Report on Braybrooke Neighbourhood Plan 2022 – 2031

An Examination undertaken for North Northamptonshire Council with the support of Braybrooke Parish Council on the submission version of the Plan.

Independent Examiner: Andrew S Freeman BSc (Hons) DipTP DipEM FRTPI

Date of Report: 7 February 2023

Main Findings - Executive Summary

From my examination of the Braybrooke Neighbourhood Plan (the Plan) and its supporting documentation, including the representations made, I have concluded that subject to the policy modifications set out in this report, the Plan meets the Basic Conditions.

I have also concluded that:

the Plan has been prepared and submitted for examination by a qualifying body – Braybrooke Parish Council
the Plan has been prepared for an area properly designated – the Braybrooke Neighbourhood Plan area (Figure 1 on Page 2 of the Plan)
the Plan specifies the period to which it is to take effect – 2022 - 2031

and

the policies relate to the development and use of land for a designated neighbourhood area.

I recommend that the Plan, once modified, proceeds to referendum on the basis that it has met all the relevant legal requirements.

I have considered whether the referendum area should extend beyond the designated area to which the Plan relates and have concluded that it should not.

1. Introduction and Background

Braybrooke Neighbourhood Plan 2022 - 2031

1.1 Braybrooke is a small village and civil parish in Northamptonshire some 25km north of the county town of Northampton. It is within the administrative area of North Northamptonshire Council. The village lies between the town of Desborough to the east-southeast and Market Harborough just over the border into Leicestershire to the northwest. The village is set in an agricultural landscape, a mixture of pasture and arable.

1.2 The decision to proceed with a neighbourhood plan was taken at the Annual Parish Meeting in 2020. Designation in April 2020 was followed by extensive discussion with residents and their involvement in plan formulation. The resultant draft Plan contains a vision, nine key objectives and some 31 policies under three broad topic headings that cover recurrent themes from the consultation.

The Independent Examiner

1.3 As the Plan has now reached the examination stage, I have been appointed as the examiner of the Braybrooke Neighbourhood Plan by North Northamptonshire Council with the agreement of Braybrooke Parish Council.

1.4 I am a chartered town planner and former government Planning Inspector with over forty years’ experience. I have worked in both the public and the private sectors. I am an independent examiner and do not have an interest in any of the land that may be affected by the draft Plan.

The Scope of the Examination

1.5 As the independent examiner I am required to produce this report and recommend either:

(a) that the neighbourhood plan is submitted to a referendum without changes

(b) that modifications are made and that the modified neighbourhood plan is submitted to a referendum

(c) that the neighbourhood plan does not proceed to a referendum on the basis that it does not meet the necessary legal requirements.

1.6 The scope of the examination is set out in Paragraph 8(1) of Schedule 4B to the Town and Country Planning Act 1990 (as amended) (“the 1990 Act”). The examiner must consider:

Whether the plan meets the Basic Conditions
Whether the plan complies with provisions under Section 38A and Section 38B of the Planning and Compulsory Purchase Act 2004 (as amended) (“the 2004 Act”). These are:

- it has been prepared and submitted for examination by a qualifying body, for an area that has been properly designated by the local planning authority;

- it sets out policies in relation to the development and use of land;

it specifies the period during which it has effect;
it does not include provisions and policies for ‘excluded development’;

and

it is the only neighbourhood plan for the area and does not relate to land outside the designated neighbourhood area.
Whether the referendum boundary should be extended beyond the designated area, should the plan proceed to referendum.
Such matters as prescribed in the Neighbourhood Planning (General) Regulations 2012 (as amended) (“the 2012 Regulations”).

1.7 I have considered only matters that fall within Paragraph 8(1) of Schedule 4B to the 1990 Act, with one exception. That is the requirement that the Plan is compatible with the Human Rights Convention.

The Basic Conditions

1.8 The “Basic Conditions” are set out in Paragraph 8(2) of Schedule 4B to the 1990 Act. In order to meet the Basic Conditions, the neighbourhood plan must:

have regard to national policies and advice contained in guidance issued by the Secretary of State;
contribute to the achievement of sustainable development;
be in general conformity with the strategic policies of the development plan for the area;
be compatible with and not breach European Union (EU) obligations (under retained EU law - the existing body of environmental regulation is retained in UK law.)

and

meet prescribed conditions and comply with prescribed matters.

1.9 Regulation 32 of the 2012 Regulations prescribes a further Basic Condition for a neighbourhood plan. This requires that the making of the neighbourhood development plan does not breach the requirements of Chapter 8 of Part 6 of the Conservation of Habitats and Species Regulations 2017. This revised Basic Condition came into force on 28 December 2018 through the Conservation of Habitats and Species and Planning (Various Amendments) (England and Wales) Regulations 2018.

2. Approach to the Examination

Planning Policy Context

2.1 The Development Plan for this part of North Northamptonshire Council, not including documents relating to excluded minerals and waste development, includes the North Northamptonshire Joint Core Strategy 2011 - 2031 and the Kettering Site Specific Part 2 Local Plan. There is an emerging Local Plan in the form of the North Northamptonshire Strategic Plan but this is at an early stage of its preparation.

2.2 The planning policy for England is set out principally in the National Planning Policy Framework (NPPF). The Planning Practice Guidance (PPG) offers guidance on how this policy should be implemented.

Submitted Documents

2.3 I have considered all policy, guidance and other reference documents I consider relevant to the examination, including those submitted which comprise:

the draft Braybrooke Neighbourhood Plan 2022 - 2031;
a map which identifies the area to which the proposed Neighbourhood Development Plan relates (Figure 1 on Page 2 of the Plan);
the Consultation Statement, March 2022;
the Basic Conditions Statement, March 2022;
all the representations that have been made in accordance with the Regulation 16 consultation;
the Braybrooke Neighbourhood Plan Strategic Environmental Assessment and Habitats Regulations Assessment Screening Report, January 2022
the Strategic Environmental Assessment and Habitats Regulations Assessment Determination Statement, 19 January 2022; and
the request for additional clarification sought in my letter dated 5 December 2022 and the response dated 14 December 2022 from Braybrooke Parish Council. View all documents.

Site Visit

2.4 I made an unaccompanied site visit to the Neighbourhood Plan Area on 9 January 2023 to familiarise myself with it and visit relevant sites and areas referenced in the Plan and evidential documents.

Written Representations with or without Public Hearing

2.5 This examination has been dealt with by written representations. I considered hearing sessions to be unnecessary as the consultation responses clearly articulated the objections to the Plan and presented arguments for and against the Plan’s suitability to proceed to a referendum.

Modifications

2.6 Where necessary, I have recommended modifications to the Plan (PMs) in this report in order that it meets the Basic Conditions and other legal requirements. For ease of reference, I have listed these modifications separately in the Appendix.

3. Procedural Compliance and Human Rights

Qualifying Body and Neighbourhood Plan Area

3.1 The Braybrooke Neighbourhood Plan has been prepared and submitted for examination by Braybrooke Parish Council, which is a qualifying body for an area that was designated by the former Kettering Borough Council on 14 April 2020. On 1 April 2021, Kettering Borough Council was replaced by North Northamptonshire Council, which carries over the statutory designation.

3.2 It is the only Neighbourhood Plan for the Braybrooke Parish and does not relate to land outside the designated Neighbourhood Plan Area.

Plan Period

3.3 The Plan specifies clearly the period to which it is to take effect, which is from 2022 to 2031.

Neighbourhood Plan Preparation and Consultation

3.4 Details of plan preparation and consultation are set out in the Parish Council’s Consultation Statement, March 2022. The groundwork for consideration of a neighbourhood plan was laid at the Annual Parish Meeting in 2019. This was followed by a decision to proceed the following year with formal designation as a neighbourhood area by the former Kettering Borough Council on 14 April 2020 (carried forward by North Northamptonshire Council).

3.5 Public meetings and face-to-face involvement of residents in a period of Covid presented particular difficulties. However, plan preparation and policy formulation were driven forward by a neighbourhood plan steering group and working groups covering frequently raised topics. Key events included a questionnaire circulated to all in October 2020 and an open meeting at the village hall in November 2021, where emerging policies were presented and discussed.

3.6 Publicity and communication with parties was on-going. Special editions of “The Braybrooke Gossip” played a pivotal role. The Parish Council’s website, emails and letters to stakeholders were also of particular importance.

3.7 Consultation under Regulation 14 was carried out in the period 6 February 2022 to 20 March 2022. Details of comments made, the Parish Council’s responses and actions taken are set out in the document ‘Neighbourhood Plan Pre submission consultation responses’. This records some 112 discrete comments mainly from individuals, statutory consultees and agents as well as North Northamptonshire Council.

3.8 Regulation 16 consultation took place between 13 June 2022 and 25 July 2022. Some 127 comments and suggested amendments were made by 14 different parties representing statutory consultees, agents and North Northamptonshire Council.

3.9 I am satisfied that, at both the Regulation 14 and the Regulation 16 stages, the consultation process met the legal requirements and there has been procedural compliance. Regard has been paid to the advice on plan preparation and engagement in the PPG.

Development and Use of Land

3.10 The Plan sets out policies in relation to the development and use of land in accordance with Section 38A of the 2004 Act.

Excluded Development

3.11 The Plan does not include provisions and policies for “excluded development”.

Human Rights

3.12 Braybrooke Parish Council is satisfied that the Plan does not breach Human Rights (within the meaning of the Human Rights Act 1998). From my independent assessment, I see no reason to disagree.

4. Compliance with the Basic Conditions

EU Obligations

4.1 The Neighbourhood Plan was screened for Strategic Environmental Assessment (SEA) by North Northamptonshire Council, which found that it was unnecessary to undertake SEA. Having read the Strategic Environmental Assessment Screening Report and Determination, I support this conclusion.

4.2 The Neighbourhood Plan was further screened for Habitats Regulations Assessment (HRA), which also was not triggered. The site is not in close proximity to a European designated nature site. Natural England agreed with this conclusion. Email dated 23 December 2021, Appendix 1 of the Screening Report. From my independent assessment of this matter, I have no reason to disagree.

Main Issues

4.3 Having regard for the Braybrooke Neighbourhood Plan, the consultation responses and other evidence, and the site visit, I consider that there are five main issues relating to the Basic Conditions for this examination. These concern:

Residential Development
Natural Environment
Historic Environment
Other Safeguarding Measures

and

Broadband.

4.4 Before I deal with the main issues, I have a few observations to make with regard to the representations. First, the Braybrooke Neighbourhood Plan should be seen in the context of the wider planning system. This includes the North Northamptonshire Joint Core Strategy as well as the NPPF and PPG. It is not necessary to repeat in the Neighbourhood Plan matters that are quite adequately dealt with elsewhere. See NPPF, Paragraph 16 f). Having said that, there may be scope to give emphasis to matters particularly relevant in the context of Braybrooke.

4.5 Secondly, the Neighbourhood Plan does not have to deal with each and every topic raised through the consultation. In this regard, the content of the Neighbourhood Plan and the scope of the policies is largely at the discretion of the qualifying body, albeit informed by the consultation process and the requirements set by the Basic Conditions.

4.6 Thirdly, my central task is to judge whether the Neighbourhood Plan satisfies the Basic Conditions. Many of the representations do not demonstrate or indicate a failure to meet those conditions or other legal requirements. Similarly, many of the suggested additions and improvements are not necessary when judged against the Basic Conditions.

4.7 The following section of my report sets out modifications that are necessary in order to meet the Basic Conditions. Some of the proposed modifications are factual corrections. Modifications for the purpose of correcting errors is provided for in Paragraph 10(3)(e) of Schedule 4B to the 1990 Act. Others are necessary in order to have closer regard to national policies and advice. In particular, plans should be succinct and contain policies that are clearly written and unambiguous. NPPF, Paragraphs 15 and 16 d). In addition, the policies should be supported by appropriate evidence. PPG Reference ID: 41-041-20140306.

Issue 1 – Residential Development

4.8 Under Policy H1: Residential Site Allocation, land at Top Yard, west of The Old Rectory is allocated for residential accommodation. Development would be limited to two residential units with no more than three bedrooms each.

4.9 With regard to the size of the units, Appendix 3 to the Plan (Appendix 3: Sustainable Site Assessment Process (SSA) records a desire to promote smaller dwellings to help balance the housing stock locally. Whilst I have not seen any rigorous local housing needs survey, and viability may be relevant in the final analysis, I accept that it would be appropriate for the Plan to seek a limit of three bedrooms.

4.10 The policy continues by identifying a number of requirements that, on the evidence before me, may be ultra vires. I have in mind the requirement to retain and restore the historic granary store; protection of the northern part of the site and the securing of a right of access; and funding for a bench or other seating area for community use. I appreciate that there may be some agreement of the landowner; also, that there would be public benefits. However, this does not mean that the requirements would be lawful.

4.11 The setting of The Old Rectory would be safeguarded, in any event, through the provisions of the Planning (Listed Buildings and Conservation Areas) Act 1990 (Section 66(1)) and the NPPF. Paragraph 200. As to the other matters, the policy should be amended so as to be supportive of the identified benefits rather than setting them out as a policy requirement.

4.12 Other amendments are needed to ensure clarity in the policy wording. In part d), the subject of the second part of the sentence is not clear. In addition, part e) implies that the Highway Authority would have a role in wildlife and biodiversity mitigation. All matters are dealt with through proposed modification PM1.

Issue 2 – Natural Environment

4.13 Under Policy ENV 1, three local sites are designated as Local Green Space. Development proposals that would result in the loss of, or have an adverse effect on, these spaces will not be permitted except in very special circumstances.

4.14 Paragraph 103 of the NPPF states that policies for managing development within a Local Green Space should be consistent with those for Green Belts. This means that inappropriate development should not be permitted except in very special circumstances. However, there may be instances where development would be “not inappropriate” and could be permissible. To bring Policy ENV 1 into line with the NPPF, a change in the wording is necessary (proposed modification PM2).

4.15 Having regard to the assessment of the sites in the Plan and to the answers to my questions (Braybrooke Parish Council’s response to my questions, 14 December 2022), I am satisfied that the sites proposed as Local Green Space generally meet the criteria for designation as set out in the NPPF and should be capable of enduring beyond the end of the Plan period.

4.16 Policy ENV 3 concerns sites and features of natural environment significance. Development proposals resulting in any harm to, or loss of, these sites will be resisted unless it can be demonstrated that the local benefit of the proposal outweighs the harm. In this regard, there may be instances where there would be a degree of harm but that harm would not be significant. This point is recognised in proposed modification PM3.

4.17 Policy ENV 4 addresses woodland, notable trees and hedges of arboricultural, biodiversity, historical or landscape importance. Some are identified on Figure 8 of the Plan but the information is not intended to be comprehensive. This begs the question of how, for example, other notable trees are to be identified.

4.18 The policy states that a tree survey should accompany proposals in order to establish the health and longevity of trees and hedges. For clarity, and in appropriate cases, the provision should require the identification of qualifying vegetation. Proposed modification PM4 refers.

4.19 Policy ENV 5 on bat conservation requires proposals to be supported with an up-to-date bat survey. I appreciate that even small-scale proposals can have an impact on bats. However, to apply the requirement to all proposals would be disproportionate. In my view, there will be some developments which would have no effect upon bats, their habitats or foraging grounds. The policy should be amended accordingly.

4.20 The policy continues by making reference to known and potential bat habitat areas and sensitive areas that would provide roosting sites. In this regard, Figure 9 in the Plan (Bats in Braybrooke) shows only the presumed situation at September 2020. For clarity, such areas should be identified in the bat survey. Necessary amendments to the policy are set out in proposed modification PM5

4.21 Policy ENV 6 (Biodiversity and Habitat Connectivity) states that “development proposals will safeguard habitats and species, including those of local significance as identified in Appendix 6”. In this regard, I am concerned that the policy would be disproportionate in applying to allhabitats and species no matter how significant or insignificant. So far as Appendix 6 is concerned, this is of limited assistance. For example, no sites are categorised as “Sites of local significance” and species are not identified. Proposed modification PM6 is recommended.

4.22 With proposed modifications PM2 to PM6 in place, the natural environment policies would be clear and reflect the available evidence. They would have appropriate regard to national policy and I am satisfied Policies ENV1 – 6 would meet the other Basic Conditions

Issue 3 – Historic Environment

4.23 Policy ENV 7 concerns sites of historic significance with Figure 11 of the Plan and the list in the policy including non-designated sites of local significance. However, designated heritage assets such as scheduled monuments are also shown.

4.24 The policy states, “The significance of the features present should be balanced against the local benefits of any development that would affect or damage them”. This appears to be an attempt to summarise NPPF policy on heritage assets. However, different provisions should apply to designated and non-designated heritage assets. In addition, the wording of the policy is, in my view, rather muddled. For example, it is the judgement that should be balanced not the significance.

4.25 Having identified sites to which the policy applies, and to ensure accuracy and clarity, it is sufficient to refer to the NPPF. Proposed modification PM7 refers.

4.26 Policy ENV 8 addresses ridge and furrow earthworks. These are to be treated as non-designated heritage assets. Again, the policy wording attempts to cover the provisions of the NPPF. For accuracy and clarity, there should be direct reference to the NPPF as in proposed modification PM8.

Issue 4 – Other Safeguarding Measures

4.27 Policy ENV 9 identifies various views that are important to the setting and character of the village. Development which would have an adverse impact on the identified views will not be supported. Be that as it may, some development could have a minor adverse impact and yet not prejudice the objectives behind the policy. In proposed modification PM9, I have made reference to significant adverse impact.

4.28 A similar point arises in Policy ENV 10 where loss of or harm to the existing network of footpaths will not be supported without appropriate mitigation. Proposed modification PM10 refers to significant harm.

4.29 Policy ENV 11 is directed at protecting the dark skies of the neighbourhood. For schemes that would include external lighting, a full lighting scheme would be required. The policy also sets out detailed requirements, for example, that the lighting should be directed downward with a beam angle below 70o.

4.30 There is no evidence to suggest that requirements such as beam angle would be possible for all types of lighting or that a full lighting scheme would be necessary. It would be sufficient to require a demonstration of the absence of significant adverse effects. In addition, and in answer to my questions, there is no evidence of best practice guidance covering nocturnal wildlife other than bats (Braybrooke Parish Council’s response to my questions, 14 December 2022). The policy should be amended accordingly (proposed modification PM11).

4.31 Policy ENV 12 is concerned with flood risk resilience. In this regard, I find the opening paragraph confusing and imprecise:

For clarity, “the areas indicated in Figure 19” should refer to the areas susceptible to flooding.
The reference to climate change targets means existing (unreferenced) national targets together with any future regional or local targets that may be adopted (Braybrooke Parish Council’s response to my questions, 14 December 2022). A developer would be uncertain as to the targets that would apply. In any event, it is the contribution to flooding that is of concern rather than the impact on targets as such.
The “locally applicable flood mitigation strategies and infrastructure” refers to a flood mitigation barrier on the River Jordan as well as such new floodwater management infrastructure as may emerge (Braybrooke Parish Council’s response to my questions, 14 December 2022). Again, the provisions are unclear.

Other points are:

As with other policies, avoiding harm to features of natural or historical environment significance should refer to avoiding significant harm.
The requirements set out in the bullet points should be applied in a proportionate way.
The area of flooding susceptibility referred to in the first bullet point should be linked to Figure 19.

4.32 In proposed modification PM12, I have sought to clarify the policy so that a prospective developer and a decision taker would be aware of relevant policy requirements.

4.33 Policy ENV 14 identifies an “Area of Separation” between Braybrooke and Market Harborough/Little Bowden. I saw on my site visit that separation would be desirable and consider that a policy to give emphasis to the policy objectives would be appropriate.

4.34 There is, however, a tension within the policy. Developments appropriate to the open countryside could be acceptable but these should be located and designed to maintain the current rural separation between the settlement. To my mind, many countryside developments, acceptable under the policy, would compromise rural separation. The reference to rural separation should be deleted (proposed modification PM13).

4.35 The proposed modifications in relation to other safeguarding measures (PMs 9 - 13) are necessary in order to reflect the evidence, ensure clarity and have necessary regard to national policies. The Basic Conditions would be met.

Issue 5 – Broadband

4.36 Policy PC1 (Broadband and Mobile Infrastructure) supports proposals to provide improved access to all businesses and households. Similar support is offered to the mobile telecommunications network. However, the wording of the policy means that support would be available only if each and every business or household were provided with improvements. This was not the intention (Braybrooke Parish Council’s response to my questions, 14 December 2022). The policy objective would be achieved by deleting “all” as in proposed modification PM14.

Other Policies

4.37 There remain a number of policies that have not been the subject of commentary in the above report. These concern Settlement Boundary (Policy H2); Housing Mix (Policy H3); Affordable Housing (Policy H4); Windfall Sites (Policy H5); Design (Policy H6); Important Open Spaces (Policy ENV 2); Renewable Energy Generation Infrastructure (Policy ENV 13); Retention of Community Facilities, Amenities and Assets (Policy CF1); New or Improved Community Facilities (Policy CF2); Traffic Management (Policy T1); Cycling and Walking (Policy T2); Electric Vehicles (Policy T3); Support for Existing Businesses and Employment Opportunities (Policy BE1); Support for Growing and New Businesses and Employment (Policy BE2); Home Working (Policy BE3); Farm Diversification (Policy BE4); and Tourism (Policy BE5).

4.38 To a greater or lesser extent, these topics are covered in NPPF Sections 5 (Delivering a sufficient supply of homes), 6 (Building a strong, competitive economy), 8 (Promoting healthy and safe communities), 9 (Promoting sustainable transport), 12 (Achieving well-designed places), 14 (Meeting the challenge of climate change, flooding and coastal change) and 15 (Conserving and enhancing the natural environment). I find that there has been regard for national policy and no substantive issues of general conformity with local strategic development plan policies arise. The Basic Conditions have been met.

Other Matters

4.39 All policy areas have been considered in the foregoing discussion. With the modifications that I have recommended, the Plan would meet the Basic Conditions. Other minor changes (PPG Reference ID: 41-106-20190509.) (that do not affect the Basic Conditions), including such changes as may be agreed with North Northamptonshire Council (Response to North Northamptonshire Council comments on the submission version of the Braybrooke Neighbourhood Plan accompanying the Parish Council’s response dated 14 December 2022 to my questions), could be made prior to the referendum at the Councils’ discretion. Consequential amendments, corrections and up-dates would also be appropriate.

5. Conclusions

Summary

5.1 The Braybrooke Neighbourhood Plan has been duly prepared in compliance with the procedural requirements. My examination has investigated whether the Plan meets the Basic Conditions and other legal requirements for neighbourhood plans. I have had regard for all the responses made following consultation on the Neighbourhood Plan, and the evidence documents submitted with it.

5.2 I have made recommendations to modify a number of policies and text to ensure the Plan meets the Basic Conditions and other legal requirements. I recommend that the Plan, once modified, proceeds to referendum.

The Referendum and its Area

5.3 I have considered whether or not the referendum area should be extended beyond the designated area to which the Plan relates. The Braybrooke Neighbourhood Plan as modified has no policy or proposals which I consider significant enough to have an impact beyond the designated Neighbourhood Plan boundary, requiring the referendum to extend to areas beyond the Plan boundary. I recommend that the boundary for the purposes of any future referendum on the Plan should be the boundary of the designated Neighbourhood Plan Area.

Overview

5.4 It is evident that a considerable amount of time and effort has been devoted to the development and production of this Plan and I congratulate those who have been involved. The Plan should prove to be a useful tool for future planning and change in Braybrooke over the coming years.

Andrew S Freeman
Examiner

Appendix: Modifications

Proposed modification number (PM)	Neighbourhood Plan page number / other reference	Modification
PM1	Page 15	In Policy H1 b), replace “Design Code” and all subsequent text with “Braybrooke Design Code (Appendix 5)”. Replace Policy H1 c) with the following: “Landscaping details being provided as part of the planning application. These shall indicate trees and hedgerows to be retained. Where retention is not possible, new trees and hedgerows shall be planted in suitable locations.” Delete the first sentence of Policy H1 e) together with the following words: “They will ensure that”. Replace with the following: “Design of a suitable and safe access that avoids an increase in traffic congestion and is guided by the Highway Authority. The design shall ensure that…”. Delete Policy H1 d) and f). Replace with a new final paragraph: “Retention and restoration of the historic granary store on the eastern boundary of the site will be encouraged as will the provision within the northern part of site of open spaces with public access and seating.”
PM2	Page 31	In Policy ENV 1, delete “except in very special circumstances” and replace with “unless consistent with national Green Belt policy”.
PM3	Page 34	Change the beginning of the second sentence of Policy ENV 3 so that it reads: “Development proposals resulting in any significant harm…..”.
PM4	Page 36	Replace the third sentence of Policy ENV 4 with the following: “As appropriate, proposals should be accompanied by a tree survey (BS5837 standard or its replacement) that identifies woodland, notable trees and hedges on the site and establishes their health and longevity.”
PM5	Page 39	Substitute the following for the opening paragraph of Policy ENV 5: “Proposals that are likely to have a direct or indirect effect on bats shall be supported by an up-to-date bat survey showing, for areas within and adjacent to the development site, known bat habitat areas, potential bat habitat areas (those of a type of habitat that supports bats) and sensitive areas (providing roosting sites).”
PM6	Page 40	Replace the first sentence of Policy ENV 6 with the following: “Development proposals shall safeguard significant habitats and species.”
PM7	Page 43	Replace the third sentence of Policy ENV 7 with the following: “These designated and non-designated heritage assets should be safeguarded as set out in the NPPF.”
PM8	Page 45	Replace the second sentence of Policy ENV 8 with the following: “They should be safeguarded as set out in the NPPF.”
PM9	Page 50	In Policy ENV 9, replace “an adverse impact” with “a significant adverse impact”.
PM10	Page 51	In Policy ENV 10, insert “significant” before “harm”.
PM11	Page 53	In the final paragraph of Policy ENV 11, delete “and other nocturnal wildlife”. Replace the remainder of the policy with the following: “In recognition of the Neighbourhood Area’s dark sky zoning status, development proposals for and/or incorporating external lighting should demonstrate that there would be no significant adverse effects individually or cumulatively on the character of the neighbourhood area, on the residential amenity of residents or on wildlife.”
PM12	Page 54	Replace the first paragraph of Policy ENV 12 with the following: “Development proposals within the areas susceptible to flooding (Figure 19) will be required to demonstrate, where appropriate, that any associated harm in relation to flooding or climate change and any conflict with local flood mitigation infrastructure are outweighed by the benefits of the development.” In the sentence above the first bullet point, insert “in a proportionate way” after “demonstrate”. In the first bullet point, after “susceptible to flooding”, add “(Figure 19)”.
PM13	Page 57	In Policy ENV 14, delete all words after “Open Countryside”.
PM14	Page 62	In Policy PC1, delete the word “all” in the first and second paragraphs.

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