WNC Local Plan Consultation
West Northamptonshire Council has prepared a draft Local Plan, out for consultation until 2 June. ‘Local Plan’ is a fairly bland term which perhaps doesn’t convey how very important this document is in determining the future shape of our area and communities – in the case of this Plan until 2041.
The Planning Inspectorate:
“A local plan addresses housing needs and other economic, social and environmental priorities by setting a foundation for longer-term decision making of how a place should change over the next 15 years or so.” https://www.youtube.com/watch?v=b14b_h39_o0
So as residents of West Northamptonshire, we all have skin in the Local Plan game, and ought to take this infrequently offered opportunity to put forward our views.
There are two ways you can respond to the consultation. Firstly, by using WNC's online questionnaire. This invites comments on each of the 15 chapters of the Plan and on the Sustainability Appraisal, plus asking if you agree/don’t agree with the policies within each chapter. There is also an opportunity for more general comments. You do not need to provide comments on every chapter.
The second option is to send an email to localplan@westnorthants.gov.uk setting out your views and concerns. This is less time-consuming, especially if there are just one or two specific issues you want to raise.
**Added 31/05/24** If active travel (cycling, walking, wheeling) is one of your concerns, Living Streets Northampton have done an excellent analysis of the council's actions on this and published their response to the Local Plan on their website. The Living Streets response covers active travel very comprehensively and can either be added to the CA-WN comments below to complete the consultation questionnaire, or pasted into an email. https://livingstreetsnorthampton.org/local-plan-consultation/
The draft Plan and supporting documentation can be found on the WNC consultation page.
CA-WN has sent in a response – our comments are included below for your reference. You are welcome to refer to or copy these as much as you like for your own response to the questionnaire. We haven’t commented on every chapter, as we focused on the areas we felt were most relevant to the climate crisis.
CA-WN response to the consultation:
Chapter 1: Introduction No comments
Chapter 2: Spatial Portrait, Vision and Objectives No comments
Chapter 3: A Spatial Strategy for West Northamptonshire
CA-WN comments on 3.2.4 Planning Practice Guidance
This section states “The strategy of this Plan and the policies that flow from it seeks to meet the guidance set out in PPG.”
The Climate Change Mitigation report included in the evidence base for the plan suggests on several occasions:
“Require higher than national standards of sustainable design and construction in new development and refurbishment requiring planning permission, e.g. via a Supplementary Planning Document (SPD), backed by financial viability evidence.”
We therefore request this section is amended to allow for higher than national standards e.g.: “The strategy of this Plan and the policies that flow from it seeks to meet the guidance set out in PPG, or to deliver higher than national standards where necessary to achieve required levels of climate mitigation and adaptation”.
Chapter 4: Placemaking
CA-WN comments on Policy PL3 – Low Carbon and Renewable Energy Schemes
We request amendment as follows:
"Proposals for large-scale renewable energy development will be supported where, with appropriate mitigation, they do not have a significant adverse impact on any of the following"
It may be necessary to accept limited adverse impact in some cases and not allowing for this is overly restrictive.
CA-WN comments on Policy PL4 - Low Carbon and Renewable Energy for New Development.
This statement:
"Commercial developments should, where practical, incorporate renewable energy into their proposal including the provision of on-site renewable energy, and low carbon technologies such as solar panels or ground source heat pumps."
is unsatisfactory as it allows developers to claim that use of renewable energy is not practical. New commercial developments reliant on fossil fuel for energy are instantly obsolete and will make it harder for the area as a whole to achieve Net Zero.
We request removal of the words 'where practical'.
This summary of the policy does not make it clear that it is relevant to existing as well as new buildings, though this is the case according to clause 12.5.2. (“Proposals for low carbon and renewable energy will be considered against policy PL4”). We request the PL4 summary is amended to make clear the relevance of this policy to existing buildings.
CA-WN comments on Policy PL10 PSID - Healthy Food Choices - Any other approaches we should consider:
Identifying areas where retail outlets offering healthy, good value food choices are not readily accessible to all residents and taking steps to address these eg by actively supporting applications for such outlets or supporting community initiatives to provide healthy, good value food.
We did not have any comments on Chapters 5 to 10
Chapter 11: Economic Growth
CA-WN comments on Policy EC9 - Daventry International Rail Freight Terminal (DIRFT) and Northampton Gateway:
We request clarification of:
"C. Development proposals will be required to:
ii. Integrate green energy principles into their designs, materials and construction process;"
The vagueness of 'green energy principles' as a term could be exploited to deliver minimum possible adherence. We request that a reference be added to documented standards setting out what this term means in practice.
CA-WN additional comments on this chapter:
We welcome the statement under 11.3.3:
"In order to meet this shortfall a site has been identified to the south of Junction 15 of the M1. .....There is therefore no further need for strategic warehousing in West Northamptonshire."
and anticipate that future planning applications for more warehousing will therefore be declined.
Chapter 12: Built and Natural Environment
CA-WN comments on Policy BN10 - Biodiversity Net Gain:
Wording 'aspiring to deliver' in clause B is weak. We request wording of clauses A.ii. and B. are aligned, so that B reads:
"Exempted development must achieve no net loss of biodiversity and should achieve appropriate net gains, making provision for at least 10% biodiversity net gain"
CA-WN comments on Policy BN12 - Trees and Hedgerow in Developments:
Points A and B are duplicated, requires correction:
“A. Proposals for development should seek to integrate existing trees, woodland and hedgerows.
B. Proposals for development should seek to integrate existing trees, woodland and hedgerows.”
CA-WN additional comments on this chapter:
‘Built environment’ in this chapter seems to mean ‘historic built environment’. Consideration needs to be given also to the large number of more modern buildings which are sub-standard in terms of energy efficiency. We request wording change as follows:
“12.5. Climate change
12.5.1. The historic and modern built environment can play an important role in mitigating the effects of climate change and can produce significant benefits for the environment in West Northamptonshire. Appropriate changes to historic and modern buildings can greatly improve their energy efficiency as well as ensuring that the CO₂ emissions embodied within existing buildings are not lost through demolition.”
We request clarification of the following:
“12.5.2. Proposals for low carbon and renewable energy will be considered against policy PL4” (Policy PL4 - Low Carbon and Renewable Energy for New Development).
The brief summary of PL4 included in the plan does not obviously make it an appropriate vehicle for assessing changes to existing buildings. We request summary of PL4 is amended to make clear its relevance to existing buildings.
Chapter 13: Transport
CA-WN comments on Policy TR3 – Future Transport Schemes:
“D. Consideration will also be given to the provision of a Northampton Northern Orbital Road”.
We contend that planning for a vision of the future prioritising active travel and public transport is compromised by choosing to invest in new roads. Building new roads has been proved to have the effect of generating more traffic. We request that this point is removed.
CA-WN additional comments on this chapter:
Under 13.2.8. the ‘Connected communities’ objectives listed are largely focused on roads and cars, with no mention of active travel. This appears to reflect a gap in the Corporate Plan, which includes no objectives relevant to active travel. We request this is addressed in the next version of the Corporate Plan.
Chapter 14: Infrastructure
CA-WN additional comments on this chapter:
14.2.7. “To achieve the above priorities this Plan supports the provision of infrastructure that will help achieve Net Zero by 2030”.
The target of Net Zero by 2030 relates to WNC as an entity only – the context here implies this clause should reference the area-wide Net Zero target of 2045.
Chapter 15: Implementation and Monitoring Framework
CA-WN additional comments on this chapter:
Please explain how any exceptions to the policies set out in the Local Plan will be approved and reported. An annual Authorities Monitoring Report published a long time after the event is not sufficient to enable policy exceptions to be tracked and any trends identified. In order for policies to be effective there must be transparent and timely reporting of exceptions and the reasons for these.
General comments on the draft Plan No comments
Sustainability Appraisal
CA-WN comments on 6.16 SA 15: "To minimise West Northamptonshire’s contribution to climate change and be adaptable to unavoidable climate change"
The detailed commentary in this section makes no reference to activities that will support the aim of being adaptable to climate change, although many are set out in the Climate Change Adaptation Report.
CA-WN comments on Table 7.1: Summary of Proposed Mitigation
"Objective 15 To minimise West Northamptonshire’s contribution to climate change and be adaptable to unavoidable climate change"
The proposed mitigations are limited, mentioning only EV charging points and maximising renewables ‘as far as possible’. Other mitigations include prioritising and providing facilities for active travel and public transport, requiring flood risk assessments, buildings to be designed to reduce risk of overheating, use of green infrastructure to provide shade and cooling.