematically
appraised and the document does not
provide a policy context within which to
protect existing employment sites or allow for
reallocation. This is particularly important in
an area which is restructuring from a
manufacturing base to a service base. In
addition, the extent of stakeholder
involvement in the Employment Land Study
is unclear and appears to have been of an
informal, as opposed to structured, nature.
The Employment Futures Report was
informed by trend analysis not site analysis




                                                  66
and it is notable that this report post dates
the Kettering Employment Study. The
CoPELA report contains data on the
deliverability of existing allocations only. The
B8 issue has not been analysed in detail
containing a general statement relating to
delivery of significant numbers of B1 and/or
B2 jobs, but providing no policy basis,
commercial analysis nor indication on the
employment market. 9. The evidence base
relating to the Kettering Borough
Employment Land breakdown is similarly
flawed as: The rural populations need for
jobs and the rural economies need for
workers has not been taken into account.
The distribution appears to be based on the
assumed continuation of the assessment of
working age population which requires
definition/analysis in view of demographic
change and alterations to pensionable age.
The estimated population is based upon
census household size and not projected
household sizes and similarly has not been
compared with mid-year estimates and
housing completions. There is no indication
of the existing number of service jobs in
Rothwell and Desborough and no
assessment of the realism of expecting 60%
of the growth in jobs to be within the two
towns service sectors; equivalent to 1,000
new jobs. In this context, it must be
recognised that the proportion of B jobs:
Service jobs will be significantly different in
smaller market towns such as Rothwell than
they are in larger urban areas such as
Kettering. It is unclear how Desborough sites




                                                   67
referred to in the Guidance Notes are
factored into the calculations; The proximity
of employment provision at Burton Latimer,
Kettering and Kettering East has not been
considered. In this respect it is doubtful
whether the Borough Council intends to
undertake any appraisal of the implications
of this distribution of employment growth.
Indeed this is not even listed as a
requirement in the Rothwell and Desborough
Urban Extension AAP Guidance Notes.
Employment land appears to have been
distributed as part of a process outside of the
sustainability process or options appraisal,
with no appraisal relating to accessibility to
jobs, implications for social cohesion or
impact on travel patterns. Indeed, the overall
spatial planning approach of considering the
needs and problems of communities, how
they interact and then relating them to the
use and development of land has not been
considered other than on the basis of an
arbitrary ratio. No reference is provided to
draft PPS4 which requires local authorities to
maximise job opportunities to all and deliver
prosperous communities with employment
policies based upon a robust evidence base.
The Authority has no basis on which to
indicate that it has an understanding of both
existing business needs or likely changes in
the market. PPS12 does not require plans to
be based on a robust and credible evidence
base which is clearly not the case in this
instance nor has the Borough Council
indicated that it is the most appropriate
strategy against all reasonable alternatives.




                                                  68
It is unclear what level of B uses are being
permitted within the context of the Kettering
Town Centre AAP Preferred Options, nor
how much will be in service or high tech uses
and therefore separate from the calculations.
Whilst the guidance for the Rothwell and
Desborough submissions provides for
precise areas of B use classes, it is notable
that the Borough Council has not provided
any indication in the SPD for Kettering East.
The calculations do not address the issue of
reducing out commuting and there is no
analysis of the implication of the proposed
distribution in this respect but as previously
stated reference is limited to an arbitrary,
unjustified reference to a job ratio. Similarly,
it is not clear how the ratio of people to jobs
is arrived at elsewhere in Kettering or Burton
Latimer. The Borough Council has provided
no explanation of why they have instigated
this methodology instead of continuing with
the previous method used to inform the
Preferred Options paper and the subsequent
February 2007 papers i.e. based on levels of
out commuting; 10. It is considered that the
Borough Councils policy direction is not in
conformity with national and regional
guidance in its approach to the distribution of
employment land insofar as: the approach
does not consider the requirements
contained in PPS1 that sustainable
development is the core principle
underpinning planning and that considering
socio-economic needs is an essential part of
that requirement. It is clear that the paper
does not do this. In fact the figure for




                                                   69
Kettering East appears to be based on
amendments to the planning application
dated July 2008 of 14.1ha indicating a
degree of possible retrofit. There is no
analysis of the phasing policy for Kettering
East nor the deliverability of the employment
sites by 2021. The approach does not
address the deliverability of the proposed
policy option and a spatial approach to
planning as required under PPS12. It
assumes a proposed ratio, and the delivery
of service jobs outside the urban extension
whilst continuing with a policy elsewhere of
directing service jobs to Kettering. 11.
Options generation is part of the plan making
process and guidance on option generation
and appraisal is provided by PAS. The
approach of the Borough Council does not
accord with this process and the decision
making process within the evidence base
does not examine different options and their
impact. There is no evidence base or audit
trail upon which to assess or justify the
Borough Councils arbitrary approach to
employment land distribution. The process of
options generation has therefore been
severely constrained by the guidance and it
is surprising that the Environmental
Statement does not require an assessment
of the socio-economic impacts of the
proposals. It is considered that the
distribution of Employment Land within
Kettering Borough should be subject to the
Sustainability Appraisal process. 12. It is
clear that the Borough Council has not
adopted an approach to the Rothwell and




                                                70
Desborough AAP which accords with current
guidance in that it has constrained options
generation and does not ensure sustainable
development. Instead the Borough Council
has sought to secure a spatial planning
approach which takes into account the wider
influences in the economic market, access to
job opportunities and the need for
community development. It is considered
that a more balanced approach could be
achieved by compensating for the difficulty in
providing service jobs in the smaller towns
by providing greater access to B use
employment. This would give a more flexible
approach to securing plan deliverability. It is
therefore proposed that a B1 provision in the
range of 11ha of B1 and B2 use at Rothwell.
13. In conclusion, the Council has not
demonstrated, therefore, why 11 ha of
employment land at Rothwell should not
come forward as part of the urban extension
to the north of the town. As stated above,
since this representation was prepared work
has commenced on the review of the
NNCSS and a call for sites has been
undertaken as part of the initial stages of the
North Northamptonshire Strategic
Employment Land Assessment. In addition
the Secretary of State has approved the East
Midlands Regional Plan. In so doing she
considered which Structure Plan policies
needed to continue to have saved status.
Having done so, the only one being saved in
the County is Policy SDA1. This enables
provision for mixed use urban extensions, in
Desborough and Rothwell adjacent to and




                                                  71
integrated with the existing urban areas and
large enough to support a wide range of
services and facilities.




                                               72
                                                        This representation relates to Rothwell North
                                                        PREFERRED POLICY DIRECTION 8
                                                        Persimmon Homes will consider bringing
                                                                                                          Live/work units are important in providing
         Persimmon                                      forward, as part of the Rothwell North
                                                                                                          flexible living and working spaces as well as
         Homes                                          development, a number of live / work units
                                                                                                          offering a range of jobs and housing. Any
276721   Midlands -   paragraph   9.2.16   No opinion   which offer flexible living + working space for
                                                                                                          employment generated by the live/work
         Rothwell                                       small businesses if it can be shown that
                                                                                                          units would contribute to the overall service
         North                                          there is a need and demand for these units.
                                                                                                          job numbers outlined in policy 8 of the CSS.
                                                        For avoidance of doubt, the accompanying
                                                        text should stress that these units would not
                                                        count towards the employment allocation.




                                                                                                                                        73
                                                  This representation relates to Rothwell North
                                                  PREFERRED POLICY DIRECTION 1
                                                  Persimmon Homes supports the overall
                                                  approach to the provision of Urban
         Persimmon                                Extensions at Rothwell and Desborough
         Homes                                    based upon the identified role of the two
276721   Midlands -   paragraph   7.0.2   Agree   towns. The proposed development at                Noted
         Rothwell                                 Rothwell North will assist in providing greater
         North                                    self containment for the town whilst seeking
                                                  to enhance the individuality of the community
                                                  through the location, design, association and
                                                  integration of the extension with the existing
                                                  town.




                                                                                                            74
                                                  This representation relates to Rothwell North
                                                  PREFERRED POLICY DIRECTION 2
         Persimmon
                                                  Persimmon Homes supports the Councils
         Homes
                                                  vision to enhance the character and
276721   Midlands -   paragraph   7.0.4   Agree                                                     Noted
                                                  individuality of Rothwell. The direction of
         Rothwell
                                                  growth, to the north of Rothwell, will create a
         North
                                                  distinct neighbourhood which will form part of
                                                  the larger community of the town.




                                                                                                            75
                                                       This representation relates to Rothwell North
                                                       PREFERRED POLICY DIRECTION 3
                                                       Persimmon Homes Midlands supports the
                                                       identification of Rothwell North as a mixed
                                                       use urban extension. In June 2007 a
                                                       planning application was submitted for 700
                                                       dwellings, 11 hectares of employment land,
                                                       (Classes B1 and B2), a local centre (Classes
                                                       A1 A5, B1a, C3 and D1), open space and
                                                       green infrastructure, an extension to
                                                       Montsaye Community Colleges playing fields
                                                       and the reconfiguration of the Junior Schools
                                                       playing fields; all in accordance with the
                                                       Councils requirements pertaining at that
                                                                                                       A planning application has been received by
                                                       time. Detailed proposals of the vehicular
                                                                                                       the Local Planning Authority. However, this
                                                       access junctions into the site from the A6
         Persimmon                                                                                     AAP has been prepared independently of
                                                       and B576, as well as footpath and cycle
         Homes                                                                                         the planning application and in general
                                                       routes access points into the site, were also
276721   Midlands -   paragraph   8.0.4   No opinion                                                   conformity with National, Regional and Local
                                                       submitted with the planning application. The
         Rothwell                                                                                      planning policies as well as being based
                                                       planning application is currently
         North                                                                                         upon assessment and research undertaken
                                                       undetermined. Since the submission of the
                                                                                                       to formulate policies and deliver a
                                                       planning application Persimmon Homes has
                                                                                                       sustainable urban extension.
                                                       been meeting regularly with the Planning
                                                       Officers and other statutory consultees to
                                                       progress the planning application. As
                                                       documented in the AAP Position Statement,
                                                       the Borough Council, in response to the job
                                                       numbers set out in the NNCSS produced a
                                                       series of background papers and reports.
                                                       These papers provided the context for the
                                                       revised employment land allocation currently
                                                       being proposed. At Rothwell North, the
                                                       Council is proposing a reduction in
                                                       employment land allocation from 11 hectares
                                                       to 4 hectares. After full consideration,
                                                       Persimmon Homes is to amend the




                                                                                                                                    76
outstanding planning application in
accordance with the Borough Councils
requirements for a smaller employment area
of 4 hectares. However in view of the
changing economic circumstances and the
commitment of the Review of the NNCSS
which will be based on up-to-date
employment evidence, including the SELA,
Persimmon Homes is of the opinion that
there will be a requirement for further
employment land at Rothwell during the
short to medium term. As a consequence,
the residual land, currently within the
planning application site area, will continue
to be promoted for employment purposes
through the emerging AAP as set out in the
response to Preferred Policy Direction 6.




                                                77
                                                       This representation relates to Rothwell North
                                                       PREFERRED POLICY DIRECTION 5 During
                                                       the consideration of the outstanding planning
                                                       application, negotiations have been on-going
                                                       with both the Highways Agency and the
                                                       highways authority. It is understood that
                                                       neither body has any objections in principle
                                                       to the proposed development; the
                                                       outstanding issues being matters of detail or
                                                       related to the S106 agreement. Improved
                                                       connections for pedestrians and cyclists The
                                                       Rothwell North development proposal will
                                                       enable the provision of a cycle route
                                                       between Rothwell and Desborough
                                                       alongside the B576. This facility will be of
                                                       particular benefit to pupils travelling between
         Persimmon
                                                       Desborough and the Montsaye Community
         Homes
                                                       College, as well as those from the
276721   Midlands -   paragraph   9.1.4   No opinion                                                      Noted
                                                       development site. A number of public rights
         Rothwell
                                                       of way cross part of the site to the east of the
         North
                                                       B576. These are popular walking routes and
                                                       will be retained and, where appropriate,
                                                       enhanced to increase the connectivity of the
                                                       proposed development site not only into
                                                       Rothwell town centre but also to Desborough
                                                       and the surrounding countryside. B576/A6
                                                       link road The western part of the
                                                       development site requires two points of
                                                       access. These will be provided by a three
                                                       arm roundabout on the A6 bypass and a
                                                       signalled junction on the B576. These
                                                       accesses will enable the provision of a new
                                                       high quality link road between the A6 and the
                                                       B576, as required by Preferred Policy
                                                       Direction 5. Public Transport Network The
                                                       Rothwell North development site benefits




                                                                                                                  78
from the proximity of the existing B576 public
transport corridor where Services 18 and 19
combine to provide hourly services to Market
Harborough and four services per hour to
Desborough and Kettering from Monday to
Saturday. Evening services are hourly with
Sunday services every two hours. A number
of improvements to the local bus services
have been identified and a financial
contribution to support the proposed
improvements will be made. Links to new
and existing Networks and Facilities The site
is accessible for those wishing to travel by
cycle and on foot. It will also be accessible to
improved public transport facilities. The
residential areas of the proposed
development have been located to enable
ease of access by pedestrians and cyclists
to the town’s shops, employment and leisure
facilities. Throughout the development,
priority will be given to pedestrians, cyclists
and public transport over the private car.
B576 to Rushton Road safeguarded route
The internal highway network to the east of
the B576 has been designed to safeguard
future potential for a highway link between
the B576 and Rushton Road which would
provide an alternative route for traffic
travelling through the town from the east; as
required by Preferred Policy Direction 5.
Detailed designs of the proposed highway
junctions at the A6 and the B576 were
submitted as part of the Rothwell North
planning application Direct access to the A6
As explained above, the Rothwell North
development provides for direct access to




                                                   79
the A6. Thus it can be seen that the Rothwell
North urban extension will improve
accessibility in the manner sought by the
Council.




                                                80
                                                                For some time the Heads of the Desborough
                                                                Primary schools have kept up a dialogue
                                                                with the Local Authoritys Education
                                                                Department as to the future of schooling in
                                                                Desborough. All schools have been
                                                                compliant in helping the LA cope with the
                                                                expansion in numbers in recent years. It had
                                                                been felt until recently that our input and
                                                                opinions were valued in working towards a
                                                                long-term solution. The recently published
                                                                results in the consultation process indicate a
                                                                proposal to build a new one-form entry
                                                                                                                 The required provision for schools has been
                                                                primary school on the Grange estate. This
                                                                                                                 identified by Northamptonshire County
                                                                we believe to be the least desirable solution
                                                                                                                 Council. Provision would be acceptable both
                                                                for the existing schools. Loatlands Primary
                                                                                                                 in the form of a new one form entry school
                     Headteach                                  school occupies an extensive site and with
                                                                                                                 or a two form entry school, linked with one
                     er                                         remodelling could absorb a high proportion
                                                                                                                 of the existing schools in Desborough. The
         Mr Andrew   Desboroug                       Strongly   of the new school population along with the
277161                           paragraph   9.9.3                                                               next iteration of the AAP - Proposed
         Spencer     h                               disagree   existing spare capacity of the Havelock
                                                                                                                 Submission will be amended to reflect this.
                     Loatlands                                  schools. Alternatively, the relocation of
                                                                                                                 However, either option is likely to be
                     Cp School                                  Loatlands Primary school to serve its existing
                                                                                                                 acceptable and a new school on the Grange
                                                                catchment area and new development would
                                                                                                                 would directly serve the pupils generated by
                                                                be a logical option in pulling together
                                                                                                                 the development whilst reducing the need to
                                                                provision for the whole community as
                                                                                                                 travel.
                                                                opposed to the standalone site proposed.
                                                                The existing schools are concerned about
                                                                the effect that a new one-form entry primary
                                                                school would have on the admission roles of
                                                                the schools. Experience of local schools
                                                                losing children to new-build schools like
                                                                Mawsley and Hall Meadow suggests that this
                                                                is a likely scenario because of the attraction
                                                                of new and shiny and because initially there
                                                                are spare places allowing for movement from
                                                                existing establishments. A more thoughtful
                                                                process of integration could address the




                                                                                                                                              81
needs of all the Desborough schools and
provide a range of facilities and services of
benefit to the whole community without
creating spare places in all schools in the
area. We believe that currently in
Northamptonshire the number of one-form
entry schools in categories is well beyond
that of two-form entry, consequently another
small-scale development is likely to weaken
rather than strengthen existing provision.
Two-form entry allows for greater flexibility in
terms of team planning and delivery, more
staff to offer enrichment opportunities and
diversity of strengths and the potential to
encourage and develop leadership with
increasing degrees of experience. A larger
school allows for future growth and flexibility
of pastoral care and the dynamics of various
cohorts. In the past there were plans afoot at
one point to expand Loatlands to 1.5-form
entry. There is even the possibility of
redeveloping to two-form entry which would
save building another primary school. The
last position we discussed with senior
education officers was the likelihood of the
Loatlands site being sold for development
and a new two-form entry primary being built.
The siting for this we believe could be close
to the Grange but also to the area of West
Desborough that Loatlands currently serves.
Community facilities are currently negligible
for this sector of town. The option of building
a new one-form entry would create a
completely new community and would in no
way enhance the character and individuality
of the existing communities east and west of




                                                   82
the A6. Some time ago a local MP and
senior education officials visited Loatlands
and remarked that the cramped and
inadequate conditions did not make for
suitable 21st Century education. The lack of
facilities impinges upon what Loatlands can
provide both in curriculum and Extended
Services. The building does not allow the
school to provide the community with the
quality facilities a 21st Century society
should be entitled to. Expanding, remodelling
or re-siting would address this issue. Even if
all new housing is situated on The Grange it
does not mean that a school needs to be
sited there. Centring all new housing and
facilities on the Grange will create a totally
separate community and will certainly
disadvantage the existing schools. Land
opposite the new distribution centre on
Harborough Road would serve both sectors
of the community and embrace the whole
community. It is appreciated that the LA will
wish to maximise what can be obtained from
the developers but, if Loatlands School is
relocated, then the current land could be
sold for housing providing monies which
could fund a new school. Thus, to
summarise, the Governing Bodies and
Heads of the three existing schools in
Desborough, after discussions with the LA,
are expressing a unanimous preference for
Loatlands to become a two-form entry school
either on the existing site or relocated to
serve its existing and the proposed new
community. We believe this will provide the
Desborough community with the necessary




                                                 83
facilities and quality education to meet its
21st Century needs. This letter has been
compiled by the collective heads and chairs
of governors listed below. Yours sincerely
Andrew J Spencer Head Teacher Mrs M.
Rooke, Headteacher, Havelock Junior
School Mrs M. Payne, Chair of Governors,
Havelock Junior School Mrs A. Davey,
Headteacher, Havelock Infant School Mr M.
Upfold, Chair Of Governors, Havelock Infant
School Mr A. Spencer, Loatlands Primary
School Mr D. Larmour, Chair of Governors,
Loatlands Primary School




                                               84
                                         This notion that to developing the Grange is
                                         to create a split Desborough away from the
                                         town centre is nonsense. The town is
                                         already split by the old A6 running through it
                                         and Sycamore Drive to the East is already
                                         nearly two miles from Buxton Drive to the
                                         West and both are nearly half a mile further
                                         from the town centre "shops" than the
                                         Grange is now. If Persimmon homes are
                                         really interested in the facilities for
                                         Desborough people and not their profit then I
                                         suggest they buy all the derelict properties
                                         today and renovate them at the same time
                                         offering low rents for new shops to move to
                                         town and low rents to young local people for
                                         accommodation. As in any other walk of life I
         Mr Paul              Strongly   think it is imperative that those making
277201             document                                                               Noted
         Jackson              Agree      comments behind the mask of a company
                                         should state openly in the first instance any
                                         benefit that would be gained to that company
                                         on the implementation of either the current
                                         plans or their own proposals. I see for this
                                         forum that PERSIMMON HOMES have
                                         spent an awful lot of time in making
                                         comments around an option they have
                                         proposed and yet which is not even on the
                                         agenda for council approval. To enable the
                                         public living in Desborough and Rothwell to
                                         review the Persimmon comments with true
                                         regard can I ask their representative to post
                                         further comment with a breakdown to show
                                         what land they currently own and what
                                         financial benefit they would have from their
                                         proposals?




                                                                                                  85
                                                        Urban Extension Action Plan Position
                                                        Statement Desborough Branch of the Labour
                                                        Party “Observations 1 It is concerned with
                                                        the proposed provision of a new primary
                                                        school. It is felt that it would be better that
                                                        funds are invested in the existing schools,       The required provision for schools has been
                                                        i.e. Loatlands Primary; Havelock Infant and       identified by NCC. Provision would be
                                                        Junior Schools, to cope with a possible           acceptable both in the form of a new one
                                                        increase in pupils resulting from the new         form entry school or a two form entry school
                      Chairman                          urban extension. An extra school could lead       linked with one of the existing schools in
         Mr Michael   Desboroug                         to underutilised staff and capital across all     Desborough. The next iteration of the AAP -
277379                            document   Disagree
         Payne        h Labour                          the schools. It is understood that this may be    Proposed Submission will be amended to
                      Party                             the feeling of the Heads and Governors of         reflect this. However, either option is likely to
                                                        existing schools. 2 It is also concerned with     be acceptable and a new school on the
                                                        the withdrawal of an allocation of                Grange would directly serve the pupils
                                                        employment land for Desborough. Whilst            generated by the development whilst
                                                        understanding the arguments which have            reducing the need to travel.
                                                        been put forward in your document, it is felt
                                                        that it is still necessary to identify
                                                        employment land to cater for the increase in
                                                        population in order to reduce the need for
                                                        travel to a minimum.




                                                                                                                                          86
                     Governme
                                                                     In general we found the position statement to
         Mr Graeme   nt Office of
146615                              document            Agree        be well written, presented and easily             Noted
         Foster      East
                                                                     understood.
                     Midlands




                                                                     The Vision and objectives are a bit general
                                                                     and there is an opportunity to make these
                                                                     more locally distinctive in the submission
                     Governme
                                                                     draft of the Plan. For example, more could        Noted, objectives will be reviewed in the
         Mr Graeme   nt Office of
146615                              paragraph   6.2.1   No opinion   be said in terms of identifying what is special   next iteration of the AAP - Proposed
         Foster      East
                                                                     about the two towns in terms of environment,      Submission.
                     Midlands
                                                                     townscape, community and character and
                                                                     how will the urban extensions be made to fit
                                                                     into this context.




                                                                     The other options considered in paragraph
                                                                     7.03 could be a bit clearer as to exactly what
                     Governme
                                                                     other options were considered rather than         Noted, other options will reviewed in the
         Mr Graeme   nt Office of
146615                              paragraph   7.0.1   No opinion   simple reference to an alternative approach.      next iteration of the AAP - Proposed
         Foster      East
                                                                     The evidence base should include a clear          Submission.
                     Midlands
                                                                     audit trail of the various alternatives and why
                                                                     these were rejected.




                                                                                                                                                     87
                                                                     The Blythe Valley Court judgement has
                                                                                                                       Noted, further assessment has been
                                                                     important implications for all DPDs in terms
                                                                                                                       undertaken and the Rothwell and
                     Governme                                        of interpreting paragraph 29 of PPS 3. It is
                                                                                                                       Desborough Housing Market Assessments
         Mr Graeme   nt Office of                                    essential that the evidence base should
146615                              paragraph   9.5.1   No opinion                                                     produced to determine need. A further
         Foster      East                                            demonstrate the extent to which the
                                                                                                                       viability assessment will be undertaken to
                     Midlands                                        affordable housing target reflects an
                                                                                                                       inform the next iteration of the AAP -
                                                                     assessment of the economic viability of the
                                                                                                                       Proposed Submission.
                                                                     allocated housing sites.




                                                                     Paragraph 9.6.3 identifies that there is a
                                                                     potential sewerage capacity issue in
                                                                     Desborough. The paragraph then goes on to
                                                                     recommend that Anglian Water is engaged           Noted, Anglian Water and other utility
                     Governme
                                                                     in the planning and phasing of growth and         providers have been engaged throughout
         Mr Graeme   nt Office of
146615                              paragraph   9.6.1   No opinion   submission draft version of the AAP. It is        the production and consultation of this AAP
         Foster      East
                                                                     essential that key stakeholders are actively      and their comments will inform the next
                     Midlands
                                                                     engaged as early as possible and that             iteration of the AAP - Proposed Submission.
                                                                     evidence can be provided by the submission
                                                                     draft stage that there is an agreed solution to
                                                                     any potential sewerage capacity issue.




                                                                                                                                                    88
                                                            Whilst noting the infrastructure requirements
                                                            identified throughout the position statement,
                                                            the submission draft AAP will need to clear in
                     Governme
                                                            terms of infrastructure planning addressing      Noted, infrastructure requirements will be
         Mr Graeme   nt Office of
146615                              document   No opinion   the what, where, when and by whom                reviewed and made explicit in the next
         Foster      East
                                                            question. The AAP should include an              iteration of the AAP - Proposed Submission.
                     Midlands
                                                            implementation schedule and will need to be
                                                            backed up by a more detailed infrastructure
                                                            plan.




                                                                                                                                         89
                                                                  Water The AAP should promote and achieve
                                                                  resource efficiency within Rothwell and
                                                                  Desborough. Every opportunity should be
                                                                  taken to build water efficiency into new
                                                                  developments, and innovative approaches
                                                                  should be encouraged. It is recommended
                                                                  that the Preferred Policy Direction 13
                                                                  ensures that development contributes to
                                                                  achieving the ODPM sustainable
                                                                  communities target of reducing water
                                                                  consumption by 25% in all properties. Water
                                                                  efficiency measures should be promoted on
                                                                  all proposed development, with metering
                                                                  encouraged on all new and existing
                                                                  buildings. In compliance with the RSS8
                                                                  Environmental Strategy, future
                     Planning                                     developments in East Midlands should
                                                                                                                    Noted, water efficiency will be reviewed in
         Environme   Liaison                                      recognise the limited availability of water and
161356                           paragraph   9.6.1   No opinion                                                     the next iteration of the AAP - Proposed
         nt Agency   Environme                                    incorporate efficiency measures and SUDS
                                                                                                                    Submission.
                     nt Agency                                    at the planning stage. In addition to this, the
                                                                  Position Statement should promote the Code
                                                                  for Sustainable Homes as best practice with
                                                                  both developers and LPA acknowledging
                                                                  and anticipating the challenges to be faced
                                                                  in delivering the Code (Managing Growth-
                                                                  Revised East Midlands Regional Housing
                                                                  Strategy 2008-2016). Working partnerships
                                                                  between developers, LPA, builders and utility
                                                                  companies will be the most effective way of
                                                                  achieving the standards of the Code. Flood
                                                                  Risk and Surface Water As stated the LPA
                                                                  has completed a Planning Policy and
                                                                  Guidance Note 25 (PPG25) standard SFRA
                                                                  for their administrative area. The Position
                                                                  Statement and Sustainability Appraisal refers
                                                                  to the Strategic Flood Risk Assessment




                                                                                                                                                  90
undertaken by Haskoning in 2005. This
SFRA is yet to be updated to Planning Policy
Statement 25 (PPS25) standard and as such
does not incorporate the latest information
on flood risk from fluvial and non-fluvial
sources in the catchment area. The
preferred development sites (Rothwell North
and Desborough North) are shown to be
within Flood Zones 1 as detailed on the
Environment Agencys Flood Zone Maps,
and as defined in Table D1 of Planning
Policy Statement 25 (PPS25). Accordingly,
any planning application must be submitted
with a PPS25 compliant Flood Risk
Assessment (FRA) which considers the
impact and consequence of flooding. The
hierarchy of drainage infers that infiltration
should be used wherever feasible and
practicable. Only where discharge via
infiltration and/or to a watercourse has been
proven to be unfeasible should discharge to
surface water sewers be considered.
Sustainable Urban Drainage Systems
(SUDS) must be implemented throughout the
development for managing/ reducing flood
risk. Relevant documents for SUDS include
the Interim Code of Practice for SUDS and
CIRIA publication C697 - The SUDS Manual.
Whilst the Position Statement recognises
SUDS, it does not reference to the possible
methods that could be utilised. The long term
maintenance and/or adoption proposals for
every element of the drainage system
proposed on the site should be addressed
for the entire lifetime of the development.
Only surface water from roofs and paved




                                                 91
areas not accessible to vehicles, should be
discharged to any soakaway, watercourse or
surface water sewer. Surface water from
roads and impermeable vehicle parking
areas shall be discharged via trapped
gullies. All surface water from roofs shall be
piped direct to an approved surface water
system using sealed downpipes. Open
gullies should not be used. Foul Sewage is
one of the most common sources of
pollution. The AAP should be informed by
the detailed North Northants Water Cycle
Strategy regarding water and sewer capacity
for the Strategic Development Areas (SDAs)
planned for Desborough and Rothwell. With
reference to MKSM SRS Policy 3, proposed
development should involve promoting the
highest level of environmental performance,
not only in the design of new buildings but
also in master planning and managing
development. Adequate and timely
environmental infrastructure provision is
essential if new houses are to be built within
the environments capacity to cope with the
additional impacts. Anglian Water Services
Ltd. should be consulted and be requested
to demonstrate that the sewerage and
sewage disposal systems serving the
development will have sufficient capacity to
accommodate the additional flows,
generated as a result of the development,
without causing pollution or flooding.




                                                 92
                                                                  Climate Change The Sustainability Appraisal
                                                                  (SA) acknowledges uncertainties with
                                                                  regards to the impacts of climate change
                                                                  (Appendix 7, page 122); however there is an
                                                                  need to limit the impact by reducing the
                                                                  production of greenhouse gases. With
                                                                  reference to PPS1 (pages 19-20), the AAP
                     Planning                                                                                    Noted. Policy 14 of the CSS and the
                                                                  has a role to play in reducing greenhouse
         Environme   Liaison                                                                                     adopted Kettering Sustainable Design SPD
161356                           paragraph   9.6.5   No opinion   gas emissions and should aim to do so by
         nt Agency   Environme                                                                                   looks specifically at reducing the effects of
                                                                  making sure developments use resources
                     nt Agency                                                                                   climate change.
                                                                  efficiently, allow wildlife to migrate and
                                                                  adapt, and make the built environment more
                                                                  resilient. We suggest the inclusion of key
                                                                  messages in the Position Statement to
                                                                  highlight its commitment to adapting and
                                                                  mitigating against climate change within the
                                                                  SDAs.




                                                                                                                                                93
                                                                  In accordance with the Northamptonshire
                                                                  Environmental Character and Green
                                                                  Infrastructure Suite Policy Context (page 2),
                                                                  local planning authorities should adopt a
                                                                  holistic approach to environmental planning
                                                                  and should ensure that new development is
                                                                  sustainable and follows the principles of
                                                                  green infrastructure. Piecemeal provision of
                                                                  green spaces and green infrastructure
                                                                  should be avoided and should instead be
                                                                  planned for strategically. Biodiversity
                                                                  enhancement alongside improved access to
                                                                  the river and greenspace should be sought
                                                                  wherever possible. The proposed
                     Planning                                     development provides a good opportunity to
                                                                                                                  Noted, green infrastructure objectives will be
         Environme   Liaison                                      improve the landscape, visual amenity
161356                           paragraph   9.8.1   No opinion                                                   reviewed in the next iteration of the AAP -
         nt Agency   Environme                                    ecological and wildlife value of the proposed
                                                                                                                  Proposed Submission.
                     nt Agency                                    site and surrounding area for the benefit of
                                                                  the existing and proposed communities.
                                                                  Links should be made with the Water Cycle
                                                                  study, green infrastructure strategy and
                                                                  policies held within PPS9, the EU Habitat
                                                                  Directive and UK Regional and local BAPs.
                                                                  In accordance to the CSS Vision for North
                                                                  Northamptonshire, development should
                                                                  strive to deliver high quality development
                                                                  that acts as a show piece for modern green
                                                                  living whilst also protecting and enhancing
                                                                  valuable built and natural resources to
                                                                  ensure that the growth will provide
                                                                  opportunities and benefits to existing
                                                                  communities and new residents.




                                                                                                                                                94
                                                                   A historic landfill is located to the North of
                                                                   Rothwell. The site name is Rear Of Goode
                                                                   And Marlow Limited, and it handled Category
                                                                   A waste which is regarded as inert material
                                                                   that either does not decompose or
                                                                   decomposes very slowly. It would be
                                                                   advisable to engage a suitable qualified and
                                                                   experienced consultant to investigate and
                                                                   assess the site, to determine whether there
                     Planning
                                                                   is a problem with landfill gas and the
         Environme   Liaison                                                                                        Noted, waste will be reviewed in the next
161356                           paragraph   9.10.1   No opinion   measures that may be necessary to ensure
         nt Agency   Environme                                                                                      iteration of the AAP - Proposed Submission.
                                                                   the safety of the development. Any waste
                     nt Agency
                                                                   excavation material or building waste
                                                                   generated in the course of the development
                                                                   must be disposed of satisfactorily and in
                                                                   accordance with section 34 of the
                                                                   Environmental Protection Act 1990 and with
                                                                   the Duty of Care and the Waste
                                                                   Management Licensing Regulations 1994.
                                                                   The waste hierarchy reduce; re-use and
                                                                   recycle should be implemented.




                                                                                                                                                95
                                                                The AAP position statement should be
                                                                aware and take into consideration the East
                                                                Midlands Environment Strategys (2002) key
                                                                objectives with regards to promoting good
                                                                environmental quality in the proposed SDAs.
                                                                In addition to this, PPS1 states that planning
                     Planning
                                                                should seek to maintain and improve the          Noted, the strategy will be taken into
         Environme   Liaison
161356                           paragraph   9.8.1   Disagree   local environment to help mitigate the effects   consideration in the next iteration of the AAP
         nt Agency   Environme
                                                                of a declining environmental quality through     - Proposed Submission.
                     nt Agency
                                                                positive policies. This is to ensure that the
                                                                proposed development will seek to improve
                                                                overall water quality, the air is cleaner and
                                                                healthier, biodiversity is protected and
                                                                enhanced and access to the environment is
                                                                improved and promoted.




                                                                                                                                               96
                                                               On behalf of ProLogis Developments                The SHLAA only looks at housing and its
                                                               Limited, Nathaniel Lichfield and Partners         deliverability not any wider impacts of
                                                               have pleasure in commenting on the                provision other uses. The Sustainability
                                                               Rothwell and Desborough Urban Extension           Appraisal and Urban Extension
                                                               Area Action Plan Position Statement               Methodology look at all the social, economic
                                                               consultation. ProLogis Developments               and environmental impacts of the proposed
                                                               Limited objects to Preferred Policy Direction     sites and are the most appropriate means of
                                                               4 as this site is not considered to represent a   assessing sites. Also, the SHLAA is a
                                                               desirable planning objective in terms of the      technical study of housing potential, working
                                                               environment and long term sustainability of       on the best available information at a point
                                                               the town. The preferred option at                 in time; this means it is not necessarily fully
                                                               Desborough North does not integrate well          inclusive. The SHLAA only provides a snap-
                                                               into the town centre and is poorly related to     shot of sites across North
                                                               the existing urban area, and it is therefore      Northamptonshire, on receipt of more
                                                               considered that the development of this land      detailed information through the
                                                               as an urban extension would conflict with the     submissions made by developers and the
                    Planner
                                                               overall objectives of the Rothwell and            detail in the Urban Extension Methodology
                    Nathaniel
         Ms Katie                                   Strongly   Desborough Urban Extension Area Action            and Sustainability Appraisal the site to the
161712              Lichfield   paragraph   8.0.6
         Webb                                       disagree   Plan. Paragraph 9.2.7of the Position              north of the Grange would actually
                    and
                                                               Statement states that well planned and            integrated better with the existing town, be
                    Partners
                                                               designed development within Desborough,           in a less prominent position, have better
                                                               and close to the town centre, would               access, serve to complete existing
                                                               strengthen town centre regeneration               development at the Grange and provide
                                                               initiatives. ProLogis Developments Limited        necessary services to the north of
                                                               agrees with this statement and urges that         Desborough. It is considered that linkages
                                                               both employment and housing opportunities         and connectively to the town can be
                                                               are provided on sites with good access to         improved to allow easier access into the
                                                               Desborough town centre. ProLogis                  town centre through the provision of a
                                                               Developments Limited consider that land to        railway bridge and improve cycleways and
                                                               the south of Desborough at Pioneer Avenue/        footpaths along existing routes as well as
                                                               Rothwell Road would provide a development         improvements to the town centre to make it
                                                               which would better relate to the existing         more appealing for visitors. The SHLAA
                                                               urban area than the preferred option at           forms part of the LDF evidence base, along
                                                               Desborough North. The development of this         with a range of other technical studies. It
                                                               site would allow natural expansion to take        does not in any way prejudice decisions to
                                                               place within the A6 bypass, which offers a        be taken by the Joint Planning Committee or




                                                                                                                                                97
natural and well-defined boundary to the          by individual district/borough planning
southern edge of the urban area. No such          authorities, in relation to preferred directions
boundary exists at Desborough North, and if       of growth, site identification in Development
additional land was required to be identified     Plan Documents (DPDs) or the
in order to meet housing supply targets,          determination of planning applications.
ProLogis Development Limited is concerned
that the open fields to the north of the site
would come under pressure for
development, resulting in the loss of valuable
open green space and further development
which would represent urban sprawl in an
unsustainable location which is distant from
the town centre. Furthermore, it is significant
to note that North Northamptonshire’s
Strategic Housing Land Availability
Assessment identifies land at Desborough
North (The Grange) as a Category 3 site
which achieves low overall scores and
performs least well against the assessment
criteria. Land to the south of Pioneer Avenue
and west of Rothwell Road, is classified as a
Category 2 site, which performs moderately
well against the assessment criteria and
appears to be achievable/ deliverable. We
trust that the above comments will be fully
taken into account in your consideration of
the Rothwell and Desborough Urban
Extension Area Action Plan Position
Statement consultation, specifically, that
ProLogis Developments Limited considers
that Preferred Policy Direction 4, which
directs housing expansion to the north of
Desborough, should be reviewed, and that
housing growth should be directed to
locations which are in line with both the
objectives of the document, and the scoring




                                                                                  98
of sites in the SHLAA, such as land south of
Pioneer Avenue and west of Rothwell Road.
We would be obliged if we could be kept fully
informed of the process of the Rothwell and
Desborough Urban Extension Area Action
Plan Position Statement, including the
summary of the responses received.




                                                99
                   Planning
                                                              Many thanks for giving Anglian Water
                   Liaison
                                                              Services Ltd the opportunity of making
                   Account
         Mr Mick                                   Strongly   comments on the position statement. I can
163113             Manager     paragraph   9.6.1                                                               Noted
         Galey                                     Agree      confirm that our organisation has no
                   Anglian
                                                              comments to make other than to fully support
                   Water
                                                              Section 9.6 Infrastructure and Utilities.
                   Services




                                                              This states "The preferred policy direction is
                                                              to enhance the character and individuality of
                                                              Rothwell and Desborough and reflect this in
                                                              the location and design of extensions” Our
                   Secretary
                                                              view is that Coalescence between
         Mr John   Desboroug
169884                         paragraph   7.0.3   Agree      settlements must be avoided, as stated at        Noted
         Kemp      h Civic
                                                              the bottom of P.6. The proposed housing
                   Society
                                                              development to the north of Rothwell would
                                                              be clearly visible from Desborough, which is
                                                              undesirable. The two towns must be kept
                                                              separate, both physically and visually.




                                                                                                                       100
                                                                 Rothwell Gullett Nature Reserve must be
                                                                 protected and an adequate buffer zone
                   Secretary                                                                                     Noted, a reasonable distance will be
                                                                 between any housing development must be
         Mr John   Desboroug                                                                                     identified in the next iteration of the AAP -
169884                         paragraph   6.5.4    No opinion   agreed with the Wildlife Trust. Are Officers
         Kemp      h Civic                                                                                       Proposed Submission to protect all nature
                                                                 aware of the other two Desborough Nature
                   Society                                                                                       reserves in close proximity to development.
                                                                 Reserves, one on The Plens and the other
                                                                 Taiby's Meadow?




                                                                                                                 Developers and landowners will only be
                   Secretary                                     "Contributions towards a permanent heritage
                                                                                                                 expected to contribute to services which
         Mr John   Desboroug                                     centre for the town" - what exactly does this
169884                         paragraph   9.7.13   No opinion                                                   might be put under pressure as a direct
         Kemp      h Civic                                       mean? Is it a definite commitment to the
                                                                                                                 result of the proposed urban extension in
                   Society                                       provision of a Heritage Centre?
                                                                                                                 order to serve the population generated.




                                                                                                                                              101
                                                     : Officers will by now be aware that we wish
                                                     to keep the proposals made in the Urban
                                                     Design Framework for the Lawrence Site for
                                                     mixed Commercial, Cultural and Community
                                                     uses. : There is considerable concern in the
                                                                                                        Sites within the town centre will be assessed
                                                     town about the provision of a medium size
                                                                                                        through the Site Specifics Proposals LDD.
                                                     Tesco Supermarket on the Lawrence Site - it
                                                                                                        The aims of this consultation were to collate
                                                     is generally felt that this would not be helpful
                   Secretary                                                                            public opinion with regards to the proposed
                                                     in the regeneration of the town centre. Key
         Mr John   Desboroug                                                                            policy directions contained within the
169884                         document   Disagree   Site 1 would be a more acceptable site for a
         Kemp      h Civic                                                                              Rothwell and Desborough Urban Extensions
                                                     small Supermarket along with a new Library
                   Society                                                                              AAP - Position Statement. Detailed
                                                     and Heritage Centre with shared communal
                                                                                                        information was available within the Position
                                                     facilities. : Finally, we are concerned about
                                                                                                        Statement and available throughout the
                                                     the lack of public consultation regarding the
                                                                                                        consultation.
                                                     Area Action Plan. The staffed exhibitions
                                                     held on 4th and 5th March were useful but
                                                     contained very little that was detailed or
                                                     concrete, making it difficult for the public to
                                                     make an informed assessment.




                                                                                                                                    102
                                                                                                                    The required provision for schools has been
                                                                                                                    identified by NCC. Provision would be
                                                                                                                    acceptable both in the form of a new one
                                                                                                                    form entry school or a two form entry school,
                   Secretary                                     : The need for building a new school is not        to be created through linking with one of the
         Mr John   Desboroug                                     proven. The suggestion that it should be on        existing schools in Desborough. The next
169884                            paragraph   9.9.3   Disagree
         Kemp      h Civic                                       Harborough Road on the West side opposite          iteration of the AAP - Proposed Submission
                   Society                                       Great Bear Distribution is ill judged.             will be amended to reflect this. Although,
                                                                                                                    either option is likely to be acceptable or a
                                                                                                                    new school on the 'Grange' would directly
                                                                                                                    serve the pupils created by the development
                                                                                                                    whilst reducing the need to travel.




                                                                 We support objective 2 on accessibility,
                   planning &
                                                                 particularly in relation to reducing reliance on
         Miss      biodiversity
                                                                 the private car by improving public transport
187857   Rachel    adviser        paragraph   6.5.3   Agree                                                         Noted
                                                                 links and providing footpaths and cycleways.
         Gorman    Natural
                                                                 This modal shift follows the established
                   England
                                                                 policy line in PPG13




                                                                                                                                                103
                                                                We welcome the inclusion of objective 3 on
                                                                environmental assets, in particular the
                                                                reference to protecting and enhancing
                                                                landscape and biodiversity. However, we
                                                                oppose the present wording of the objective.
                                                                We request that the objective should be
                                                                made more robust by seeking a net gain in
                  planning &                                    the biodiversity resource of the district. This
                                                                                                                  Noted, this will be included in the next
         Miss     biodiversity                                  objective should be amended accordingly in
                                                                                                                  iteration of the AAP - Proposed Submission,
187857   Rachel   adviser        paragraph   6.5.4   Disagree   line with paragraph 5 (ii) of PPS9 and policy
                                                                                                                  although the AAP will not repeat National,
         Gorman   Natural                                       28 of RSS8. We also oppose the omission of
                                                                                                                  Regional or Local Planning Policy.
                  England                                       seeking a net gain in green infrastructure
                                                                (GI) within this objective. Although implicit
                                                                reference has been made to GI in objective
                                                                3, given the focus and importance of GI
                                                                within the East Midlands Regional Plan and
                                                                the North Northamptonshire Joint Core
                                                                Strategy, the objective should be amended
                                                                to make this explicit.




                                                                                                                                             104
                  planning &
         Miss     biodiversity                                  We support objective 4 to secure high quality
187857   Rachel   adviser        paragraph   6.5.5   Agree      development that safeguards and enhances          Noted
         Gorman   Natural                                       townscape and landscape quality.
                  England


                  planning &
         Miss     biodiversity                                  Rothwell - Preferred Policy Direction 3 We
187857   Rachel   adviser        paragraph   8.0.1   Agree      support the preferred policy direction as         Noted
         Gorman   Natural                                       stated.
                  England



                  planning &                                    Desborough “Preferred Policy Direction 4 We
         Miss     biodiversity                                  support the preferred policy direction as
187857   Rachel   adviser        paragraph   8.0.1   Agree      stated. This site provides a major opportunity    Noted
         Gorman   Natural                                       for the enhancement of biodiversity and the
                  England                                       provision of GI.




                                                                Recreational infrastructure Preferred Policy
                  planning &
                                                                Direction 15 We strongly support this policy
         Miss     biodiversity
                                                     Strongly   direction, particularly the intention to secure
187857   Rachel   adviser        paragraph   9.7.2                                                                Noted
                                                     Agree      contributions and maintenance contracts to
         Gorman   Natural
                                                                ensure the long term maintenance of open
                  England
                                                                space / GI.




                                                                                                                          105
                                                                We strongly support the inclusion of a policy
                                                                specifically on Green Infrastructure and
                                                                support the policy direction as stated. In line
                                                                with the MKSM sub-regional strategy, the
                                                                provision of GI needs to be addressed
                                                                throughout the sub-region so as to ensure a
                  planning &                                    net gain to meet the needs generated by
                                                                                                                  Noted, reference will be made to the
         Miss     biodiversity                                  growth and, where relevant, help to address
                                                     Strongly                                                     importance of green infrastructure linkages
187857   Rachel   adviser        paragraph   9.8.1              existing deficiencies. This may take the form
                                                     Agree                                                        throughout the sub-region in the next
         Gorman   Natural                                       of protection, enhancement or extension of
                                                                                                                  iteration of the AAP - Proposed Submission.
                  England                                       existing resources, or the provision of new or
                                                                replacement facilities. We are encouraged
                                                                by the references to KBCs emerging Green
                                                                Infrastructure Strategy and are pleased to
                                                                note that this has been used as a steer for
                                                                identifying important GI links such as the Ise
                                                                Valley.




                                                                                                                                             106
                                                                Biodiversity Preferred Policy Direction 18 We
                  planning &
                                                                strongly support the focus on the protection,
         Miss     biodiversity
                                                     Strongly   enhancement and creation of priority BAP
187857   Rachel   adviser        paragraph   9.8.7                                                              Noted
                                                     Agree      habitats within this section. The preferred
         Gorman   Natural
                                                                policy direction provides maximum benefit for
                  England
                                                                increasing and protecting biodiversity.




                                                                                                                        107
                                                              We welcome the creation of a distinct set of
                                                              development principles to guide a master
                                                              planning process and concur with the
                                                              importance placed on design issues such as
                                                              the impact on the surrounding landscape,
                                                              the retention of existing landscape features
                  planning &
                                                              and green infrastructure. We support the
         Miss     biodiversity
                                                              preferred policy direction as the use of
187857   Rachel   adviser        paragraph   9.12.1   Agree                                                   Noted
                                                              development principles can help secure
         Gorman   Natural
                                                              sustainable growth. Opportunities should be
                  England
                                                              taken to enhance important existing
                                                              environmental assets and promote the
                                                              provision of new GI to enhance the
                                                              attractiveness of the area and meet the
                                                              needs of its population (as identified in the
                                                              MKSM Sub-Regional Strategy).




                                                                                                                      108
                                                                 It is essential to establish a process of
                                                                 ensuring that relevant and effective plan
                                                                 policies are identified and put into place.
                                                                 When monitoring the plan, appropriate
                                                                 indicators must be included to identify the
                                                                 impact of the final chosen policy approach
                  planning &                                     on the biodiversity resource and landscape
         Miss     biodiversity                                   character of the area. Preferred Policy         Noted, wording will be amended accordingly
187857   Rachel   adviser        paragraph   10.1.1   Disagree   Direction 25 We oppose the wording of this      in the next iteration of the AAP - Proposed
         Gorman   Natural                                        policy direction. It should be amended to       Submission.
                  England                                        read ˜the plan will seek to secure the use of
                                                                 planning obligations to secure appropriate
                                                                 mitigation required as a result of the
                                                                 development. This would then cover the
                                                                 provision of habitat creation/enhancement
                                                                 and GI as well as traditional infrastructure,
                                                                 services and facilities.




                                                                                                                                            109
                                                                 The Wildlife Trust strongly disagrees that
                                                                 "other than minor boundary alterations"
                                                                 everything is fine with the proposals for the
                                                                 northern-side boundary of the Rothwell North
                                                                 extension area. The proposed width ( an
                                                                 assumed minimum of 50 metres ) for the
                                                                 buffer strip between the Rothwell Gullet
                                                                 Nature Reserve and the built development at
                                                                 Rothwell North is not sufficient to satisfy all
                                                                 of its intended roles; protection for the
                                                                 Nature Reserve itself, badger sett protection
                                                                 and badger foraging areas, SUDS, GI / open
                                                                 space provision, soft landscaping, etc.
                                                                 Please refer to The Wildlife Trust's letter of
                   Planning &                                    Objection, dated 9th July 2007, to the
                   Biodiversit                                   previous Planning Application for the
                                                                                                                   Noted. A designated buffer necessary to
                   y Officer                                     Rothwell North scheme - No.
                                                                                                                   protect wildlife and their habitats will form
         Mr Alan   The                                Strongly   KET/2007/0461. As already mentioned
205837                           paragraph   2.1.10                                                                part of the next iteration of the AAP -
         Smith     Wildlife                           disagree   above, we are very concerned about just
                                                                                                                   Proposed Submission and the Proposals
                   Trust for                                     how close to the edge of the Rothwell Gullet
                                                                                                                   Map.
                   Northampt                                     site this proposed urban extension to
                   onshire                                       Rothwell is shown as coming. As a reminder,
                                                                 the site at Rothwell Gullet is a Wildlife Trust
                                                                 Nature Reserve, a non-statutory (County)
                                                                 Wildlife Site and a RIGS. To avoid potentially
                                                                 adverse affects upon this valuable site –
                                                                 such as unmanaged, increased visitor
                                                                 pressure, domestic cats and dogs and the
                                                                 unwanted dumping of waste materials
                                                                 (especially garden rubbish), for example we
                                                                 believe that the Rothwell Gullet Nature
                                                                 Reserve will require robust buffering against
                                                                 the encroachment of the Rothwell urban
                                                                 extension. The Wildlife Trust would suggest
                                                                 a minimum of 100 metres as the appropriate
                                                                 width for such a buffer zone. The Rothwell




                                                                                                                                                 110
Gullet Nature Reserve should not only be
protected / buffered in this fashion, but it
should also be enhanced through
appropriate conservation management input
and linkages. There are also at least 4
potential new Local Wildlife Site areas either
within, or else adjacent to, the northern and
eastern edges of the proposed Rothwell
North urban extension zone.




                                                 111
                   Planning &
                   Biodiversit                                  On behalf of The Wildlife Trust, please refer
                                                                                                                  Noted. A designated buffer necessary to
                   y Officer                                    to our comments made elsewhere earlier in
                                                                                                                  protect wildlife and their habitats will form
         Mr Alan   The                               Strongly   respect of Paragraph 2.1.10. The proposed
205837                           paragraph   3.1.2                                                                part of the next iteration of the AAP -
         Smith     Wildlife                          disagree   Rothwell North extension area lies far too
                                                                                                                  Proposed Submission and the Proposals
                   Trust for                                    close to the designated site at Rothwell
                                                                                                                  Map.
                   Northampt                                    Gullet.
                   onshire




                                                                The Rothwell North proposed extension
                   Planning &                                                                                     Noted. However, this list is not intended to
                                                                area's plans, as far as we currently
                   Biodiversit                                                                                    be a comprehensive list of all the necessary
                                                                understand them to be, certainly do not
                   y Officer                                                                                      provision and contributions. Planning
                                                                deliver on all of the elements shown in this
         Mr Alan   The                               Strongly                                                     obligations will be calculated based upon
205837                           paragraph   3.1.2              list here. Please refer to the content of The
         Smith     Wildlife                          disagree                                                     the impact of the urban extension on the
                                                                Wildlife Trust's letter of Objection, dated 9th
                   Trust for                                                                                      area. The required contributions may evolve
                                                                July 2007, in response to the previous
                   Northampt                                                                                      and will be outlined in the next iteration of
                                                                Rothwell North Outline Planning Application;
                   onshire                                                                                        the AAP – Proposed Submission.
                                                                No. KET/2007/0461.




                                                                                                                                                112
                   Planning &                                   In the view of The Wildlife Trust, however,
                   Biodiversit                                  this list of objectives here should also include
                   y Officer                                    specific references to making provision for
                                                                                                                    Noted, wording will be amended in the next
         Mr Alan   The                               Strongly   (species and habitats to have the time and
205837                           paragraph   6.5.4                                                                  iteration of the AAP - Proposed Submission
         Smith     Wildlife                          Agree      the space to undergo) adaptation to climate
                                                                                                                    to reflect these comments.
                   Trust for                                    change effects and also the aim of delivering
                   Northampt                                    habitat creation, and future management, at
                   onshire                                      a landscape-scale.




                   Planning &                                   In line with our earlier comments, made
                   Biodiversit                                  elsewhere here before, The Wildlife Trust
                                                                                                                    Noted. A designated buffer necessary to
                   y Officer                                    believes that this diagram shows the
                                                                                                                    protect wildlife and their habitats will form
         Mr Alan   The                               Strongly   Rothwell North extension area lying far too
205837                           paragraph   8.0.4                                                                  part of the next iteration of the AAP -
         Smith     Wildlife                          disagree   close to the designated site at Rothwell
                                                                                                                    Proposed Submission and the Proposals
                   Trust for                                    Gullet - as well as to a string of other existing
                                                                                                                    Map.
                   Northampt                                    and potential non-statutory sites along its
                   onshire                                      northern edge.




                                                                                                                                                  113
                   Planning &
                   Biodiversit
                                                                However, in addition, it is the opinion of The
                   y Officer
                                                                Wildlife Trust that this approach must also      Noted, wording will be amended in the next
         Mr Alan   The                               Strongly
205837                           paragraph   9.6.7              have as an integral part of it a provision to    iteration of the AAP - Proposed Submission
         Smith     Wildlife                          disagree
                                                                allow for the adaptation (of biodiversity /      to reflect these comments.
                   Trust for
                                                                ecosystems) to climate change effects.
                   Northampt
                   onshire




                                                                These lists are already missing some
                   Planning &                                   existing, important, sites, and some
                   Biodiversit                                  potentially significant ones too. For example,
                   y Officer                                    The Wildlife Trust strongly recommends that      Noted, reference will be made to important
         Mr Alan   The                                          in the list for Desborough there needs to be     sites including Tailby Meadows and The
205837                           paragraph   9.7.5   Agree
         Smith     Wildlife                                     a specific reference made to the Nature          Plens in the next iteration of the AAP -
                   Trust for                                    Reserve sites at Tailby Meadows and The          Proposed Submission.
                   Northampt                                    Plens - in respect of retention, protection,
                   onshire                                      enhancement, buffering, extension, linkage,
                                                                etc.




                                                                                                                                            114
                   Planning &
                   Biodiversit                                  However, as we have stated elsewhere here
                   y Officer                                    before, The Wildlife Trust strongly
                                                                                                            Noted, wording will be amended in the next
         Mr Alan   The                               Strongly   recommends that the existing Nature
205837                           paragraph   9.8.5                                                          iteration of the AAP - Proposed Submission
         Smith     Wildlife                          Agree      Reserve sites at Tailby Meadow and The
                                                                                                            to reflect these comments.
                   Trust for                                    Plens are included here by means of
                   Northampt                                    specifically-named references.
                   onshire




                                                                                                                                       115
                                                                On a point of information, and for reasons of
                                                                clarity, The Wildlife Trust asks for further
                                                                details to please be provided as to just what
                                                                the "North Northamptonshire Biodiversity
                   Planning &                                   Action Plan" document is?? Furthermore, we
                   Biodiversit                                  are of the view that the list of priority habitats
                   y Officer                                    given here (please note, habitats only - no
                                                                                                                     Noted, wording will be amended in the next
         Mr Alan   The                                          species are given??!!) has been taken from
205837                           paragraph   9.8.9   Disagree                                                        iteration of the AAP - Proposed Submission
         Smith     Wildlife                                     the original Northamptonshire county
                                                                                                                     to reflect the revised BAP.
                   Trust for                                    Biodiversity Action Plan document. The
                   Northampt                                    county BAP was refreshed and relaunched
                   onshire                                      on 21st July 2008; with a further revision
                                                                being uploaded to the website in January
                                                                2009. Please refer to
                                                                www.northamptonshirebiodiversity.org for
                                                                further details.




                                                                                                                                                116
                                                                 And, in the view of The Wildlife Trust, an
                   Planning &
                                                                 adequate proportion of the funding levied in
                   Biodiversit
                                                                 this, or other ways, needs to be spent of
                   y Officer
                                                                 delivering the full scope of Green
         Mr Alan   The                                Strongly
205837                           paragraph   10.1.2              Infrastructure - especially the biodiversity      Noted
         Smith     Wildlife                           Agree
                                                                 elements - wide-ranging biodiversity
                   Trust for
                                                                 enhancements, adaptation to climate change
                   Northampt
                                                                 measures and landscape-scale wildlife
                   onshire
                                                                 conservation.




                                                                 However, in the opinion of The Wildlife Trust,
                   Planning &
                                                                 it is going to be an impossible task to report
                   Biodiversit
                                                                 against the monitoring of biodiversity gains,
                   y Officer
                                                                 as is stated here as one of the various
         Mr Alan   The                                Strongly
205837                           paragraph   10.2.2              monitoring objectives, if adequate financial,     Noted
         Smith     Wildlife                           Agree
                                                                 and other forms of, support are not provided
                   Trust for
                                                                 in order to deliver a fully-integrated Wildlife
                   Northampt
                                                                 Sites System, and Local Records Centre, for
                   onshire
                                                                 the county of Northamptonshire.




                                                                                                                           117
                                                                 But, since in the view of The Wildlife Trust,
                   Planning &                                    the economy is a subsidiary of the
                   Biodiversit                                   environment - and not vice versa - there will
                   y Officer                                     need to be a fully-comprehensive and front-
                                                                                                                 Noted, further work with regards to green
         Mr Alan   The                                           loaded Green Infrastructure appraisal
205837                           paragraph   10.3.1   Agree                                                      infrastructure is required to inform the next
         Smith     Wildlife                                      approach, coupled with an extensive
                                                                                                                 iteration of the AAP - Proposed Submission.
                   Trust for                                     Biodiversity Opportunity Mapping exercise,
                   Northampt                                     undertaken in advance in order to guide and
                   onshire                                       inform all future development works,
                                                                 including the Phasing process.




                                                                 In addition, The Wildlife Trust strongly
                   Planning &                                    recommends that these evolving
                   Biodiversit                                   development plans for Rothwell and
                   y Officer                                     Desborough also use the Regional-level
         Mr Alan   The                                Strongly   reference source of the document entitled "A    Noted, this document will inform the next
205837                           paragraph   9.8.8
         Smith     Wildlife                           Agree      Biodiversity Strategy for the East Midlands"    iteration of the AAP - Proposed Submission.
                   Trust for                                     (produced in 2006 and published by EMRA
                   Northampt                                     and the East Midlands Biodiversity
                   onshire                                       Partnership) in order to provide guidance
                                                                 and advice in biodiversity matters.




                                                                                                                                             118
                                          Desborough From a Desborough town                This AAP puts great emphasis on improving
                                          centre regeneration point of view there are      connectivity especially into Desborough
                                          two flaws in the proposal. 1. the location of    town centre. This is very important in the
                                          the residential land will accelerate the         delivery of sustainable urban extensions.
                                          development of a two-part town split by the      Policy direction 5 aims to improve
                                          railway. The current Grange development          connectivity and will ensure better linkages
                                          included a bridge into the town in the old       over the railway line. As outlined in the
                                          station area. This has not been provided.        Sustainability Appraisal the proposal is
                                          There appears to be no contractual need for      actually no further from the town centre than
                                          the new development to provide additional        other options considered and parts of the
                                          connectivity into the existing town centre.      extension are actually closer to the town
                                          Without this residents of the proposed new       centre than Desborough West, due to the
                                          housing development are more likely to turn      separation which would exist taking into
                                          right into Market Harborough than left into      consideration the Pocket Park. Therefore,
                                          Desborough to do their shopping and spend        development to the West of Desborough
                                          leisure time. 2. the removal of all              would also result in a 'split' between
                                          employment land. Desborough needs a              residential properties and the town centre.
         Mr Robin                         balanced economic and social development         Construction on the Pocket Park would
268504              document   Disagree
         Matthews                         plan, particularly including the provision of    result in the loss of an important open space
                                          local jobs. The regeneration of town centre      as well as the destruction of wildlife habitats
                                          sites will provide some employment               and could lead to loss of important species.
                                          opportunities but insufficient to decrease the
                                          outflow of local people to their places of       The section 106 agreement for the existing
                                          work. The original Desborough 'Central'          'Grange' outlined the necessity for the
                                          proposal involving both residential and          developer to undertake 'reasonable
                                          employment land would give the town a            endeavours' to secure a footbridge over the
                                          much better chance of returning to its           railway line linking the Grange with
                                          previous position as a thriving, self-           Desborough. KBC has been in regular
                                          sustaining, market town. The new houses          communication with developers,
                                          would be nearer to the town centre, the          landowners, highways authority and the
                                          'pocket park' would need to positively           railway company to secure the footbridge
                                          accommodate the proposed new road and            and is continuing to do so. If not brought
                                          some (not the original 20 hectares)              forward in the short term, it is considered
                                          employment land could be provided either on      that improving connectivity will be a priority
                                          the Desborough Central site or the               in the emerging AAP.
                                          Braybrooke Road. The need for a new




                                                                                                                        119
primary school could be met by modifying      The Kettering Borough Employment Land
the Strategic Development Area to include     Breakdown report of 16 September 2008
the land to the west of the Harborough Road   provided an assessment of the number of
just past the new Grange roundabout and       jobs available against the working age
encouraging its development for residential   population of the towns within Kettering
and school use.                               Borough. This assessment considered those
                                              employment developments delivered in the
                                              period 2001-2008 and then projected
                                              forward to include population forecasts for
                                              the end of the plan period, 2021 based on
                                              the planned levels of growth including the
                                              Urban Extensions at Kettering, Rothwell and
                                              Desborough. In Desborough as detailed in
                                              the Employment Breakdown Report since
                                              publication of the Preferred Options
                                              Document land to the north of the Grange
                                              and an extension of Rigid Containers has
                                              received detailed planning approval for
                                              15.29 hectares of employment. To date
                                              12.27 hectares of B8 development out of the
                                              total 15.29 hectares has been developed
                                              and is providing jobs within Desborough.
                                              This employment development is therefore
                                              significantly contributing to employment
                                              development and the provision of jobs in
                                              Desborough during this plan period, which
                                              for both the CSS and the Rothwell and
                                              Desborough Urban Extension Area Action
                                              Plan is the period 2001 to 2021. The
                                              remaining extant planning permission at
                                              Magnetic Park, North of the Grange, will
                                              increase the job provision within the town.
                                              This will be supplemented by town centre
                                              regeneration that will enhance the provision
                                              of jobs and services within the town.




                                                                         120
                                                                                       A new junction will be required to serve the
                                                                                       Rothwell Urban Extension off the A6,
                                                                                       connecting through the urban extension to
                                                                                       B576. A further connection to Rushton Road
                                                                                       would cut through a green infrastructure
                                       Rothwell proposals generally balance the
                                                                                       corridor and a wildlife migration route as well
                                       requirements to accommodate more housing
                                                                                       as the open countryside to the detriment of
                                       and employment to compliment the existing
                                                                                       its character and local wildlife. A Public
                                       layout of the town. The one major exception
         Mr Robin                                                                      Realm Strategy for Rothwell is intended to
268504              document   Agree   to this is the lack of an additional E-W road
         Matthews                                                                      improve the public realm and reduce the
                                       link. The current levels of traffic through
                                                                                       amount of on-street car parking in the town
                                       Bridge Street are going to be increased
                                                                                       to prevent traffic 'bottle-necks' and aid the
                                       considerably, resulting in serious congestion
                                                                                       free-flow of traffic through the town centre.
                                       at both ends of the working/ school day
                                                                                       The AAP will also help to achieve the modal
                                                                                       shift as outlined in policy 13 of the CSS
                                                                                       through improving connectivity via walking
                                                                                       and cycling as well as improving public
                                                                                       transport.




                                                                                                                    121
                                            I would like to point out that 700 dwellings in
                                                                                              The development will contribute to
                                            each town equals 1400 and with
                                                                                              improving the existing road network
                                            approximately two cars to each dwelling
                                                                                              including the routes in between settlements.
                                            totals at least 2,800 additional vehicles on
                                                                                              A new access off A6 to serve Rothwell will
                                            the roads in and around Desborough and
                                                                                              provide for the residential and commercial
                                            Rothwell. Has anybody considered how
                                                                                              development as well as making the A6 more
                                            congested the roads will be in-between
                                                                                              accessible for local users. A Public Realm
                                            these two towns, especially on the
                                                                                              Strategy for Rothwell is intended to improve
         Mrs Elaine                         Desborough/Kettering Road where it is
275522                document   Disagree                                                     the public realm and reduce the amount of
         Towning                            already struggling to cope with the volume of
                                                                                              on-street car parking in Rothwell town
                                            cars, lorries and vans that travel each day.
                                                                                              centre to prevent traffic 'bottle-necks' and
                                            Although we have a bypass everyone knows
                                                                                              aid the free-flow of traffic. In accordance
                                            that residents do not go out of their way to
                                                                                              with policy 13 of the CSS development will
                                            use this. Could you please consider and
                                                                                              be designed to encourage a modal shift
                                            comment on what infrastructure plans you
                                                                                              from car usage to other means and to that
                                            have made. To not have any plans in place
                                                                                              end improvements to public transport,
                                            alongside these houses being built would be
                                                                                              footways and cycleways will be sought.
                                            very short-sighted.




                                                                                                                          122
                                                  This representation relates to Rothwell North
                                                  PREFERRED POLICY DIRECTION 9
                                                  Persimmon Homes support Preferred Policy
                                                  Direction 9. The Rothwell North development
                                                  provides for a local centre to the east of the
                                                  B576, opposite the new medical centre. The
                                                  local centre has been designed to provide for
                                                  the needs of the proposed development
                                                  whilst not detracting from the services
                                                  provided within the town centre. In terms of
                                                  composition, the local centre will include a         The Local Planning Authority considers that
                                                  maximum of 600 square metres (sq m) of               the size and level of provision proposed is
                                                  retail floorspace which could provide 6 small        excessive in this location. We are concerned
                                                  (100 sq m) units or, more likely, 2 or 3             about the proposed position of the retail
         Persimmon                                slightly larger units. Although described as         centre and its distance from existing housing
         Homes                                    the retail units, the occupiers of these             (which would be the only source of income
276721   Midlands -   paragraph   9.3.1   Agree   premises may include the following uses: A1          whilst the proposed housing is being built).
         Rothwell                                 Shops (e.g. Convenience Store, hairdresser,          Also, some concern exists over its potential
         North                                    etc); A2 Financial and Professional; A3              impact on the town centre. Further work
                                                  Restaurant and/or Cafe; A5 Hot Food                  needs to be undertaken to ensure the
                                                  Takeaway; B1 Business (e.g. Offices) which           correct level of provision is identified without
                                                  it is anticipated could be provided as first         negatively affecting viability and vitality of
                                                  floor accommodation; and D1 Non-                     the town centre.
                                                  residential institutions (e.g. a crèche). A retail
                                                  study in support of the submitted planning
                                                  application was submitted to the Borough
                                                  Council in June 2007 setting out the type
                                                  and scale of existing retail and associated
                                                  facilities in Rothwell. At the request of the
                                                  planning officer, a revised retail study was
                                                  submitted in August 2008. This considered
                                                  the impact of the Rothwell North local centre
                                                  on Desborough town centre.




                                                                                                                                     123
                                                  This representation relates to Rothwell North
                                                  PREFERRED POLICY DIRECTION 10 The
                                                  master plan submitted with the Rothwell
         Persimmon
                                                  North planning application provides for a
         Homes
                                                  variety of densities within the development
276721   Midlands -   paragraph   9.4.2   Agree                                                   Noted
                                                  area ranging from 20 to 60 dwellings per
         Rothwell
                                                  hectare (dph) whilst providing an average
         North
                                                  net density across the development of 35
                                                  dph, in accordance with Preferred Policy
                                                  Direction 10.




                                                                                                          124
                                                       This representation relates to Rothwell North
                                                       PREFERRED POLICY DIRECTION 11 The
                                                       proposed development at Rothwell North
                                                       provides 700 dwellings; in the order of 350 to
                                                       the west of the B576 and 350 to the east. To
                                                       ensure a balanced mix of age, income,
                                                       household composition and tenure within the
                                                       proposed development, the planning
                                                       application set out the following housing mix:
                                                                                                          Development should have regard to the
                                                       Type of Dwelling Number of Dwellings % of
                                                                                                          Rothwell HMA. Also, the exact split of
                                                       Dwellings 1 bedroom 22 3% 2 bedroom 267
                                                                                                          350/350 across the B576 may not respond
                                                       38% 3 bedroom 213 30% 4 bedroom 178
         Persimmon                                                                                        well to the character of the area. Higher
                                                       25% 5 bedroom 20 3% TOTAL 700 100% It
         Homes                                                                                            densities should be located adjacent to
                                                       is anticipated that nine of these dwellings will
276721   Midlands -   paragraph   9.4.4   No opinion                                                      existing housing and to the centre of the
                                                       be provided as bungalows which would be
         Rothwell                                                                                         development and make reference to existing
                                                       suitable for older people and others with
         North                                                                                            characteristics (including layout, design and
                                                       special needs. Persimmon Homes will
                                                                                                          materials) with lower densities towards open
                                                       continue its discussions with the Borough
                                                                                                          countryside allowing good separation from
                                                       Council Planning and Housing Officers to
                                                                                                          the Rothwell Gullet.
                                                       determine the exact housing mix. It should
                                                       however be noted that the housing mix, set
                                                       out above, was prepared before the current
                                                       change in market conditions. In the current
                                                       market conditions Persimmon Homes may
                                                       have to alter the housing mix in order to
                                                       ensure that the Rothwell North scheme
                                                       reflects current housing needs and
                                                       demands.




                                                                                                                                      125
                                                     This representation relates to Rothwell North
                                                     PREFERRED POLICY DIRECTION 12
                                                     Persimmon Homes has given consideration
                                                     to the requirements of Policy 15 of the
                                                     NNCSS which seeks to meet local housing
                                                     need and ensure that a percentage of all
                                                     new development is genuinely affordable
                                                     and sought in line with the target of 30% in
                                                     Kettering Borough. As part of the
                                                     negotiations on the planning application,
                                                     Persimmon Homes has agreed to provide
                                                     30% of the dwellings as affordable housing
                                                     units, split between social rent and shared
                                                     ownership, subject to financial viability
                                                     considerations including the availability of
                                                     grant. Notwithstanding Persimmon Homes
         Persimmon                                                                                     Housing provision shall be in accordance
                                                     agreement to provide 30% affordable
         Homes                                                                                         with the Rothwell HMA, which supports
                                                     housing, it is pertinent that the Inspector who
276721   Midlands -   paragraph   9.5.3   Disagree                                                     policy 15 of the CSS. Viability testing will
                                                     held the examination into the East
         Rothwell                                                                                      inform the next iteration of the AAP -
                                                     Northamptonshire Rural North, Oundle and
         North                                                                                         Proposed Submission.
                                                     Thrapston AAP has recently advised that he
                                                     is unconvinced that the affordable housing
                                                     policy is supported by an adequately robust
                                                     and credible evidence base; nor that the
                                                     viability of the affordable housing targets
                                                     accord with government guidance as set out
                                                     in PPS3. He continued by explaining that:
                                                     The Blythe Valley Court judgement has
                                                     important implications for all DPDs in its
                                                     interpretation of the guidance in paragraph
                                                     29 of PPS3. The inclusion of words within
                                                     the policy to the effect that viability factors
                                                     will be assessed on an individual site basis is
                                                     not sufficient. It follows that the evidence
                                                     base should demonstrate the extent to which
                                                     the affordable housing target for the plan




                                                                                                                                     126
area and the site-size thresholds and
proportions reflect an assessment of the
likely economic viability of land for housing
within the area taking account of risks to
delivery and the likely availability of finance.
Such information is not evident in the SHMA.
The SHMA on which the Borough Council is
relying in justification for the emerging
affordable housing target in the Rothwell and
Desborough Urban Extensions AAP Position
Statement is the same SHMA that was found
wanting at the Rural North, Oundle and
Thrapston Examination. It therefore follows
that the same conclusions in respect of the
policys unsoundness will be reached. In any
event it is essential that the changing market
and economic conditions are taken into
account when formulating any affordable
housing policy.




                                                   127
                                                       This representation relates to Rothwell North
                                                       PREFERRED POLICY DIRECTION 14
                                                       Persimmon Homes is committed to providing
                                                       high quality design and environmental
                                                       sustainability. The Rothwell North planning
                                                       application was considered by the East
         Persimmon                                     Midlands Design Review panel. A workshop,
         Homes                                         involving Persimmon Homes, SSR Planning,
276721   Midlands -   paragraph   9.6.8   No opinion   LDA Design, ATLAS representatives and            Noted
         Rothwell                                      officers from the Borough Council was also
         North                                         held to discuss the design features of the
                                                       proposed development. As a result of these
                                                       workshops, and subsequent meetings with
                                                       the Planning Officers, Persimmon Homes will
                                                       be amending the master plan and in so
                                                       doing will ensure that high quality design and
                                                       environmental sustainability is secured.




                                                                                                                128
                                                     This representation relates to Rothwell North
                                                     PREFERRED POLICY DIRECTION 15 As
                                                     part of the proposed development, a total of
                                                     21.5 hectares of public open space will be
                                                     provided. This includes: A linear park; A 50
                                                     metre buffer zone to the Rothwell Gullet
                                                     Nature Reserve; Dual use Sustainable
                                                     Urban Drainage Scheme; Two additional
                                                     sport pitches for adult and junior use with
                                                     suitable changing accommodation;
                                                     Allotments; On-site LEAPs and NEAPs;
                                                     Strategic landscaping; Montsaye playing
                                                     field extension; The long term maintenance      The list of contributions sought is for the
                                                     of the open space provision will be secured     purposes of example only and is not explicit.
                                                     through the S106 agreement. The draft S106      The necessary contributions arising from the
                                                     agreement submitted with the planning           development will be outlined in the next
         Persimmon
                                                     application also provides a financial           iteration of the AAP – Proposed Submission.
         Homes
                                                     contribution to improvements to biodiversity    Contributions are likely however, to be
276721   Midlands -   paragraph   9.7.6   Disagree
                                                     and public access in the Ise Valley.            sought for the Desborough Leisure Centre.
         Rothwell
                                                     Persimmon Homes does however have               As outlined in policy direction 1 some
         North
                                                     concerns (set out below) regarding the          facilities will be shared between the two
                                                     additional contributions now being sought       towns. The additional housing at Rothwell
                                                     towards: Rothwell Gullet; Desborough            will put pressure on, as well as support
                                                     Leisure Centre; Refurbishment and               facilities such as the Leisure Centre.
                                                     enhancement of Squires Hill Rothwell Gullet
                                                     Detailed consideration has been given to the
                                                     impact of the development on biodiversity. A
                                                     50 metre buffer zone is being provided
                                                     between the edge of the development and
                                                     the Rothwell Gullet Nature Reserve. It is
                                                     considered that this measure is sufficient
                                                     enough to protect the Rothwell Gullet and
                                                     that there is no justification for seeking
                                                     further contributions. Desborough Leisure
                                                     Centre Persimmon Homes does not accept
                                                     that the development at Rothwell North will




                                                                                                                                 129
provide a need for a contribution towards
Desborough Leisure Centre. The extension
to the Grange Leisure Centre should be
secured through the Desborough Urban
Extension. Persimmon Homes believes that
such a contribution cannot be justified as it
fails to meet the needs arising from the
development. Refurbishment and
enhancement of Squires Hill Persimmon
Homes would like to gain an understanding
of the justification for seeking a contribution
towards the refurbishment and enhancement
of Squires Hill as it is not clear that its need
arises as a direct result of the Rothwell North
development. It should be noted that
Persimmon Homes will not be willing to
contribute to anything which is not directly
related to the proposed development at
Rothwell North or in accordance with
Government guidance. Persimmon Homes is
making substantial contributions towards
open space in accordance with the policy
and questions the justification for the further
contributions being sought.




                                                   130
                                                      This representation relates to Rothwell North
                                                      PREFERRED POLICY DIRECTION 16
                                                      Persimmon Homes notes that the Councils
                                                      pre-commencement work in the form of
                                                      Developer Guidance and the Community
                                                      Strategy has identified a number of key
                                                      community facilities required as a
                                                      consequence of increased growth in the
                                                      towns. Persimmon Homes has reviewed the
                                                      contributions being sought and makes the
                                                      following comments: Wayfinding Scheme for
                                                      new residents Persimmon Homes would like
                                                                                                           The list of contributions contained within the
                                                      to gain a better understanding of the
                                                                                                           Position Statement is intended only to guide
                                                      wayfinding scheme and the benefits
                                                                                                           local contributions, it is not exhaustive and is
                                                      associated with it. Full justification of its need
                                                                                                           a reflection of key costs arising at this time.
                                                      will be required as Persimmon Homes will
         Persimmon                                                                                         The proposed urban extension will put
                                                      not be willing to contribute to anything unless
         Homes                                                                                             pressure on key local facilities including the
                                                      it is directly related to the proposed
276721   Midlands -   paragraph   9.7.14   Disagree                                                        Art and Heritage Centres as well as
                                                      development at Rothwell North. Contribution
         Rothwell                                                                                          Borough wide facilities such as the museum,
                                                      to Rothwell Arts and Heritage Centre
         North                                                                                             art gallery and swimming pool. The
                                                      Persimmon Homes requests details of what
                                                                                                           calculation for contributions will be based
                                                      the contribution towards the Rothwell Arts
                                                                                                           upon the pressure exerted by the proposed
                                                      and Heritage Centre will be used for.
                                                                                                           development and contributions will be
                                                      Justification for its need will also be required.
                                                                                                           required on this basis.
                                                      As stated above, Persimmon Homes will not
                                                      be willing to contribute to anything unless it
                                                      is directly related to the proposed
                                                      development at Rothwell North.
                                                      Contributions to Rothwell Community Centre
                                                      The refurbishment and enhancement of the
                                                      Rothwell Community Centre is required now;
                                                      its need is not the result of the increase in
                                                      population arising from the Rothwell North
                                                      development. Persimmon Homes has
                                                      previously indicated that subject to its
                                                      consideration and approval of detailed plans




                                                                                                                                         131
and costings for the enhancement of the
Community Centre, it would be willing in
principle to make a contribution towards
these costs. However, in so doing it was
stressed that its contribution would be
calculated on the basis of the number of
residents at Rothwell North as a proportion
of the population of the town as a whole.
Contributions to Rothwell Market House
Persimmon Homes objects to a contribution
being sought towards the Rothwell Market
House as it is not considered that the need
to enhance the Market House arises as a
direct result of the Rothwell North
development. The contribution being sought
is therefore contrary to government
guidance. Refurbishment of Market Square
and car park Persimmon Homes omitted
contributions towards the townscape, town
environment, public art, etc from the draft
S106 submitted with the planning application
as it understood that the Rothwell Town
Centre Improvement Plans had been
abandoned and a revised scheme had not
been produced. If, however, proposals for
the Town Centre have now been produced
Persimmon Homes Midlands would be
willing to consider this matter further and
requests that it be provided with the plans
and costings of this refurbishment. Any
contribution would be based on a similar
formula to that for the Community Centre
and described above. Contributions to a
Rothwell Support Officer Persimmon Homes
suspects that the request for this contribution
has arisen from comparisons being made




                                                  132
with the development worker provided at
Mawsley. The Rothwell North development is
very different to Mawsley. Mawsley is an
isolated new settlement which required the
creation of a whole community; the Rothwell
North development has been designed to
integrate with the towns existing community
and will therefore have fewer needs to those
at Mawsley. Any contribution sought for a
support officer at Rothwell should reflect this.
Contributions to a Community Fund It is
understood that a Community Fund would
provide grants to community groups to
support recreational and cultural activities
within the boundaries of Rothwell. As for the
support officer this request fails to recognise
the many community groups which already
exist in Rothwell. It is reasonable to expect
that the new residents would join many of
these and therefore a contribution does not
appear to be justified, nor should it be
assumed that no community groups exist in
Rothwell, as was the case at Mawsley.
Improvements to the public realm within the
urban extensions and the town including
important gateways The Rothwell North
development will provide a high quality
public realm throughout the development, in
particular at the entrance to the development
site off the A6 and the approach to the town
from the north on the B576 where gateway
features to the town will be created.
Persimmon Homes has been working with
the Planning Officers to ensure that these
new gateways enhance the main entrances
to the town. Contributions to Borough Wide




                                                   133
facilities e.g. Museum and Gallery
Persimmon Homes will give consideration to
the provision of contributions towards
Borough wide facilities. However, as stated
previously, full justification of its need as a
direct result of the Rothwell North
development will be required. Provision for a
district base for the Safer Communities
Team Persimmon Homes requires full
justification for the provision of a district base
for the Safer Communities Team within the
site, particularly as it would appear to be
needed to meet the needs of the town as a
whole. Only once the justification is received
will Persimmon Homes be able to give this
matter further consideration. Contribution to
Community Safety e.g. CCTV Persimmon
Homes will give further consideration to
providing a centralised CCTV system.
However, it is not considered necessary or
appropriate to include CCTV provision within
the site. In any event, full justification of its
need as a direct result of the Rothwell North
development will be required.




                                                     134
                                                     This representation relates to Rothwell North
                                                     PREFERRED POLICY DIRECTION 17
                                                     Persimmon Homes original proposals for the
                                                     urban extensions at Rothwell and
                                                     Desborough included the provision of a
                                                     country park between the two towns.
                                                                                                        Green infrastructure contributions are
                                                     However, this proposal relied upon both the
                                                                                                        required for the provision of the local
         Persimmon                                   Rothwell North and Desborough Central
                                                                                                        network. This network is not boundaried like
         Homes                                       sites being brought forward. The Council
                                                                                                        the settlements themselves therefore
276721   Midlands -   paragraph   9.8.5   Disagree   subsequently decided there was no
                                                                                                        contributions will be sought on the basis of
         Rothwell                                    requirement for a country park as part of the
                                                                                                        the impact of the proposal on the overall
         North                                       Rothwell North proposal. Instead Clause
                                                                                                        local network and not just the space
                                                     4.7.1 of the draft S106 agreement submitted
                                                                                                        adjacent to each settlement.
                                                     with the Rothwell North planning application
                                                     provides for improvements towards public
                                                     access and biodiversity in the Ise Valley.
                                                     Persimmon Homes is unwilling to make any
                                                     further contributions particularly to facilities
                                                     for the benefit of Desborough residents.




                                                                                                                                    135
                                                        This representation relates to Rothwell North
                                                        PREFERRED POLICY DIRECTION 18 The
                                                        network of open space in the Rothwell North
                                                        urban extension will provide for the needs of
                                                        the community, as well as creating and
                                                        enhancing biodiversity, through the creation
                                                        of new habitats as well as improving existing
                                                                                                        Noted. This proposed buffer zone may be
         Persimmon                                      ones. Dual functionality SUDs have been
                                                                                                        insufficient in width to adequately protect the
         Homes                                          incorporated into the site (as referred to in
                                                                                                        Rothwell Gullet. The necessary protection
276721   Midlands -   paragraph   9.8.10   No opinion   Preferred Policy Direction 13). A 50 metre
                                                                                                        for the Rothwell Gullet will be outlined in the
         Rothwell                                       landscaped buffer zone between the
                                                                                                        next iteration of the AAP - Proposed
         North                                          development and the Rothwell Gullet Nature
                                                                                                        Submission.
                                                        Reserve has also been provided in order to
                                                        protect this habitat. In developing the
                                                        Rothwell North masterplan great emphasis
                                                        has been paced on the integration of natural
                                                        and man-made systems and the need to
                                                        take a long-term approach to their
                                                        management and development.




                                                                                                                                     136
                                                  This representation relates to Rothwell North
         Persimmon
                                                  PREFERRED POLICY DIRECTION 19 The
         Homes
                                                  masterplan submitted with the Rothwell
276721   Midlands -   paragraph   9.9.1   Agree                                                    Noted
                                                  North planning application provides 2.13
         Rothwell
                                                  hectares of land for additional sports pitches
         North
                                                  to the north of the college.




                                                                                                           137
                                                      This representation relates to Rothwell North
                                                      PREFERRED POLICY DIRECTION 21
                                                      Preferred Policy Direction 21 reflects
                                                      Preferred Option (PO20) of the Rothwell and
                                                      Desborough Urban Extensions Area Action
                                                      Plan Preferred Options Paper, September
                                                      2006. At the time of the Preferred Options      The Northamptonshire Waste Local Plan
                                                      Paper this policy was already out of date as    and the SPD on Development and
         Persimmon                                    the Council had introduced a comprehensive      Implementation Principles give guidance
         Homes                                        kerb-side collection service throughout the     with regards to the requirements for waste
276721   Midlands -   paragraph   9.10.1   Disagree   Borough. It is understood that this service     facilities. The emerging Minerals and Waste
         Rothwell                                     results in three separate containers for        Core Strategy may contain further guidance
         North                                        different types of waste to be recycled which   with regards to this and if adopted will inform
                                                      can be summarised as paper; glass, tins and     the next iteration of this AAP - Proposed
                                                      plastic; garden waste and other compostable     Submission.
                                                      materials. In the circumstances it is unclear
                                                      exactly what facilities for the separation,
                                                      storage and collection of waste the Council
                                                      will require as part of the development, if
                                                      indeed onsite waste management facilities
                                                      are required at all.




                                                                                                                                   138
                                                        This representation relates to Rothwell North
                                                        PREFERRED POLICY DIRECTION 22 The
                                                        masterplan submitted with the Rothwell
                                                        North planning application seeks to address
                                                        all of the design headings listed in Preferred
                                                        Policy Direction 22. Since the submission of
                                                        the planning application Persimmon Homes
         Persimmon                                      has been working with its team of
         Homes                                          consultants, the Planning Officers and
276721   Midlands -   paragraph   9.12.1   No opinion   ATLAS to develop the masterplan. An              Noted
         Rothwell                                       amended masterplan will be submitted to the
         North                                          Council in due course. The planning
                                                        application and masterplan have also been
                                                        considered by the East Midlands Design
                                                        Review Panel. The suggestions and
                                                        comments made at this session will also be
                                                        incorporated into the amended masterplan,
                                                        as set out in the response to Preferred Policy
                                                        Direction 14.




                                                                                                                 139
                                                        This representation relates to Rothwell North
                                                        PREFERRED POLICY DIRECTION 24
                                                        Persimmon Homes understands that the
                                                        Rothwell Town Centre Improvement Plans
                                                        were abandoned and a revised scheme has
                                                        not yet been produced. If however proposals
                                                        for the town centre have now been produced
                                                        Persimmon Homes would be willing to
                                                                                                         Links into Rothwell town centre are
                                                        consider this matter further and requests that
                                                                                                         important and could be achieved through
         Persimmon                                      it be provided with the plans and costings.
                                                                                                         recognisable gateways and/or improved
         Homes                                          Any contribution towards these costs would
                                                                                                         wayfinding. Kettering Borough Council are
276721   Midlands -   paragraph   9.14.4   No opinion   be calculated on the basis of the number of
                                                                                                         producing a Public Realm Strategy for
         Rothwell                                       residents at Rothwell North as a proportion
                                                                                                         Rothwell, the contents of which will be taken
         North                                          of the population of the town as a whole.
                                                                                                         into consideration in the next iteration of this
                                                        Persimmon Homes proposals at Rothwell
                                                                                                         AAP - Proposed Submission.
                                                        North will however provide two new
                                                        gateways into the town. One on the B576
                                                        approaching the town from the north and one
                                                        along the new link road from the A6.
                                                        Persimmon Homes has been working with
                                                        the Planning Officers to ensure that these
                                                        new gateways enhance the main
                                                        entrances/route-ways to the town.




                                                                                                                                       140
                                                        This representation relates to Rothwell North
                                                        PREFERRED POLICY DIRECTION 25
                                                        Persimmon Homes is willing, in principle, to
                                                        enter into a planning obligation with the
         Persimmon
                                                        Borough Council and others, as required, to
         Homes
                                                        secure the infrastructure and other facilities,
276721   Midlands -   paragraph   10.1.2   No opinion                                                     Noted
                                                        the need for which arises from the
         Rothwell
                                                        development, and will negotiate accordingly.
         North
                                                        A draft S106 agreement was submitted with
                                                        the planning application detailing those
                                                        contributions deemed necessary and which
                                                        is the subject of ongoing negotiations.




                                                                                                                  141
                                                       This representation relates to Rothwell North
                                                       PREFERRED POLICY DIRECTION 13 The
                                                       masterplan identifies the locations of the
                                                       balancing ponds, required as part of the
                                                       Sustainable Urban Drainage System
                                                       (SUDS). These are all located within areas of
                                                       public open space in order that they have the
                                                       dual functionality sought. The long term
         Persimmon                                     maintenance of the SUDs will be secured
                                                                                                          Noted, further engagement with the
         Homes                                         through the S106 agreement. Anglian Water
                                                                                                          Environment Agency and Anglian Water will
276721   Midlands -   paragraph   9.6.3   No opinion   has confirmed that based on average build
                                                                                                          inform the next iteration of the AAP -
         Rothwell                                      rates, Broadholme Sewage Treatment Works
                                                                                                          Proposed Submission.
         North                                         has sufficient capacity to accommodate the
                                                       DCLG housing and growth targets up to
                                                       2013, when planned upgrades will be
                                                       necessary at the works to fulfil its obligations
                                                       up to 2016 and beyond. A revised addendum
                                                       to the Flood Risk Assessment (FRA) has
                                                       been submitted to the Environment Agency.
                                                       It is understood that the Environment Agency
                                                       has verbally agreed the FRA addendum.




                                                                                                                                    142
                                           Town Centre Regeneration in Desborough
                                           First. I agree with the comment made that
                                           the town centre redevelopment should take
                                           priority in any plan. The development of the
                                           Lawrence's Factory Site should be
                                           undertaken - in it's 'original' form, not the
                                           current 'rumoured' plan to sell out to Tesco
                                           and flatten the factory - to bring some life
                                           back into the town, provide for small
                                                                                             Policy direction 5 aims to improve
                                           enterprises to get started, some housing and
                                                                                             connectivity and will ensure better linkages
                                           so forth. There are many reasons for this: -
                                                                                             over the railway line. As outlined in the
                                           the town would retain some of it’s identify
                                                                                             Sustainability Appraisal the proposal is
                                           and links with the past - I remember the
                                                                                             actually no further from the town centre than
                                           disaster of the demolition of many beautiful
                                                                                             other options considered and parts of the
                                           ironstone buildings in the centre for better
                                                                                             extension are actually closer to the town
         Mrs Paula              Strongly   traffic flow. What happened then was that
277655               document                                                                centre than Desborough West due to the
         Holmes                 disagree   Desborough lost a lot of its identity and we
                                                                                             separation which would exist taking into
                                           ended up with a row of brick built shops with
                                                                                             consideration the Pocket Park. The
                                           no design and no soul. - there would be a
                                                                                             proposed new junction onto the A6 from the
                                           town centre again, not a split community -
                                                                                             Desborough West development is actually
                                           with those able to get to the edge of town
                                                                                             more likely to lead to leakage from the town
                                           easily doing so and the rest 'putting up' with
                                                                                             due to the ease of access by car onto the
                                           what's left in the town. I also think if you
                                                                                             A6.
                                           travelled to the edge of the town, you would
                                           just keep on going to Harborough anyway. -
                                           we would be preserving the past to create a
                                           future for Desborough - for there to be a
                                           sense of individuality about the town and
                                           hopefully some pride in it. Have you seen
                                           how terrible the site looks? - the
                                           regeneration of that site would 'support' other
                                           redevelopment plans, but not vice versa.




                                                                                                                         143
                                          I have read the documentation and attended
                                          the presentation at Desborough on March
                                          5th 2009. My wife and I are strongly in
                                          disagreement with the proposals for 700
                                          additional dwellings at the Grange. Having
                                          lived here and run local businesses in the
                                          town centre for 40 years we feel qualified to
                                          comment on Desborough town centre and
                                          future business and employment, as well as
                                          more general issues around living and using
                                          services in the town. We have lived through
                                          the decimation of the old Desborough with
                                          the realignment of the A6 and the
                                          subsequent bypass. The key to the town
                                          centre is ease of access for residents both
                                          on foot and by car, and adequate parking
                                          provision. We believe, as did the
                                                                                           New development will be dependent on the
         Mr Derek              Strongly   overwhelming majority of Desborians who
277664              document                                                               delivery of improved links and better
         Veevers               disagree   were consulted on different options in 2006,
                                                                                           connectivity to Desborough town centre
                                          that the Desborough Central area to the east
                                          of the town would be a much more
                                          appropriate location for future development
                                          because it would be more integral to the
                                          town. The proposed development at Grange
                                          would be a bolt on, disconnected to the rest
                                          of the town, and perhaps becoming as much
                                          like a Market Harborough suburb as a part of
                                          Desborough itself. The disconnection is
                                          because of the lack of easy access,
                                          particularly on foot, because of the railway
                                          line. The location of the town centre, and of
                                          key services such as the schools, the
                                          Doctors, library and the recreation areas will
                                          be much more accessible to new
                                          development at the Desborough central site,
                                          rather than the Grange site, which simply




                                                                                                                     144
does not make sense. We also oppose the
new plans to remove any future employment
development in the town. Although some of
the Desborough factories have been in
decline, particularly the shoe industry, we
must not just give up on providing local
employment, and let Desborough become a
dormitory town. We need to replace the jobs
that have been lost recently and develop
new employment opportunities. Many people
want to work locally and this is good for the
town, including the use and viability of the
town centre shops and local services.
Consultation with local residents must be
real and it seems at present that the majority
of views expressed in favour of Desborough
Central site are not being taken fully into
account.




                                                 145
                                            Comments on Urban Extension Area Action
                                            Plan I wish to comment on the Rothwell and
                                            Desborough Urban Extension Area Action
                                            Plan. I am concerned that the preference
                                            policy direction for Desborough is to locate
                                            residential development to the North as
                                            indicated in Plan 2. I am convinced that this
                                            location would have the tendency to create      Development of smaller sites around
                                            what would be perceived as two separate         Desborough are unlikely to achieve
                                            communities divided by the railway line and     comprehensive development which supports
                                            the result of this would be adverse to any      the character of the area and makes
                                            hope of regeneration of the existing town       provision for the variety of uses necessary
                                            centre. The plan puts considerable faith in     to sustain an increasing population. Policy
                                            better connectivity to the town centre          direction 5 aims to improve connectivity and
                                            including footpaths and bridges over the        will ensure better linkages over the railway
                                            railway, improved footpaths and cycleways       line. As outlined in the Sustainability
         Mr Michael                         plus public transport connections. I do not     Appraisal the proposal is actually no further
277695                document   Disagree
         Payne                              believe that this would avert the tendency      from the town centre than other options and
                                            towards the creation of a North and South       parts of the extension are closer to the town
                                            Desborough with the likelihood of both being    centre than Desborough West due to the
                                            served by inadequate commercial and retail      separation which would exist taking into
                                            facilities. I have still not heard convincing   consideration the Pocket Park. The
                                            arguments against developments to the           proposed new junction onto the A6 from the
                                            West of the town. Plans suggested by            Desborough West development is actually
                                            Persimmon seemed to me to be a promising        more likely to lead to leakage from the town
                                            start for the developing of a more natural      due to the ease of access by car onto the
                                            residential development. Ideally, for the       A6.
                                            regeneration of the town centre, smaller
                                            development could be allowed to take place
                                            to the North, South, West and East and
                                            Central Desborough but I assume this would
                                            not lead to the investment in the town that
                                            you hoped you could extract from
                                            developers. Was this ever considered?




                                                                                                                        146
                                             I moved to Desborough 3 years ago,                 This Area Action Plan is to plan primarily for
                                             purchasing a house on the Grange as my             urban extensions to Rothwell and
                                             previous experience of living in a                 Desborough. It is recognised that
                                             redevelopment area (the Gorbals                    improvements to Desborough town centre
                                             redevelopment in Glasgow) was such a               are necessary to support the proposed
                                             positive one. In the 3 years since my              population and a contribution will be
                                             husband and I have lived here we have seen         required to support this regeneration.
                                             none of the supposed redevelopment come            Improvements to the public realm may act
                                             to fruition, instead we got a warehouse we         as a catalyst for further regeneration.
                                             were not expecting. The town centre is still a     However, a more comprehensive strategy
                                             shadow of what it could be, the derelict           for the regeneration of Desborough Town
                                             Lawrence Factory site looks awful, there's a       Centre will be developed and publically
                                             huge plot of wasteland that should have a          consulted upon during the adoption of the
                                             Leisure Centre on it and the people who built      Kettering Site Specific Proposals Local
                                             the Great Bear distribution centre have not        Development Document.
                                             started to build any of the facilities that they
                                             promised other than the industrial units. It       Policy direction 5 aims to improve
         Mrs Anne-                           seems that the council is only willing to          connectivity and ensure better linkages over
277988                 document   Disagree
         Marie Lofts                         advance projects that bring in revenue such        the railway line and to the town centre. The
                                             a private houses and distribution centres.         Local Planning Authority have been working
                                             While I agree that a further 700 houses next       with developers of the current Grange
                                             to the Grange are likely to cause a divide         development to provide the best possible
                                             between north and south I am more                  leisure facility in this location. A planning
                                             concerned that this proposal again is all          application is expected in June and
                                             about revenue generation and only pays lip         construction of Phase 1 of this facility should
                                             service to what many people see to be the          follow shortly after determination. Phase 2 is
                                             key issue - the redevelopment of the town          to be brought forward following
                                             centre. If the proposal does go ahead I'm          commencement of construction of this
                                             curious as to how the council will route traffic   planned urban extension. The existing
                                             to the new development as their current            Desborough Leisure Centre has squash
                                             choice is past the derelict factory site or the    courts which will not be brought forward till
                                             Rigid and Great Bear distribution centres -        Phase 2 of the new leisure centre. The
                                             neither of which exactly sell the town and         Squash Club have been informed but the
                                             encourage people from outside of                   intention is to provide regional competition
                                             Desborough to buy a new home. I would like         squash courts with glass backs which are
                                             to see some firm commitments and                   much improved from the existing in Phase 2.




                                                                                                                             147
timescales around the redevelopment of the    Facilities such as a pub and crèche are
town centre including the factory site, the   market led.
new Leisure centre and the amenities that
are supposed to be built next to Great Bear
(I believe it was supposed to be a Nursery
and a pub) before we plan for 700 more
houses.




                                                                          148
                                           I believe it to be absolutely imperative that
                                           the Desborough town centre regeneration is
                                           progressed before any further development
                                           on the outskirts of the town. The current
                                           infrastructure is not sufficient to support
                                           continued expansion by the building of
                                           further dwellings particularly given the
                                           current state of the economy both local and     This Area Action Plan is to plan primarily for
                                           global. The preponderance of boarded-up         urban extensions to Rothwell and
                                           buildings is unpleasant and demoralizing for    Desborough. It is recognised that
                                           residents who would wish to take pride in       improvements are necessary in Desborough
                                           their town. Desborough has the makings of a     town centre to support the proposed
                                           lovely community but is let down by the         population and a contribution will be
                                           tattiness of Station Road and Harborough        required to support the regeneration of the
                                           Road from Gold Street/"The Oak" corner up       town. Improvements to the public realm may
                                           towards The Grange roundabout and the           act as a catalyst for further regeneration.
                                           light industrial area. The Section 106 monies   However, a more comprehensive strategy
         Mrs Linda              Strongly   provided by all the Developers to the           for the regeneration of Desborough Town
278049               document
         Sherer                 disagree   County/Borough/Town Councils MUST be            Centre will be developed and publically
                                           deployed for the benefit of the                 consulted upon during the adoption of the
                                           residents/council tax payers of Desborough.     Kettering Site Specific Proposals Local
                                           Has this happened to any degree since 2005      Development Document.
                                           or prior? What has happened to these funds
                                           in the meantime? The creation of 700 new        The Local Planning Authority is aware of the
                                           houses - when many newly-built properties       current economic climate and that there has
                                           are standing empty/unsold (and not              been a reduction in the sale of houses.
                                           generating council tax payments) - would be     However, this plan is intended to guide the
                                           a costly and futile exercise in the current     delivery of housing throughout the plan
                                           economic climate. The existing facilities       period to 2021.
                                           should be strengthened and consolidated;
                                           the built environment of the town and its
                                           centre should be improved to attract people
                                           to live and work in Desborough; the exiting
                                           businesses/shops/outlets should be
                                           supported to enable growth and stability. A
                                           One Stop Shop for all three Councils should




                                                                                                                        149
be provided in Desborough, for example at
the excellent though small library, so
residents will use their own town for their
queries about Northamptonshire County
Council, Kettering Borough Council,
Desborough Town Council matters, instead
of travelling further afield and taking their
business with them to the larger towns.
Concentrate on filling the existing
complement of houses within Desborough by
the expansion of shared-ownership schemes
perhaps supported by Council Funds (the old
S.106 agreements or current similar deals),
and support businesses in the town by the
reduction of Business Rates (Kettering
Borough Council). Get all three Councils
working together on a scheme.




                                                150
                                                               On behalf of ProLogis Developments               Preferred policy direction 4 outlines the
                                                               Limited, we have pleasure in submitting          necessary allocations for a sustainable
                                                               comments on the Rothwell and Desborough          urban extensions at Desborough in
                                                               Urban Extension Area Action Plan - Position      accordance with the requirements and
                                                               Statement consultation. ProLogis                 allocations outlined in the Core Spatial
                                                               Developments Limited objects to Preferred        Strategy. The AAP encourages better
                                                               Policy Direction 4 as this site is not           connectivity to the town centre. Land to the
                                                               considered to represent a desirable planning     south of Desborough was not proposed as a
                                                               objective in terms of the environment and        potential site for an urban extension during
                                                               long term sustainability of the town. The        the call for sites in 2008. Therefore, there is
                                                               preferred option at Desborough North does        potential concern over its deliverability.
                                                               not integrate well into the town centre and is   However, further development to the south
                                                               poorly related to the existing urban area, and   of Desborough and to the north of Rothwell
                                                               it is therefore considered that the              would have a negative impact on the
                                                               development of this land as an urban             Rothwell Gullet, green infrastructure and
                                                               extension would conflict with the overall        biodiversity. Also, visually it could give the
                    Planner
                                                               objectives of the Rothwell and Desborough        impression of linking both towns together,
                    Nathaniel
         Ms Katie                                              Urban Extension Area Action Plan.                negatively impacting the character and
161712              Lichfield   paragraph   9.2.7   Disagree
         Webb                                                  Paragraph 9.2.7 of the Position Statement        individual identity of the towns to their
                    and
                                                               states that well planned and designed            detriment.
                    Partners
                                                               development within Desborough, and close
                                                               to the town centre, would strengthen town        The SHLAA only looks at housing and its
                                                               centre regeneration initiatives. ProLogis        deliverability, not any wider impacts of
                                                               Developments Limited agrees with this            provision nor other uses. The Sustainability
                                                               statement and urges that both employment         Appraisal and Urban Extension
                                                               and housing opportunities are provided on        Methodology look at all the social, economic
                                                               sites with good access to Desborough town        and environmental impacts of any proposed
                                                               centre. ProLogis Developments Limited            site and is the most appropriate means of
                                                               considers that land to the south of              assessing sites and site selection. Also, the
                                                               Desborough at Pioneer Avenue/Rothwell            SHLAA is a technical study of housing
                                                               Road would provide a development which           potential, working on the best available
                                                               would better relate to the existing urban area   information at a point in time; this means it is
                                                               than the preferred option at Desborough          not necessarily fully inclusive. The SHLAA
                                                               North. The development of this site would        only provides a snap-shot of sites across
                                                               allow natural expansion to take place within     North Northamptonshire. On receipt of
                                                               the A6 bypass, which offers a natural and        more detailed information through the




                                                                                                                                              151
well-defined boundary to the southern edge       submissions made by developers and
of the urban area. No such boundary exists       collection of detail contained within the
at Deborough North, and if additional land       Urban Extension Methodology and
was required to be identified in order to meet   Sustainability Appraisal the site to the north
housing supply targets, ProLogis                 of the Grange would actually integrated
Developments Limited is concerned that the       better with the existing town, be in a less
open fields to the north of the site would       prominent position, have better access,
come under pressure for development,             serve to complete the existing development
resulting in the loss of valuable open green     at the Grange and provide necessary
space and further development which would        services to the north of the town. It is
represent urban sprawl in an unsuitable          considered that linkages and connectively to
location which is distant from the town          the town can be improved to allow easier
centre. Furthermore, it is significant to note   access into the town centre through the
that North Northamptonshire's Strategic          provision of a railway bridge and improve
Housing Land Availability Assessment             cycleways and footpaths along existing
identifies land at Desborough North (The         routes as well as improvements to the town
Grange) as a Category 3 site which achieves      centre to make it more appealing for visitors.
low overall scores and performs least well       The SHLAA forms part of the LDF evidence
against the assessment criteria. Land to the     base, along with a range of other technical
south of Pioneer Avenue and west of              studies. It does not in any way prejudice
Rothwell Road, is classified as a Category 2     decisions to be taken by the Joint Planning
site, which performs moderately well against     Committee or by individual district/borough
the assessment criteria and appears to be        planning authorities, in relation to preferred
achievable/deliverable. We trust that the        directions of growth, site identification in
above comments will be fully taken into          Development Plan Documents (DPDs) or
account in your consideration of the Rothwell    the determination of planning applications.
and Desborough Urban Extension Area
Action Plan - Position Statement
consultation, specifically, that ProLogis
Developments Limited considers that
Preferred Policy Direction 4, which directs
housing expansion to the north of
Desborough, should be reviewed, and that
housing growth should be directed to
locations which are in line with both the
objectives of the document, and the scoring




                                                                              152
of sites in the SHLAA, such as land south of
Pioneer Avenue and west of Rothwell Road.
We would be obliged if we could be kept fully
informed of the process of the Rothwell and
Desborough Urban Extension Area Action
Plan - Position Statement, including the
summary of the responses received.




                                                153
                                                            The Theatres Trust is the national advisory
                                                            public body for theatres and a statutory
                                                            consultee on planning applications affecting
                                                            land on which there is a theatre. This applies
                                                            to all theatre buildings, old and new, in
                                                            current use, in other uses, or disused.
                                                            Established by The Theatres Trust Act 1976
                                                            to promote the better protection of theatres,
                                                            our main objective is to safeguard theatre
                                                            use, or the potential for such use but we also
                                                            provide expert advice on design,
                                                            conservation, property and planning matters
                                                            to theatre operators, local authorities and
                   Planning                                 official bodies. Due to the specific nature of
                   Assistant                                the Trusts remit we are concerned with the
         Ms Rose
163104             The         paragraph   9.7.11   Agree   protection and promotion of theatres and         Noted
         Freeman
                   Theatres                                 having perused the document we find this
                   Trust                                    consultation is not directly relevant to the
                                                            Trusts work. However, we support Preferred
                                                            Policy Direction 16 as it includes a
                                                            requirement for general infrastructure to
                                                            provide cultural facilities in the Borough.
                                                            Although it is unlikely Kettering will need
                                                            another theatre, new developments such as
                                                            mixed use areas and urban extensions,
                                                            should include plans for local multi-purpose
                                                            community facilities for cultural and leisure
                                                            activities to ensure the population have the
                                                            capacity to reap the health and social
                                                            benefits which accrue from participation in
                                                            regular cultural and leisure pursuits.




                                                                                                                     154
                    Regional
                    Planner,
                    East
         Miss Ann                                               English Heritage has no comments to make
163411              Midlands   document            No opinion                                                  Noted
         Plackett                                               at this stage.
                    Region
                    English
                    Heritage




                                                                                                               Noted, job numbers have been converted
                                                                                                               into land area. However, in accordance with
                                                                Rothwell Town Council is disappointed that     the Core Spatial Strategy it is appropriate to
                                                                the amount of employment land has been         quote number of jobs created and this is
                                                                reduced from eleven hectares and we would      contained in the background employment
                    Clerk                                       like an assurance that four hectares will be   papers which informed the Position
         Mrs
                    Rothwell                                    sufficient to provide enough jobs for          Statement. The land area proposed is of a
163971   Carolyn               paragraph   4.0.9   No opinion
                    Town                                        Rothwell, although we are pleased that only    size reasonable to accommodate the
         Mackay
                    Council                                     B1 and B2 development will be permitted,       required number of jobs (as outlined in the
                                                                We would prefer this paragraph to refer to     CSS). In Rothwell an over-allocation of
                                                                the projected number of jobs to be provided,   employment could, either result in a large
                                                                rather than just land area.                    area of allocated employment land standing
                                                                                                               empty or detract from the focus of
                                                                                                               development on the urban core of Kettering.




                                                                                                                                            155
                                                               We are not satisfied with the third point that
                                                               facilities and services could be shared
                                                               between the two towns when it is not               It is not intended that the AAP will make
                                                               feasible to duplicate provision. Rothwell has      provision for all types of facilities in both
                   Clerk                                       already lost its Medical Centre to the edge of     urban extensions. The sharing of services
         Mrs
                   Rothwell                                    the town, and our dental surgery has closed        may be required for those which would not
163971   Carolyn              paragraph   6.5.2   Disagree
                   Town                                        and the dentist has moved to Desborough. In        be economically viable to have in both
         Mackay
                   Council                                     view of the fact that these facilities have        towns i.e. a leisure centre. Improved
                                                               been moved, we would like this clause              connectivity between the towns and to
                                                               amended to ensure it does not provide the          facilities will be a priority.
                                                               basis for a further reduction in services in our
                                                               town.




                                                               The Rothwell Gullet to the north of the town,
                   Clerk                                       and the one off Shotwell Mill Lane (footpath       Noted, the next iteration of the AAP -
         Mrs
                   Rothwell                                    UH26) are much valued and there should be          Proposed Submission will address the
163971   Carolyn              paragraph   6.5.4   No opinion
                   Town                                        a buffer zone of at least 100 metres between       necessary separation between the Rothwell
         Mackay
                   Council                                     these biodiversity areas and any                   Gullet and the proposed urban extension.
                                                               development.




                                                                                                                                               156
                                                                                                              Noted, section 9.6.5 Sustainable Design,
                                                                                                              Energy Efficiency and Climate Change,
                   Clerk
         Mrs                                                                                                  relates to the use of renewables in new
                   Rothwell                                    All renewable sources of power should be
163971   Carolyn              paragraph   6.5.6   No opinion                                                  development and the Kettering Sustainable
                   Town                                        considered for this development.
         Mackay                                                                                               Design SPD further re-enforces sustainable
                   Council
                                                                                                              design principles outlined in policy 14 of the
                                                                                                              CSS.




                                                               The Town Council welcomes this statement,
                   Clerk
         Mrs                                                   particularly point 2 but this link should be   Noted, the phased delivery of the proposed
                   Rothwell
163971   Carolyn              paragraph   9.1.4   Agree        provided at an early stage in the              A6 access will be outlined in the next
                   Town
         Mackay                                                development. Points 5 and 6 must be            iteration of the AAP - Proposed Submission.
                   Council
                                                               safeguarded as being essential.




                                                                                                                                           157
                                                                                                                Any retail development within the proposed
                                                                                                                extension should only be minimal to serve
                                                               Rothwell Town Council would like the policy
                                                                                                                the day to day needs of the proposed
                                                               for Rothwell to be as specified in paragraph
                                                                                                                community and not compete with the vitality
                                                               9.3.3, currently listed as one of the other
                                                                                                                and viability of the town centre as outlined in
                                                               options considered, that there will not be any
                                                                                                                PPS6 and policy 3 of the Core Spatial
                                                               retail development within the urban
                   Clerk                                                                                        Strategy. A small number of retail uses
         Mrs                                                   extension. If this policy is not amended, a
                   Rothwell                                                                                     serving day to day needs will ensure
163971   Carolyn              paragraph   9.3.3   No opinion   retail area away from the town centre would
                   Town                                                                                         sustainable development through reducing
         Mackay                                                undermine the fourth point on page 15 to
                   Council                                                                                      the need to travel. The number, size and
                                                               integrate the existing residential areas with
                                                                                                                use of units needs to be carefully
                                                               the urban extensions, and also the second
                                                                                                                considered and located adjacent to existing
                                                               point in paragraph 6.5.6 to encourage
                                                                                                                residential dwellings to ensure viability
                                                               investment in sites and buildings in the town
                                                                                                                during construction. This will be further
                                                               centre, which we would prefer.
                                                                                                                considered in the development of the next
                                                                                                                iteration of the AAP - Proposed Submission.




                                                                                                                                             158
                                                                                                            It will be important to integrate affordable
                   Clerk                                                                                    housing across the development. It should
         Mrs                                                   The Town Council supports 30% for
                   Rothwell                                                                                 be indistinguishable from other residential
163971   Carolyn              paragraph   9.5.3   Agree        affordable housing and that this should be
                   Town                                                                                     development. This will be outlined in the
         Mackay                                                spread throughout the development
                   Council                                                                                  next iteration of the AAP - Proposed
                                                                                                            Submission.




                                                               The sewerage network, capacity and
                                                               treatment works will need to be improved
                                                                                                            The AAP relates to the need associated with
                                                               before the development is started, as the
                                                                                                            the development and can not be used as a
                                                               sewerage system is already overloaded in
                                                                                                            tool to provide for existing deficiencies.
                   Clerk                                       various parts of the town. A policy should
         Mrs                                                                                                However, the urban extension can act as a
                   Rothwell                                    therefore be included in the Position
163971   Carolyn              paragraph   9.6.3   No opinion                                                catalyst for the delivery of a new/upgraded
                   Town                                        Statement that Rothwell needs a new,
         Mackay                                                                                             sewage system. The AAP will contain
                   Council                                     modem sewerage system which can cope
                                                                                                            policies which are specifically designed to
                                                               with the existing need and the projected
                                                                                                            deliver the necessary utilities for the urban
                                                               growth, and which would obviate the need
                                                                                                            extension.
                                                               for any sewage to be stored in the area
                                                               before onward transmission.




                                                                                                                                         159
                                                                                                                     The Rothwell Public Realm Strategy will
                                                                   The following item should be added to the         identify issues and potential improvements
                      Clerk
         Mrs                                                       list of key community facilities for Rothwel1:-   for the town centre. It is recognised that
                      Rothwell
163971   Carolyn                 paragraph   9.7.13   No opinion   Refurbishment of the footways in the High         some public realm improvements are
                      Town
         Mackay                                                    Street, Bridge Street and Market Hill in          required to attract users from the urban
                      Council
                                                                   keeping with the historic buildings.              extension as well linking the proposal to the
                                                                                                                     existing.




                                                                   An additional paragraph should be added
                      Clerk                                        that the Nursery School at Rothwell is not
         Mrs
                      Rothwell                                     large enough for the all children wanting to      Noted, additional nursery provision may be
163971   Carolyn                 paragraph   9.9.1    No opinion
                      Town                                         attend, so provision will be made to extend       required.
         Mackay
                      Council                                      this to accommodate the capacity required
                                                                   as a result of the identified growth.




                                                                   Rothwell Town Council supports the policy
                      Clerk
         Mrs                                                       for phasing delivery and is confident this will
                      Rothwell
163971   Carolyn                 paragraph   10.3.1   Agree        enforce the implementation of infrastructure      Noted
                      Town
         Mackay                                                    led development in accordance with national
                      Council
                                                                   policy.



                                                                                                                     Noted, the proposed directions for growth
                                                                   I feel sad that so much countryside is going
164206   Pearl Lowe              paragraph   7.0.1    Disagree                                                       have been promoted with as minimal green
                                                                   to be taken over by this building plans.
                                                                                                                     land take as possible.




                                                                                                                                                  160
                                                   Firstly I think the regeneration of the Town
                                                   Centre is vitally important as at the moment
                                                   for shopping we have the Co-op and the Co-
                                                   op and again the Co-op rather a big
                                                   monopoly of the town. I have been told by
                                                   long standing Desborough people that the
                                                   Co-op owns a lot of the property and land
                                                   around here and have a special covenant or
                                                   something similar that does not allow the
                                                   Council to take over any of their assets. I
                                                   hope this is not true, although by the look of
                                                                                                      This AAP seeks to improve connectivity
                                                   the town it is as everywhere you go it's Coop
                                                                                                      between the urban extension and
                                                   and I do feel that the Council would have by
                                                                                                      Desborough town centre by means other
                                                   this time done some extensive alteration to
                                                                                                      than the private car and to encourage a
                                                   the town perhaps bringing in a proper town
                                                                                                      modal shift in accordance with policy 13 of
                                                   car park the streets around and about the
                                                                                                      the CSS. However, contributions from the
                                                   town are very hazardous as there is no place
                                                                                                      urban extension will be expected for
                                                   to park so each side of the road has parking
164206   Pearl Lowe   paragraph   9.13.1   Agree                                                      improvements to the public realm within the
                                                   on it which make it dangerous as lady drivers
                                                                                                      town centre to link it to the extension and
                                                   seem to think that whatever, it is there turn to
                                                                                                      increase its attractiveness and viability to
                                                   go through and they do - Fast! and perhaps
                                                                                                      the proposed population (as well as existing
                                                   with a car park some of this street parking
                                                                                                      residents). The Site Specific Proposals LDD
                                                   could be resolved. My husband hates driving
                                                                                                      will look at the regeneration of individual
                                                   around this place and tries to go to Market
                                                                                                      sites within the town centre and increasing
                                                   Harborough or Kettering where facilities are
                                                                                                      the retail offer.
                                                   so much better. The other things I am in
                                                   favour of is footpaths and cycle ways and
                                                   improved public transport this is very good
                                                   indeed. I like to walk a lot with my husband
                                                   but find it very hard to find anywhere nice to
                                                   walk around Desborough as the hedgerows
                                                   are not looked after the ditches mostly are
                                                   full of rubbish not all, and it seems that we
                                                   are always put on the back burner and
                                                   forgotten so it is about time something nice
                                                   came along for us. I know you do have a




                                                                                                                                  161
problem with the youths in the town as they
don't seem to want anything nice or to look
nice they have to break it, its sad world we
live in now! I do not blame the Government
for the today's Youth's behaviour it is the
Parents and they should be punished when
their children, which they have not brought
up properly, do something bad.




                                               162
                                                       The A14 bypassing Kettering is one of the
                                                       most congested sections of the A14 It has
                                                       closely spaced junctions with other major
                                                       road corridors such as the A43 and A6 Much
                                                       of the congestion on the A14 is caused by
                                                       traffic that has an origin and destination in
                                                       the Kettering area A study of the A14
                                                       Corridor was carried out during 2008 which
                                                       looked at a number of options to facilitate
                                                       and support the significant growth proposed
                                                       for the area It showed that the introduction of
                                                       ramp metering on a number of junctions and
                                                       widening of the section between Junction 7
                                                       and 9 would have the greatest benefits. In
                                                       January 2009 the Government announced
                                                       that it was giving high priority to schemes
                    Planning                           which facilitate housing growth, helping to
         Mrs Lisa   Manager                            support the Government's target to deliver
165133                         document   No opinion                                                     Noted
         Maric      Highways                           three million new homes by 2020
                    Agency                             Consequently the proposed widening of the
                                                       A14 between junctions 7 & 9 is programmed
                                                       for construction starting in 201 1112 I am
                                                       pleased to confirm that funding for the ramp
                                                       metering scheme from the Community
                                                       Infrastructure Funding (CIF) was announced
                                                       on 27 March The ramp metering can be
                                                       done relatively easily and it is anticipated
                                                       that the scheme could be delivered by March
                                                       2011 ,, The Highways Agency will continue
                                                       to review the performance of the A14
                                                       following the delivery of these schemes, to
                                                       ensure that the safe and efficient operation
                                                       of the network is maintained in the context of
                                                       the growth agenda within the borough and
                                                       site specific developments coming forward
                                                       for the Rothwell and Desborough area The




                                                                                                                 163
implications of the potential location for
growth within the borough should be
considered within this context




                                             164
                                                           The Agency supports in principle, the
                                                           Preferred Policy Direction (1) in seeking to
                                                           ensure the towns of Rothwell and
                                                           Desborough benefit from greater self-
                    Planning
                                                           containment and improved connectivity It
         Mrs Lisa   Manager
165133                         paragraph   7.0.1   Agree   provides the opportunity for local residents to   Noted
         Maric      Highways
                                                           seek required employment, retail and other
                    Agency
                                                           services locally thereby reducing the need to
                                                           travel and potential stress on the strategic
                                                           road network, particularly the A14, as has
                                                           been previously highlighted.




                                                                                                                     165
                                                              Location of Extensions It is not possible for
                                                              the Agency to endorse the actual site
                                                              allocations for the proposed extensions in
                                                              either Rothwell or Desborough on the basis
                                                              of the information contained within the
                                                              Position Statement (Preferred Policy
                                                              Direction 3 & 4). A detailed evaluation of the
                                                              potential impacts of the sites allocated in
                                                              terms of trip generation, traffic movements,
                                                              the ability for each site to reduce the need to
                                                              travel and maximise the use of public
                                                              transport services, and encourage walking
                                                              and cycling is required before the Agency
                                                                                                                Submissions from developers and
                                                              can determine the implications for the A14
                                                                                                                landowners did include a Transport
                                                              The provision of a transport evidence base
                                                                                                                Assessment. Further assessment would be
                                                              drawing out these findings is required to
                                                                                                                required on submission of a planning
                    Planning                                  support the Action Plan to allow the Agency
                                                                                                                application to fully determine impact of the
         Mrs Lisa   Manager                                   to understand the potential cumulative
165133                         paragraph   8.0.1   Disagree                                                     proposal on the highways and identify any
         Maric      Highways                                  transport impact of development sites, the
                                                                                                                necessary highway improvements or
                    Agency                                    ability of proposed measures to mitigate
                                                                                                                mitigation measures. The Local Planning
                                                              these and how and when they will be
                                                                                                                Authority continue to encourage joint
                                                              delivered. The Agency would be pleased to
                                                                                                                working in responding to any potential
                                                              work alongside the authority, and the County
                                                                                                                issues.
                                                              Council as the local highway authority. At
                                                              this stage, it is unclear as to whether
                                                              additional stress on the A14 will be
                                                              minimised, particularly impacts on the
                                                              junction of the A14 with the A6 In principle,
                                                              the Agency would support the designation of
                                                              sites for development which reduce the need
                                                              to travel, maximise the use of public
                                                              transport, walking, cycling, and reduce the
                                                              reliance on the private car; and where
                                                              mitigation is required, a supporting
                                                              programme of infrastructure works needs to
                                                              be clearly identified along with funding




                                                                                                                                            166
sources, timescales and responsibilities for
delivery.




                                               167
                                                           Accessibility: The Agency fully supports the
                                                           proposals in Preferred Policy direction (5) to
                                                           improve connections and sustainable
                    Planning                               accessibility in, and between the two towns It
                                                                                                            Noted, reference will be made to improving
         Mrs Lisa   Manager                                would be helpful if reference could also be
165133                         paragraph   9.1.1   Agree                                                    accessibility into Kettering in the next
         Maric      Highways                               made to improving accessibility between the
                                                                                                            iteration of this AAP - Proposed Submission.
                    Agency                                 two towns and Kettering as this would help
                                                           reinforce the policy framework in terms of
                                                           minimising and mitigating potential impacts
                                                           on the A14 and the junction of the A141A6.




                                                           Economy: An approach which minimises the
                    Planning                               need to travel for local residents to access
         Mrs Lisa   Manager                                employment is favoured by the Agency, and
165133                         paragraph   9.2.1   Agree                                                    Noted.
         Maric      Highways                               this corresponds with the basis of Preferred
                    Agency                                 Policy Direction (6) within the Position
                                                           Statement on employment land allocations




                                                                                                                                       168
                                                           New Homes: The Position Statement cites a
                                                           preference to deliver housing provision at
                    Planning
                                                           higher densities along key bus routes
         Mrs Lisa   Manager
165133                         paragraph   9.4.1   Agree   (Preferred Policy Direction 10) This is      Noted
         Maric      Highways
                                                           welcomed by the Agency as it will help
                    Agency
                                                           maximise opportunities for travel by
                                                           sustainable modes




                                                                                                                169
                                                               Developer Contributions: The inclusion of a
                                                               reference to the need to secure funding for
                                                               general transport improvements in the
                                                               borough to support the urban extensions
                                                               proposed within the Position Statement is
                                                               welcome (Preferred Policy Direction 16)
                                                               However, it would assist if further
                                                               consideration could be given to the transport
                                                               infrastructure required to support
                                                               development in the area, and an indication of
                                                               the ability of development to bring forward
                                                               this infrastructure It should also be noted that
                    Planning                                   the Agency would expect mitigating
                                                                                                                  Noted, transport infrastructure will be further
         Mrs Lisa   Manager                                    measures deemed to be required on the
165133                         paragraph   9.7.11   Disagree                                                      considered in the next iteration of the AAP -
         Maric      Highways                                   strategic road network as a result of
                                                                                                                  Proposed Submission.
                    Agency                                     development in the two towns to be
                                                               considered as part of the totality of
                                                               infrastructure required, and for which
                                                               developer contributions may be sought As a
                                                               result, to improve certainty and clarity for
                                                               developers, and the weight attached to the
                                                               Area Action Plan itself, a supporting
                                                               Infrastructure Delivery Plan based upon the
                                                               development of a transport evidence base
                                                               should be provided This should detail the
                                                               measures required, their triggers for delivery
                                                               and an equitable designation of funding
                                                               requirements.




                                                                                                                                                170
                                                                 Site Development: In developing master
                                                                 plans for the development of specific sites as
                                                                 set out in Preferred Policv Direction (22).
                                                                 Attention should be aid to the designation of
                                                                 a road user hierarchy, prioritising the needs
                                                                 of pedestrians and cyclists initially, followed
                                                                 by public transport access and finally the
                    Planning                                     needs of general traffic Through embedding
                                                                                                                   Noted, sustainable transport will be further
         Mrs Lisa   Manager                                      such sustainable travel principles in the
165133                         paragraph   9.12.1   No opinion                                                     considered in the next iteration of the AAP -
         Maric      Highways                                     master plans for each site, the ability to
                                                                                                                   Proposed Submission.
                    Agency                                       encourage a modal shift away from the
                                                                 private car will be maximised. In addition,
                                                                 Travel Plans should be required to be
                                                                 produced for each site, setting out
                                                                 opportunities for sustainable travel and
                                                                 providing incentives for residents and
                                                                 employees to use public transport, walk or
                                                                 cycle,




                                                                                                                                                171
                                                      Northamptonshire Police would like to see
                                                      reference made within this section to
                                                      community cohesion being a key objective of
                                                                                                    Noted, community cohesion objectives will
         Ch Supt                                      the planning process. Cohesion plays a
171011               paragraph   6.5.2   No opinion                                                 be considered in the next iteration of the
         Paul Fell                                    major role in ensuring that communities
                                                                                                    AAP - Proposed Submission.
                                                      remain balanced and harmonious and as
                                                      such it should be recognised within this
                                                      objective.




                                                                                                                                172
                                                 There is a welcome reference within the first
                                                 bullet point to high quality design reducing
                                                 the risk and fear of crime. This is supported.
                                                 It is, however, suggested that there should
                                                 be an amendment to include a reference to
                                                 Anti-Social Behaviour. This is distinct from
                                                 crime and can more negatively impact on the
                                                 quality of life of residents than crime. I would
                                                 therefore like to see a reference included
                                                 within this bullet point. From an emergency
                                                                                                     Noted. The next iteration of the AAP will be
         Ch Supt                                 services perspective, it is pleasing to note
171011               paragraph   6.5.5   Agree                                                       amended to make reference to anti-social
         Paul Fell                               that bullet 3 of this objective is to ensure that
                                                                                                     behaviour.
                                                 road design and layout prevents speeding
                                                 and allows easy access for emergency
                                                 vehicles. This latter point is particularly
                                                 relevant for our colleagues in Fire and
                                                 Rescue Service who operate appliances that
                                                 are larger than the national guidelines and
                                                 should be consulted to ensure appliances
                                                 can get sufficiently close to all parts of any
                                                 new development to ensure community
                                                 safety is maximised.




                                                                                                                                 173
                                                    Northamptonshire Police are delighted to
                                                    note the importance placed on this objective
                                                    within the plan and specifically on protecting
                                                    and enhancing health, safety and security. It
         Ch Supt                         Strongly   is particularly pleasing that this plan notes
171011               paragraph   6.5.6                                                                 Noted
         Paul Fell                       Agree      that community safety is about more than
                                                    designing out crime and trust that this
                                                    objective will help to ensure that this thinking
                                                    is put into action on the ground in Rothwell
                                                    and Desborough.




                                                    Northamptonshire Police agree with the
                                                    suggested policy to provide more self-
                                                    containment of the two towns whilst
                                                                                                       Noted, the need for a Police facility will be
         Ch Supt                                    recognising that some services will serve
171011               paragraph   7.0.2   Agree                                                         expressed in the next iteration of the AAP -
         Paul Fell                                  both towns. One such service is the police
                                                                                                       Proposed Submission.
                                                    whereby any new facility in the area will be
                                                    required to serve both Rothwell and
                                                    Desborough.




                                                                                                                                    174
                                                 It is most welcome to see the inclusion of a
                                                 variety of leisure and open space facilities
                                                 within the position statement. It is vital that
                                                 there are sufficient things to do within the
                                                 area, not only for the new residents but for
                                                 existing residents as well It is particularly
                                                 pleasing to note the intention to ensure there
                                                 is provision of facilities for young people       Noted, opportunities for facilities in Rothwell
         Ch Supt
171011               paragraph   9.7.6   Agree   within Desborough. Opportunities for              will be further considered in the next
         Paul Fell
                                                 complementary facilities in Rothwell should       iteration of the AAP - Proposed Submission.
                                                 also be explored. Local young people should
                                                 be encouraged to be involved in deciding on
                                                 what formal and informal facilities they
                                                 actually want within the area. This will give
                                                 the young people the sense of ownership
                                                 required to ensure the facility is well used
                                                 and looked after.




                                                                                                                                 175
                                                     The list of community facilities included with
                                                     this policy is to be welcomed. Both the
                                                     provision for a base for a Safer Community
                                                     Team to cover the Rothwell and Desborough
                                                     area and contributions towards other
                                                     measures of community safety including
                                                     CCTV and Automatic Number Plate
         Ch Supt                          Strongly
171011               paragraph   9.7.14              Recognition (ANPR) is strongly supported.        Noted
         Paul Fell                        Agree
                                                     This policy should take into account the work
                                                     that is on going across North
                                                     Northamptonshire to produce a
                                                     Supplementary Planning Document on
                                                     Developer Contributions to ensure there is
                                                     consistency across the planning policy of the
                                                     area.




                                                                                                              176
                                                  Northamptonshire Police welcomes the
                                                  reference to ensuring safe environments
                                                  within the paragraphs surrounding this
                                                  policy. It is also welcome to see within the
                                                  policy itself the reference to the promotion of
                                                  Secured by Design principles. It should be
                                                  remembered that Part 2 Accreditation of
                                                  Secured by Design also provides applicants
                                                  with the Security elements of the Code for
                                                  Sustainable Homes, as well as helping to
                                                  meet a number of other points within the
                                                  Code. Therefore meeting Secured by Design
                                                  helps to address the wider sustainability of
                                                  the houses, something that the Borough
                                                  Council will no doubt be keen to promote
         Ch Supt                                  with the drive towards carbon neutral homes
171011               paragraph   9.12.1   Agree                                                     Noted
         Paul Fell                                by 2016. The inclusion of safe and
                                                  convenient movement networks within the
                                                  policy is also to be welcomed. Both this and
                                                  the Secured by Design element, are areas
                                                  that Northamptonshire Police, through Crime
                                                  Prevention Design Advisors, can help to
                                                  ensure occur. Within Kettering Borough, the
                                                  Crime Prevention Design Advisor is keen to
                                                  work in partnership with the council and any
                                                  applicants to ensure that issues to address
                                                  community safety and designing out crime
                                                  are addressed. It is suggested that Preferred
                                                  Policy Direction 14 is incorporated into this
                                                  policy, as it does not add anything new to
                                                  Policy 22, which is by far the more
                                                  comprehensive policy for sustainable design.




                                                                                                            177
                                                       These policies on improving the public realm
                                                       including improving connectivity, lighting,
                                                       signage and improving the appearance of an
                                                       area, are also areas where the Crime
                                                       Prevention Design Advisors can have a
                                                       major impact to ensure that the area is
                                                       welcoming to all the community, to ensure
         Ch Supt                                       that the spaces are well used and that the
171011               paragraph   9.13.2   No opinion                                                   Noted
         Paul Fell                                     long term maintenance of the area is
                                                       considered fully. Once again,
                                                       Northamptonshire Police would be keen to
                                                       work in partnership with the Borough Council
                                                       on these issues to provide a high quality and
                                                       safe environment that the community in the
                                                       Borough can be proud of for many years to
                                                       come.




                                                                                                               178
                                                                Preferred Policy Direction 1 Accessibility to
                                                                the Town Centre and existing road network
                                                                for the proposed new development is
                                                                absolutely critical. At present there is only
                                                                one access road from the proposed
                                                                development to the Town Centre via Back
                                                                Lane and over the Pipewell Road Bridge.
                                                                The Pipewell Road Bridge has single lane
                                                                traffic lights which may cause congestion if
                                                                road usage in this area is increased. On the
                                                                map provided, however, there is no direct
                                                                road link shown from the proposed site to the
                                                                Pipewell Road Bridge. As part of the
                                                                infrastructure for the proposed development        Noted, improved connectivity is vital to the
                                                                a proper road network should be established        delivery of sustainable urban extensions. A
                                                                which can adequately meet demand. The s.           new junction off the A6 will be required and
                     Clerk                                      106 agreement for the existing development         is outlined in preferred policy direction 5, to
         Mrs Leigh   Desboroug                                  at the Grange provided for a footbridge over       serve the proposed extension, especially
173073                           paragraph   7.0.1   Disagree
         Parkin      h Town                                     the railway, this has not been built. It is        large vehicles and lorries. Green
                     Council                                    essential that this is put in place prior to any   infrastructure contributions including
                                                                further development taking place to enable         contributions to walking and cycling links will
                                                                connectivity between The Grange and the            be sought as well improvements to
                                                                Town Centre. It is recommended by                  footpaths.
                                                                Desborough Town Council that Kettering
                                                                Borough Council consider buying the Station
                                                                House (which is currently for sale) situated
                                                                along Gladstone Street for the footbridge
                                                                development. The preferred access road
                                                                from the B576 towards Kettering needs to go
                                                                through the new Rothwell North
                                                                development directly onto the A6 bypass.
                                                                This route should be given priority over all
                                                                other local Rothwell routes. The possibility of
                                                                housing development on the opposite side of
                                                                the road (B576) to Magnetic Park should not
                                                                be excluded. If considered however this




                                                                                                                                                179
should be in lieu of the equivalent number of
houses on the proposed new development
site. This would allow more space for greater
community use, green areas and sporting
facilities. If housing is not considered for this
area of land there could be a land swap (see
points under Policy Direction 16) where
Loatlands Primary School could be located
here and housing built on the existing
Loatlands site. A further possibility for
housing development could be the existing
Desborough Football Club Site which is
closer to the Town Centre. The Football Club
would need to be relocated within easy
walking distance of the Town Centre with
provision made for a new ground and
facilities to include adequate parking. This is
an ideal time to consider this option following
the major fire at the Club in December 2008.




                                                    180
                                                                                                            Noted, improved connectivity is vital to the
                                                                                                            delivery of sustainable urban extensions. A
                                                                                                            new junction off the A6 will be required and
                     Clerk                                                                                  is outlined in preferred policy direction 5, to
         Mrs Leigh   Desboroug                                  Preferred Policy Direction 2 - see points   serve the proposed extension, especially
173073                           paragraph   7.0.3   Disagree
         Parkin      h Town                                     made in Preferred Policy Direction 1.       large vehicles and lorries. Green
                     Council                                                                                infrastructure contributions including
                                                                                                            contributions to walking and cycling links will
                                                                                                            be sought as well improvements to
                                                                                                            footpaths.




                                                                                                                                         181
                                                                Preferred Policy Direction 4 The key to the
                                                                success of this location is the provision of
                                                                improved cycle & walk ways which will               Improved connectivity is vital to the delivery
                                                                ensure good connectivity to the Town                of sustainable urban extensions. Green
                                                                Centre. It is re-emphasised that the S.106          infrastructure contributions including
                                                                agreement footbridge over the railway needs         contributions to walking and cycling links will
                                                                to be built for the existing Grange                 be sought as well improvements to
                                                                development before any new development              footpaths. The LPA have been working with
                                                                takes place. The new Leisure Centre which           developers of the current 'Grange'
                                                                is to be built on The Grange needs to               development to provide the best possible
                                                                incorporate the squash courts when building         leisure facility in this location. A planning
                                                                work commences and not at a later date. It is       application is expected in June and
                                                                critical that the new Leisure Centre provides       construction of Phase 1 of this facility should
                                                                like for like facilities with the existing Centre   follow shortly after determination. Phase 2 is
                                                                and takes into consideration the proposed           to be brought forward following
                     Clerk                                      increase in population to ensure adequate           commencement of construction of this
         Mrs Leigh   Desboroug                                  facilities are provided. Consideration should       planned urban extension. The existing
173073                           paragraph   8.0.5   Disagree
         Parkin      h Town                                     be given to further industrial development          Desborough Leisure Centre has squash
                     Council                                    behind Rigid Containers which can be                courts which will not be brought forward until
                                                                accessed by Brampton Wood Lane. This                Phase 2 of the new leisure centre. The
                                                                would provide increased employment                  Squash Club have been informed but the
                                                                opportunities. Paragraph 9.1.3 - The                intention is to provide regional competition
                                                                provision of a tram style service using the         squash courts with glass backs which are
                                                                existing railway network should be                  much improved from the existing.
                                                                considered which would provide a real               Commercial development as proposed
                                                                alternative to the use of buses and personal        would be physically detached from the town
                                                                cars. This would require a stopping place in        and residential population and would
                                                                Desborough. The Town would then be well             encourage unsustainable travel. A tram
                                                                connected to Leicester, Market Harborough,          service may be difficult to sustain
                                                                Kettering and Wellingborough enabling               economically. However, contributions to
                                                                interchange to fast train services to London        improve public transport facilities are
                                                                and Nottingham. Existing bus services do            required.
                                                                not link to the Kettering Train Station or
                                                                Corby.




                                                                                                                                                 182
                                                                Paragraph 9.2.7 - Desborough Town Council
                                                                are fully supportive of the proposed
                                                                development at Ecklands Lodge Business
                                                                Park (KET/2008/0697 and
                                                                APP/L2820/A/09/2093335/NWF). This is in
                                                                line with Objective 4: Quality of Development
                                                                6.5.5 (last bullet point) – Integrating
                                                                development into the countryside setting         This application was not granted permission
                     Clerk
                                                                through appropriate siting and landscaping.      for reasons outlined in the planning
         Mrs Leigh   Desboroug
173073                           paragraph   9.1.1   Disagree   In addition reference is made to Paragraph       application, the site due to its physical
         Parkin      h Town
                                                                3.3.1 of the Site Specific Proposals Local       separation from the town does not form part
                     Council
                                                                Development Document “Issues Paper               of this AAP.
                                                                Consultation March 2009 which discusses
                                                                the conversion, re-use and replacement of
                                                                buildings in the countryside. Para 9.2.8 “this
                                                                reinforces the point already made about
                                                                ensuring that the existing s.106 agreement
                                                                of the provision of a footbridge over the
                                                                railway line is undertaken.




                                                                                                                                            183
                     Clerk
                                                                   Preferred Policy Direction 7 - This is
         Mrs Leigh   Desboroug
173073                           paragraph   9.2.14   Disagree     supported but again the footbridge over the       Noted
         Parkin      h Town
                                                                   railway needs to be built.
                     Council

                     Clerk                                         Preferred Policy Direction 8 - The Town
         Mrs Leigh   Desboroug                                     Council support the provision of live/work
173073                           paragraph   9.2.15   Agree                                                          Noted
         Parkin      h Town                                        units which provide for small business
                     Council                                       activities.




                                                                   Preferred Policy Direction 9 It is imperative     A small supermarket which does not
                                                                   that the words ˜or supermarket are removed        compete with the town centre or threaten to
                     Clerk
                                                                   from this direction statement. To locate a        undermine its vitality or viability is likely to
         Mrs Leigh   Desboroug
173073                           paragraph   9.3.1    Disagree     supermarket within the proposed new               be acceptable in this location. Any planning
         Parkin      h Town
                                                                   development site would not meet the               application for this type of use would need to
                     Council
                                                                   objective to enhance regeneration of the          be sequentially tested in accordance with
                                                                   Town Centre.                                      PPS6.




                                                                   Preferred Policy Direction 10 Traditionally
                                                                   houses within Desborough and Rothwell             Noted. Policy direction 11 encourages a
                     Clerk
                                                                   have benefitted from substantial gardens          wide range of house sizes and types. This
         Mrs Leigh   Desboroug
173073                           paragraph   9.4.1    No opinion   which have enabled people to provide their        would include provision for a range of
         Parkin      h Town
                                                                   own sustainable food products. The                garden sizes taking into consideration
                     Council
                                                                   continuation of this facility would be strongly   property size.
                                                                   supported.




                                                                                                                                                   184
                                                             Preferred Policy Direction 11 This Direction
                                                             is supported, however, it is noted that there
                                                                                                             Policies will be informed by the HMA. A
                     Clerk                                   is no provision of bungalows on the existing
                                                                                                             range of housing types should be
         Mrs Leigh   Desboroug                               Grange development which is deplored. It is
173073                           paragraph   9.4.4   Agree                                                   encouraged. However, it is important for the
         Parkin      h Town                                  understood that bungalows should have
                                                                                                             market to determine the exact number and
                     Council                                 been provided. The proposed new
                                                                                                             mix of properties.
                                                             development should highlight bungalows as
                                                             a priority and enforce this provision.




                     Clerk
         Mrs Leigh   Desboroug                               Preferred Policy Direction 13 - The Town
173073                           paragraph   9.6.1   Agree                                                   Noted
         Parkin      h Town                                  Council support this Direction.
                     Council
                     Clerk
         Mrs Leigh   Desboroug                               Preferred Policy Direction 14 - The Town
173073                           paragraph   6.5.5   Agree                                                   Noted
         Parkin      h Town                                  Council support this Direction.
                     Council




                                                                                                                                         185
                                                                                                                 The development will be responsible for
                                                                                                                 contributing to and providing facilities
                                                                                                                 necessary to sustain the proposed
                                                                Preferred Policy Direction 15 S.106
                                                                                                                 increases in population created by the urban
                                                                agreement monies from the current Grange
                                                                                                                 extension. The precise community
                                                                development provide for a new Leisure
                                                                                                                 requirements will be outlined in the next
                                                                Centre. The size of this development
                                                                                                                 iteration of the AAP – Proposed Submission.
                                                                urgently needs to be re-examined due to the
                                                                                                                 The list provided in support of policy
                                                                proposed increase in the population. Phase
                                                                                                                 direction 16 is not intended to be
                                                                1 and 2 of the new Leisure Centre need to
                                                                                                                 exhaustive. The LPA have been working
                                                                be built together incorporating the squash
                                                                                                                 with developers of the current 'Grange'
                                                                courts. Please also refer back to the
                     Clerk                                                                                       development to provide the best possible
                                                                comments made on Desborough Town
         Mrs Leigh   Desboroug                                                                                   leisure facility in this location. A planning
173073                           paragraph   9.7.1   Disagree   Football Club in Preferred Policy Direction 1.
         Parkin      h Town                                                                                      application is expected in June and
                                                                The Outdoor Bowls Club has recently
                     Council                                                                                     construction of Phase 1 of this facility should
                                                                accommodated improvements to its facilities.
                                                                                                                 follow shortly after determination. Phase 2 is
                                                                The Indoor Bowls Club has an ideal Town
                                                                                                                 to be brought forward following
                                                                Centre location. Consideration should be
                                                                                                                 commencement of construction of this
                                                                given to the purchase of land within the
                                                                                                                 planned urban extension. The existing
                                                                vicinity of the Indoor Bowls Club to provide
                                                                                                                 Desborough Leisure Centre has squash
                                                                additional community facilities, for example,
                                                                                                                 courts which will not be brought forward until
                                                                a community centre/meeting rooms/office
                                                                                                                 Phase 2 of the new leisure centre. The
                                                                space. This type of facility could also be
                                                                                                                 Squash Club have been informed but the
                                                                utilised by Desborough Town Council.
                                                                                                                 intention is to provide regional competition
                                                                                                                 squash courts with glass backs which are
                                                                                                                 much improved from the existing.




                                                                                                                                              186
                     Clerk
                                                                 Preferred Policy Direction 16 There has
         Mrs Leigh   Desboroug
173073                           paragraph   9.7.11   Disagree   been a long term aspiration in Desborough     Noted
         Parkin      h Town
                                                                 for the provision of a swimming pool.
                     Council



                                                                 Preferred Policy Direction 17 Rockingham
                     Clerk                                       Forest Trust undertook a survey
         Mrs Leigh   Desboroug                                   approximately 18 months ago. At present the
173073                           paragraph   9.8.1    Disagree                                                 Noted
         Parkin      h Town                                      implementation of the plans that were
                     Council                                     produced at this time have yet to be
                                                                 implemented.




                                                                                                                       187
                                                                The Heads of the Desborough Schools
                                                                regard the proposal to build a new one form
                                                                entry primary school on The Grange Estate          The required provision for schools has been
                                                                is the least desirable solution for the existing   identified by NCC. The current advice is that
                                                                schools. Loatlands Primary School occupies         further primary school provision is required
                                                                an extensive site and with remodelling could       at Desborough. Provision would be
                                                                absorb a high proportion of new school             acceptable both in the form of a new one
                     Clerk                                      population along with the existing spare           form entry school or a two form entry school
         Mrs Leigh   Desboroug                                  capacity of the Havelock Schools.                  created through linking with one of the
173073                           paragraph   9.9.3   Disagree
         Parkin      h Town                                     Alternatively the relocation of Loatlands          existing schools in Desborough. The next
                     Council                                    Primary School to serve its existing               iteration of the AAP - Proposed Submission
                                                                catchment area and new development would           will be amended to reflect this. However,
                                                                be a logical option (See comments under            either option is likely to be acceptable and a
                                                                Preferred Policy Direction 1). Centering all       new school on the Grange would directly
                                                                new housing and facilities at the Grange will      serve the pupils created by the development
                                                                create a totally separate community instead        whilst reducing the need to travel.
                                                                of embracing the whole community and will
                                                                certainly put our schools at a disadvantage.




                                                                                                                                                188
                     Clerk
                                                                   Preferred Policy Direction 21 A re-cycling
         Mrs Leigh   Desboroug
173073                           paragraph   9.10.1   No opinion   facility used to exist along the Pipewell     Noted
         Parkin      h Town
                                                                   Road. This could be re-opened.
                     Council




                                                                   Paragraph 9.11.1 It is questioned whether
                                                                   the doctors surgery in Desborough is large
                                                                   enough to cope with the existing population
                                                                                                                 The development will be expected to make
                     Clerk                                         as they are unable to provide some services
                                                                                                                 contributions to improving health care
         Mrs Leigh   Desboroug                                     at present due to lack of space. The Town
173073                           paragraph   9.11.1   Disagree                                                   across the Borough and this will be outlined
         Parkin      h Town                                        Council are also concerned as to whether
                                                                                                                 in the next iteration of the AAP – Proposed
                     Council                                       the Desborough and Rothwell surgeries will
                                                                                                                 Submission.
                                                                   be able to accommodate an increased
                                                                   population with the two proposed 700
                                                                   housing developments.




                     Clerk
         Mrs Leigh   Desboroug                                     Preferred Policy Direction 22 - The Town
173073                           paragraph   9.12.1   Agree                                                      Noted
         Parkin      h Town                                        Council support this Direction.
                     Council




                                                                                                                                             189
                                                                   Preferred Policy Direction 23 Discussions
                                                                   need to take place with Northamptonshire
                                                                   County Council in respect of the
                                                                   implementation of a one way traffic scheme
                                                                   within Desborough Town Centre. With the
                                                                                                                   Improved connectivity through the
                                                                   location of the new Leisure Centre at The
                                                                                                                   development and connectivity into the town
                                                                   Grange it is also imperative that there is
                     Clerk                                                                                         centre is vital in the delivery of a sustainable
                                                                   connectivity from the older part of the Town
         Mrs Leigh   Desboroug                                                                                     urban extension. This will be delivered
173073                           paragraph   9.13.1   No opinion   to the new (from south to north). Again the
         Parkin      h Town                                                                                        through green infrastructure contributions
                                                                   footbridge across the railway is critical for
                     Council                                                                                       including contributions to walking and
                                                                   access between these two areas. It is
                                                                                                                   cycling links as well improvements to
                                                                   essential that the appearance of the Town
                                                                                                                   highway footways and cycle lanes.
                                                                   Centre is enhanced and existing derelict
                                                                   buildings, for example, Foxs Lodge, the Ritz,
                                                                   the Diaries and the shop on the corner of
                                                                   New Street, be brought into use. Please also
                                                                   refer to previous comments on connectivity.




                     Clerk
         Mrs Leigh   Desboroug                                     Preferred Policy Direction 24 - The Town
173073                           paragraph   9.14.1   Agree                                                        Noted
         Parkin      h Town                                        Council support this Direction.
                     Council




                                                                                                                                                 190
                     Clerk
         Mrs Leigh   Desboroug                                Preferred Policy Direction 25 - The Town
173073                           paragraph   10.1.1   Agree                                                     Noted
         Parkin      h Town                                   Council support this Direction.
                     Council




                                                              In addition, the contents of paragraph 9.7.9
                                                              are supported, specifically the statement that
                                                              contributions may be required for the
                                                              provision of open space and indoor leisure
                                                              facilities based on the Council's findings to
                                                              be published within the Kettering Borough
                     Planning
                                                              Sports Facilities Strategy and following open
         Mr Tony     Manager
181369                           paragraph   9.7.9    Agree   space improvements which may occur during         Noted
         Aitchison   Sport
                                                              the adoption of the plan. Sport England has
                     England
                                                              supported the development of this strategy
                                                              and is keen that as soon as it is available its
                                                              findings should taken into account when
                                                              determining the most appropriate investment
                                                              in open space, playing fields and built sports
                                                              facilities.




                                                                                                                        191
                                                         In terms of the chain of conformity, as you
                                                         refer to in your document the AAP should
                                                         conform with the adopted North
                                                         Northamptonshire Joint Core Strategy as a
                                                         legal requirement. However, it may be
                                                         helpful to make specific reference to the
                                                         existing regional spatial strategy (RSS) at the
                                                         relevant time as this provides the
                                                         overarching strategic policy context both for
                    Policy
                                                         the Core Strategy, and in turn this AAP. In
                    Adviser
                                                         particular, Policy MKSM Northamptonshire
                    (Planning
                                                         SRS1 of the Draft RSS with Proposed
                    Conformity
                                                         Changes July 2008 provides for                    Noted, the next iteration of the AAP -
         Mr Steve   and Best
214905                           document   No opinion   development outside the main urban centres        Proposed Submission will reflect the
         Bolton     Practice)
                                                         to be focussed on Daventry as a Sub-              changes as proposed.
                    East
                                                         Regional Centre, the smaller towns including
                    Midlands
                                                         Desborough and Rothwell, and the rural
                    Regional
                                                         service centres. Policy 11 seeks to maintain
                    Assembly
                                                         the roles of the small towns in the Southern
                                                         Sub-area through the retention of basic
                                                         services and facilities, environmental
                                                         improvements and the safeguarding of their
                                                         rural hinterlands from encroachment by
                                                         larger centres. Policy 2 of the Draft RSS also
                                                         provides a useful checklist of matters to take
                                                         into account in the design of new urban
                                                         extensions.




                                                                                                                                        192
                                                                   Reference in Section 10.3 of your document
                    Policy
                                                                   to the AAP introducing an implementation
                    Adviser
                                                                   and phasing programme is welcome.
                    (Planning
                                                                   Paragraph 3.5.7 of the Draft RSS refers to
                    Conformity
                                                                   infrastructure investment and provision, in
         Mr Steve   and Best
214905                           paragraph   10.3.1   Agree        particular to local partners in                Noted
         Bolton     Practice)
                                                                   Northamptonshire working to develop clear
                    East
                                                                   and transparent Delivery Programmes for
                    Midlands
                                                                   each Local Delivery Vehicle area. Phasing is
                    Regional
                                                                   an essential component of the delivery
                    Assembly
                                                                   programmes.




                    Policy
                    Adviser
                    (Planning                                      The Regional Assembly will be guided by the
                    Conformity                                     views of other key stakeholders on the
         Mr Steve   and Best                                       precise location of the proposed urban
214905                           document             No opinion                                                  Noted
         Bolton     Practice)                                      extensions in terms of issues such as flood
                    East                                           risk, biodiversity, highways, historic
                    Midlands                                       buildings, landscape and archaeology.
                    Regional
                    Assembly




                                                                                                                          193
                    Access
                    Developme
                    nt Officer                               Northamptonshire County Council Rights of
         Ms Carla
216126              Northampt    paragraph   6.2.1   Agree   Way Team agrees with the vision in the        Noted
         Boswell
                    onshire                                  position statement.
                    County
                    Council




                                                             Northamptonshire County Council Rights of
                    Access                                   Way Team agree with the key issues
                    Developme                                identified and would welcome involvement in
                                                                                                           Noted, policy 13 of the CSS outlines the
                    nt Officer                               improving opportunities to build on and
         Ms Carla                                                                                          need for encouraging a modal shift. The
216126              Northampt    paragraph   6.4.1   Agree   create links to Green Infrastructure and
         Boswell                                                                                           Local Planning Authority encourages
                    onshire                                  reducing congestion and improving road
                                                                                                           partnership working.
                    County                                   safety. We would welcome the inclusion of
                    Council                                  the encouraging the 20% modal shift from
                                                             the Local Transport Plan 2006/7 - 2010/11.




                                                                                                                                       194
                                                                We strongly agree with objective 2
                                                                Accessibility, in planning the development
                                                                with everything within walking distance and
                                                                providing walking and cycling facilities that
                                                                are safe and attractive for users to
                    Access                                      encourage modal shift for local journeys.
                    Developme                                   Please note the terminology used throughout
                                                                                                                  Noted, references to cycle ways and
                    nt Officer                                  the document with references to cycle ways
         Ms Carla                                    Strongly                                                     footpaths will be amended to reflect what
216126              Northampt    paragraph   6.5.1              and footpaths. Public Footpaths are Public
         Boswell                                     Agree                                                        they refer to in accordance with the
                    onshire                                     Rights of Way and Footways are pedestrian
                                                                                                                  descriptions outlined here.
                    County                                      facilities such as pavements provided in
                    Council                                     urban areas. Cycle ways, do you mean cycle
                                                                tracks, the off road provision and cycle lanes
                                                                are on road? I think it would be beneficial for
                                                                Kettering Borough Council to clarify what
                                                                they actually mean in this document as it can
                                                                get confusing.




                                                                                                                                              195
                    Access                                                                                         Noted, reference should be made to
                    Developme                                     Does this include Public Rights of Way and       improving access via walking and cycling
                    nt Officer                                    Cycling facilities? I only ask because walking   within and to new infrastructure and
         Ms Carla
216126              Northampt    paragraph   6.5.7   No opinion   and cycling is a key part of the road            facilities. Green infrastructure contributions
         Boswell
                    onshire                                       infrastructure and access to those services      including contributions to walking and
                    County                                        provided.                                        cycling links will be sought as well
                    Council                                                                                        improvements to footways.


                    Access
                    Developme                                     We note and support 6.6.1 the necessity to
                    nt Officer                                    ensure both towns are linked, improve
         Ms Carla
216126              Northampt    paragraph   6.6.1   Agree        linkages and promote sustainable travel,         Noted
         Boswell
                    onshire                                       especially between Rothwell and
                    County                                        Desborough.
                    Council


                    Access
                    Developme
                                                                  We agree with 6.6.2 to support to improve
                    nt Officer
         Ms Carla                                                 connectivity between the towns and
216126              Northampt    paragraph   6.6.2   Agree                                                         Noted
         Boswell                                                  extensions and that Green Infrastructure has
                    onshire
                                                                  been identified as a main topic.
                    County
                    Council


                    Access
                    Developme
                    nt Officer                                    We note and support the approach that
         Ms Carla
216126              Northampt    paragraph   7.0.2   Agree        requires improved connectivity between the       Noted
         Boswell
                    onshire                                       towns.
                    County
                    Council




                                                                                                                                                 196
                    Access                                        In achieving the 20% modal shift target
                    Developme                                     published in the Local Transport Plan 2006/7
                                                                                                                  Noted, the requirement for convenient, safe
                    nt Officer                                    - 2010/11, Northamptonshire County Council
         Ms Carla                                                                                                 and secure cycle parking will be included
216126              Northampt    paragraph   9.1.1   No opinion   Rights of Way service wish to see
         Boswell                                                                                                  within a relevant policy in the next iteration
                    onshire                                       convenient and secure cycle parking
                                                                                                                  of the AAP - proposed submission.
                    County                                        designed into the extensions to encourage
                    Council                                       the reduction in motor vehicle use.




                    Access
                    Developme
                    nt Officer                                    We support the policy in terms of cycling and
         Ms Carla
216126              Northampt    paragraph   9.1.4   Agree        pedestrian connections and improved safety      Noted
         Boswell
                    onshire                                       by traffic reduction.
                    County
                    Council


                    Access
                    Developme                                     We agree and support improvements to
                    nt Officer                                    public transport and walking and cycling
         Ms Carla                                                                                                 Noted, the AAP will seek to encourage
216126              Northampt    paragraph   9.2.8   Agree        routes and would welcome the involvement
         Boswell                                                                                                  engagement and partnership working.
                    onshire                                       in the design and consultation of these
                    County                                        schemes at the time.
                    Council




                                                                                                                                               197
                    Access
                    Developme
                    nt Officer
         Ms Carla                                             We agree and support the improvement of
216126              Northampt    paragraph   9.2.9    Agree                                                Noted
         Boswell                                              connectivity between the towns.
                    onshire
                    County
                    Council


                    Access
                    Developme                                 We agree and support the improvements for
                    nt Officer                                connectivity and public transport, cycle
         Ms Carla
216126              Northampt    paragraph   9.2.14   Agree   tracks and footpath and footways between     Noted
         Boswell
                    onshire                                   the towns, towns centres and employments
                    County                                    sites.
                    Council



                    Access
                    Developme                                 We agree and support this section of the     Noted, public rights of way are an important
                    nt Officer                                document, however we would welcome the       element of open space and green
         Ms Carla
216126              Northampt    paragraph   9.7.3    Agree   inclusion of: 9.7.3 there is no mention of   infrastructure and reference be made to
         Boswell
                    onshire                                   Public Rights of Way in the provision for    them in the next iteration of the AAP -
                    County                                    Green Infrastructure and open space.         Proposed Submission.
                    Council




                                                                                                                                       198
                    Access
                    Developme
                    nt Officer
         Ms Carla                                                 We note and support the issue of
216126              Northampt    paragraph   9.7.4   Agree                                                            Noted
         Boswell                                                  maintenance has been acknowledged.
                    onshire
                    County
                    Council




                                                                  There is no mention to include creating
                                                                  circular walks into the countryside from
                                                                  Rothwell or Desborough in the list or               Noted, reference should be made within the
                                                                  specifically access by Public Rights of Way.        next iteration of the AAP - proposed
                    Access
                                                                  The Rights of Way Improvement Plan                  submission to circular walks and to
                    Developme
                                                                  (ROWIP) 2005 network assessment                     improving circular routes and walking
                    nt Officer
         Ms Carla                                                 identifies that there is no current provision for   /cycling between the two towns. Specific
216126              Northampt    paragraph   9.7.5   No opinion
         Boswell                                                  a circular walk from Desborough Town using          reference has been made to improving
                    onshire
                                                                  the PRoW network. However Rothwell is               connectivity between the towns and green
                    County
                                                                  better served by Public Rights of Way               infrastructure contributions including
                    Council
                                                                  (PRoW). There is also no mention of an off          contributions to walking and cycling as well
                                                                  road walking/cycling route between the              improvements to footpaths.
                                                                  towns using PRoW as off site contributions
                                                                  from the proposed developments.




                                                                                                                                                  199
                    Access
                    Developme
                                                                   We would welcome the involvement with the       Noted, the AAP will promote improvements
                    nt Officer
         Ms Carla                                                  improvements to local footpaths and cycle       to green infrastructure, local footways and
216126              Northampt    paragraph   9.7.13   Agree
         Boswell                                                   track/lane development within the town          cycle track/lanes in its next iteration -
                    onshire
                                                                   centre scheme when it gets implemented.         Proposed Submission.
                    County
                    Council


                    Access
                    Developme
                    nt Officer                                     Again there is no mention of Public Rights of   Noted, Public Rights of Way will be included
         Ms Carla
216126              Northampt    paragraph   9.8.1    No opinion   Way in this section of the document,            in the next iteration of the AAP - Proposed
         Boswell
                    onshire                                        particularly creating new PRoW.                 Submission.
                    County
                    Council


                    Access
                    Developme
                    nt Officer                                     We agree and support the provision of safer
         Ms Carla
216126              Northampt    paragraph   9.9.3    Agree        routes to school to use access other than the   Noted
         Boswell
                    onshire                                        car.
                    County
                    Council




                                                                                                                                               200
                    Access
                    Developme                                 We agree and support the master plan to
                    nt Officer                                identify access and road infrastructure in
         Ms Carla
216126              Northampt    paragraph   9.12.1   Agree   relation to promoting an integrated and        Noted
         Boswell
                    onshire                                   energy efficient movement network which
                    County                                    prioritises pedestrian and cycling activity.
                    Council


                    Access
                    Developme                                 We agree and support better provision of
                    nt Officer                                footpaths, footways and cycle routes to the
         Ms Carla
216126              Northampt    paragraph   9.13.1   Agree   eastern edge of town and welcome the           Noted
         Boswell
                    onshire                                   involvement of such schemes at the time of
                    County                                    design and implementation.
                    Council


                    Access
                    Developme
                    nt Officer                                We agree and support this policy in
         Ms Carla
216126              Northampt    paragraph   9.13.2   Agree   improving access and connectivity into the     Noted
         Boswell
                    onshire                                   town centre and the public realm.
                    County
                    Council




                                                                                                                     201
                                                         Summary of Representations This
                                                         correspondence is in response to publication
                                                         of the above document, which identifies the
                                                         Councils preferred locations for Sustainable
                                                         Urban Extensions (SUE) to Rothwell and
                                                         Desborough. The following representations
                                                         demonstrate Sols support for the preferred
                                                         location for a SUE at Desborough North, in
                                                         terms of both its scale and location, and
                                                         consider that there is potential for land at
                                                         Magnetic Park to represent a suitable
                                                                                                            A small food store might be acceptable
                                                         location for a food store which will better
                                                                                                            which supports the day to day needs of the
                                                         contribute to the identified wider objectives of
                                                                                                            proposed urban extensions and does not
                                                         the AAP. Land west of Magnetic Park The
                                                                                                            compete with the vitality and viability of the
                                                         land is located within the wider extent of
                                                                                                            town centre. However, a large store would
         Sophie   Indigo                                 Magnetic Park, which was granted outline
244743                       paragraph   8.0.1   Agree                                                      not be acceptable in this location as it would
         Lucas    Planning                               planning permission in 2005 for a business
                                                                                                            encourage non-sustainable travel and
                                                         park (LPA Ref. KET/2004/0760). The subject
                                                                                                            compete with the vitality and viability of the
                                                         site extends to some 0.5 ha, and is situated
                                                                                                            town centre. Any out of town retail
                                                         approximately 600m to the north of
                                                                                                            development would be subject to a
                                                         Desborough Town Centre. The site is bound
                                                                                                            sequential test in accordance with PPS6.
                                                         to the northeast by Bear Way and to the
                                                         southeast by Cockerel Rise, which form new
                                                         access roads into the wider business park
                                                         development, from Harborough Road. The
                                                         above document sets out, at Section 6.5, a
                                                         number of objectives for the AAP, which
                                                         have been applied to the subject site in order
                                                         to demonstrate its appropriateness and
                                                         suitability for a food store to meet the retail
                                                         need of the population of the proposed urban
                                                         extension. Details of these are set out below.




                                                                                                                                         202
                                                              Balanced Communities The subject site will
                                                              assist in meeting the Councils objective for
                                                              the creation of balanced communities
                                                              (Objective 1, p13). New retail provision in
                                                              this location will assist in the provision of new
                                                                                                                  A small food store might be acceptable
                                                              employment opportunities, within walking
                                                                                                                  which supports the day to day needs of the
                                                              distance of a significant existing and growing
                                                                                                                  proposed urban extensions and does not
                                                              local population. A food store in this location
                                                                                                                  compete with the vitality and viability of the
                                                              would result in a number of economic and
                                                                                                                  town centre. However, a large store would
         Sophie   Indigo                                      social benefits for Desborough and its
244743                       paragraph   6.5.2   No opinion                                                       not be acceptable in this location as it would
         Lucas    Planning                                    surrounding area, including the provision of a
                                                                                                                  encourage non-sustainable travel and
                                                              retail service capable of meeting the bulk
                                                                                                                  compete with the vitality and viability of the
                                                              shopping needs of its existing and future
                                                                                                                  town centre. Any out of town retail
                                                              residents. This in turn will reduce the need
                                                                                                                  development would be subject to a
                                                              for residents to travel to the neighbouring
                                                                                                                  sequential test in accordance with PPS6.
                                                              towns of Kettering and Market Harborough,
                                                              thereby retaining retail expenditure within the
                                                              catchment, which will support the economic
                                                              regeneration and prosperity of the town as a
                                                              whole, including the town centre.




                                                                                                                                               203
                                                              Accessibility As mentioned above, given that
                                                              the site is within easy walking distance of
                                                              significant existing and growing residential
                                                              population, a food store in this location will
                                                              assist in reducing the need to travel
                                                              generally by private transport modes
                                                              (Objective 2, p14). The development will also
                                                              improve the sites connectivity with
                                                              surrounding residential areas. The site is
                                                              also located approximately 200m south of         A small foodstore might be acceptable
                                                              the proposed SUE at Desborough North,            which supports the day to day needs of the
                                                              which will support an additional 700             proposed urban extensions and does not
                                                              dwellings. The subject site is therefore         compete with the vitality and viability of the
                                                              clearly within convenient walking and cycling    town centre. However, a large store would
         Sophie   Indigo
244743                       paragraph   6.5.3   No opinion   distance (para 6.12) of a growing local          not be acceptable in this location as it would
         Lucas    Planning
                                                              residential catchment. The site also benefits    encourage non-sustainable travel and
                                                              from good linkages to the Desborough Town        compete with the vitality and viability of the
                                                              Centre, which is approximately 680m to the       town centre. Any out of town retail
                                                              south. The nearest bus stop to the site, is      development would be subject to a
                                                              also approximately 60m to the south, and is      sequential test in accordance with PPS6.
                                                              served by frequent services which provide
                                                              sustainable linkages to Desborough Town
                                                              Centre, in addition to the Town Centres of
                                                              Rothwell and Kettering (bus service no 19).
                                                              This is in contrast to the SUE which is
                                                              located in a more peripheral location further
                                                              to the north west of the town centre.
                                                              Accordingly, the SUE does not offer the
                                                              same potential for linked trips.




                                                                                                                                            204
                                                              Preferred Policy Direction 1 (PPD1) PPD1
                                                              recognises the requirement to enhance local
                                                              services in order to support the planned
                                                              SUEs. Clearly a foodstore at the subject site    A small foodstore might be acceptable
                                                              would meet the objectives of PPD1, in            which supports the day to day needs of the
                                                              providing increased employment                   proposed urban extensions and does not
                                                              opportunities, in addition to ensuring greater   compete with the vitality and viability of the
                                                              self containment by meeting the needs of the     town centre. However, a large store would
         Sophie   Indigo
244743                       paragraph   7.0.1   No opinion   residents of Desborough within the town          not be acceptable in this location as it would
         Lucas    Planning
                                                              itself. SSL support PPD1 which seeks to          encourage non-sustainable travel and
                                                              bolster local services and provide better        compete with the vitality and viability of the
                                                              connectivity and employment. SSL                 town centre. Any out of town retail
                                                              particularly support the objective of            development would be subject to a
                                                              increasing self-containment for Desborough       sequential test in accordance with PPS6.
                                                              and Rothwell in tandem, with services and
                                                              local facilities potentially meeting the needs
                                                              of both towns




                                                                                                                                            205
                                                              Preferred Policy Direction 4 (PPD4) In
                                                              addition to the above PPD, PPD4 identifies
                                                              the location and scale of the planned SUE at
                                                              Desborough North. Given the proximity of
                                                                                                                A small foodstore might be acceptable
                                                              the SUE to the subject site (i.e. 200m), SSL
                                                                                                                which supports the day to day needs of the
                                                              consider that a foodstore in this location
                                                                                                                proposed urban extensions and does not
                                                              would assist in promoting the integration of
                                                                                                                compete with the vitality and viability of the
                                                              the urban extension with Desborough Town
                                                                                                                town centre. However, a large store would
         Sophie   Indigo                                      Centre. The site is located closer to the town
244743                       paragraph   8.0.1   No opinion                                                     not be acceptable in this location as it would
         Lucas    Planning                                    centre than any part of the SUE, on the main
                                                                                                                encourage non-sustainable travel and
                                                              vehicular access into the town (Harborough
                                                                                                                compete with the vitality and viability of the
                                                              Road). Therefore there will be greater
                                                                                                                town centre. Any out of town retail
                                                              potential for linked trips, aiding the future
                                                                                                                development would be subject to a
                                                              regeneration of the Town Centre. SSL
                                                                                                                sequential test in accordance with PPS6.
                                                              support the identification of land to the north
                                                              of Desborough, through Preferred Policy
                                                              Direction 4 (PPD4), to meet future residential
                                                              demand and to address this objective.




                                                                                                                                             206
                                                              Preferred Policy Direction 9 (PPD9) The
                                                              Councils preferred policy guidance for future
                                                              retail development is set out at PPD9, which
                                                              acknowledges that additional facilities will be
                                                              required within the urban extensions to
                                                              accommodate the day to day needs of the
                                                              local community, which may include small
                                                              shops or supermarkets. SSL are also
                                                              supportive of paragraph 9.24, which               A small foodstore might be acceptable
                                                              advocates the sequential approach identified      which supports the day to day needs of the
                                                              by PPS6, and which acknowledges that a            proposed urban extensions and does not
                                                              need does exist to provide additional retail      compete with the vitality and viability of the
                                                              provision which is close to were people live.     town centre. However, a large store would
         Sophie   Indigo
244743                       paragraph   9.3.1   No opinion   On this basis, it should be noted that the site   not be acceptable in this location as it would
         Lucas    Planning
                                                              is well located adjacent to existing (and         encourage non-sustainable travel and
                                                              future) surrounding, residential communities,     compete with the vitality and viability of the
                                                              and therefore comprises an easily accessible      town centre. Any out of town retail
                                                              and sustainable location. SSL support the         development would be subject to a
                                                              objective of PPD9 which identifies a need to      sequential test in accordance with PPS6.
                                                              locate an appropriate level of retail
                                                              development within the SUE, to meet day to
                                                              day needs. Such provision could be
                                                              combined with facilities to meet bulk
                                                              shopping requirements. Such provision could
                                                              be located in close proximity to the SUE
                                                              whilst still according with the requirements of
                                                              PPS6.




                                                                                                                                             207
                                        There is insufficient road access from the
                                        Braybrooke road development area, to
                                        service Desborough, local schools etc. This
                                        road is problematic at present with
                                        widespread parking and cycling allowed on
                                        footpaths. The local GP seems unable to
                                        cope at present, insisting on telephone
                                                                                         Contributions from the proposed extension
                                        consultations not personal visits. The social
                                                                                         will be expected to improve accessibility and
         Mr Ian                         care system is unable to provide carers to
284677            document   Disagree                                                    local facilities through contributions to green
         Jacobs                         Desborough at weekends. The lack of
                                                                                         infrastructure including walking and cycling
                                        entertainment choices available in the
                                                                                         links as well improvements to footways.
                                        evenings, further removes income from the
                                        town, and leaves young people with little to
                                        do except experiment with sex and drugs
                                        and socially disruptive behaviour that the
                                        police refuse to intervene in. The poor public
                                        transport facilities limit employment
                                        possibilities as well as socialisation.




                                                                                                                      208
                                                                 We have previously written about retaining
                                                                 the sporting facilities at Rothwell Corinthians
                                                                 Football Club which has been in existence
                                                                 for 75 years. We are concerned with regard
                                                                 to the detail shown which does not give
                                                                 access to our ground. Part of the area shown
                    Rothwell
         Mr Mark                                                 as our club is continually described by the
288519              Corinthians   paragraph   9.7.3   Disagree                                                     Noted
         Budworth                                                Planning Consultants as ours when
                    FC
                                                                 unfortunately it is not. If the option was
                                                                 pursued with the existing boundary and
                                                                 preferred access routes, we would find
                                                                 ourselves land locked. This may be
                                                                 something to be discussed further at the
                                                                 detailed stage.




                                                                                                                           209
                                                    Regarding the potential for linking the B576      Noted, a junction between the A6 and the
                                                    to Rushton Road - Bridge Street suffers           proposed urban extension will be required to
                                                    congestion on most days. This is particularly     sustain the increased levels of traffic.
         Mr C                                       bad at certain times of the day (school run).     However, more sustainable means of travel
289063               paragraph   9.1.4   Disagree
         Middleton                                  Some relief for Bridge Street is already          is encouraged to create a modal shift as
                                                    required and it is disappointing to see that it   outlined in the Core Spatial Strategy. This
                                                    is only seen as 'potential'. Preferred Policy     will be further promoted in the next iteration
                                                    Direction = 5                                     of this AAP – Proposed Submission.




                                                                                                                                   210
                                                    Following the recent presentation in
                                                    Desborough with regard to the intention to
                                                    build a further 700 dwellings in each small
                                                    market town, I would like to raise some
                                                    reservations. Whilst I understand that the
                                                    need for further dwellings is government led
                                                    and therefore to a certain extent your hands
                                                    are tied - I do have a major concern that the
                                                    health services in both Rothwell and
                                                    Desborough will not be able to cope with a
                                                    further influx of patients judging by how long
                                                    we have to wait now to get a GP
                                                    appointment. But an ever greater concern is
                                                    the bed situation at Kettering General
                                                                                                     Contributions are likely to be sort from the
                                                    Hospital. The pressures on this hospital are
                                                                                                     Primary Care Trust to fund improvements to
         Mrs Beryl                                  enormous and whilst it cannot be
289179               paragraph   8.0.3   Disagree                                                    health care provision. Further details of this
         Norman                                     generalised, possibly a large number of new
                                                                                                     will be contained in the next iteration of this
                                                    homes would be taken by young couples,
                                                                                                     AAP - Proposed Submission.
                                                    with a possible increase in the local birth
                                                    rate. This at a hospital that already copes
                                                    with wide catchment areas, as well as taking
                                                    many patients from Market Harborough area
                                                    who choose - as is their right - to have their
                                                    babies at Kettering General Hospital. Not
                                                    just the maternity services will be over-
                                                    stretched as the outpatient services, which
                                                    are already slow, will be further
                                                    compromised. I was assured that extra
                                                    schooling would be provided for these new
                                                    build homes, but I feel the extra pressure on
                                                    the local NHS facilities has been somewhat
                                                    overlooked.




                                                                                                                                   211
                                                             CJC welcome the publication of the Position
                                                             Statement and the account it provides of the
                                                             events arising since the publication in
                                                             September 2006 of the Rothwell and
                                                             Desborough Urban Extension Area Action
                                                             Plan Preferred Options Paper. CJC note and
                                                             support the Councils continued identification
                                                             of Desborough North as the most
                                                             sustainable/appropriate location to
                   Partner
         Mr John                                  Strongly   accommodate some 700 dwellings at
289501             Pegasus    paragraph   3.2.2                                                               Noted
         Holden                                   Agree      Desborough to address the distribution of
                   Planning
                                                             housing described at Policy 10 and Table 5
                                                             of the North Northamptonshire Core Spatial
                                                             Strategy. CJC particularly endorse the
                                                             comment at paragraph 3.2.2 of the Position
                                                             Statement that Desborough North maximises
                                                             the use of existing infrastructure by building
                                                             upon the nature/physical extent of the
                                                             existing community and public transport
                                                             provision.




                                                                                                                      212
                                                               We note the content of paragraph 3.3.1 of
                                                               the Position Statement but would observe
                                                               that reference also needs to be made to the
                                                               East Midlands Regional Plan which was
                                                               published by the Secretary of State for
                                                               Communities and Local Government on 12th
                   Partner                                     March 2009. In preparing their comments,
         Mr John
289501             Pegasus    paragraph   3.3.1   No opinion   CJC have also taken into consideration the    Noted
         Holden
                   Planning                                    North Northamptonshire Core Strategy
                                                               Review Regulation 25 Consultation issued
                                                               by the North Northamptonshire Joint
                                                               Planning Unit in February 2009 and the
                                                               North Northamptonshire Joint Planning Unit
                                                               Strategic Housing Land Availability
                                                               Assessment published in February 2009.




                                                                                                                     213
                                                          A planned urban extension at Desborough is
                                                          in accord with the North Northamptonshire
                                                          Core Spatial Strategy. Paragraph 3.80 of the
                                                          CSS anticipates smaller sustainable urban
                                                          extensions at four settlements, including
                                                          Desborough. That growth will secure new
                   Partner
         Mr John                                          investment and population to help to
289501             Pegasus    paragraph   4.0.4   Agree                                                  Noted
         Holden                                           regenerate the town centres and
                   Planning
                                                          strengthen/improve local services.
                                                          Paragraph 4.31 of the CSS indicates that
                                                          smaller sustainable urban extensions will be
                                                          brought forward at the smaller towns within
                                                          North Northamptonshire, including
                                                          Desborough.




                                                                                                                 214
                                                               Paragraph 4.0.3 of the Position Statement
                                                               indicates that the adoption of the CSS has
                                                               necessitated a re-examination of the quantity
                                                               of employment land required within the
                                                               Borough. Paragraph 4.0.4 of the Position
                                                               Statement observes that the adoption of the
                                                               CSS has resulted in a strategic requirement
                                                               for less B1 jobs, more B2 employment
                                                               opportunities and less B8 jobs. A planned
                                                               urban extension at Desborough is in accord
                                                               with the North Northamptonshire Core
                                                               Spatial Strategy. Paragraph 3.80 of the CSS
                                                               anticipates smaller sustainable urban
                                                               extensions at four settlements, including
                                                               Desborough. That growth will secure new
                   Partner                                     investment and population to help to
         Mr John
289501             Pegasus    paragraph   4.0.8   No opinion   regenerate the town centres and                 Noted
         Holden
                   Planning                                    strengthen/improve local services.
                                                               Paragraph 4.31 of the CSS indicates that
                                                               smaller sustainable urban extensions will be
                                                               brought forward at the smaller towns within
                                                               North Northamptonshire, including
                                                               Desborough. We acknowledge the content of
                                                               paragraph 4.0.8 of the Position Statement
                                                               and would note that some land allocated for
                                                               employment purposes at Magnetic Park
                                                               remains undeveloped. We would comment
                                                               that the employment land provision/location
                                                               described at paragraph 4.0.8 underpins the
                                                               validity/sustainability of the Councils
                                                               Preferred Policy Direction 4 which requires
                                                               the provision of 700 dwellings and
                                                               associated facilities at Desborough North.




                                                                                                                       215
                                                          CJC support the vision for the AAP
                                                          described at paragraph 6.2.1 of the Position
                                                          Statement. Preferred Policy Direction 4 is
                                                          complementary to and will complete the
                                                          sustainable urban extension being
                                                          implemented at The Grange. Policy 16 of the
                                                          North Northamptonshire Core Spatial
                                                          Strategy describes the approach to the
                                                          provision of sustainable urban extensions
                                                          which are expected to incorporate an
                   Partner
         Mr John                                          appropriate level of retail, leisure, social,
289501             Pegasus    paragraph   6.2.1   Agree                                                    Noted
         Holden                                           cultural, community and health facilities that
                   Planning
                                                          meet local needs but do not compete with
                                                          the relevant town centre. Paragraph 4.34 of
                                                          the CSS expects the sustainable urban
                                                          extensions to create substantial new
                                                          communities that will function as sustainable
                                                          neighbourhoods, integrated physically and
                                                          socially into the existing urban structure.
                                                          Appropriate community facilities will support
                                                          the establishment of sustainable
                                                          communities.




                                                                                                                   216
                                                               CJC consider that Preferred Policy Direction
                                                               4 will complement/complete The Grange and
                                                               create a sustainable neighbourhood which
                                                               will enhance and form part of the existing
                                                               urban structure of Desborough. Paragraph
                                                               4.5 of the CSS states that building
                                                               sustainable communities in North
                                                               Northamptonshire is all about adopting an
                                                               integrated approach to development and the
                                                               way it relates to existing infrastructure and
                                                               established built areas. Paragraph 4.6 of the
                                                               CSS notes that sustainable communities are
                                                               those where the needs of both the existing
                                                               and future population are met whilst
                                                               paragraph 4.8 of the CSS observes that the
                                                               starting point for the CSS is that new
                                                               development should retain and, where
                   Partner
         Mr John                                               possible, enhance existing community
289501             Pegasus    paragraph   8.0.6   No opinion                                                      Noted
         Holden                                                assets, services and facilities. The
                   Planning
                                                               development proposed at Preferred Policy
                                                               Direction 4 will be well related to the existing
                                                               urban structure of Desborough and can be
                                                               implemented in a manner which responds to
                                                               the content of Policy 13 of the North
                                                               Northamptonshire Core Spatial Strategy. The
                                                               vision for the AAP will be achieved by the
                                                               implementation of Preferred Policy Direction
                                                               4. The Grange has been planned as a
                                                               sustainable urban extension and
                                                               Desborough North will appropriately
                                                               complement the existing urban form and
                                                               community facilities. The delivery of the
                                                               vision for the AAP will not be secured by
                                                               seeking to focus almost solely upon the
                                                               perceived physical relationship between an
                                                               urban extension and the town centre. Such a




                                                                                                                          217
restricted view of sustainability represents an
ill-considered appreciation of a sustainable
extension to Desborough which will expand
upon and enhance existing/proposed leisure
facilities, employment opportunities and the
country park at The Grange.




                                                  218
                                                                Paragraph 10 of PPS3 requires the planning
                                                                system to achieve specific outcomes when
                                                                delivering housing schemes. Housing
                                                                developments are to be provided in suitable
                                                                locations which offer a good range of
                                                                community facilities and with good access to
                                                                jobs, key services and infrastructure. This
                                                                outcome will be achieved by the relationship
                                                                between Desborough North and the existing
                                                                urban framework, including The Grange.
                   Partner                                      Equally, Desborough North will address
         Mr John
289501             Pegasus    paragraph   10.1.1   No opinion   directly and in a positive manner the            Noted
         Holden
                   Planning                                     requirement established at paragraph 38 of
                                                                PPS3 that sites for new housing must take
                                                                into account the accessibility of the proposed
                                                                development to existing local community
                                                                facilities, infrastructure and services,
                                                                including public transport. The location of
                                                                housing should facilitate the creation of
                                                                communities of sufficient size and mix to
                                                                justify the development of, and sustain,
                                                                community facilities, infrastructure and
                                                                services.




                                                                                                                         219
                                                          CJC support Preferred Policy Direction 1
                                                          which states that the AAP will make
                                                          provision for urban extensions at Rothwell
                                                          and Desborough as outlined in the Core
                                                          Spatial Strategy. We note that Preferred
                                                          Policy Direction 1 will require improved
                                                          connectivity between the two towns and will
                                                          seek to enhance the individuality of the two
                                                          communities through the location, design,
                                                          association and integration of the extensions
                                                          into the wider townscapes. The
                                                          accommodation of further growth at
                                                          Desborough reflects the content of section
                                                          4.1 of the East Midlands Regional Plan.
                                                          Paragraph 4.1.3 of the EMRP anticipates
                                                          development being accommodated at
                                                          smaller towns in Northamptonshire, including
                   Partner
         Mr John                                          Desborough, outside the main growth
289501             Pegasus    paragraph   7.0.2   Agree                                                     Noted
         Holden                                           centres of Northampton, Corby, Kettering
                   Planning
                                                          and Wellingborough. Desborough is
                                                          specifically referred to as forming part of the
                                                          Spatial Framework described at Policy
                                                          MKSM SRS Northamptonshire 1. Paragraph
                                                          4.1.8 of the East Midlands Regional Plan
                                                          indicates that the smaller settlements such
                                                          as Desborough will seek to consolidate and
                                                          extend their roles in providing for local
                                                          services. A balanced range of housing,
                                                          employment and local services/facilities
                                                          should be secured whilst protecting local
                                                          identity, including preventing coalescence
                                                          with neighbouring settlements. Growth at
                                                          Desborough and the other smaller towns will
                                                          be accommodated in line with the sequential
                                                          approach primarily within the existing built up
                                                          areas or in the form of one or more




                                                                                                                    220
sustainable extensions at each town. The
exact scale, nature and location of growth
and any enhancement proposals will be
determined through the preparation of LDDs.
Preferred Policy Direction 1 is supported not
only by the North Northamptonshire Core
Spatial Strategy but also the East Midlands
Regional Plan (Regional Spatial Strategy)
which was published on 12th March 2009.




                                                221
                                                          CJC support Preferred Policy Direction 2 as
                                                          it indicates that the urban extensions will
                                                          create a distinct neighbourhood but will form
                                                          part of the larger community through
                                                          respecting the identity and character of each
                                                          town. Preferred Policy Direction 4 will
                                                          complement the sustainable extension of
                                                          Desborough at The Grange. We would
                                                          observe that Preferred Option (PO4) of the
                   Partner
         Mr John                                          Rothwell and Desborough Urban Extension
289501             Pegasus    paragraph   7.0.4   Agree                                                     Noted
         Holden                                           Area Action Plan Preferred Options Paper
                   Planning
                                                          stated that Desborough North maximises the
                                                          use of existing infrastructure, building on the
                                                          existing community and public transport
                                                          infrastructure. We agree with Preferred
                                                          Option (PO4) and would note that alternative
                                                          options at Desborough were rejected on the
                                                          basis of impact on the environment, ability to
                                                          build sustainable communities, accessibility
                                                          and access to the town centre.




                                                                                                                    222
                                                          CJC support Preferred Policy Direction 4
                                                          which proposes the allocation of land to
                                                          accommodate new housing at Desborough
                                                          North. The description of Desborough Norths
                                                          location readily identifies its
                                                          close/sustainable linkages with The Grange,
                                                          Magnetic Park and the outstanding
                                                          commitment for employment land. Other
                                                          Options Considered CJC support fully the
                                                          Councils conclusion that Desborough North
                                                          is the most appropriate/sustainable location
                                                          for the development described in Preferred
                                                          Policy Direction 4. Equally, they endorse the
                                                          Councils decision to reject Desborough West
                                                          as a potential policy direction as shown on
                                                          Plan 4. We have reviewed the Councils
                                                          Sustainability Appraisal and would concur          Noted. The Local Planning Authority also
                   Partner
         Mr John                                          with the observations contained therein with       note the comments with regard to the
289501             Pegasus    paragraph   8.0.6   Agree
         Holden                                           regard to Desborough West. We note the             deliverability of Desborough North and the
                   Planning
                                                          observation that the pocket park physically        SHLAA.
                                                          separates the extension from the town
                                                          centre. The preferred site is more compact
                                                          and therefore closer to services. Equally, we
                                                          have noted the Councils observation that
                                                          due to the linear form of the development
                                                          and the separation from the town by the
                                                          pocket park the community will find it harder
                                                          to assimilate. The Councils commentary
                                                          states that the site would not easily
                                                          assimilate into the existing fabric of the town.
                                                          Furthermore, the Councils comments note
                                                          that parts of the site are remote from the
                                                          town centre and may use A6 as a direct
                                                          route out of Desborough for services. We
                                                          would observe that paragraph 2.6 of the
                                                          Urban Extension Area Action Plan Preferred




                                                                                                                                         223
Options Paper states that the B576 stills
forms a major barrier to housing areas east
and west of the towns. Page 15 of the
Councils Sustainability Appraisal states that
Desborough North, when compared with the
rejected options, provided better integration
with the existing communities recently
developed and the town and would build
upon that community. It performed well in
terms of providing an opportunity to enhance
biodiversity and Green Infrastructure. By way
of contrast, Desborough West gave rise to
increased areas of uncertainty and did not
perform as well in terms of community
development, land efficiency and impact on
biodiversity and landscape. The Council
stated that the preferred option is to proceed
with Option 1, which provides for high
deliverability and community and
environmental benefits. North
Northamptonshire Strategic Housing Land
Availability Assessment We have noted that
the North Northamptonshire Joint Planning
Unit Strategic Housing Land Availability
Assessment: Volume 2 Appendices to Main
Report (February 2009) describes
Desborough North as a Category 3 site.
Paragraph 8.15 of Volume 1 Main Report
indicates that sites in Category 3 have more
significant constraints; for these sites to be
considered appropriate for development or
for allocation it would have to be clearly
demonstrated that the significant constraints
could be overcome in order to make them
deliverable. The constraints assumed to exist
in the context of Desborough North are not




                                                 224
described in the Appendices. Given our own
analysis and the content of the Councils
Sustainability Appraisal, we find it extremely
difficult to understand how the SHLAA has
identified Desborough North as a Category 3
site. It would appear that one of the key
concerns arising in the context of Category 3
sites is the extent to which they are
deliverable as defined at paragraph 54 of
PPS3. We can confirm that Desborough
North is available, suitable and achievable.
Furthermore, as the Councils Sustainability
Appraisal acknowledges, Desborough North
is not within a flood risk zone, the allocation
of the site will support the development of
sustainable transport systems, additional
development will give rise to improved
community provision and the site can be
integrated with the existing physical fabric of
the town. We do not consider that the
conclusion regarding Desborough North in
the SHLAA is credible or robust. We would
note that paragraph 6.14 of the North
Northamptonshire Strategic Housing Land
Availability Assessment: Volume 1 –Main
Report states clearly that the inclusion of a
site in a higher Category band should not be
taken to represent a recommendation that it
should be allocated in the LDF, as our
categorisation process does not take
account of all the policy considerations that
are relevant in selecting sites for allocation.
Equally, it should not be concluded that a
site assigned to a lower Category band
cannot come forward, or that it cannot be
allocated for development. Rather, it would




                                                  225
need to be demonstrated that the sites
constraints could be overcome in order to
secure its deliverability. We are not aware of
any constraints that would question the
deliverability of Desborough North. The
SHLAA has inappropriately considered the
merits of Desborough North and placed the
site in an incompatible Category. Paragraph
8 of the SHLAA: Executive Summary of
Study Findings clearly acknowledges that
the SHLAA does not in any way prejudice
decisions to be taken by the Joint Planning
Committee or the individual district/borough
planning authorities in relation to preferred
directions of growth, site identification in
Development Plan Documents (DPDs) or the
determination of planning applications.
Paragraph 9 of the Executive Summary
recognises that considerable further work will
be required in order to ensure that the
identification of sites in DPDs is based on
sound and up-to-date information. Paragraph
10 notes that the SHLAA will be reviewed on
an annual basis and it is at this time that new
and updated assumptions regarding the sites
assessed through the study can be captured.




                                                  226
                                                                CJC acknowledge the observation at
                                                                paragraph 9.2.10 of the Position Statement
                                                                that Desborough North will incorporate a
                                                                local centre providing a small number of
                                                                jobs. It is also extremely well related to
                                                                Magnetic Park and the remaining
                   Partner
         Mr John                                                employment land allocation there. Thus,
289501             Pegasus    paragraph   9.2.10   No opinion                                                  Noted
         Holden                                                 Desborough North is accompanied by a
                   Planning
                                                                choice of employment opportunities and the
                                                                relationship between homes and jobs will
                                                                contribute to the objective of ensuring that
                                                                North Northamptonshire has a diverse
                                                                economy that is not overly dependent on
                                                                commuting.




                                                                                                                       227
                                                                Preferred Policy Direction 7 suggests that
                                                                development at Desborough will contribute
                                                                to the regeneration of the town centre.
                   Partner
         Mr John                                                Connectivity to the town centre, including
289501             Pegasus    paragraph   9.2.14   No opinion                                                     Noted
         Holden                                                 provision across the railway line, will be
                   Planning
                                                                improved in association with the
                                                                implementation of the AAP for the purposes
                                                                of walking and cycling.




                                                                CJC acknowledge the requirement in
                                                                Preferred Policy Direction 8 to the effect that
                                                                Desborough North will make provision for
                                                                live/work units which offer flexible living and
                                                                working space for small businesses. This
                   Partner                                      approach is supported as it will enable the
         Mr John
289501             Pegasus    paragraph   9.2.15   Agree        creation of a range of jobs and help to           Noted
         Holden
                   Planning                                     reduce the need to travel. The sustainability
                                                                of The Grange and Desborough North is
                                                                underlined by the proximity of Magnetic Park
                                                                and the remaining 2 hectares of the
                                                                employment land allocation that have yet to
                                                                be implemented.




                                                                                                                          228
                                                          CJC support Preferred Policy Direction 9
                                                          which states that the AAP will accommodate
                                                          an appropriate level of retail development
                                                          within the proposed urban extension to
                   Partner                                accommodate the day-to-day needs of the
         Mr John
289501             Pegasus    paragraph   9.3.1   Agree   local community. The identification of a        Noted
         Holden
                   Planning                               preferred urban extension at Desborough
                                                          North will provide the opportunity to enhance
                                                          the provision of community and service
                                                          facilities being provided in conjunction with
                                                          The Grange.




                                                                                                                  229
                                                               In the light of the content of paragraphs 46,
                                                               47 and 50 of PPS3, we acknowledge the
                                                               intention of Preferred Policy Direction 10 to
                                                               provide a range of densities for the urban
                                                               extensions. In addition, we would observe
                   Partner                                     that good design is fundamental to using
         Mr John
289501             Pegasus    paragraph   9.4.2   No opinion   land efficiently and achieving the              Noted
         Holden
                   Planning                                    development of high quality new housing
                                                               which contributes to the creation of
                                                               sustainable, mixed communities. Preferred
                                                               Policy Direction 10 follows the guidance to
                                                               be found at Policy 16 of the North
                                                               Northamptonshire Core Spatial Strategy.




                                                                                                                       230
                                                          4.6. CJC support Preferred Policy Direction
                                                          11 which seeks to ensure the provision of a
                                                          range of housing. Policy 16 of the CSS
                                                          states that master plans will be produced for
                                                          all sustainable urban extensions and should
                                                          make provision for a broad balance and
                                                          range of housing choice, including both
                   Partner
         Mr John                                          market and affordable housing. Paragraph
289501             Pegasus    paragraph   9.4.4   Agree                                                   Noted
         Holden                                           23 of PPS3 states that developers should
                   Planning
                                                          bring forward proposals for market housing
                                                          which reflect demand and the profile of
                                                          households requiring market housing, in
                                                          order to sustain mixed communities.
                                                          Paragraph 26 of PPS3 states that local
                                                          planning authorities should plan for the full
                                                          range of market housing.




                                                                                                                  231
                                                               Preferred Policy Direction 12 states that the
                                                               AAP will seek to achieve affordable housing
                                                               provision of 30%. The precise mix of tenure
                                                                                                               Noted, this policy direction is intended not to
                                                               will be based on local need. We note that the
                   Partner                                                                                     set the percentage requirement of affordable
         Mr John                                               affordable housing requirement reflects the
289501             Pegasus    paragraph   9.5.3   No opinion                                                   housing but ensure that the type and size of
         Holden                                                content of Policy 15 of the North
                   Planning                                                                                    housing required is in accordance with the
                                                               Northamptonshire Core Spatial Strategy
                                                                                                               relevant HMA.
                                                               which states that affordable housing
                                                               provision in Kettering Borough will be sought
                                                               in line with the identified target of 30%.




                   Partner                                     CJC support the approach described at
         Mr John
289501             Pegasus    paragraph   9.6.3   Agree        Preferred Policy Direction 13 and Preferred     Noted
         Holden
                   Planning                                    Policy Direction 14.




                                                                                                                                            232
                                                              CJC acknowledge the fact that Policy 16d) of
                                                              the North Northamptonshire Core Spatial
                                                              Strategy requires sustainable urban
                                                              extensions to incorporate an appropriate
                                                              level of community infrastructure that meets
                                                              local needs. Given that context, we do not
                                                              object to the proposition that Desborough
                                                              North should make an appropriate
                                                              contribution to the provision of necessary
                                                              community facilities that are directly related
                                                              to the nature and size of the urban extension
                                                                                                                Noted, the developer will only be expected
                                                              proposed at Desborough North. Paragraph
                                                                                                                to provide facilities which will serve the
                                                              B5 of Annex B to ODPM Circular 05/2005
                                                                                                                urban extension. However, a close
                                                              states that planning obligations must be
                                                                                                                geographical link does not necessarily
                                                              directly related to the proposed
                                                                                                                determine whether a facility will or will not be
                                                              development. We do not consider that all the
                                                                                                                put under pressure from the urban
                                                              proposed contributions sought from
                   Partner                                                                                      extension. The list is intended to provide
         Mr John                                              Desborough North at Preferred Policy
289501             Pegasus    paragraph   9.7.14   Disagree                                                     examples of the types of provision
         Holden                                               Directions 15 and 16 are either directly
                   Planning                                                                                     necessary to serve the proposed additional
                                                              related to Desborough North or necessary to
                                                                                                                populations at both Rothwell and
                                                              make that urban extension acceptable in
                                                                                                                Desborough. Also, the list is not exhaustive
                                                              planning terms. Whilst we accept the
                                                                                                                and contributions/provision should be made
                                                              proposition that Desborough North be
                                                                                                                in accordance with the necessary
                                                              supported by an extension to the country
                                                                                                                requirements to be outlined in the next
                                                              park established in connection with The
                                                                                                                iteration of the AAP – Proposed Submission.
                                                              Grange and an enlargement of the leisure
                                                              centre to be constructed at The Grange,
                                                              other requirements are not fairly and
                                                              reasonably related in scale and kind to the
                                                              proposed urban extension at Desborough
                                                              North. It is difficult to establish how some of
                                                              the proposed contributions exhibit a
                                                              functional or geographical link between
                                                              Desborough North and the item being sought
                                                              as part of the wider developer contribution.
                                                              Those contributions/payments must be




                                                                                                                                              233
directly related in scale to the impact which
the proposed development will make.
Contributions sought from Desborough North
should not be used to resolve existing
deficiencies in infrastructure/community
service provision. Decisions on the level of
contributions should be based on negotiation
with intending developers regarding an
approach that can be demonstrated as
reasonable to be taken while still allowing
development to proceed and be
economically viable.




                                                234
                                                                CJC acknowledge the observation at
                                                                paragraph 9.12.1 of the Position Statement
                                                                that the success of the proposed urban
                                                                extensions at Desborough and Rothwell is
                   Partner                                      dependent upon the ability to create
         Mr John
289501             Pegasus    paragraph   9.12.1   No opinion   communities that appear and feel like part of   Noted
         Holden
                   Planning                                     the existing towns. Desborough North is
                                                                complementary to the existing development
                                                                at The Grange where community facilities
                                                                are being provided for the benefit/use of the
                                                                town as a whole.




                                                                                                                        235
                                                                The provision of Desborough North accords
                                                                with the principles established at paragraph
                                                                38 of PPS3, including the requirement to
                                                                ensure the accessibility of any proposed
                   Partner                                                                                        This will need to be demonstrated in detail
         Mr John                                                development area to existing local
289501             Pegasus    paragraph   9.12.1   No opinion                                                     on receipt of a planning application and in
         Holden                                                 community facilities, infrastructure and
                   Planning                                                                                       accordance with this AAP.
                                                                services, including public transport. Preferred
                                                                Policy Direction 22 will provide the basis for
                                                                the production of an appropriate master plan
                                                                for Desborough North.




                                                                CJC recognise the need to ensure that the
                                                                proposed urban extension will contribute to
                   Partner                                      the success and prosperity of the town
         Mr John
289501             Pegasus    paragraph   9.13.1   No opinion   centre. This objective can be secured by a        Noted
         Holden
                   Planning                                     combination of means, including those
                                                                described at paragraph 9.13.1 of the Position
                                                                Statement.




                                                                                                                                              236
                                                             I refer to my letter dated 28 November 2008      The Kettering Borough Employment Land
                                                             in connection with the above Area Action         Breakdown report of 16 September 2008
                                                             Plan (AAP) and to the Council's recently-        provided an assessment of the number of
                                                             published Position Statement thereon. We         jobs available against the working age
                                                             act on behalf of Goodman International Ltd       population of the towns within Kettering
                                                             (formerly Rosemound Developments Ltd).           Borough. This assessment considered those
                                                             This letter contains the response of the         employment developments delivered in the
                                                             Company to the Council's latest position in      period 2001-2008 and then projected
                                                             relation to employment land at Desborough        forward to include population forecasts for
                                                             in the context of the AAP. In particular, it     the end of the plan period, 2021 based on
                                                             refers to the Desborough North West              the planned levels of growth including the
                                                             element of Preferred Option PO4 of the AAP       Urban Extensions at Kettering, Rothwell and
                                                             Preferred Options Paper 2006. The site           Desborough. In Desborough as detailed in
                                                             includes an additional parcel of land to the     the Employment Breakdown Report since
                                                             north-east and is indicated on the attached      publication of the Preferred Options
                                                             plan. The site has also been recently            Document land to the north of the Grange
                                                             promoted through the Northamptonshire            and an extension of Rigid Containers has
         Julie     Holmes                                    Strategic Employment Land Assessment             received detailed planning approval for
289666                      paragraph   4.0.1   No opinion
         Warwick   Antill                                    (SELA) 'call for sites' process. The Council's   15.29 hectares of employment. To date
                                                             stance has not changed regarding                 12.27 hectares of B8 development out of the
                                                             employment land in Desborough since my           total 15.29 hectares has been developed
                                                             previous letter, therefore many of the           and is providing jobs within Desborough.
                                                             comments made in that letter still stand, and    This employment development is therefore
                                                             are re-iterated here. As you know, the           significantly contributing to employment
                                                             Desborough Consortium (made up of CJC            development and the provision of jobs in
                                                             Development Co. Ltd and Goodman) was             Desborough during this plan period, which
                                                             formed directly in response to the Council's     for both the CSS and the Rothwell and
                                                             request to ioin forces and promote PO4 in a      Desborough Urban Extension Area Action
                                                             comprehensive, collective manner (i.e.           Plan is the period 2001 to 2021. In autumn
                                                             Desborough North and Desborough North            2006, the Rothwell and Desborough Urban
                                                             West). Whilst the Council is supporting          Extension Area Action Plan: Preferred
                                                             Desborough North for housing development,        Options was publically consulted upon. At
                                                             it has rejected the formerly-proposed            this time the Northamptonshire County
                                                             employment allocation at Desborough North        Structure Plan outlined the requirement for
                                                             West. It is our view that both sites should be   urban extensions to both Rothwell and
                                                             promoted for the purposes set out in the         Desborough. Also, the Kettering Borough




                                                                                                                                         237
Preferred Options Paper as this still          Local Plan employment land allocation on
represents the most appropriate spatial        land to the north of Desborough, allocated in
response to the creation of a sustainable      1995 had not been brought forward. The
community at Desborough. Our clients wish      Structure Plan policy SDA1, the Borough
to make clear to the Council that they         Employment Land Requirements Quantity
endorse the Desborough Preferred Option        paper (June 2006) and the
as set out in the Options Paper of             Desborough/Rothwell SDA Employment
September 2006 and continue to promote         Needs and Availability paper (June 2006)
that concept. Whilst this letter of            provided the evidence base for the
representation is concerned with the           proposed employment land allocations in
promotion of Desborough North West, it         Rothwell and Desborough, as outlined in the
should not be viewed in isolation from         Preferred Options. The responses from the
Desborough North as both sites are             Preferred Options consultation were
fundamental in terms of the creation of        considered by planning policy committee in
sustainable development and indeed both        June and July 2007. The relevant committee
sites are viewed together as one Option (the   reports, attachments and minutes of those
Preferred Option) in the Preferred Options     meetings are available on our website at
Paper. North Northamptonshire Core Spatial     www.kettering.gov.uk. The reports have
Strategy During the autumn of 2008, the        been attached for your reference. In view of
Council decided that there was no longer a     these reports, Members resolved that
requirement for 36 hectares of employment      Officers should seek additional information
land to be allocated at Rothwell and           regarding preferred and rejected sites to
Desborough (Report to the Planning Policy      support their proposals. On 12 June 2008,
Committee 16 September 2008). Following        the Core Spatial Strategy for North
the adoption of the North Northamptonshire     Northamptonshire was adopted. Policy 1 of
Core Spatial Strategy (CSS) in June 2008,      the Core Spatial Strategy (CSS) states that
the Council re-calculated its future           all future development is to be principally
employment land requirements and               directed towards the urban core with a focus
subsequently considered that the total         on the three main Growth Towns of Corby,
requirement for both towns was 7 hectares      Kettering and Wellingborough. The CSS
(4 hectares at Rothwell and 3 hectares at      also introduced net job figures by district
Desborough). The February 2009 Position        and sector, as detailed in table 6, not
Statement now states that no further           specific land requirements. Guidance on the
employment allocation is required for          conversion of job numbers to land
Desborough, hence the previous allocation      requirements is provided by the CSS
of 36 hectares for both towns is now reduced   Technical Note for partner Local Planning




                                                                           238
to just 4 hectares for Rothwell. The Council's   Authorities on translation of job numbers
justification for the removal of any             into employment land requirements January
employment allocation for Desborough is          2008. The adoption of the CSS required a
based around the desire to regenerate            review of the previously identified
Desborough Town Centre, the existence of         employment proposals. ˜Kettering Borough
remaining employment land at Magnetic            Employment Land Requirements Quantity
Park (a former Local Plan allocation of which    Update July 2008" translated job numbers
approximately only 2 hectares remain) and        outlined in table 6 of the CSS into land
the aim of the CSS to concentrate                areas (as outlined in the attached committee
development in the urban core of Kettering.      report dated 30 July 2008). Using this
We consider the conclusions drawn by the         translation, only 12 hectares of B1, 12
Council to be unduly inflexible and contrary     hectares of B2 and no further B8 were
to the numerous comments in the evidence         identified as required employment land for
base already assembled regarding the need        the whole of Kettering Borough. The
to achieve a strong local economy,               previous employment land allocation at
contributing to the creation of a balanced,      Desborough would considerably exceed the
sustainable community. One of the key            entire Boroughs allocation. This would not
objectives of the CSS is the achievement of      be in accordance with the Policy 1 of CSS.
a spatial planning framework which will          During the review of above-mentioned
contribute in a positive manner to the           Kettering Borough employment papers it
reduction in commuting flows. Given this         was identified that the previous total
context, the planned increase in housing at      employment land allocation figure for
Desborough would be expected to be               Desborough at 2006, as outlined in the
supported by significantly more local            Preferred Options, should be reduced by
employment opportunities than now                any subsequent employment permission
envisaged by the Council. The CSS has            granted from that point on. This included the
been prepared over a period of time, the         land identified in the Local Plan where Great
various stages of which will have been taken     Bear, Magnetic Park has been constructed.
into account throughout the evolution of the     This has therefore been taken into
Preferred Options for Rothwell and               consideration in the revised allocations.
Desborough. The change of direction by the
Council in effectively setting aside the
Preferred Options Paper following the
adoption of the CSS suggests that there are
significant differences between the version
submitted to the Secretary of State in




                                                                             239
February 2007 and the version adopted in
June 2008. A comparison of these two
documents however shows that the policies
and provisions in relation to employment,
Sustainable Urban Extensions and mixed
uses have not changed. In particular, Table
6 of the CSS, which relates which relates to
job growth for each District (by sector)
seems to have been the driving force behind
the Council's recalculation of employment
land requirements, yet this remains
unchanged. Equally, Policy 16 of the CSS,
which requires all sustainable urban
extensions in North Northamptonshire to
incorporate a wide range of local
employment opportunities that offer a choice
of jobs and training prospects, remains
unchanged but does not appear to have
been taken into account by the Council. The
AAP Preferred Options Paper assessed the
employment land requirement to be provided
at Desborough within the context of the
wider policy framework at that time. We do
not consider that the adoption of the Core
Spatial Strategy leads to a position which
fundamentally requires such a wholesale
removal of additional employment land
provision at Desborough now advocated in
the Position Statement. We would direct the
Council to paragraphs 5.1 1 and 5.12 of the
AAP Preferred Options Paper of September
2006 wherein it is noted that a potential
approach would be to reduce the quantity of
employment land, leading to an increased
level of out-commuting, "but this option was
rejected on the basis that it would not




                                               240
achieve the maximum benefits for
regeneration and not be so sustainable in
terms of commuting patterns." Equally, the
Paper stated that Desborough provides the
greater opportunity "to supply deliverable
sites that are close to the local community
and can be served by a choice of transport".
We have also scrutinised the content of
reports prepared for the Local Planning
Authority in recent years regarding the
provision of further employment
opportunities and can discern therein no
plausible reason to remove a potential
employment land allocation at Desborough.
We can therefore only conclude that the
Council's change of approach to employment
land at Desborough is not a result of 'new'
advice contained in the CSS, but rather a
different (and unsubstantiated) interpretation
on the part of the Council. The spatial policy
position has clearly not changed in the
interim; moreover, it clearly supports the
prospect of additional employment in
Desborough, in our view. By way of example,
and as alluded to earlier, paragraph 3.70 of
the CSS states that it aims to achieve "a
broad balance between homes and new jobs
so that overall commuting patterns into and
out of North Northamptonshire in 2021 are
broadly the same as in 2001." Paragraph
3.74 of the CSS recognises that it is
"desirable to have a link between new
homes and jobs so that the two remain
broadly in balance.” Finally, paragraph 3.83
of the CSS states that the "Sustainable
Urban Extensions will be of sufficient scale to




                                                  241
include a mix of homes, jobs and other uses
and to deliver the high quality infrastructure,
facilities and environment needed to support
a step change in the rate of housing
development and to create thriving
communities where people want to live and
work." The Council's proposed removal of
the provision of new employment areas at
Desborough therefore runs contrary to the
wider sustainable spatial objectives to create
balanced communities in North
Northamptonshire, with particular regard to
the issue of out-commuting. Additionally, in
relation to local job opportunities and out-
commuting, one of the reports to the 16
September 2008 Planning Policy Committee
related to employment land breakdown in
Kettering Borough. It acknowledges that
"there are relatively few employment
opportunities available to local residents of
working age in Rothwell and Desborough"
(as at 2001) and that between 2001 - 2008
the ratio of jobs to working population would
get worse in the two towns. The problem
would inevitably be exacerbated further by
2021 if no additional employment was
created, which obviously begs the question
as to why the Council wishes to remove
further employment development allocations.
The Position Statement suggests that the
balance of the former Local Plan allocation
at Magnetic Park, together with the potential
for redevelopment of sites within close to the
Town Centre for employment uses, will
satisfy the CSS requirements. We would
argue that the Local Plan employment




                                                  242
allocation was to serve the concurrent
housing allocations and therefore the
additional 700 dwellings still proposed for
Desborough as a new allocation will give rise
to the need for additional employment land
over and above that which remains from the
Local Plan and that which can be
accommodated within the Town Centre. The
lack of local job opportunities that will
inevitably result from such an imbalance of
homes and employment will serve only to
worsen problems of out commuting. Indeed,
the aforementioned report states that
"outside the growth town of Kettering modest
employment development will be
encouraged in the plan period and in
particular in those locations which have high
levels of out-commuting at present,
consistent with the CSS." It is contended that
Desborough experiences a significant level
of out-commuting (as is evident in the 2006
Sustainability Appraisal into the AAP) and
that the lack of employment land provision
now proposed can only increase the
problem. The Tables set out in that report
give a very clear picture that the ratio of jobs
to working population in Desborough has
deteriorated between 2001 and 2008, and
that this will be significantly exacerbated by
2021 in the absence of any additional
employment. In terms of the number of
working population per job this equates to
2.26 in 2001; 2.44 in 2008 and 3.08 in 2021.
To get down to the ratio of 2.3 referred to by
the Council would require the provision of an
additional 855 jobs in Desborough to 2021.




                                                   243
Notwithstanding the above, we would argue
that a target that seeks to return to a ratio
similar to the 2001 level is insufficiently
ambitious and clearly will not serve to reduce
out-commuting. Moreover, out-commuting
will continue to rise with the extent of
population growth proposed. This is contrary
to the principles of sustainability and
Government advice (e.g. in relation to eco-
towns) that mixed use developments should
work on the basis of 1 job per dwelling.
Using this approach, 700 new jobs would be
needed to serve the proposed housing
allocation north of The Grange (Desborough
North). This is on top of outstanding job
creation at Magnetic Park, which is an old
allocation to serve previous Local Plan
housing commitments. Although this would
provide a good balance between new homes
and new jobs, it again would not redress the
wider problem of out-commuting from
Desborough. Planning Guidance.
Regional/Strategic Policies and Employment
and Requirements The Council's new
approach to employment provision in
Desborough would therefore appear to
conflict with overarching planning objectives
in relation to sustainable development and a
healthy economy. In addition, the final
revision of the East Midlands Regional Plan
(issued 23 March 2009) states under
paragraph 3.2.8 that in the growth areas
(including Northampton) "there will be a need
to ensure that there are adequate
employment sites to match the needs arising
from increased levels of population. In




                                                 244
addition, the opportunity should be taken to
reshape and change perceptions of the
Northamptonshire employment sites and
premises offer, to promote innovation and
growth.” Our clients do not consider that this
wholesale change in proposed employment
land provision is appropriate when judged
against national planning policy guidance,
the East Midlands Regional Plan, the Milton
Keynes and South Midlands Sub-Regional
Strategy and the spatial planning framework
advanced in the CSS. There is no
justification for the proposed removal of the
employment land component at Desborough
North West, and it is contended that our
clients' approach more appropriately reflects
the wider spatial planning objectives
described in the documents referred to
above. The approach described in the
Council's Position Statement is short-sighted
and contrary to spatial planning objectives
which seek to reduce commuting flows,
achieve sustainable communities and work
towards a more sustainable balance
between homes and jobs. Deliverability The
significant body of work that our clients have
already produced demonstrates that they are
plainly in a position to deliver the
employment element of the Desborough
Preferred Option. Deliverability is key in
realising the aspirations for employment and
hence help to regain economic growth and
thus benefit the local community. In addition
to the significant job opportunities, the
following benefits will also be delivered: The
opportunity to construct a new road link




                                                 245
between the A6 and Harborough Road;
Providing a new bridge over the railway line
to carry the proposed road; The proposed
employment area offers the advantage of
direct access to the A6, leading to the A14,
and resulting in a reduction in HGV
movements through Desborough; Providing
better connectivity to adjacent urban areas
and green infrastructure; Using land of low
landscape sensitivity within the visual
context of Desborough; Enhance public
transport provision to link the town centre
with existing and proposed employment
areas; A traffic calming gate on Braybrooke
Road. These benefits would be enhanced
and supplemented by the complimentary
provision of additional housing at The
Grange, hence the desire to promote the
Desborough North and North West sites as a
single option; indeed, the whole is greater
than the sum of the parts. The Council has
already carried out assessments of the
acceptability of differing tracts of land at the
edge of Desborough to accommodate the
planned urban extension. The Sustainability
Appraisal and Urban Extension Methodology
produced by the Council in June 2006 both
underline the appropriateness of the
Desborough Preferred Option. Paragraph
3.1 1 of the Urban Extension Methodology
notes that the range of employment studies
undertaken "have indicated a potential for
further employment growth at Rothwell and
Desborough to reduce out commuting and
pressure on the AI4 junctions around
Kettering. This would have the benefit of




                                                   246
providing the opportunity to make the towns
more sustainable provided commercial
attractive sites were available which could
come forward early in the plan process." The
Kettering Employment Study of September
2005 highlighted the attractiveness/delivery
of the employment component of the
Desborough Preferred Option. Paragraph
4.5 of the Urban Extension Methodology
maintains that "the direction of growth which
would have the least impact and most
benefit would be a combination of
Desborough North - for residential
development and Desborough North-West -
for employment development. This takes into
account the policy preference for providing
25 hectares of employment land at
Desborough. This would maximise the
benefit of providing a commercially attractive
employment site with good links to the
strategic road network and existing
community. "A report was prepared by the
Head of Development Services for
submission to the Planning Policy Committee
on 1 May 2008 regarding progress in
delivering the Area Action Plan. That report,
which was withdrawn before being formally
considered by the Committee, reviewed the
content of the further submission received by
the Council in December 2007. In relation to
employment, it considered that "land to the
north and north west demonstrates the most
suitable option for development" and that
"the majority of the preferred option
employment site to the north west of
Desborough lies within the 'most desirable'




                                                 247
location for employment.” In the report, the
Head of Development Services
recommended that the Desborough
Preferred Option be taken forward as the
strategy for the town in the submission
version of the AAP. The work provided to the
Council by our clients in June 2004 and
December 2007 underlines that conclusion.
We are therefore at a loss to understand why
the Council had a change of heart between
the publication of this report and the date of
the Planning Policy Committee; there was no
change in the policy framework upon which
the AAP was based, for reasons already
explained above. A number of positive
aspects were identified in that report in
relation to the Desborough Preferred Option,
many of which are of a similar nature to
those identified above. However, our clients
have noted the comments regarding the
perceived negative aspects and these are
addressed below. The May report remarked
that the Preferred Option site is poorly
sewed by existing public transport. A whole
series of new public transport links were
included in the submission scheme
documentation to overcome the existing
deficiencies. This issue can thus be dealt
with appropriately. A contribution towards
Town Centre regeneration would be dealt
with through a s106 agreement in the usual
way. The details of funding and needs would
be negotiated with the Council. The railway
bridge link would form a committed
component of the scheme and is indeed
necessary to improve connectivity, as




                                                 248
acknowledged by the Council, and the
significance of this should not be under-
estimated. Whilst it is not vital to
serve/develop the site, it is required to allow
the internal site roads to act as a 'bypass',
thus relieving Braybrooke Road. It thus
enables vehicles from Desborough North
West and Magnetic Park to directly access
the A6 and A14, without having to pass
through the town. The number of commercial
vehicle movements through the Town Centre
would therefore be reduced. The improved
accessibility clearly also has advantages to
other, existing, development in the north and
west of Desborough. The May report also
pointed to concerns regarding landscaping
and ecology. A full response to these
concerns was set out in my letter of 28
November 2008 and it is still considered that
many positive effects would arise as a result
of the development in connection with
wildlife and biodiversity and green
infrastructure links. Significant landscaping is
proposed to help screen the development
from existing residential areas to the south-
east and the wider open areas to the
west/north-west, thus reducing its visual
impact. Type of Employment Development
The CSS seeks to diversify the local
economy by promoting a higher proportion of
Class B1 and B2 uses and less reliance on
Class 88. It is acknowledged, however that
B8 remains a growth sector and will continue
to be important to the North
Northamptonshire economy (over 9,000 jobs
are forecast in this sector between 2001 and




                                                   249
2021). Previous reports on employment land
have concluded that B8 would be important
on this site in terms of viability and
deliverability and is more likely to provide the
infrastructure needed to attract B1/B2
occupiers - reducing B8 would therefore
affect delivery of B1/B2. It therefore seems to
us that not only should the employment land
set out in the Preferred Option be
maintained, it should include a suitable
element of B8 so as to assist in delivery. This
view is not at odds with the CSS; the
provision of B8 should help in securing B1
and B2 which otherwise may be more
difficult to attract. The Desborough Preferred
Option would be further enhanced by the
inclusion of land off Harborough Road to
facilitate the relocation of the operational
activities of Knights of Old, as indicated on
the attached plan. This is a readily available,
deliverable site which would significantly kick
start the rest of the employment land.
Knights of Old have advised that
Desborough is their only realistic prospect of
remaining in the Borough and hence it is
clearly highly desirable to retain the local
employment associated with the company.
Conclusion For the reasons set out above,
our clients contend that the Desborough
Preferred Option (and adjacent land)
remains the most appropriate, sustainable
and deliverable response to local spatial
planning objectives. The submissions put
forward in December 2007 and November
2008 therefore still stand. It is acknowledged
that the CSS places a focus on the Growth




                                                   250
Towns of Corby, Kettering and
Wellingborough, but equally it has always
promoted supplementary growth within the
identified smaller Sustainable Urban
Extensions, one of which is at Rothwell and
Desborough. Such locations are to include a
mix of uses, including employment. The CSS
has not changed course during its
preparation; its policies in relation to
sustainable development and employment,
including job requirements, have remained
consistent. It is therefore difficult to see why
the Borough Council has now interpreted this
information in a different manner and re-
calculated its employment land
requirements. Moreover, its actions would
appear to be contrary to the advice
contained in planning guidance at the
national and regional level, and to this end
the new AAP proposals would not be in
conformity with such guidance and thus at
odds with Planning Policy Statement 12. In
our view, the Council's new approach
amounts to a complete negation of a
sustainable spatial planning process.
Furthermore, it flies in the face of the
Council's own stated desire to reduce out-
commuting and redress the ongoing
imbalance of jobs and working population.
The Position Statement cites Balanced
Communities as Objective 1, and refers to
the need to provide a broad range of housing
and improved quantity and quality of
employment opportunities to meet strategic
requirements and the needs of local people.
The lack of employment land allocation is




                                                   251
therefore completely at odds with this
important objective. The Position Statement
acknowledges the advantages of the
Desborough North West site of direct access
to the A6 and then the A14 and direct access
to the centre of Desborough for local traffic.
It also refers to the CSS requirement for
modest extensions to Rothwell and
Desborough and the fact that it too aims to
achieve a balance between homes and jobs
so as to avoid over-dependence on in or out
commuting. It then goes on to state that
Desborough North West has now been
rejected on the basis of lack of access and
accessibility to the town centre and failure to
accord with the adopted CSS, among other
factors. There is a clear contradiction here,
within the same document. It is therefore
concluded that the 2006 Desborough
Preferred Option should be reinstated, as
supported by the plethora of evidence that
led to its inclusion in the first place and in the
absence of any evidence to the contrary.




                                                     252
                                                               Sport England strongly supports the contents
                                                               of section 9.7.5 especially the proposals for
                                                               provision of open space, sports pitches and
                                                               built sports facilities including mention of:- In
                                                               Rothwell - Provision of appropriate open
                                                               space in accordance with Supplementary
                                                               Planning Document: - Open Space
                                                               (including allotments). - Additional adult and
                                                               junior football pitches with suitable changing
                                                               accommodation. - Contribution to
                                                               Desborough Leisure Centre, and in
                                                               Desborough - Provision of appropriate open
                     Planning                                  space in accordance with Supplementary
         Mr Tony     Manager                        Strongly   Planning Document: - Open Space
289717                          paragraph   9.7.5                                                                  Noted
         Aitchison   Sport                          Agree      (including allotments). - Contributions to fund
                     England                                   the new Leisure Centre at the Grange plus
                                                               an extension to accommodate the new
                                                               population. - Additional adult and junior
                                                               football pitches with suitable changing
                                                               accommodation. - Contributions to the
                                                               refurbishment of buildings, pitches and other
                                                               associated infrastructure at Desborough
                                                               Town Football Club. - Contributions towards
                                                               the development and possible relocation of
                                                               Desborough Indoor Bowls club. -
                                                               Contributions to the existing outdoor bowls
                                                               green at Dunkirk Ave Recreation Ground to
                                                               improve the facility.




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