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Core Strategy amended proposals consultation

Amber Valley Borough Council are now consulting on the revised proposed Core Strategy as it relates to housing allocations and we all have until 4.30 on Monday 8th December to make further representations. Transition Belper would like to gauge the opinions of as many people as possible to give some weight to the response we make. We have therefore devised a simple survey that will be open until Saturday 23rd November. At this time we will collate and publish the results and incorporate them into our response.

The original Transition Belper representations stand in that;

  • Flood Risk – A detailed Flood Risk Assessment needs to be carried out on the impact on ANY proposed development in Belper for the whole town and further down the Derwent Valley, not just the site being developed.
  • Brownfields must be priority and we need to understand why 2 significant brownfield sites highlighted in our first response equating to 357 houses (SHLAA figures) have not been included.
  • World Heritage Setting – The Derwent Street site is in the WHS conservation area. The Bullsmoor Site is in the WHS buffer zone. We agree with English Heritage that no development can take place that could put this status at risk and thorough assessments need to be carried out before land is allocated for use.
  • A Sustainable Economy – Despite AVBC's comment that the Distribution of Housing means that South Derbyshire will meet Derby’s additional housing needs, 2,256 houses from the AVCBC allocation are for Derby housing. This cannot be sustainable to build commuter housing on green field sites. The Derby housing needs to be in Derby or adjacent to the City.

The consultation ending at 8th September:

Amber Valley Borough Council have proposed additional housing allocations throughout Amber Valley as part of the review of the new Core Strategy. The new allocation includes three additional sites in Belper. This proposal is open for a six week public consultation period ending 8th September. The proposed sites are:

• Derwent Street, Belper – 120 dwellings
• Bullsmoor/Cherry House Farm, Belper – 250 dwellings
• Pottery Farm, Belper – 200 dwellings

Maps of the areas in question:

maps

Here are some historical notes provided by David Village

The Doomsday Book reflects a village named Bradlei, which has never been found, YET, History says that twenty acres of hay was stored at Bullsmoor, which would have been grown either side of the Coppice Brook. The ideal site for the Vikings for a settlement was a number of underground springs passing through a gravel topped hill that filters the water, which surface on a slope bound by trees to keep the water cool where wells would have been made. The settlement would have been built just above the wells on the slope for good drainage to the long houses and the hay would have been stored in barns or long houses with people and their animals. The Sandbed Lane fall to Bullsmoor is perfect for a Viking settlement. Once the land is destroyed so will be your roots.

Letter from Pauline Latham
For those of you who missed it or have inadvertently binned it here is the letter sent by Pauline Latham MP to all Belper households:
Pauline Latham letter (PDF 231 KB)

English Heritage to respond to consultation. Follow link

Comments and suggestions from the Transition Belper Facebook page - https://www.facebook.com/groups/119516118070116/
Ian Jackson: It's going to be interesting to see if a sustainable plan for the whole area can be pulled together. So far I have found 4 brownfield sites in AV with over 50 houses potential each that haven't been included for some reason. Milford Mill, Stevenson's Dye Works, Butterley Engineering and American Adventure. Does anybody know of any other +50 house brownfield sites in AV not considered (Derwent Street and Cinderhill are already in the plan).
Darren Wheatcroft: Is there any reason smaller <5 house sites aren't being considered? OK, you lose economies of scale, but scattering lego houses around in small numbers will have less of an impact visually than a bloody big block of them
Ian Jackson: This is only Part 1 of the Local Plan. Part 2 will look at smaller housing opportunities (<50) & other things like employment land. I don't understand why AVBC are not making a larger allowance for houses to be found in Part 2 of the process as I suspect they will be the ones easiest to develop in the first 5 years. Around the Pottery Farm site we have one or two obvious smaller brownfield sites such as ex Walt Mason's that should be included.

Responding to the consultation
Guidance Notes on Legal Compliance and Soundness (PDF 20.3 KB)
This is still in council speak but it is a 2 page document that summarises what issues will be considered in responses to the Proposed Core Strategy, that must challenge the Legal Compliance or Soundness.
To respond to the consultation online you need to register with Amber Valley Borough Council  and then make your representation. You can register here:  http://www.ambervalley.gov.uk/environment-and-planning/planning/community-planning/community-planning-latest-news/register-interest.aspx

The following has been posted on the Protect Belper Facebook page:
For those of you who want to make a representation regarding the proposed developments in a simpler form. A local resident has contacted AVBC regarding how to respond during the consultation period and was told that they accept responses in any form, the preferred option online makes it easier for them but they acknowledge that this is not always convenient and suitable for a lot of people. You must include your name and address and also please note that everyone in your household can make an individual representation or write a letter etc. As far as we know, anyone of any age can do this, on the official form on the back page there is a tick box which includes under 16's. So please everyone get writing!

Some key points: (as far as we know the following policies are still current but if you know otherwise please let us know and we will check and amend where necessary)
* The proposed development of 450 houses is wholly within the Derwent Valley Mills World Heritage Site buffer zone, which if allowed would set a precedent for potential development anywhere within the DVMWHS buffer zone. This contradicts planning for the historic environment as expressed in Planning Policy Statement 5 and local plan policy EN29.
* The proposed development would not be within the existing built framework (housing) and therefore would be against local plan policies H3 and H5 and also against development in the countryside policy EN1.
* Flooding of the Coppice Brook has become more regular since the expanding development of John O'Gaunts Way, Whitemoor Lane etc towards Heage has occurred. Land now built on would previously have acted as a slow soak away for surface water, but tarmac and concrete have a different effect, and at times of heavy rainfall, this overwhelms the Coppice Brook causing the flooding. The proposed development sites on the other side of Kilbourne Rd would multiply this effect many times; even if they include in proposals SuDS ponds (sustainable drainage system) they would not be able to cope as the hillside around Pottery Farm/Bullsmoor/Cherry House Farm is full of natural springs.

This has been prepared by a Belper Resident

Response to the changes to the Core Strategy Local Plan Part 1

Not sound on the basis that the numbers proposed for Amber Valley are both more than Amber Valley’s own need and more than the outstanding need for the Derby HMA.

Amber Valley Build .v. Own Need

 

Amber Valley

Derby

South Derbys

Total

Stated ’11 – ’28 Need

7395

16388

9605

33388

% of Total Need

22%

49%

29%

 

Stated ’11 – ’28 Capacity

8586

10987

12341

31914

Outstanding Need   (Capacity–Need)

+1191

-5401

+2736

-1474

Proposed Increase

+1474

0

0

+1474

Proposed  Capacity

10060

10987

12341

33388

Proportionate Option
(each area takes a % of the Outstanding Need based on its Own Need)

+ 22% of 1474 = 324

+ 49% of 1474 = 722

+ 29% of 1474 = 428

 

+1474



  • Overbuilding : Amber Valley is already planning to build 1,191 homes more than it needs to support the total need for the Derby HMA.
  • Allocation of Outstanding Need : How can it be objective that Amber Valley is expected pick up all of the outstanding Derby HMA need of 1,474 homes.
    If Amber Valley were to pick up a proportionate additional allocation based on its own stated need, it would only be 324 homes.  This figure is probably achievable without the need for additional strategic housing land.

Actual Numbers Added

Amber Valley Need

7395

Planned Extra Capacity

+1191

Proposed Increase

+1474

Total

10060

Completed, committed, allocated and proposed

8395

Outstanding requirement

(10060 – 8395)

             1665

Additional Strategic Sites

2860

Over-allocation in additional strategic sites

(2860 – 1665)                  1195 (42%)

  • Why do the additional strategic sites add 1195 (42%) more houses than actual need?  It seems most unlikely that strategic sites will under-deliver on expected capacity by more than 40%.

Brownfield Sites

  • It seems both remarkable and unlikely that the Council have been unable to identify more than one brownfield site in its proposals for additional strategic sites, when there are many through the Borough, eg:
    • Butterly Engineering
    • American Adventure
Not based on current evidence
Pollution
Traffic
Flooding

5 year Supply

It seems illogical to focus the 5 year supply on large strategic sites, when they are the ones that require additional infrastructure, are likely to meet with most opposition through planning and are the most difficult to identify.

Not sound as the opportunity for the local community to participate was curtailed both by the Council acting unconstitutionally by barring members of the public from the Council meeting where the Proposed Changes were voted on the very short timescale allowed for consultation following the vote.

Repsonses specific to Pottery Farm (SLHAA Ref AVBC/2008/0230) and Bullsmoor / Cherry House Farm (SLHAA Ref AVBC/2011/0016 & AVBC/2013/0007)

Not sound on the basis that facts that are considered in some parts of the Proposed Changes have been ignored when considering these sites.

Constraints

  • Why is it that the Council has noted the constraints of
    • The capacity of the A38 to take additional traffic
    • The setting of Keddleston Hall Historic Park and Garden
    • The setting of Mackworth Conservation Area
    • The scope for any further expansion of educational facilities at Ecclesbourne School
But has failed to take account of the similar issues in Belper:
  • The capacity of the A609 to take additional traffic.
  • The setting of the Derwent Valley Mills World Heritage Site
  • The scope for any further expansion of the educational facilities at Belper School and Pottery School.

Not sound on the basis that the facts about the location of these sites are being obscured by the way they stated

Logic Being Applied
  • The Pottery Farm site was originally considered in the Options for Housing Growth published in 2011.  The key constraints at that time were:
    • It’s inclusion in the DVMWHS buffer zone and the impact that the development could have on the Outstanding Universal Value of the World Heritage Site.
    • The significant impact that development could have on the surrounding highway network.
  • As the Pottery Farm development has been reduced in scale from that proposed in 2011, it is now considered that the site could address any constraints in relation to the impact on the surrounding highway network.
  • This logic completely ignores the fact that Bullsmoor and Cherry House Farm are contiguous with the Pottery Farm development and this will actually be a larger development as a whole than the one proposed, in 2011.

Not sound on the basis that it contains no infrastructure delivery planning to accommodate additional traffic, additional pressure on schools or additional pressure on medical services

Traffic

  • The Core Strategy fails to address the road infrastructure issues within Belper, specifically roads, which would be severely negatively impacted by either of the proposed strategic sites at Bullsmoor / Cherry House Farm, and Pottery Farm.
  • It is no longer feasible to take a piecemeal approach to infrastructure planning, where each housing development is studied and justified individually.  The Core Strategy needs to include a whole term assessment of the total impact on infrastructure, if all of the sites identified on the SHLAA were to be adopted.
  • This is also a critical issue for the town’s economy, which is increasingly dependent on tourism and visitors to the town.  It runs directly against Core Strategy 6.11 Policy SS5, which states that “The strategy for regeneration in Belper is to promote it as a tourist attraction..
  • If adopted, these two sites would add a total of 450 houses, so an estimated 900 vehicles to the roads, emptying onto Belper’s Roads, at completely inappropriate locations:
  • Kilbourne Road on either side of Pottery Infant School.
  • Kilbourne Road onto the roundabout that is within 100 metres of the entrance to  Belper Senior School.
  • Kilbourne Road via Sandbed Lane, the junction of which is on the brow of a blind hill.
  • Via Parks Road, which empties onto Bargate Road past the main children’s recreation area for the Parks Estate and then where – Gibfield Lane into town which is horribly congested, or back onto Sandbed Lane (see above) past another children’s recreation area.
  • This is going to negatively impact the whole of West and South Belper:
  • Openwoodgate and Whitemoor estates via John O’Gaunts Way and Over Lane.
  • Nottingham and Spencer Roads directly.
  • Park’s Estate, Holbrook and Bargate, via Sandbed Lane, Parks Road and Bargate Road.
  • Holbrook via Killis Lane.
  • All traffic heading out of the town centre to the A38

Not sound on the basis that it directly negatively impacts the preferred economic strategy for Belper.

World Heritage Status

  • This development would reduce the unique characteristic of Belper that is a part of its World Heritage Status, ie the industrial setting within a green landscape, its “arrested urbanisation”.
    • This runs against Core Strategy 6.4 Safeguarding Key Amber Valley Assets, which “..include the Derwent Valley Mills World Heritage Site and its defined buffer zone
  • Hill Top Farm (a piece of land contiguous to the new proposed strategic sites) applied for planning permission for 70 homes.  The planning was turned down, appealed and dismissed.
    • The Inspector’s report on the appeal noted that “..incremental loss of the surviving landscape setting will undermine one of the significant physical attributes of one of the World Heritage Site’s key values…”. 
  • Parts of the Pottery Farm site are visible from Crossroads Farm and Dalley Farm, which are listed as key properties within the area on the DVMWHS Management Plan.
  • The site is also visible from, Spencer Road, Marsh Lane, Crich Lane, much of Whitemoor, the Windmill area, Farnah Green, as well as the roads that directly back onto it: it impacts on the stated unique characteristic, from the viewpoint of about 1/2 of the town.
  • This runs against Core Strategy 10.4, Policy E4, which states that “Development proposals that will have an unacceptable impact on landscape character (and) visual amenity….will not be permitted.

Response to the changes to the Core Strategy Local Plan Part 1

Not sound on the basis that full consideration has not been given to brownfield sites.

Amber Valley Brownfield Sites

  • With no inside knowledge or expertise, we have been able to identify two additional brownfield sites in the Borough that have not been included in the revision document, in spite of both a commitment by AVBC to consider brownfield sites in preference to greenfield, and this being national planning policy:
    • Butterly Engineering - 137
    • American Adventure – 220
  • The revised document only allows for 700 windfall houses between 2011 and 2028.  This averages to just 41 houses per year.
  • Within 1/4 mile of the South East of the Pottery Farm proposed site, there are currently 2 small brownfield sites, totalling up to 12 houses, and 3 empty properties.
    41 across the whole of Amber Valley seems unfeasibly low.

Derby City Brownfield Sites

  • There does not appear to be a supporting document in the AVBC considerations that show which brownfield sites have been considered within Derby city and the reasons that they have been dismissed. ie it is not possible to judge what questions AVBC have asked to justify that they should accept the full outstanding requirement of the Derby HMA.
  • As an example, the government is providing funding to clear the DRI London Road site for development.  Why should Morrisons supermarket get the full benefit of this funding at the expense of greenfield sites in Amber Valley?

Response to the changes
Not sound on the basis that is directly contradicts the Core Strategy for the Spatial Vision for Amber Valley (4), and the economic strategy for Belper (6.11 Market Towns – Belper (Policy SS55)).

“….. Belper, the only town in the East Midlands that lies within a World Heritage Site will have tourist based employment opportunities to replace lost manufacturing jobs based on the textile industry.  The character and appearance of the town will have to be improved through initiatives to restore historic buildings, improve areas used by the public and ensure that new development is of the highest standard of sustainable design which protects the Outstanding Universal Value of the World Heritage Site.”

  • How is it feasible to protect Outstanding Universal Value by building on it?
    • This development would reduce the unique characteristic of Belper that is a part of its World Heritage Status, ie the industrial setting within a green landscape, its “arrested urbanisation”.
    • Hill Top Farm (a piece of land contiguous to the new proposed strategic sites) applied for planning permission for 70 homes.  The planning was turned down, appealed and dismissed and the Inspector at appeal noted that :
       “..incremental loss of the surviving landscape setting will undermine one of the significant physical attributes of one of the World Heritage Site’s key values…”.

“The strategy for regeneration in Belper is to promote is as a tourist attraction as well as a traditional market town and maintain and improve its historic character and appearance.”

  • How is it sound to build on an area which is fundamental to the stated regeneration strategy?
  • This development would reduce the unique characteristic of Belper that is a part of its World Heritage Status, ie the industrial setting within a green landscape, its “arrested urbanisation”.
  • The site is visible from, and so it impacts on this unique characteristic, from the viewpoint of about 1/2 of the town, which also directly contradicts Core Strategy 10.4, Policy E4, which states that “Development proposals that will have an unacceptable impact on landscape character (and) visual amenity….will not be permitted.”


Not sound as the process has not given sufficient opportunity for the local community to participate and be consulted.

Council Meetings

  • The Council acted unconstitutionally at the Council meeting where the Proposed Changes were voted to go forward to consultation, by preventing most members of the public who wanted to attend from accessing the meeting.
  • The Council is planning to act unconstitutionally again, by restricting the number of members of the public who can attend the Council meeting where the Revised Strategy following consultation will be voted on.  The Mayor is intending to issue numbered tickets to people outside the council Chamber in the hour before the meeting, giving priority to those people who have pre-registered to speak.

Very Short Public Consultation Period

  • It is clear from the level of detail available about many of the revised sites that landowners, agents and developers have been in consultation with the Council for some time.
  • The Inspector’s letter challenging the proposed Core Strategy was sent to the Council on 12 May 2014, but the Council meeting which voted to put the proposed revisions out to consultation was not until 23 July, two months later.  The Council spent over 10 weeks on this, before it came fully into the public domain.
  • The public consultation period is just over 6 weeks in total, nearly half the time that the Council has taken.

The public consultation events run from just under 4 weeks to just over 2 weeks prior to the consultation period being closed, so most people will have less than 4 weeks to review and respond to the proposed changes.

Repsonses specific to Pottery Farm (SLHAA Ref AVBC/2008/0230) and Bullsmoor / Cherry House Farm (SLHAA Ref AVBC/2011/0016 & AVBC/2013/0007)

Not sound on the basis that the revision takes no account of population growth and recent house building distribution across Amber Valley.


    Population

    1991

    2011

    % change

    Alfreton

    22822

    22763

    -0.3

    Belper

    18213

    23417

    +28.6

    Heanor

    22180

    25644

    +15.6

    Ripley

    18310

    19315

    +5.5

    Amber Valley

    112200

    122521

    +9.2

    Derby City

    710003

    769686

    +8.4

Since 2011, this pressure on Belper has continued :

    • Houses built in Amber Valley since 2011 = 694
    • Houses built in Belper since 2011 = 378 (54%)

There has not been a corresponding development of road and school infrastructure to support this level of growth.

Repsonses specific to Pottery Farm (SLHAA Ref AVBC/2008/0230) and Bullsmoor / Cherry House Farm (SLHAA Ref AVBC/2011/0016 & AVBC/2013/0007)

Not sound on the basis that development of these sites would directly contradict three of Amber Valley Borough Council the Core Strategy’s Strategic Objecties.

Objective 7

“To protect and enhance the environmental quality and local distinctiveness of spaces and places in the Borough in relation to landscapes and heritage, including, but not limited to, the Derwent Valley Mills World Heritage Site and the Special Landscape Area.”

    • Parts of the Pottery Farm site are visible from Crossroads Farm and Dalley Farm, which are listed as key properties within the area on the DVMWHS Management Plan.
    • The whole of these sites sit within the Derwent Valley Mills World Heritage Site Buffer Zone.  This is also mentioned in Core Strategy 6.4 : Safeguarding Key Amber Valley Assets, which “..include the Derwent Valley Mills World Heritage Site and its defined buffer zone

Objective 8

“To protect, maintain, restore, enhance and create areas of nature conservation and woodland in the environment, with a focus upon enhancing wildlife corridors and networks of habitats, preventing further fragmentation and extending the connectivity of habitats.”

    • The whole of these sites are currently Greenfield.
    • Most of the fields are boundaried by longstanding hedgerow and woodland.
    • The space is crossed by several natural springs.
    • Through its uninterrupted connection to the Belper Parks, it provides a wildlife corridor and a continuous habitat network.

Objective 9

“To ensure that a network of easily accessible and high quality open spaces, parks, recreational areas, …… green infrastructure and cultural facilities is maintained and enhanced in the Borough.”

    • This space is used by a high number of different user groups as a recreational area and green infrastructure :
    • Children going to and from Belper School and Pottery School.
    • Dog walkers.
    • Walkers and runners.
    • Horse Riders.
    • Cyclists.
    • Visitors to Belper
    • The whole of these sites sit within the Derwent Valley Mills World Heritage Site Buffer Zone, which must be considered a cultural facility.


Useful Documents

World Heritage Site Nomination Document


This document gives all the grounds on why the sites were nominated as buffer zones. It also includes the guidelines which supported this decision. Further down it it states how a skyline to skyline approach has been used to designate this area. Sandbed fields etc are clearly part of this strategy. Furthermore it has been designated as special landscape with certain character features and as designated greenbelt it has been preserved as urban containment. The current plans clearly go against that.

WHC Nomination Document (296 kb)

Jane & Mike have been looking at the World Heritage site info and have prepared the following info regarding the impact on the views that are monitored as part of this.

Impact on Derwent Valley Mills World Heritage Site Buffer Zone. (486 kb)

Here is the link that doesn't work in the document above: http://www.derwentvalleymills.org/images/stories/pdf/Appendix_21_monitoring_views.pdf - on page 19 you'll find the last comparison photos and a note that any significant development proposals for the western side of the town will need to be assessed in part on their impact on this view.


Comments from the Public Meeting

There will be an extraordinary meeting held 7pm Tuesday 2 September at St John’s Chapel to approve the Council’s comments regarding AVBC Core Strategy proposals.

Planning consultant Bob Pick has collated the comments from the Public Meeting held 18 August and he would be interested to hear if you have any additional objections. These can be sent to the Council office, St John's Chapel, The Butts, Belper or to admin@belpertowncouncil.gov.uk so that they can be added to Bob’s report. The latest version will be circulated prior to the meeting.

Notes from Public Meeting (73.1 kb)

 

 

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