Pegasus Group

4 The Courtyard | Church Street | Lockington | Derbyshire | DE74 2SL

T 01509 670806 | F 01509 672247 | W www.pegasuspg.co.uk

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GLO.01.glo.5186/P17-0463

04 October 2018

Local Strategy Service

Daventry District Council

Lodge Road

Daventry

Northants

NN11 4FP

Dear Sir/Madam

Daventry Part 2 Local Plan – Submission Draft Consultation

Please find attached representations in relation to the Part 2 Local Plan in relation to land to

the west of Daventry.

Yours faithfully

Guy Longley

Executive Director

guy.longley@pegasusgroup.co.uk Enc: Representations Forms

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This form has two parts: Part A – contact details Part B – your representation Please fill in a separate sheet for each representation you wish to make. Part A

1. Personal Details*

2. Agent’s Details (if applicable)

* If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in column 2.

Title Mr

First name Guy

Last name Longley

Job title (where relevant)

Executive Director

Organisation (where relevant)

Pegasus Group Pegasus Group

Address line 1 4, The Courtyard

Line 2 Church Street

Line 3

City/Town Lockington

County Derbyshire

Postcode DE74 2SL

Telephone number 01509 670806

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

Guy.longley@pegasusgroup.co.uk

Publication Stage (Regulation 19) Proposed Submission Settlements and Countryside

Local Plan (Part 2) for Daventry District (August 2018) Statement of Representation Form

Ref:

(for official use) only)

(for

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Part B: Please use a separate sheet for each representation

Please note all comments will be made publically available. If you do not have sufficient space in the box please continue on a separate sheet or expand the box.

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

Paragraph number

Policy number

Policies Maps

Chapter 3 – Vision and Objectives

7.2 EC4

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

4. (1) Legally compliant?

Yes ✓ No

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

Yes ✓ No

4. (3) Sound?

Yes No ✓

4 (3) Please give details of why you consider the Local Plan is not sound, referring to the tests of soundness as appropriate, be as precise as possible. Policy EC4 sets out the policy approach for the safeguarding of existing Strategic Employment

Areas. Daventry Royal Oak Industrial Estate (EC4b) is identified on the Proposals Map as one

of the existing Strategic Employment sites for safeguarding.

Paragraph 7.2.11 outlines the approach the Council has taken to new employment land

provision, based on the Employment Land Study, October 2017. The plan makes provision

for some 16.2 -28.7 ha of employment land to meet demand over a 7 year period, with an

additional supply of 7.3-19.8 ha beyond that 7 year period. New employment land allocations

are proposed in the Part 2 Plan at Naysmith Avenue (Policy EC7) and the Daventry South East

Gateway (Policy EC9). The development at Naysmith Avenue involves an extension to the

Drayton Fields Industrial Estate, and the South East Gateway an extension to the Daventry

Marches existing employment area.

The plan makes no provision for the extension of the Royal Oak Industrial Estate Strategic

Employment Area. This is one of the key existing employment estates for Daventry Town and

the plan should seek to make provision for the expansion of the estate.

Land to the west of the existing industrial estate, identified in the Housing and Employment

Land Availability Assessment (HELA) as site reference 135, is considered to be a suitable

opportunity to provide for further expansion of this key employment site.

The assessment of the site in the Sustainability Appraisal supporting the Part 2 Plan Annex B

to Part 3A, page 90) highlighted an overall negative impact for landscape and townscape but

noted in terms of potential mitigation/enhancement that the site could be designed sensitively

with respect to the landscape character and views to/from local landmarks.

It is noted that for the South East Gateway site proposed for allocation, the Sustainability

Appraisal of that site (ref 323, Page 182) identified an overall major negative impact for

archaeology and cultural heritage as well as a major negative effect for landscape and

townscape.

Given the Council’s decision to allocate the South East Gateway site for additional

employment, notwithstanding these negative impacts, the decision not to provide for an

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appropriate extension to the Royal Oak Industrial Estate is inconsistent and not adequately

justified or effective.

It is considered that it is important that the plan allows for the extension of the existing

strategic employment sites to allow for the growth and expansion of existing businesses who

may not wish to relocate. The HELA assessment noted that the site could contribute to

meeting the needs for small and medium sized employment units in Daventry.

There is scope to provide for additional employment land in this location, with provision for a

new landscaped edge to the west of the site, with the remaining land allocated for

employment use. In total the land assessed in the HELA under site reference 135 extended

to some 69 hectares. Our land interest extends over a larger site of some 160 hectares,

providing greater flexibility to accommodate new employment uses and appropriate

landscaping (see attached plan).

The Part 2 Plan should therefore be amended to include land to the south of the A45

Braunston Road to provide for an extension to the Royal Oak Industrial Estate Strategic

Employment Area.

5. Please set out what modification(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the matter you have identified at part 4(1) or 4(3) above where this relates to soundness. (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination). You will need to say why this modification will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. The Plan should be amended to include an additional allocation of employment land as an

extension to the Royal Oak Industrial Estate Strategic Employment Area.

Please note your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage.

After this stage, further submissions will be only at the request of the Inspector, based on the matter and issues he/she identifies for examination.

6. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? (please tick as appropriate)

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

Yes, I wish to participate at the oral examination

✓

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7. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary.

It is important that Pegasus Group participates in the oral part of the examination in relation

to the need for additional employment allocations as extensions to existing strategic

employment sites.

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination.

8. Please tick the box if you wish to be notified of further progress of the Local Plan.

✓

9. Signature

Date 4th October 2018

Thank you for taking the time to complete the form.

Please return it to the Local Strategy Service at Daventry District Council by 4.30pm on Friday 5th October 2018.

Responses received after this time will not be accepted.

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‘Map data shown may contain Ordnance Survey ® products supplied by

Pear Technology Services Ltd; Email: info@peartechnology.co.uk© Crown Copyright and database rights from date shown above

Ordnance Survey ® licence number 100023148

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