No, We Cannot Support You

Ilke Homes have not managed to meet the minimum standards of several policies. They admit to some of these, but still request support for their application.

NO Ilke Homes, WE CAN NOT SUPPORT YOU to flout Planning Policies that are meant to protect our nature, heritage, safety and freedom of movement. Below are just a few of the Planning Policy Statements that they have blatantly disregarded, but hope we will let them get away with. Sorry Ilke, we’ve spotted these fouls and will support the Council in not letting you get away with these things! Please feel free to add any of these to your objection letters.

No, we cannot support you. Planning Policy Statements refuted points.

5.6 Policy 3 – Landscape Character – Development should be located and designed in a way that is sensitive to its landscape setting, retaining and, where possible, enhancing the distinctive qualities of the landscape character area which it would affect.  (Does not link pocket park or have green buffers, does not link to greenway, removes footpaths, does not provide play facilities or enough green space.  This is not in any way sensitive and is packed in housing in an enclave.)

5.7 Policy 4 – Biodiversity and Geodiversity – Confirms that the council will seek to secure a net gain in biodiversity through development proposals. Applications will need to take into account the Northamptonshire Biodiversity Supplementary Planning Document, the Upper Nene Valley Gravel Pits Special Protection Area Supplementary Planning Document and the JPU Mitigation Strategy for the Upper Nene Valley Gravel Pits Special Protection Area. (Does not gain Biodiversity and deeply impact local species of deer, lizards, etc. They admit that themselves and their own reports are flawed when mentioning the Play facilities etc. )

5.9 Policy 7 – Community Services and Facilities – Development should support and enhance community services and facilities, where appropriate by Providing accessible greenspace in accordance with Natural England’s Accessible Natural Greenspace Standards (ANGSt) and the Woodland Trust’s Woodland Access Standard unless local standards have been adopted.(No play facilities and not enough green space, with no community services and enhancements. Not even a communal community bench.)

5.10 Policy 8 – North Northamptonshire Place Shaping Principles – Development should create connected places, make safe and pleasant streets and spaces, ensure adaptable, diverse and flexible places, create a distinctive local character, ensure quality of life and safer and healthier communities. (Not well connected to local area basically a walled off area with no access to John Clark Way, Greenway, logical travel flows, and not pleasant streets and spaces, car parking back to back, tiny gardens, no green space, no play facilities, no footpaths, no cycle paths….) 

5.12 Policy 19 – The Delivery of Green Infrastructure – development should ensure a net gain in green infrastructure. (No evidence of safe walkways, links to footpaths, access to greenway, cycle paths just back to back cars and packed housing….)

5.16 Policy 30 – Housing Mix and Tenure – Sets a target of 30% affordable housing in residential developments of 15 or more dwellings. The internal floor area of new dwellings must meet the National Space Standards as a minimum in order to provide residents with adequate space for basic furnishings, storage and activities. New dwellings must meet Category 2 of the proposed National Accessibility Standards as a minimum and the local planning authority will negotiate for a proportion of Category 3 (wheel-chair accessible) housing based on evidence of local needs. (Different number of bedrooms per property but not a viable mix of tenures.  100% social and affordable.  Why not a mix?)

5.23 Policy H3 – Location of New Housing Development – identifies sitespecific criteria for the site as follows: • the proposed development will make provision for older peoples’ accommodation; • the proposed development will provide for appropriate vehicular (Is appropriate access through a bottlenecked congested street and illogical travel flows with no access to John Clark Way and the bypass…….) and pedestrian access; • any application for development of the site will demonstrate that ground conditions have been investigated and any necessary remediation or mitigation is to be undertaken;(Not investigated thoroughly with impact of arsenic and asbestos with prevailing wind and construction soil floating onto neighbouring houses and the greenway.  Their docs state soil will be a factor for neighbouring properties through construction.) • the proposed development will make provision for publicly accessible open space and a well-connected network of public footpaths; (Very little open space and not enough even for basic per person calculation, with no play facilities, removal of footpaths to the greenway and east to west connection)• the proposed development will provide for a minimum of 150 dwelling

5.26 Policy H5 – Self Build – Proposals which include opportunities for self- build homes will be supported. Self-build plots must be offered as ‘serviced plots’ that, as a minimum, must provide appropriate connections to water, electricity, sewerage and communications infrastructure (including high speed broadband) as well as a safe and appropriate means of access on to a highway.(There are no self-build plots being provided.)

5.27 Policy EN1 – Design in Development – requires all new developments to be of a high quality of design.(Debatable high quality design in favour of crushed in minimum living conditions, poor car parking, tight roads, cul-de sacs, no footpaths, little green space, lack of privacy and overlooking, poor access, no play facilities, flooding issues, ……)

5.29 Policy T1 – Development Generating a Transport Impact – Planning permission will only be granted for development that generates a transport impact if the development would not result in a significant residual impact on any aspect of the transport network.(Impact to roads and junctions on Higham Rd\Washbrook Rd\ etc.  There will be massive congestion on Prospect Avenue during construction, but the site will increase already over impacted roads by 2031.)

5.30 Policy CL2 – Provision of New Open Space and Amenity Space – Development proposals that result in a net gain of 15 or more dwellings or with a site area over 0.42 ha will be required to provide suitable amenity space, through the provision of either: semi-natural open space, natural open space or children’s playspace, or a combination of each, in accordance with East Northamptonshire Council’s Open Space Supplementary Planning Document or other document that supersedes it.(Plainly not met………they only put in the small space they do have because of the flooding issues and a need for overflow.  No facilities for children – 0-5years or 5 to 8 years.)

Draft East Northamptonshire Local Plan Part 2

5.34 Policy EN1 – Spatial Development Strategy – Identifies Rushden as the focus for major development, as the designated Growth Town. 5.35 All new residential developments of 10 or more dwellings (or sites more than 0.3 ha) will be required to contribute to the enhancement and provision of open space to meet the needs of the population arising from the development. The(Not even remotely met…)

5.37 Policy EN10 – Enhancement and Provision of Open Space – All new residential developments of 10 or more dwellings (or sites more than 0.3 ha) will be required to contribute to the enhancement and provision of open space to meet the needs of the population arising from the development. The provision of new open space will be required for development where there is Ilke Homes Planning Statement Land off Prospect Avenue, Rushden April 2021 | DW/BC | P20-1722 Page | 19 insufficient access to existing open space within the local area. New open space will need to meet the accessibility standards set out in Table 7, and the quantity standards set out in Table 8 (both reproduced below).( (Not even remotely met…The children’s facilities they discuss are for older children and at an overused facility across a busy road made more dangerous with the impact of the extra vehicles.  Younger children’s facilities should also be accessible.)

5.51 Biodiversity SPD For Northamptonshire (2016) 5.51 Confirms that developments will be required to deliver net gains for biodiversity, where possible, which should be appropriate to the scale, type and location of the development.(This is not happening here and not attempted.)

5.52 SPD confirms that the following information is required to support applications for outline planning permission in order to assess impacts upon the SPA: • A statement of the maximum number of units proposed • Proposed greenspace provision: its extent, location, connections to other nearby greenspaces, and indicative information regarding its design and function, for example whether it will provide a safe and attractive place for people to exercise dogs, and • Existing and proposed links to the SPA footpath/Rights of Way network, including permissive Rights of Way and commonly used pedestrian routes/access points, even where these have not been classified as Rights of Way. (This development does not consider even rights of way that have been awaiting application granting for many years and that residents have pointed out to them.  It does not even have footpaths in some areas and is blocking whole streets from getting to schools nearby.)

Ecology and Bio-diversity – OBJECTIONS

  • The planning application issued by Ilke Homes does not include a copy of the Ecology Survey results. The included Biodiversity Report is acknowledged but the Phase 1 Habitat Survey should be made available for review/comment.
  • Bat activity and moderate potential for bat roosting in trees is confirmed in the Design Access Statement. In this respect a full and detailed bat survey should be completed, per the Wildlife and Countryside Act 1981, and in accordance with the Bat Conservation Trust. The results should be published.
  • Specific details regarding the number, location and type of bat and bird box installations, to mitigate loss of bats and birds, should be included in the planning application.
  • In the Ilke Holmes Design Access Statement, Ilke Holmes confirm common lizards are present on the site therefore, as required by Natural England and DEFRA, there should be a reptile survey and mitigation plans published on how to avoid, reduce or manage any negative effects to the common lizards, which are a protected species.
  • The planning application does not include any details of a hedgehog highway network. Hedgehogs are protected by law and since the passing of a petition by the British Hedgehog Preservation Society, the government has passed guidance regarding hedgehog highway networks that should be included in all new developments.
  • Greenway links along the North boundary and West boundary of the site should be included, in the main site plans for the development, as indicated in page 20 of Ilke Homes Design Access Statement and in the Rushden Strategy Statement 1996. There are no green links between the existing Greenway and the Pocket Park, located to the Northwest of the site, which is against council policy.
  • The current proposals by Ilke Home confirms a “nett loss of –9.62 habitat units” which is against council policy. The council policies (North Northamptonshire Joint Core Strategy 2011-2031 – 3.34 Sites designated at a local level, and also against Biodiversity SPD for Northamptonshire) states that a Biodiversity gain, not loss, should be achieved.
  • The plans include a very small area of open space of 751.7m2 which is not sufficient for a development of this size. If the area of green open space were increased, this would reduce the loss of habitat units.
  • There is a line of existing mature Maple trees identified, adjacent to the Southeast boundary, which are marked as to be removed. Ilke Homes should revise their site plan to relocate the proposed road slightly, which would enable the trees to be retained, which would improve the habitat loss and provide a natural screen between the development and the disused railway. The trees are noted to be in good condition, per DEFRA technical guidance, and may allow bats to roost.
  • The site plans included within the Biodiversity Report differ to the main site layout plan drawings 8806-L-103 sheets 1-4, where the extent and location of proposed properties and new planting differ. ALL drawings in the proposals by Ilke Homes should be consistent.
  • A number of semi-mature and mature trees are identified as being removed and replaced with younger trees which are not an equivalent replacement, thus reducing the number of habitat units and should be avoided.
  • Natural England and DEFRA state that the developer must consult Natural England if a development proposal might affect a  site of special scientific interest (SSSI). The Ilke Homes proposal identifies 3 SSSI sites within 3km, including Rushden Lakes, and therefore Natural England should review and comment on the proposals.
  • Item 4.11 of the Biodiversity report (item 4.11) states that the site is surrounded by residential and industrial development, which is not true. The East boundary borders the disused railway and the Greenway, which currently supports a broad variety of wildlife. To the Northwest corner of the site is located a coppice and grassland, which supports further wildlife. These areas which support existing wildlife should be acknowledged and protected.