Braybrooke Parish Council response to clarification questions

Formatting

Not applicable

The main improvement to the format of the Plan is not to justify the text on the righthand side, as this will assist those with visual disabilities, along with ensuring all the text is a minimum of 12pt font. This is also an appropriate ‘reasonable adjustment ‘under the 2010 Equalities Act.

We believe the NP meets the requirements of The Public Sector Bodies (Websites and MobileApplications) AccessibilityRegulations 2018. This is the legal requirement.

Despite extensive comments at Regulation 14 stage, NNC did not suggest this further “adjustment” then.

And we note, for example, that the North Northamptonshire Joint Core Strategy 2011-2031is published in right-justified form.

However, if the local planning authority wish to make these changes, and the Examiner agrees, we have no objection.

Policies

Not applicable

There is nothing in the text that clarifies how the policies are being presented e.g., in blue, compared to the supporting text or even their significance compared to the supporting text. It would be much clearer to read if the policies were presented in either bold text and / or a box.

Also, some policies, or parts of policy are in a darker blue (the heading blue) than the rest of the policy and needs amending when proofing the Plan.

In addition, all the Policies in c. Community Sustainability have a different format to the other policies as they do not have a space between the letter(s) and number.

In fact, it is the Policies in b. The Natural, Historic and Social Environment whose designation formats differ slightly from the other sections.

Proofing the Plan is of course now a matter for NNC.

Policies

Not applicable

Criteria re-wording to ensure they make sense following the previous sentence e.g., in Policy H1, Development will be supported subject to a) ‘Any development of the site is limited…’. Perhaps the first sentence should say ‘Development will:’ and

then criterion a) could then read ‘Be limited to two residential units…’. Other policies where this applies are Policy H6, Policy BE4.

No response

Community Action

Not applicable

Compared to some of the other titles the subject matter is missing e.g.,” Community Action ENV1:Conservation Areas” Also Community

Action CF1 and Community Action PC1.

No response

Terminology

Not applicable

Reference to ‘Kettering Borough Council (now North Northamptonshire Council)’, has already been clarified in para 3.1 and the text in the brackets is not required. There are a few examples of this in the Plan where this applies e.g. Paragraphs 7.16, 7.17 & 7.19, 7.64 and 7.103.

No response

Terminology

Not applicable

As para 5.5, has already clarified what ‘NPPF’ stands for, it does not need to be repeated again and the date needs amending. There are a few examples of this in the Plan where this applies e.g. Paragraphs 7.48, 7.63, 7.92and 7.123.

Putting the title in full can be a helpful reminder to the lay reader who dips in and out.

However, we note and agree the need to amend references:

paras 7.48 and 7.123 should both be amended to refer to NPPF (2021) rather than NPPF (2019)

Evidence

Not applicable

Although there is clear reference to factual (or qualitative data), there is a significant lack of reference to local community support (or quantitative data) for the policies in the Plan. Also, there are many statements that are not backed up by any detailed evidence e.g., Paragraphs 2.9, 4.4, 7.36,7.45, 7.68, 7.79, 7.80, 7.82 – 7.86, 7.111, 7.120, 7.123, 7.150, 7.167,7.186, 7.190 and Policy ENV7

We take issue with the statement about lack of reference to community support. There is considerably more support for the policies in the NP than is normally found in local planning documents.

The Consultation Statement addresses the issue of community consultation at length, starting with the open event that took place in November 2021. We consider the evidence base to be wholly proportionate to neighbourhood planning and contained in the appendices or the main body of the NP.

Maps

Not applicable

Although all the maps have included a copyright, they all have some other basic information missing e.g., North Rose, Key & Scale and need to be included (particularly the first two) when the Plan is proofed (see comments below). Also, some of the text in the Key’s need to be increased in size to be able to read and implement the policy they refer to.

Such a comment might helpfully have been made prior to submission. NNC provided some of the maps and omitted the elements they are now saying need to be provided, but they are well placed to rectify this if they wish.

Maps

Not applicable

A number of maps are also difficult to read and need to be enlarged to ensure they can be more easily read. The particular maps, which this applies to are as follows: Figures 1, 4-15, 17-18, in particular Maps 7, 8 10, 11 & 19 may need to cover two pages or on A3 if necessary.

High resolution versions of all maps are available.

Appendixes

Not applicable

The Appendixes should be a summary of data that is too detailed to include to include in policy; it should not contain the detailed supporting evidence.

We disagree with this opinion.

Specific Comments

Foreword from Chairman

1

A very clear and useful introduction to the work on the Neighbourhood Plan.

Noted

1. Introduction

Para 1.7, 2nd sentence

3

The end of the sentence needs amending to be accurate“….and the Neighbourhood Planning (General) Regulations 2021 (as amended)” should be changed to read “‘and the Neighbourhood Planning (General) Regulations 2012 (as amended)”

We agree, this was a typographical error.

2. About Braybrooke Parish

Para 2.3, 1st sentence

4

This sentence is not very clear as a word/s seem missing “but the development of the domestic (??) worsted (??)industry in the 18th century(??) enabled agricultural labourers...”

Worsted is a wool yarn used at the time and produced by spinners working at home. It is an appropriate reference and we believe the sentence is perfectly clear.

Census and Land Registry Data

4

This section may need updating due to the Census2021 data being issued.

The first results of Census 2021 were not released until after the commencement of the Regulation 16 consultation, and the full analysis has yet to be published

3. How the Neighbourhood Plan was prepared

A helpful summary on the consultation work carried out, however the outcomes of this have not been addressed in the supporting text as evidence justifying the policy.

The outcomes are appropriately referenced in the Consultation Statement.

4. Vision and Objectives

Vision Box

8

Without any clarification about the role of the planning policies compared to the supporting text, placing the vision being in blue text suggests a status it does not have. Therefore, the colour of

this blue text may need to change to avoid any confusion.

We do not see the need for change. The text makes the status of the Vision Box perfectly clear, but if the local planning authority wish to make these changes, and the Examiner agrees, we have non objection.

5. How the Plan fits into the planning system

Para 5.5

10

The requirement is stronger than ‘encourage’ as it is to ‘achieve’ sustainable development.

No response

Omission

Not applicable

There is no reference to the newer ‘basic condition’ (2017) regarding Habitats and Species.

No response

6. Sustainable Development

Para 6.4

11

Planning policies have more statutory weight than any supporting text; the latter is there to justify the former.

The point of 6.4 is to confirm that individual policies should not be considered in isolation.

7. Policies
a. Housing and the Built Environment

Para’s 7.5-7.7

12-14

It is not ‘good practise’ to duplicate from other plans e.g., the Local Plan. Also, such policies can’t be directly amended by this Plan and when such policies are revised, by coping them in this Plan, they

will make (parts) of the neighbourhood plan out of date sooner. A summary of other plan’s policy, in terms of its intention and a link in the supporting text, is more effective.

We do not consider this to be necessary. Minor reviews to the NP can be made to ensure general conformity at any time, but it is likely that the NP will be reviewed to coincide with a review of the Local Plan and Core Strategy. However, if the local planning authority wish to make this change and the Examiner agrees, we do not object

Para 7.11 - Omission

15

The summary of the detailed evidence for policy H1should be included in this supporting text and not in an Appendix, which is also missing from Appendix 3 (See comments on Appendix 3) e.g., why only 2 residential units or no more than 3 bedrooms each (Reference to para’s 7.27 & 7.30 would provide some justification for this latter approach). Also why was the RAG SCORE ‘Green 10’ and why was the ‘Rank and outcome’. Reference also needs to be made to which defining principle has been used to include the residential site allocation in Policy H1.

It is not a requirement that the evidence should be contained in the supporting text.

Policy H1: Residential Site Allocation and a)

15

This policy duplicates part ofAppendix 3, in Annex 1, which refers to ‘planning condition’s’ not ‘planning policy criteria’ yet this has been incorrectly used for this purpose. (Also see comments on Appendix 3).

No response

b)

15

To be consistent with the format taken in Policy H6 “…in the Braybrooke Design Code which forms part of the Braybrooke Neighbourhood Plan (Appendix 5);” should be amended to read “…in the Braybrooke Design Code (Appendix 5);”

No response

c)

15

A formal landscaping plan for such or small-scale development is likely to have viability implications. A more reasonable approach is to change “A landscaping plan is details are provided as part of the …” to read “Landscaping details are provided as part of the”

No response

e)

15

A policy should not specifically dictate what outcome from another organisation should be.

This clause was inserted following consultation with the Highways Authority and simply reinforces the relevance to the planning process of Highways Authority guidance, whatever it might be.

f)

15

This is currently written as supporting text rather than policy and such matters will require an appropriate legal agreement that will need to form part of a Section 106 agreement which will be subject to DM negotiation.

“Legal assurances are obtained to protect the northern section of Top Orchard from future development and secure aright of public access;

funding is made available for a bench or other seating area for community use” should be changed to read “A planning obligation will be required to protect the northern section of Top Orchard from future development and secure a right of public access; funding for a bench or other seating area for community use”

The policy is written to add weight to the infrastructure requirements agreed with the landowner.

However, we have no objection to NNC’s suggested wording changes with respect to a Section 106 agreement.

Figure 2: Residential site allocation

16

The map is a good read size.

No response

Omission

17

What local support is there for the allocation of this Settlement Boundary?

There was strong support for the settlement boundary through the consultation event in November 2021. People had the opportunity to comment at Reg 14 and Reg 16 and can ultimately support the NP or not at Referendum. There have been many opportunities for community

engagement.

Para 7.19

Not applicable

It needs to be made clear which boundary has been used as a starting point of review and decision. It is assumed that this is the Kettering Site Specific Local Plan (adopted December2021) and should be referenced in paragraph

7.19. Further explanation is required to explain how the changes to boundary accord with the defining principles.

The methodology is explained in sufficient detail and is noted at para

7.19 to be based on the Kettering Borough Council Local Development Plan. It is not necessary to go into the level of detail requested here.

Figure 3

19

The map is clear and a good size. It is noted that the village boundary is cutting through some private gardens in the village.

Noted. This follows from Principle 3(a)

– para 7.22 (a)

Policy H3: Housing Mix

20

Despite this not being required as this already applies through NNJCS Policy 30, if this is to be retained, making specific reference to another ‘development plan’ policy is likely to result in the Neighbourhood Plan policy becoming out of date sooner (as it is already in the process of being revised) unless this is clarified e.g.,“… providing they meet the provision set out in NNJCS Policy 30 (Housing Mix and Tenure) or subsequent Local Plan policy on this issue.

No response

Policy H3: Housing Mix

20

“There will be a presumption against dwellings providing 4 or more bedrooms”. This is very restrictive

and difficult to enforce. Also, it duplicates (in reverse) the support at the start of the policy for smaller dwellings and should be removed.

It adds further local detail given the current imbalance in the housing stock which the policy seeks to address.

Policy H4 - Affordable

Housing, last sentence

21

Despite this not being required as this already applies through NNJCSPolicy 13.

It highlights the requirement and is helpful in ensuring it is taken into account in decision making.

Para 7.38, 3rd sentence

22

If a site is not allocated it will always be classified as a windfall site therefore the supporting text needs amending e.g., “…development beyond the housing allocation described above will be restricted to windfall sites within theSettlement Boundary, other than in exceptional circumstances” should be changed to read” development beyond the housing allocation described above will be treated as windfall sites within the Settlement Boundary, other than in exceptional circumstances such as rural exception sites.

No response

Para 7.40, 1st sentence

22

It is incorrect to state Policy H1(Residential Site Allocation) “…applies to all forms of development”,

as it only applies to ‘residential development’ and therefore requires amending e.g., “As with Policy H1 (Residential Site Allocation), Policy H5 applies to…” should be changed to read “Policy H5 applies to”

We agree this is an error: it should refer to Policy H6, not H5, and we are happy for this amendment to be made.

Policy h5: Windfall Sites

22

c) This needs to be clarified that ‘the garden space’ it applies to adjoining or host dwelling space e.g.,

“...does not reduce existing garden space to an extent where it

We do not believe the policy needs changing as it is clear as it stands.

Policy H5: Windfall Sites

22

e) duplicates criteria c) regarding ‘amenity of neighbours’, but in more detail, so should be combined.

No response

Policy H6: Design a)

23

This is a very broad requirement, as there is no reference to ‘relevant’ recommendations. The benefit of summarising theDesign Code in the form of a checklist would make it much easier to implement (See comments in Appendix 5Design Code).

It is entirely reasonable to require that development proposals meet the requirements of criterion a).

7. Policies
b. The Natural, Historical & Social Environment

Para 7.49, 1st sentence

24

What are ‘areas of environmental significance’? If they are ‘designated’ environmental areas this needs to be made clearer e.g., “… (and the designated environmental sites and areas of environmental significance covered by them)…”

“Areas of environmental significance” is explained in para 7.80

Para 7.54, 4th sentence para

26

Is the reference to Policy ENV9 correct as there is no

reference to ‘ridges and furrows of the medieval plough lands’ in this policy, but there is in Policy ENV 8?

Yes, this is an error, it should be Policy Env 8

Para 7.57

26

It would be helpful to refer to the relevant maps e.g., Figure14: Statutorily protected heritage assets and Figure 15: Braybrooke Conservation Area (left); part of the 1985 Appraisal map (right) to confirm their location.

No response

Para 7.58

27

Reference to Figure 7 would be useful, as this has occurred in para 7.80.

No response

Plots

29-30

We welcome the inclusion of photographs showing the sites.

Noted

Para 7.70, 4th sentence

30

It is not accurate to conclude that because landowners did not make comments on the allocation of their land as ‘Local Green Space’ that ‘two supported it by omission’.

The Consultation Statement (para 6.1, 4th sentence) gives the context of landowner attitude to the LGS proposals, showing they were fully engaged in the process and justifying the conclusion that they

gave tacit support.

Policy ENV 1: Local Green Spaces

31

As previously advised, the term ‘very special circumstances’ has a specific meaning (regarding Green Belts in national guidance) and this does not apply to Local Green Spaces and therefore should be amended e.g., change to “exceptional circumstances’’.

We disagree. The phrase ‘very special circumstances’ has been used in other Made NPs and indeed suggested by Examiners as an appropriate description. Its link to the Green Belt is significant because the LGS carries similar levels of protection to the Green Belt, therefore the reference is

appropriate.

Policy ENV 1: Local Green Spaces

31

Policy should also be positively phrased e.g., “Development proposals that would result in the loss of, or have an adverse effect on, the following Local Green Spaces (map Figure 5) will not be permitted except in very special circumstances…”(NPPF, para 10, 15, 16 b), 38 etc) should be changed to read “Development proposals that would result in the loss of, or have an adverse effect on, the following Local Green Spaces (Figure 5) will only be permitted except in very special circumstances…”

The revised policy wording does not make sense. The current wording is appropriate.

Para 7.79

32

What is an ‘important open space’ as opposed to an ‘open space’ as there is no clarification in the Plan on this matter?

Important Open Spaces are those identified in the Plan in Policy Env 2, as stated.

Policy ENV 2: Important

Open Spaces, 1st sentence

32

These are statements and not policy that should guide development. It seems to confuse ‘Open space’ with ‘Local Green Space’, as it refers to some of the required criteria for ‘Local Green Spaces’. ‘Open Space’ has a much wider definition and there is no relevant justification for this current approach, therefore delete.

We believe that the opening sentence provides helpful context.

32

Policy should be positively phrased e.g., “Development proposals that result in their loss, or have a significant adverse effect on them, will not be supported unless the open space is replaced by…”. (NPPF, para 10, 15, 16b), 38 etc) should be changed to read “Development proposals that result in their loss, or have a significant adverse effect on them, will only be supported where the open space is replaced by…”

We believe the policy to be appropriately worded.

32

This policy does not make it clear that Braybrooke Castle cricket ground and All Saints churchyard have already been designated as ‘open space’ in the Local Plan. Also, that The Green, School Lane; Chase Park, Church Close & Church Close corner, and verge (although referred to as ‘Church Lane/Harborough Road corner green space’ in the Inventory) are new designations.

The Local Plan does not specify which KBC open spaces are covered by Policy NEH4. So, the list with policy ENV2 references the KBC Open Spaces Audit, where applicable, including giving the numerical references therein to the sites listed. And it is true that the KBC SSP2 interactive map for planning shows only the cricket ground and churchyard as KBC designations.

However, the QB is happy if NNC wish to add a clarifying note, subject to the Examiner’s agreement

Para 7.80

33

(both Natural England designations)’ - It would have been more appropriate to refer to this when these designations were first mentioned e.g., Para7.58.

We are happy for the earlier reference to be made.

Policy ENV 3: Sites and Features OF Natural Environment Significance,1st two sentences.

34

These are statements and not policy so move to the supporting text.

We believe the policy to be appropriately worded.

Policy ENV 4: Woodland, Notable Trees and Hedges

36

What is a ‘notable tree’? This needs to be defined as this terminology has no formal status in town planning.

Notable trees are trees worthy of recognition. We are happy for this definition to be included where appropriate.

Policy ENV 5: Bat Conservation

39

Development proposals should “contain policies that are clearly written and unambiguous” (16 d), NPPF) and this policy would benefit from rephrasing as it is not as clear as it could be.

We believe the policy is clear. The first sentence is drafted as proposed by the local planning authority at Regulation 14.

Policy ENV 5: Bat Conservation

39

c) is not reasonable as it is over and above NPPF and NNJCS requirements and has viability implications if applied to all proposals. Such requirements would be dealt with by the relevant expert at the planning application stage via conditions.

This references best practice considerations and is considered appropriate. If the local planning authority had any concerns this could helpfully have been raised at Regulation 14.

Policy ENV 6 Biodiversity and Habitat Connectivity

40

The policy is far too strategic and could apply anywhere. It fails to take account of national guidance which provides different protection according to the type of designation e.g., the more significant the more protection. Either provided more details and refer to Figure 7, rather than Appendix 6, or delete the first sentence.

The policy is deliberately intended to apply anywhere in Braybrooke,

i.e. all development proposals should be determined by reference to Policy ENV 6. Almost without exception, proposed development sites which have not been designated or identified as having significant biodiversity value (ENV 3) will nevertheless have species and habitats on-site to which the conditions and mitigations specified should be applied. This does not prohibit development but helps to ensure that the key features are protected.

We note that a requirement for biodiversity net gain at10% to be delivered by (applicable) new development is expected to be added to the relevant NPPF paragraphs soon (Policies ENV 3 and 6) in compliance with the Environment Act 2021

Policy ENV 7: Sites of Historic Environment Significance

43

This has been written as supporting text, and not policy that guides development, and will therefore require rephrasing.

We believe the policy to be appropriately worded. If the local planning authority had any concerns this could helpfully have been raised at Regulation 14.

Policy ENV 8: Ridge and Furrow

45

The first sentence is a statement and should be moved to the supporting text.

The third sentence needs criteria to qualify what is considered a ‘balance judgement’ or be moved to the supporting text.

We disagree. The balancing requirement explains that it is a judgement between harm and benefit.

Community Action ENV1:

N.B. NNC is not aware it has agreed to this Community Action.

The Parish Council will work with the community and NNC to support a review of the Conservation Area (1985) as required by Section 71(1) of

the Planning (Listed Buildings and Conservation Areas) Act1990.

Policy ENV 9: Important

Views, 1st sentence

50

The first sentence is a statement and should be moved to the supporting text.

The second and third sentences are duplicating one another from different perspectives. Amend the second sentence and delete the third one to achieve a more detailed positive policy e.g., “Proposals should protect and where possible, enhance them” should be changed to read “As appropriate to their scale, nature and location, the design, massing, and orientation proposals should protect and where possible, enhance the views listed below, as identified in Figure 16 and Appendix 8”

No response

Para 7.113, 1st sentence

51

It would be clearer if the supporting text clarified the coding on the map e.g., G2-9 & GC12-13.

No response

Policy ENV 10: Footpaths and Other Walking Routes

51

It would add strength to the policy if the following was added to the end of the policy “…appropriate mitigation” should be changed to read “appropriate replacement due to their limited availability in the village”

No response

Para 7.117

53

For this statement to have any impact refer to Policy ENV 5 and summarise the main requirements in a checklist as an Appendix.

We agree that a reference to ENV5 would be helpful, but it could be misleading to attempt to summarise the requirements of a technical guidance document that may evolve.

Policy ENV 11: Dark Sky,

1st sentence

53

To apply this to all proposals, the bullet points are too restrictive, as they go beyond the requirements of the NPPF and NNJCS and may cause viability issues. They need amending to just require providing the lighting details, unless required by a relevant expert at the planning application stage.

The policy is intended, where it applies to Braybrooke, to go beyond NNPF and NNJCS, else there would be no purpose to it.

It was amended to its present form at Regulation 14 in line with comments received from NNC.

Policy ENV 11: Dark Sky,

3rd sentence

Not applicable

See comment on para 7.117 re an Appendix checklist.

Our response to the comment on para 7.117 applies.

Policy ENV 12: Flood Risk

Resilience, 2nd & 3rd bullet points.

54/55

A Flood risk assessment is more appropriate for minor development (less than 10 units) than a ‘hydrological study’ or a ‘Surface Water Drainage Strategy’.

Noted

Para 7.122, 3rd sentence

56

Was the question about renewable generation infrastructure generally or a specific type of infrastructure? There is also concern about the use of the term ‘threat’ as the provision of such infrastructure is a Government target.

Noted. To the extent that any infrastructure might have adverse effects, this is a statement about community views. Para7.123 recognises government policy.

Policy ENV 13: Renewable Energy Generation Infrastructure

56

The threshold chosen for medium and large-scale development proposals need to be justified and further context needs to be provided as to the reason behind this.

We believe the policy to be appropriately evidenced.

Policy ENV 14: Area of Separation

57

Where is the evidence to justify the extent of this area e.g., planning applications/appeals for the land to the northeast and southwest of Braybrook Road / Harborough Road?

Also, clarification needs to be given as to the protection that is sought to that already afforded to the area by relevant policies in the North Northamptonshire Joint Core Strategy and Kettering Site Specific Part 2 Local Plan.

The area of separation is considered appropriate to avoid potential development encroaching into the Parish from Harborough. It is intended to reinforce any other relevant protections.

c. Community Sustainability

Policy CF1: Retention of Community Facilities, Amenities and Assets

60

Policy should be positively phrased e.g. “…play area will not be supported unless it can be demonstrated that:” should be changed to read “…play area will be supported where it can be demonstrated that:”

If the local planning authority wish to make these changes, and the Examiner agrees, we have no objection, however we do not consider it necessary

Policy CF2: New or Improved Community Facilities, a)

61

This part of the policy is very restrictive and will need to include some flexibility e.g.,” a) will not result in significant disturbance to residential properties including negative impacts as a result of changes in traffic flow…”.

This policy was amended at Regulation 14 in line with comments received from NNC. Does this now say these revisions are wrong? This is extremely unhelpful.

Policy T1: Traffic Management c)

64

It is not appropriate to require any new development to make any ‘necessary improvements’; these should only address issues that arise as a result of the development.

It is the development that makes them necessary …

Community Action T1: Traffic Management, c)

66

As previously advised, the reference to ‘Highways’ needs to be clearer such as referring to ‘North Northamptonshire Highways’, rather than just ‘Highways’.

We are content for NNC to make this change if agreed by the Examiner.

Policy BE1: Support for Existing Businesses &Employment Opportunities

67

As the first sentence is a statement, rather than policy and duplicates the 2nd sentence, it can be deleted.

We believe the first sentence adds context and should be retained. It refers to proposals involving the loss of employment. The 2nd sentence refers to proposals that might or might not add employment opportunities.

Policy BE2: Support for Growing and New Businesses and Employment, e)

68

In relation to the loss of dwellings, this needs to be clarified as it provides the decision maker with uncertainty (because of the term ‘generally’), as how to approach proposals for new employment opportunities where it involves a potential loss of dwellings.

The word ‘generally’ was intended to add some flexibility but can be removed.

Policy BE5: Tourism, a)

71

This policy either needs to be amended to read “are withinBraybrooke parish and on a scale appropriate to the settlement” or be split to read as two separate criteria.

This is a matter of style and not necessary to be changed.

8. Monitoring and Review

Para 8.2

72

Unless there is going monitoring, a yearly review may prove too time consuming, so reference to a ‘frequent’ review would provide more flexibility.

This is a matter for the Qualifying Body. It is good practice to formally visit the potential for a review annually.

Appendixes

1(a) Housing Census data, 1(b)Land Registry data & 2 Housing Needs Report

Not applicable

As the Plan makes no reference to any of these Appendixes, this data should be removed from the Plan.

They provide useful background information and, even though not directly referenced, are the source of evidence on which some statements

are based.

3 Residential Site Assessment process & 4 Affordable Housing for Sale Assessment.

Not applicable

As supporting evidence there is no need to include these in the Plan. Just a summary of the key issues in the supporting text or an Appendix and referring to the title of the document where it is mentioned in the Plan, is sufficient.

This is an individual opinion and is noted.

3 Residential Site Assessment process –Omission

Not applicable

For the allocated site ‘E1 -Adjacent Top Orchard’, the detailed justification for the following is missing:

a) only 2 residential units

b) no more than 3bedrooms each

c) why was the RAG SCORE ‘Green 10’

and

d) why was the ‘Rank and outcome’

Also, the score for every criterion for every site needs to be shown here in detail, rather than a summary of the overall scoring process, for transparency. This detail will show why the sites were given the scores shown and the comparison between the sites. This will also provide context as to the content of the proposed policies, especially for the proposed allocation.

We understand that the key issue for the examination is whether or not the selected site meets the Basic Conditions.

It is not relevant to review each of the scoring appraisals.

5 Design Code

Not applicable

To aid the use of this document, the Key issues should be summarised as a checklist in an Appendix rather than include this whole document in the Plan.

We think the whole document is

appropriate for inclusion as an Appendix to aid decision-making.

6 Environmental Inventory

Not applicable

Aside from the location map is missing a North Rose, Key and Scale, there is no need to include this supporting evidence in thePlan. Referring to the title of the document where it is mentioned in the Plan is sufficient.

Also, the Green, School Lane; Chase Park, Church Close & Church Lane/Harborough Road corner green space (although referred to as ‘Church Close corner and verge’ in the policy) are incorrectly referred to as being allocated as ‘AmenityOpen Space’ when they have just been designated as ‘OpenSpace’.

We believe that the environmental inventory provides an essential tool for decision making, as it identifies the specific features that are contained in

the environmental policies.

These were (at the time of submission, based on available Kettering Area and NNC information) not designated open spaces, they were submitted as Neighbourhood Plan designations and given what were considered to be the appropriate open space typology names

7 Bat Survey of Braybrooke 2020

Not applicable

There is no need to include this supporting evidence in the Plan. Referring to the title of the document where it is mentioned in the Plan is sufficient.

We believe it is helpful background information.

8 Important Views

Not applicable

We support the inclusion of this Appendix to support Figure 16.

Noted.

General comments

Figures

Not applicable

The format titles of some of the Figures are not consistent with one another e.g., add a colon after ‘Figure 1’, ‘Figure 3’ & ‘Figure 19’ and delete the dash after ‘Figure3’.

No response

Proofing

Not applicable

This document needs further proofing before it is used for the Referendum as there are several presentation and terminology inconsistencies.

This is for NNC to undertake as per the Neighbourhood Plan Regulations.

Specific comments

Contents – Omission

Not applicable

A list of the figures in the Plan have been

omitted from the Contents list, as have the Community Actions.

We do not see this as necessary, but do

not object if NNC wishes to make these changes and the Examiner agrees.

1. Introduction

Para 1.6, 3rd sentence

3

It would be clearer if reference was made to “…in support of the formal planning policies contained in this NP, that guide development”.

No response

Para 1.8, after the 1st sentence

3

New text needs to be added to be accurate “When the examination has closed, any Neighbourhood Plan policy that is relevant to a planning application must be taken into account”.

We presume this is intended to be added to the end of para 1.8 else it suggests the plan applies regardless of the referendum outcome.

We have no objection to this being added, but question whether it is appropriate for NNC to re-write the NP in this way.

2. About Braybrooke Parish

Census and Land Registry Data– Omission

4

Graphics would assist some of the points being made e.g., population statistics

It does not conflict with the Basic Conditions. If the local planning authority wish to make these changes, and the Examiner agrees, we have no objection, however we do not consider it necessary

4. Vision and Objectives

Objectives, 6th bullet point

9

No reference has been made to ‘loss of daylight’, but it has been referred to in policy H5.

Not all policies are referenced in the objectives.

7. Policies
a. Housing and the Built Environment

Para 7.8

Not applicable

What is the factual evidence for this statement e.g., what % the local community supported

it? Also, what local support is there for the allocation of this site?

The factual evidence is provided in the consultation statement which includes

the analysis of the questionnaire for November 2020.

Policy H1: Residential Site Allocation a)

15

Deleting the duplicated text and phrasing the policy more positively e.g., “Any development of the site is limited to two residential units with has no more than three bedrooms in each” should be changed to read “Any development no more than three bedrooms in each unit”.

We think that the current words are appropriate.

Para 7.43

22

To ensure consistency with terminology it would be clearer to use the actual name of the document being referred to e.g. “The Policy and Design Code highlighted in this section seeks to reflect the design principles …” should be changed to read “The Braybrooke Design Code (Appendix 5) highlighted in this section seeks to reflect the design principles”.

No response

Figure 4: Topography (left) &geology of the Plan Area

25

These are not referred to in any policy or text (See comment on Para 7.122)

It provides useful context, including, as noted, to para 7.122

Policy ENV2 –Important Open Spaces

32

A space needs to be inserted before ‘built- up’ into the first sentence, so to read ‘….and are within or close to the built-up area.

No response

Policy ENV 5: Bat Conservation

39

a) an extra space is required in ‘areas) unless’.

No response

Para 7.100

44

Add a line space under this para to be consistent with the format of para7.87.

Some spacing was adjusted to enable balanced pagination.

Figure 16: Important views

51

The graphics will need to be amended so the No 6 is not covered up by an arrow.

No response

Dark Sky, para 7.114, 2nd sentence

52

Figure 15’ should read ‘Figure18’.

Agreed. This was an error.

Para 7.122, 1st sentence

56

It would be useful to refer to Figure 4 to help clarify the point being made re Topography.

No response

Policy CF1: Retention of Community Facilities,

Amenities AND Assets

60

Most of the first paragraph is in a darker blue font than the rest of the policy and needs amending.

No response

Policy CF2: New or Improved Community Facilities, a)

61

The first paragraph is in a darker blue font than the rest of the policy and needs amending.

No response

Policy T1: Traffic Management

64

The first paragraph is in a darker blue font than the rest of the policy and needs amending, and a full stop is missing at the end of the policy.

No response

Policy T2: Cycling and Walking

65

The policy is in a darker blue font than the rest of the policy in the plan and needs amending.

No response