The Local Plan Part 1: Core Strategy Regulation 22 Statement of Consultation

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The Local Plan Part 1:

Core Strategy

Regulation 22

Statement of Consultation

December 2013

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Contents

1. Introduction 2

2. Regulation 18 – Summary of the Main Issues Raised 2

2.1 Background 2

2.2 Summary of comments from the public 3

2.3 Summary of comments from Parish/Town Councils 53

2.4 Summary of comments from Borough/County Councillors/MP 64

2.5 Summary of comments from neighbouring local authorities 82 and Derbyshire County Council

2.6 Summary of comments from national bodies 96

2.7 Summary of comments from local groups 123

2.8 Summary of comments from developers, landowners 151 and consultants

3. Regulation 20 – Summary of the Main Issues Raised 202

Appendix A – Persons and bodies invited to make representations 234 under regulation 18

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1. Introduction

Under Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012, a local authority is required when submitting a local plan to produce a statement setting out:

(i) which bodies and persons the local authority invited to make representations under regulation 18,

(ii) how those bodies and persons were invited to make representations under regulation 18,

(iii) a summary of the main issues raised by the representations made pursuant to regulation 18,

(iv) how any representations made pursuant to regulation 18 have been taken into account;

(v) if representations were made pursuant to regulation 20, the number of representations made and a summary of the main issues raised in those representations; and

(vi) if no representations were made in regulation 20, that no such representations were made.

This document has been produced to comply with these requirements. The responses to representations made pursuant to regulation 18 outline how any representations made have been taken into account when the Core Strategy was being produced. There are also responses to some of the representations made pursuant to regulation 20, indicating those representations where further changes to the Core Strategy have been suggested that are supported.

2. Regulation 18 – Summary of the Main Issues Raised

2.1 Background

The Borough Council produced the following documents as part of the Regulation 18 consultation that took place from 28 June to 23 August 2013. These were:

• Local Plan Part 1 - The Draft Core Strategy; • Sustainability Appraisal; • Draft Infrastructure Delivery Plan; and • Habitats Regulations Assessment

The Local Plan Part 1 Pre-Submission Core Strategy sets out the strategic planning policies for the Borough along with the preferred locations for strategic growth sites and indicates which of the adopted Local Plan (2006) policies will be saved and incorporated into Part 2 of the new Local Plan – a Site Allocations and Development Management Policies DPD.

The Sustainability Appraisal (SA) is a mechanism for considering and communicating the likely effects of a draft plan, and alternatives, in terms of sustainability issues, with a view to avoiding and mitigating adverse effects and maximising the positives. An SA of Local Plan Part 1 - The Core Strategy is a legal requirement.

The Infrastructure Delivery Plan is a key supporting document for the Local Plan Part 1 – The Core Strategy. It sets out the transport, physical, social and green infrastructure required to support the Borough’s future growth up to 2028.

In total approximately 360 individual representations were received commenting on the Local Plan Part 1 - The Draft Core Strategy. Consultees were asked to comment on the documents and the policies within the Draft Core Strategy document.

The bodies and persons who were invited to make representations is attached at Appendix A. These include all bodies and persons who have previously made representations in respect of previous consultation exercises and/or those whose details were collected when previous public consultation exercises took place by entering their details on attendance sheets.

All of these bodies and persons were contacted individually by email. Those who do not have an email address were sent a letter in the post.

2.2 Summary of comments from the public

Comments on the Spatial Portrait

• Green Belt should be retained at all costs

• The majority of the Borough is rural and open. There is nothing that reflects this in the Spatial Portrait.

• Needs to describe the landscape and the contrast between the east, west and south west of the Borough.

• Might have included the decline in town centres which underlies the need to seek shopping and leisure activities outside the Borough. Increasingly, villages and smaller settlements are margining under the impact of peripheral housing developments.

• Would be helpful to include a map of the Borough.

• The eastern side of the Borough clearly has a much higher population density and no doubt this affects the emphasis of the document but policies that are relevant to urban sites and populations are, frequently, not relevant to rural landscape and populations.

• Needs to include vibrancy and sustainability – some parts of Amber Valley are very vibrant and desirable.

• Fails to identify what is distinctive about Amber Valley – that it is predominantly rural. Does not mention the SLA designation, the high level of visitors and tourism in the countryside.

• Undervalues the very special landscape in the Ecclesbourne Valley in the west of the Borough.

Response

The Spatial Portrait has been amended to reflect these suggestions.

Comments on the Spatial Vision of Amber Valley

• No. 4 – acknowledges that new village development to meet “the needs of the community” will be provided. We support this approach, but feel that the Core Strategy does not include sufficient policy wording to enable this to happen.

• Not concentrating growth on the four market towns.

• Not sure that sufficient emphasis has been given to the very high quality from a visual, amenity and wildlife perspective of the delightful rural landscape in the west of the Borough.

• What about Areas of Multiple Environmental Sensitivity (AMES)?

• A worthy vision but:

a) Local distinctiveness cannot be maintained in the face of additional standardised design – so often the case with new housing estates. b) Increasingly built-up areas cannot provide increased access to open public space. c) Increased housing provision served by existing roads are likely to lead to more traffic congestion, not less. d) The deployment of forecasts are welcome – if perhaps optimistic in the present economic climate.

• Support the statement of villages and rural areas will be protected from unsustainable development, however, should also state that rural areas, especially, should be protected from ‘unsympathetic’ development.

• Concentrates on improving the quality of the built environment; it should also take into account the importance of improving and protecting the quality of the existing rural environment – does not only relate to biodiversity but also the unique quality of the landscape, the peace and quiet, and freedom from light pollution etc.

• No development should proceed until existing sites, e.g. the Denby commercial site, have been developed and occupied.

• Vision/strategy is meaningless as the housing led plan is based on sites put forward by developers (as confirmed by CLLR Bowley at an ‘Have you say’ meeting in January 2013) and which has stifled any serious debate about the locations of future developments.

• No mention of protecting and enhancing the countryside and natural landscape.

• Should reflect importance of landscape and countryside in west of Borough.

Response

The Spatial Vision has been amended to reflect some of these suggestions. However, some comments are not relevant to the Spatial Vision.

Comments on the Strategic Objectives

• No. 10 – The road referred to here needs to be a by-pass to the same standard as the Ripley by-pass and Langley Mill by-pass. A link road will not meet the needs of Codnor or of the traffic using the A610.

• Not growing Belper you are creating out of town development problems in Codnor.

• These seem good.

• Support strategic objectives 7 & 8

• Laudable objectives apart from item 10 – improvements to the transport system are welcome but the A610 link road is a contentious matter.

• In the objectives matrix against objective 7 an important policy has not been included – this is Saved Policy EN11 (Agricultural Development). This policy is important in preventing the erosion of settlement patterns in rural areas and it has been used previously to minimise the adverse impact of unsympathetic development.

• Strategic Objective 11 aims to mitigate ‘severe’ traffic congestion. This seems unambitious, amounting as it does to an admission that the Core Strategy will lead to traffic congestion and is unsound.

• Objective 7 -& 8 supported but not enough about the countryside. Saved policy EN1 should become part of the objectives matrix.

• Objectives need to defend the beauty of landscapes in the west of the Borough.

Response

The Strategic Objectives have been amended to reflect some of these suggestions. However, some comments relate to matters that are too specific to be included in these strategic objectives.

Comments on the Spatial Strategy

• Not sure that sufficient emphasis has been given to the very high quality from a visual, amenity and wildlife perspective of the delightful rural landscape in the west of the Borough.

• The need to protect the Green Belt is highlighted but nothing about the countryside.

• Saved Policy EN11 needs including with the other saved policies in Objective 7 matrix – It has been used successfully to control/and guide the location of but not necessarily stop development. It is a very useful policy as it conserves the character of settlement patterns in rural areas.

• Infers that EN11 may be replaced by policies in the Site Allocations and Development Management Policies document however am unable to see how the essence of EN11 can be achieved in this second section.

• The requirements of the Derby Housing Market do not necessarily coincide with the needs of Amber Valley. The need for a spatial strategy that accommodates 9,400 houses is open to question. There are un built sites here, indicative of lack of demand and also developer disinclination. A potential land banking situation instead.

• The ‘presumption in favour’ of the NPPF does not reflect local needs.

• Protecting the Green Belt – sizeable amounts are earmarked for housing development, road building and employment – where is the Green Belt review in relation to these demands?

• Support para 6.1 & 6.2 – priority of protecting the Green Belt and maximising development of brownfield land before greenfield.

• The developments within 1 mile of Codnor equate to an increase in population of 5,000 people which effectively doubles the population of the village destroying its identity as a village. The strategy will create an uninterrupted housing area from Hammersmith in the north to Crosshill in the south, effectively making a Greater Ripley conurbation.

• The Core strategy is unsound because alternatives to sites proposed in the Green Belt have been dismissed without convincing reasons. No strategic review of the Green Belt appears to have been carried out.

• Reasoning to support policies SG2 and SG7 is back to front – justification of development proposals in order to deliver new road infrastructure.

• No evidence to back up claims that new A610 will alleviate traffic congestion. There are contradictions in the Transport Assessments in the accompanying IDP which do not support the need for the new road.

• I support AVBC in protecting Green Belt land. In most cases development to 2028 can be achieved without encroaching onto Green Belt land.

• I support AVBC in maximising the use of brownfield land prior to greenfield development. A target figure for brownfield development would be beneficial to the public, officers and the Council. ABVC needs to ensure brownfield land comes forward ahead of greenfield. Set targets will ensure opportunities are not lost because developers will always favour greenfield sites.

• It is disappointing that AVBC does not place more emphasis on the re-use of empty properties, especially those above businesses. These are the most visible properties in a town centre and have a huge impact on ambiance. ABVC should look favourably on change of use applications to support a reduction in numbers of houses becoming derelict. AVBC should promote the change of use of space above shops to residential to support sustainable living.

• I support (para 6.5) that the Site Allocations and Development Management Policies document will ensure that brownfield land is considered first and that the Green Belt is protected from development.

• Now that the EMRP has been revoked, it would be a good opportunity to review the dispersion of houses across Amber Valley and ensure that young people are not priced out of their communities.

• I do not see a specific policy document that addresses creating economic and employment opportunities.

• Para 6.9: I suggest you clearly define in the Local Plan Part 2 the re-allocation of poor quality industrial and employment sites for housing and re-adjust your housing requirements numbers. Part 2 could also provide a framework for monitoring the shifting economic situation and the changing land requirements of modern businesses, which are less than that for the historical manufacturing industry.

• Concerned that development will take place on greenfield/Green Belt sites in preference to brownfield sites. The site at Denby which is close to Derby and has good transportation links could accommodate much of the housing requirement for the Borough. The Planning Minister suggested the redevelopment of the former Butterley Works at a recent visit to the Borough. A FOI request to AVBC revealed that 80% of necessary growth could be accommodated on brownfield sites.

• Unbalanced distribution of strategic sites resulting in coalescence of existing settlements, unsustainable demands on existing facilities and services and an inability to meet the greater housing demand in the west of the Borough.

• Includes protecting the Green Belt, but nothing about the countryside.

• Support 6.3 re-using empty properties. Conditions on holiday let properties should be removed so they can become homes.

• Unbalanced spatial distribution of strategic growth sites Borough wide, focusing over 90% of the proposed development on a 3.5 mile radius of Ripley and Codnor. The ability of local facilities and services to grow at an adequate pace to account for the scale of development has not been taken into account. The scale of development within a 1 mile radius of Ripley and Codnor equates to 1,714 houses and an increase in the population from 5,000-7,000.

• Ripley, Codnor and Waingroves will become merged settlements and suburbs of Ripley, contrary to the NPPF.

• Codnor will be completely enclosed by new development and no recreational space will be available to a village which has always afforded a rural setting with links to Codnor Castle. The current green space around Ripley and Codnor will be reduced by 87%.

• The Draft Core Strategy fails acknowledge that the national rail network stations are in Langley Mill, Alfreton and Belper, but Codnor and Ripley which have no station will take the majority of the housing.

• Green Belt is addressed but no protection is offered to the countryside.

Response

The Spatial Strategy has been amended to reflect some of these suggestions. However, some comments relate to matters that are too specific to be included in the Spatial Strategy or are just general comments.

Comments on Policy SS1: Housing Land Requirements and Distribution

• How can this bias plan have got this far, surely there should be a better split right across the Borough rather than just concentrate on the Eastern side of the A38.

• The plan has identified a more than adequate amount of new houses

• No additional information is provided in this current strategy that would indicate neither evidence based, objectively assessed need, nor that would justify this forecast. On this basis alone, the need for key strategic sites to be identified is not proven.

• Belper villages – Policy SS1 recognises the need to maintain the rural character and individual settlement identities of the villages. Over the past 30 years, Belper has expanded to pull in many of its surrounding villages (Broadholme, Milford, and Openwoodgate) and would urge that those which remain separate from the town by green spaces are kept so, namely Bargate, Blackbrook, Farnah Green, Heage and Holbrook.

• The wording in relation to villages is not clear, suggest deletion of “the settlements of”, purely to simplify the language used. In addition add “A limited amount of small scale growth will be considered in villages in accessible and sustainable locations, specifically to meet the needs of the local community”.

• The proportion of affordable housing required was substantially reduced – why?

• The large scale of proposed development is disproportionate to the needs which can be met by currently ailing town centres.

• Don’t understand why the majority of proposed sites are in the east, especially around Codnor. Schools and medical services would struggle to cope with the numbers of people.

• Reasoning behind justifying allocations SG2 and SG7 are flawed – NPPF requires LPAs to identify land for housing based on an objective assessment of local housing need, an assessment of the capacity of local infrastructure, key environmental constraints, and whether sites can be accessed by non-transport modes. AVBC has assumed the desirability of the Codnor Bypass and is retrofitting site allocations to generate resources to funds it.

• ABVC need to show it has the assessments and Sustainability Appraisal in place for this scale of development before any more planning permissions are granted on strategic sites.

• What impact will development of this size have on mental health and deprivation?

• The plan treats all the Borough as being part of the Derby HMA but in reality only the southern area functions in this way. The number of houses required is based on this assumption and has led to a figure which is unrealistic. The focus of new housing growth on Alfreton, Ripley and Heanor is excessive and represents a level of growth never seen in these areas which is unsustainable given the decline in the base industries of the area.

• Distinction has to be made on what Government is trying to achieve, building houses so that more people can find their way onto the property ladder, especially first-time buyers or helping kickstart the building/construction industry to achieve more economic growth for the country as part of the recovery process.

Response

It is considered that this policy will meet the full, objectively assessed needs for housing in the Borough as required by paragraph 47 of the NPPF. It is based on work carried out by consultants who are specialists in assessing housing need who produced a Housing Requirements Study for authorities in the Derby Housing Market Area in 2012 and updated the housing projections when they were commissioned a Strategic Housing Market Assessment (SHMA) in 2013. This included a response to representations that were received on the Council’s Preferred Growth Strategy which was the subject of public consultation in 2012.

The policy, has, however been amended to make it clearer where housing growth is proposed. Some of these statements are just general comments.

Comments on Policy SS2: Business and Industrial Land Requirements

• Well-designed policies for economic growth are welcomed.

• Cannot understand why there is not a prestigious business site within Amber Valley especially as it covers such a long period.

• No mention of the land and properties owned by Tesco which they no longer intent to develop – this is a large brownfield site with good access to the town and its public transport networks. This site could potentially fulfil all of the building needs proposed within Belper, but has not been identified as an opportunity in the strategy.

• Due to the changing nature of business it is believed that the sites identified as Business & Industrial Land need to be monitored throughout the duration of the Local Plan, as defined intervals in time, as there may still be an over allocation of land for this purpose.

• Were appropriate AVBC should allow re-cycling of employment land as older style businesses (with a need for large sites) are replaced by technology & knowledge based businesses, requiring less employment land compared with traditional manufacturing businesses. This would support the changing face of our economy and improve dated brownfield sites by transferring them to housing land. An example where land could be recycled for housing be Smiths Flour Mills in Langley Mill.

• Address improvements which could be made to existing sites rather than using Green Belt for employment.

• De-allocation of existing sites will create large brownfield sites- these are not readily utilised at present.

• New businesses have to be attracted to Heanor if a large site is to be developed at Newlands/Taylor Lane.

• The site at Lily Street Farm, Derby Road, Swanwick could come forward as part of the preparation of the Site Allocation and Development Management Policies document (Part 2 of the new Local Plan). It is worth pointing out that the reason for not taking this site forward as a Strategic Preferred Growth site for housing was, it was not well related to Alfreton and Swanwick and its development would urbanise an area which currently provides a rural open break between Swanwick and Alfreton.

Response

The policy has been amended to emphasise that the Council will review existing business and industrial land allocations and the consideration of potential new allocations in the Site Allocations and Development Management Policies DPD and to ensure that sufficient high quality sites are included in the overall provision. Some of these suggestions are too specific for a strategic policy or are just general comments.

Comments on Policy SS3: The Role of Settlements

• Settlements should be kept separate at all costs which plan does not reflect.

• Regarding retail – concerns over the vagueness of the term ‘larger –format units’ - these units need to be in keeping with the heritage of Belper.

• Although one aim of the Core Strategy is to ‘extend and improve the quality of the retail offer and provide a wider retail offer to ensure that spending takes place within the Borough’ it needs to be clear that this will enhance, not conflict with the current retail on offer.

• Settlements need to develop to survive. Pubs, shops and local facilities even in the smallest communities need to be supported.

• The Borough settlements are set within a rural landscape so there should be reference to the potential impact of new development on the urban/real interface.

• New development can be used to improve the rural urban interface by high quality design in line with the local landscape character and incorporate landscape mitigation such as appropriate planting, boundary construction, building materials, design and colour.

• Need policy wording that positively deals with the potential impact of new development on the urban/rural interface.

• Issue of town centre regeneration must be addressed in order to maintain settlement distinctiveness and economic vitality.

• It will not be possible to promote and improve town centres if two major sites some way away from existing town centres are allocated to housing and associated retail development with a road designed to channel traffic away from existing town centres.

• Support independent retail sector by not inviting large format units.

• Policy needs to address rural amenities – village pub and shop.

• Small settlements with threatened facilities need support as well.

• The proposal to focus local development in the District Centre of Langley Mill and the local centres of Duffield, Codnor, Leabrooks, Swanwick and Somercotes will have to be dealt with very sympathetically, especially in respect of the neighbouring villages of Leabrooks, Swanwick and Somercotes, as too much development will lead to unnecessary and unwanted urbanization of these individual communities.

Response

These are just general comments or relate to matters not relevant to a policy on the role of settlements. It is considered that no amendments to this policy are required.

Comments on Policy SS4: Town Centre Regeneration in Alfreton

• Do need a masterplan for Alfreton, all towns need your help

• Alfreton has high social needs; the town will be augmented by 500+ houses under current proposals. A lesser scale of development would facilitate an appropriate approach to regeneration.

Response

The policy does state that the Council will consider the need for a Masterplan to be produced. The other comment relates to a matter that not relevant to this policy. It is considered that no amendments to this policy are required.

Comments on Policy SS5: Town Centre Regeneration in Belper

• You write ‘The strategy for regeneration in Belper….’ We argue that ‘regeneration’ is not the right word and should only be used in the context of the Meadows/Derwent Street site. Otherwise, we suggest ‘enhancement’.

• ‘Larger-format units’ – needs to be defined clearly. Can there be a size limit on any larger-format multi-national and maximum of units within one development area?

• Agree with ‘it is vital that this does not involve development that would detract from the character of this historic market town……’ etc, but concerned how this can be prevented if there are no specific guidelines in the local plan regarding the scale and extend of larger-format national multiple retailers.

• Support independent retailers to keep town centre vibrant.

• A good summary

• Would appear to be a direct contradiction in stating that Belper needs more larger national retailers, but that the independent sector is a key asset. The large number of independents and low number of national retailers is a key part of the individual identity of the town, which should be maintained.

• Agree totally with a Masterplan especially if this could involve the community.

• Need adequate parking for coaches and a tourist office nearby.

• There needs to be policy wording in SS5 and/or SS8 that deals with the potential impact of regeneration/development on the wider area. A Design Brief should be required and it must consider the impact of the development on the wider area including landscape character, visual and environmental sensitivity.

• Belper is more prosperous and does not face development on the scale found in the east of the Borough.

• Support this positive policy.

Response

The policy does state that the Council will consider the need for a Masterplan to be produced and refers to development in the town centre looking to improve parking for coaches. However, it has been amended to refer to supporting independent retailers. However, no other changes are considered necessary, as the other suggestions refer to matters too detailed for a strategic policy or they are just general comments.

Comments on Policy SS6: Town Centre Regeneration in Heanor

• These plans have been around for some time but very little seems to get delivered.

• Fully support regeneration of Heanor town centre.

• The more people who live in our town centres (i.e. above shops) & close to the town centres (ex-relief road land and associated car park (ex. Somerfield supermarket) can only help to support the shops and traders; as such AVBC needs to ensure its policies support the creation of housing in our town centres.

• New businesses have to be attracted to the area to provide job opportunities.

• Need 1 hour free parking on the Market Place.

• Support the regeneration of Heanor Town Centre. The more people who live in and near our town centres the better to support the shops and traders. AVBC needs to ensure there are policies to support the creation of housing in town centres which includes the ex-relief road allocation and Somerfield Supermarket car park.

• I am concerned that Heanor is a dormitory town and people spend their leisure time away from Heanor. This is because Heanor has limited job opportunities, leisure and shopping facilities to attract people. As such the amount of housing proposed on the edge of Heanor should be reduced if possible.

• Heanor suffers from low retail due to the proximity of the large retail park with free parking.

• I suggest that the Council support regeneration prioritising development in and around the Market Place. I have previously made suggestions on how regeneration should be approached in the town, involving constructing the relief road on the back of a relocated supermarket on this land with an interface with the town centre on the site of the former Somerfield. This land could accommodate the petrol station that requires relocation for the current major supermarket operator to release consent for their extension. Relocation would place the main retail anchor in the heart of the town and enable to existing supermarket site to be released for development. Fundamentally I do not consider that the council has a strong enough strategic approach to the regeneration of the town centre, that is failing due to the placement of two large supermarkets either side of Heanor Hill.

Response

The general policy for development in town centres (SS8) makes reference to supporting the provision of new housing, if it can demonstrated that it will not impact on the vitality and viability of the town centre. It also refers to supporting the use of upper floors for residential use. However, no other changes are considered necessary, as the other suggestions refer to an inner relief road which was previously proposed by Derbyshire County Council which is no longer to be provided and matters too detailed for a strategic policy or they are just general comments.

Comments on Policy SS7: Town Centre Regeneration in Ripley

• Ripley has been waiting for investment for some time. It has seen a decline as it appears that the Borough Council has concentrated on Belper alone. A new out of town supermarket is not what the Town or public want. The Ripley masterplan has been a joke, with no timescales ever been given reasons why it has not been delivered.

• Regeneration of Ripley town centre would not be helped by the building of an out-of- town supermarket.

• Not taking into account all relevant independent advice given and that the viability and vitality of Ripley town centre will be put at great risk if the proposals for an out of town supermarket is approved, as the NPPF requires you to protect and enhance existing town centres.

• It is important to attract development into the town centre and to protect what we already have as required in the NPPF and not to promote development on the outskirts of Ripley as with the Morrison’s proposal.

• 2 hours free parking is necessary to encourage shoppers into the town.

• If you allow the development of Morrison’s it will seriously affect the vitality and viability of the centre resulting in the closure of the Co-Op and several other stores.

• Development that takes footfall to the market place is good. Support policy.

Response

No changes are considered necessary, as some comments refer to a proposal on the edge of the town and other comments refer to the adequacy of the Ripley Masterplan.

Comments on Policy SS8: Development in Town Centres

• There is a need for some stimulation to attract people back to the towns surely free parking would be an attraction.

• Agree with the policy

• Can it be specific when a retail impact assessment is ‘appropriate’?

• A Design brief should be required and it must consider the impact of the development on the wider area including landscape character, visual and environmental sensitivity.

• Residential development in town centres should only be considered when commercial alternatives have been exhausted.

Response

The general policy for development in town centres (SS8) makes reference to supporting the provision of new housing, but only if it can demonstrated that it will not impact on the vitality and viability of the town centre. However, this policy has been amended to be more specific about when an impact assessment will be required. Car parking charges are not a planning issue and a development brief in the form of a Supplementary Planning Document has already been adopted for land between the A6 and the River Derwent in Belper.

Comments on Policy SS9: Primary Shopping Frontages

• Ripley Primary Shopping Frontage as indicated does not correspond with that on the ground. Grosvenor Road, Church Street and the High Street need to be included.

Response

Restricting non retail town centre uses on these streets would have a negative impact on the vitality and viability of the town centre.

Comments on Policy SS10: Green Belt

• Fully support AVBC in protecting Green Belt land from inappropriate development and that the boundaries shall only be changed under exceptional circumstances.

• Maintenance of the Green Belt is a fundamental importance of protection of the countryside.

• Part b) Not convinced it should include sports facilities

• Point e) limited infilling in villages, and limited affordable housing for local community needs. This should be qualified, by adding, ‘Where the local community has identified that need and has agreed by consultation that it is necessary’.

• Point f) seems extraneous, it is actually talking about brownfield sites, and as far as I am aware the fact they are ‘brownfield’ ipso facto means they can’t be green belt.

• Point J) should be qualified ‘engineering operations’ could be used to cover all manner of other developments that don’t fall within any other category.

• Part I & j) these can have a very significant detrimental effect so there should be wording about restraints.

• Over the past 30 years, Belper has expanded to pull in many of its surrounding villages (Broadholme, Milford, and Openwoodgate) and would urge that those which remain separate from the town by green spaces are kept so, namely Bargate, Blackbrook, Farnah Green, Heage and Holbrook.

• Green Belts check the unrestricted sprawl of large built-up areas and assist in safeguarding the countryside from encroachment.

• This policy also requires additional wording to accommodate the needs of villages washed over by Green Belt, such as Holbrook. The final paragraph of SS10 also needs adjusting to accommodate such local village growth.

• The first section of this is basically a summary of points from the NPPF.

• The first sentence of SS10 should state, ‘Within the designated Green Belt, planning permission will only be granted where exceptional circumstances can be demonstrated, and where the development falls in one or more of the appropriate categories listed below’.

• Poor farmland should be considered before good – e.g. poor quality land that has been outcropped and not drained properly.

• Too much emphasis on Green Belt. If the site is ideal apart from Green Belt issues, why not use it? Green Belt land not fit for farming is a constant headache plagued by motorbikes, dog walkers and vandals.

• A policy of little substance given the excessive erosion of the Green Belt in Ripley and Codnor.

• Weak policy – purports to protect the Green Belt, but indicates circumstances where some may be lost as with the new link road.

• Policy SS10 has far too many reasons for granting appropriate development and because of this weakens the protection Green Belt land is afforded.

Response

Some of the wording of this policy cannot be changed, as this would not be in accordance with the NPPF. It is not agreed that the policy should allow more development in villages washed over by the Green Belt.

The policy has been changed to state that:

‘Within the designated Green Belt, planning permission will only be granted where exceptional circumstances can be demonstrated, and where the development falls in one or more of the categories for appropriate development, as follows’

Comments on Policy SS11: Amendments to the Green Belt

• There should be a strategic review of the Green Belt across neighbouring LPA areas under the Duty to Co-operate to see if a more sustainable approach of accommodating future growth exists. This was proposed by the EMRP (which is still a material consideration).

• There should be no changes to the Green Belt until all brownfield sites have been developed.

• The arguments used to justify the amendments are totally flawed with no recognition of the objections shown by the independent survey carried out by the Ripley & Heanor News and other petitions and letters totally objecting to the desecration of our Green Belt

• There is no justifiable reason to change the Green Belt boundary at this time around Heanor as there is sufficient and more appropriate development land available within the town boundary which will support and encourage economic growth.

• In principle against identifying Green Belt land

• Strongly object to the amendment – Development of another large supermarket that the town doesn’t need is leading the need to push for housing and the road line to be moved to the north into open countryside and the green belt. It will be visually intrusive, spoiling the landscape of the area and the openness of the countryside.

• No Green Belt review is indicated for Amber Valley.

• The integrity of the Green Belt must be maintained, housing developments designed to fund a contentious road – also proposed for the Green Belt – not acceptable.

• Green Belt boundaries should not be altered only in exceptional circumstances, and in my opinion Amber Valley have not demonstrated that exceptional circumstances apply in these cases to warrant moving the green belt boundary.

• The suggested amendments to the green belt as indicated are not justifiable in accordance with paragraph 85 of the NPP; this is clearly shown in figure 11.

• ‘The A610 link road and a former railway line will provide a clear defensible boundary for the Green Belt, in accordance with paragraph 85 of the NPPF’. This is a misinterpretation of the NPPF. The proposed altered boundary of the green belt to the east of Codnor has not been defined by ‘using physical features that are readily recognisable and likely to be permanent’, it has in fact assumed an artificial boundary first, the proposed link road, the defined that as the boundary; there are clearly no ‘physical features that are readily recognisable’ where this boundary is proposed now.

• Paragraph 3 says ‘Paragraph 90 of the NPPF refers to local transport infrastructure as a form of development that is not inappropriate in the Green Belt, provided it preserves the openness of the Green Belt’. This may well be the case but had the link road not been deliberately routed to include within it the redesigned areas of housing and commercial development, but as it does it certainly doesn’t protect the openness of the green belt; as such your next paragraph and bullet points therefore do not apply.

• There is no need for the land to be redesigned, the housing need in this part of Amber Valley has been exaggerated out of all proportion. The need for a link road to say the least is spurious, being supported mainly by those who seek to gain from its construction.

• Old open-cast barren farmland should be considered as recommended by the Government.

• No change to boundaries without consulting the owners/public.

• Insufficient attention has been given to the identification of brownfield sites as alternative areas of housing, including underused and semi-derelict industrial estates.

• The creation of the ‘relief road’ is being used as justification for building houses on Green Belt land east of Alfreton Road when in truth it is only there to serve those houses and will not act as a proper bypass for Codnor.

• The link road is not a priority, therefore not a good reason to allow the release of the Green Belt to the east of Codnor.

• AVBC has not demonstrated that exceptional circumstances exist to allow alteration of the Green Belt boundaries for sites SG2 and SG7. A long standing commitment to deliver the A610 Codnor Bypass does not constitute ‘exceptional circumstances.’

• No evidence AVBC has carried out a strategic review of the Green Belt using a methodology for prioritising different parts of the Green Belt in terms of the degree to which they fulfil the 5 purposes of the Green Belt.

• Most are not necessary. The genuine housing need provision can be met without taking further Green Belt land.

• Is the new link road and housing really necessary? Amounts to urban sprawl.

• Even a reduction of 0.5% in the Green Belt is too much as this important protected land will not be replaced.

Response

A key component of the Spatial Strategy is the protection of the Green Belt. However, it is proposed to delete land from the Green Belt at Ripley and Codnor, in conjunction with proposals for mixed use development and the provision of a new A610 link road between Ripley and Woodlinkin. There is a longstanding commitment by both the Borough and Derbyshire County Council to securing the completion of a new A610 link road between Ripley and Woodlinkin. The provision of this new link road will not only relieve traffic congestion on the current A610 route, but will also improve the east-west link between the A6/A38 and the M1 through the Borough, enabling the provision of new housing development and the development of high quality employment land, which will help to improve the local economy. Unlike other potential strategic sites in the Green Belt that were not previously selected as preferred sites, the allocation of these sites would also not lead to any coalescence of settlements, as there are no nearby settlements.

It is not considered that a review of the Green Belt boundaries is required, as the Spatial Strategy is to only allocate land in the Green Belt for development where exceptional circumstances can be demonstrated. Although a Green Belt Review was carried out by the Derby HMA authorities for those areas adjacent to the built up area of Derby, it is not considered necessary to carry out such a review as such for the rest of the Borough. When a comprehensive review of all potential strategic sites took place, those that were located in the Green Belt where no exceptional circumstances could be demonstrated were not selected as preferred sites, as they would involve a significant reduction in the distance from nearby settlements and the new boundaries created would not be permanent in the long term and capable of enduring beyond the plan period.

It is accepted that the proposed amendments to the Green Belt boundaries do not have clear defensible boundaries at present, but these amendments will not be made unless the new alignment of the A610 is implemented that will provide such a boundary. The NPPF does not require such boundaries to be natural. However, the background text referring to local transport infrastructure as a form of development that is not inappropriate in the Green Belt has been take out of the background text to this policy.

There are no proposed changes to the Green Belt at Heanor.

Comments on Policy SS12: Countryside

• We need to retain as much countryside as possible for the use of everyone

• Agree with the policy

• There is no mention of the policy of allowing houses of “exceptional design quality” to be built in the countryside. Is this policy still in effect?

• It is essential that any new buildings in the more rural areas of Amber Valley are adjacent to existing buildings and in similar style and scale.

• A definition of what is meant by ‘essential in conjunction with the requirements of agriculture’ and ‘is necessary within the countryside’ would be helpful.

• Careful control needs to be exercised over development proposals outside the built framework of settlements, which will maintain the openness of the countryside, whilst recognising the need to accommodate development which is necessary to sustain the rural economy, or which is otherwise essential within a countryside location.

• The NPPF reinforces the need to retain the saved EN11 Agricultural Development policy in this section of the plan. Need to include – any proposed buildings in the countryside are located within or adjacent to existing buildings to minimise visual impact. – Support this policy but need to include an additional point to ‘retain the openness of the countryside and minimise the impact of visual amenity’.

• Concerns about the method of monitoring as this monitoring tool is extremely negative and the damage will have been done which cannot the be rectified.

• Should be a relevant SPD with criteria against which to check/assess the appropriateness of an application to the policy before an application is approved and it may then also be used for monitoring.

• It is all very well to quote the NPPF in regards to the countryside but this core strategy does little if nothing to promote and enhancement of it whatsoever, in fact in this section it seeks to reinforce the council’s ability to grant planning within the countryside.

• Generally support but could policy EN11 of the Local Plan be incorporated into SS12?

• Definition of the words ‘essential’ and ‘necessary’ would be useful.

• (a) even if development is essential a balance has to be struck to maintain the attractiveness of the countryside and other interests e.g. for tourism, bio-diversity, and environmental concerns. (b) No development is absolutely necessary. This must be a balance between gains for an individual and a loss for the whole community.

• Under the previous Local Plan this policy was EN1 and as this policy was used in conjunction with EN5, which protected Open Land between Alfreton, Somercotes and Swanwick and because EN5 was not a standalone policy, this weakened the protection afforded to this Open Land over many years. Serious consideration now needs to be given to a policy in the Local Plan (Part 2) regarding the protection of the field to the north and to the field to the south of the proposed Crematorium/Burial Ground, to prevent expansion, which will inevitably come in the future and prevent any other development coming forward in the future. This standalone policy needs to be unambiguous and categorical in its nature.

Response

The NPPF refers to special circumstances for development in the countryside, but it is not considered necessary to refer to this in this policy. The policy has been amended by adding:

“All forms of development in the countryside will be required to be of an appropriate scale or character and to not have a significant adverse impact on the character of the locality and is, where possible, located within or adjacent to existing buildings to retain the openness of the countryside and minimise visual impact.

Development will also be required to comply with the criteria set out in policies E2, E3, E4 and where applicable, E5”

Comments on Policy SS13: Presumption in Favour of Sustainable Development

• You have not shown a convincing argument of sustainability for the majority of sites selected for growth.

• ‘Where there are no policies relevant to the application’ seems to be a green light in favour of development. This paragraph needs to be much tighter.

• Request that AVBC ensure that it includes sufficient clauses within this section and policy to ensure that compliance with all the requirements of the Local Plan are mandatory, prior to allowing development to proceed per this clause and policy.

• Plan should meet objectively assessed needs; these should be published and up to date.

• The section is totally meaningless, objectives are laudable but languages translate into often unhappy development.

• ‘Sustainable development’ challenges definition, not readily corresponding to reality.

• I suggest the following is added to Line 1 of para 1: “When considering….. ….National Planning Policy Framework, provided the application is in accordance with the policies of this Local Plan.”

• Fine in principle but you need to develop a more robust test of sustainability than has been demonstrated in your reports to the Planning Board in the last 3 years.

• Concerned at “where there are no policies relevant to the application or relevant policies are out of date at the time of decision making”. Surely until the emerging plan is adopted the existing Local Plan policies will apply.

• The community affected by any development must not be disadvantaged in order to secure the gain for an individual/development company.

Response

This policy wording has been suggested by the Planning Inspectorate and should not therefore be changed. However, the words “provided the application is in accordance with the policies of this Local Plan” have been added to the policy as suggested.

Comments on Policy SG1: Outseats Farm, Alfreton

• A £15,000 traffic survey proved this site to be unsustainable.

• The combined impact of the development of this site and the site at Eachwells Lane will create severe traffic congestion

• Is on a scale disproportionate to the existing settlement – local housing needs are not on this scale and local need for social or ‘affordable’ housing seems unlikely to be met by developers.

• Inevitable that it will place heavy demands on already overstretched community services.

• Potential problems of traffic congestion need to be addressed.

• Local public open space will be significantly reduced.

• Is a gross of over exaggeration of housing needs in Amber Valley particularly in the areas around Alfreton, Ripley, Codnor, Heanor and Denby – these areas are being unfairly burdened with the proposed housing development.

• This area of development should not be included in the Core Strategy.

Response

This site now has outline planning permission. However, the policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG2: Alfreton Road, Codnor

• Codnor is not a market town.

• Belper is a more suitable location

• Flooding problems would be created

• Development would result in neat sewage entering the local water course

• The argument is flawed and the infrastructure will not support this level of housing.

• Codnor needs a by-pass not a link road, so reference to the A610 needs to state this.

• Use of Green Belt is not acceptable.

• Community identity is likely to be submerged by the weight of proposed housing developments in Codnor.

• The proposed development relates to the provision of a major road rather than meeting housing needs.

• Main justification for using this site appears to be that the development of the site for housing would deliver the A610 link road is not acceptable and is considered a low priority in the Derbyshire Local Transport Plan.

• Green Belt is supposed to be protected by the NPPF and confirmed by the Planning Minister Nick Bowles so why is this site still being considered.

• This area of proposed re-designation of green belt is only possible because of the misinterpretation in the strategy of the intentions in the NPPF.

• The development will separate Codnor from its castle.

• The land has historical significance as it is part of the once larger Codnor Common owned by the illegitimate son of William the Conqueror and should not be covered by a housing estate.

• Old mine workings may lead to subsidence problems.

• How will the spring, the source of the watercourse be accommodated?

• This site may be able to contribute to the delivery of a new A610 link road, but there are far too many houses in a small area.

• The huge influx of people due to the new housing development would only add to the problem of traffic congestion as there would be more cars in use. Public transport links are poor so new residents would be heavily reliant on cars.

• The building of 600 houses on Green Belt land will merge communities and is contrary to NPPF policy.

• Completely out of scale with the existing area.

• The inclusion of this site is a political aspiration. All the sites selected are in the Labour controlled wards.

• An exit poll of attendees at the consultation of the Draft Core Strategy in Codnor in October 2012 showed 87% against the development of this site. 91% of representations to the Draft Core Strategy in December 2012 were against development of this site.

• A petition of 1,091 signatures opposing development of this site has been previously presented to AVBC by STOP 500 Residents Group. The petition raised the following objections:

1. The entire site lies within nationally protected Green Belt, the release of which is contrary to the National Planning Policy Framework. The proposed release of Green Belt is totally against the wishes of Amber Valley residents who have continually expressed overwhelming support for the protection of the Green Belt at each consultation stage in the Local Plan preparation to date.

2. We do not believe that the best practice has been followed at each stage with regard to the required integral sustainability appraisal process to inform the preferred site options that have been put forward. This has no doubt had an effect on the preferred site selection process, which has not been open, clear and transparent. Amber Valley residents are therefore unsure as to how decisions have been made.

3. We believe the use of brownfield sites in preference to greenfield sites to accommodate future growth across the Borough has not been fully and robustly explored.

4. Codnor does not have the necessary services and facilities to support this level of growth in a sustainable way. Over 1,500 new houses are being proposed within a mile radius of Codnor. This concentration of preferred sites in the Ripley/Codnor area is not a sustainable approach to meeting the housing needs of the Amber Valley Borough area as a whole.

5. As no transport study including a cost benefit analysis or business case has been undertaken with regard to the need for a by-pass nor alternative traffic management options explored the exceptional circumstances to justify the proposed release of green belt at this location cannot be evidenced.

• Failure to acknowledge well used public ROW across SG2.

• There will not be the demand for this scale of new housing as there are not enough people who want to live in the Ripley/Codnor/Waingroves area.

• The residents are extremely proud of their doomsday village heritage and identity. The Green Belt land to the east of the village forms part of the Codnor Castle ancient deer park.

Response

The reasons for amending the Green Belt in this location have already been explained in the response to the comments on policy SS11. However, this policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG3: Land North of Denby

• This is possibly the most contaminated plot in the UK

• The run-off from this site will end up in the Bottle Brook which will in turn flood Kilburn and Denby

• As a site identified to provide a significant amount of housing - roughly in favour.

• Remediation of contaminated land is to be welcomes as is the provision of employment land, schools and community facilities.

• No reference made to nature conservation and this could be included.

• Uneasy about the impact on Belper

• Understand that the latest proposal to alleviate Lower Kilburn traffic increase from development is to replace the toll bar lights with an island instead. If so this new traffic island will need part time traffic lights at peak times. Not sure that traffic lights will be required off the A38 at Coxbench, as they will just back-up the traffic dangerously onto the dual-carriageway.

• Brickyard Lane should not be used as a secondary link road to Rawson Green/Northfield and Belper Road A609.

• Protection should be made to ensure flooding does not happen.

• No Green belt land should be used.

• Should exclude land to the north of the bridle way leading from the occupation bridge across the A38 (including the bridle way itself).

• Need to ensure there is good frequent public transport between this site once developed and Belper to avoid necessity to use of car. (There is good connection between Ripley and Derby).

• Too large a development without A38 link road.

• Supportive of housing development, particularly the Phase 1 application for approximately 120-170 dwellings. However, the scale of the site is excessive and I am concerned about the impact on landscape and wildlife in the nearby woods and nature reserve. Need assurances on how these will be protected from impact.

• Concerned that Denby, Marehay, Kilburn and Belper will merge.

• Proposed changes to roads must not be detrimental to historic and village character.

• Concerned that new shopping will threaten existing businesses that are already struggling.

• Consider a larger play area and public open space.

• Past agreement between AVBC and local residents on remediation of the tar pits and the use of the A38 to serve the development (not the B6179 and A609) must not be reneged on.

• Severe mining subsidence in the area must be taken into account.

• Need Green Infrastructure to retain identity of semi-rural area.

• No development should commence until the new A38 link road is in place.

• Development traffic must not use Brickyard Lane so as to avoid contamination from tar pit waste on lorry wheels.

• New health facilities required for the development.

• Impact on police, fire, ambulance, clergy and education services must be mitigated.

• Capping the tar pits will not work and 20 years later the new residents will have died from cancer.

• Good to use brownfield land and remediate the tar pits, but the proposal is for too many homes.

• AVBC should consider allocating a larger number of houses here in order to protect the Green Belt at sites SG2 and SG7. This would be the most sustainable place in which to alter the Green Belt boundary to meet housing requirements.

Response

The allocation does not involve any land within the Green Belt.

The policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG4: Newlands/Taylors Lane

• Happy that some of the housing will be on a brownfield site.

• Newlands – Great care should be taken to protect the land and wildlife adjoining Bailey Brook and retain the green space and various habitats in the area (north and south of the brook)

• Taylor Lane – appears to have potential for development and even better if money could be made available to improve the recreational area around Loscoe dam.

• Housing allocation in the Heanor area is considered to be very high and suggest it is reduced if possible and the area has limited facilities.

• Will lead to the merging of settlements in Heanor, Loscoe and Langley Mill. Taylor Lane should be employment land.

• It is not made clear whether the sites are Greenfield or Green Belt.

• Development which supports regeneration of Heanor town centre would be positive.

• Good land should not be used if there is an alternative.

• Already an over-developed area which will cause traffic congestion.

• How can this site have the potential to provide employment and services when there are all the empty shops in Heanor?

• In a floodplain with serious traffic congestion issues.

• The site is in close vicinity to Codnor and Waingroves and new residents will undoubtedly use the current road system through Waingroves and Codnor to obtain access to Ripley, Derby the Peak District and the M1.

Response

The policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG5: Radbourne Lane, Mackworth

• The proximity of the site at Radbourne Lane, Mackworth, to Derby is a positive factor. The adoption of a huge tract of countryside is a negative one.

Response

The site now has full planning permission. However, the policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG6: Coppice Farm, Ripley

• This is important agricultural land

• Waingroves village will be destroyed

• Development will involve excessive traffic movements on to roads that are already congested

• Run off from the site will create flooding problems

• Neat sewage already runs into Bottle Book and the problem will be made worse by the development of this site

• Again green open space site is being developed prior to brownfield sites being used.

• The infrastructure does not support this development

• It is regrettable that productive farm land is designated for building and employment.

• Development will complete the built-up area of Waingroves and lead to the merging of communities.

• There should be more provision for affordable housing on this scheme, in the region of 20-30% below this figure is unacceptable.

• Area has a long time history of being used by local people for recreation and I heard that all the local community are against so this proposal seems to particularly fly in the face of the NPPF.

• Loss of agricultural land at Coppice Farm is unacceptable.

• Steam Mill Lane already suffers with congestion.

• There will be problems with surface water run-off for new residents at the bottom of the hill. Run-off already creates flooding. Proposed SUDS by Peveril Homes will simply flood all over the public walkways.

• Access road into the proposed development is regularly gridlocked and near to the local primary school.

• Object to this site being included in the Core Strategy. Planning permission for 98 homes granted on appeal has been obtained for a site on the Codnor/Waingroves boundary. This site is accessed from Waingroves Road which is already gridlocked with traffic before any new build commences. A further 79 homes on that site are awaiting a second planning application appeal (Codnor/Waingroves site).

• This is an appropriate area on which to provide housing as it would genuinely fit into the surrounding development and would include an element of previously developed land. As with all the other housing developments in the area it should be serviced by the prior development of an improved highway system and not built before.

• There will not be the demand for this scale of new housing as there are not enough people who want to live in the Ripley/Codnor/Waingroves area.

Response

The site now has outline planning permission. However, the policy has been amended by adding criteria to address the concerns that have been raised.

Comments on Policy SG7: Nottingham Road, Ripley

• Not required especially the new supermarket as the AVBC and other surveys on retail have demonstrated.

• New supermarket will kill Ripley and don’t need a new one –see retail study.

• It is a nice way to see Ripley for the first time.

• No compelling reason for building in the Green Belt.

• Green Belt is supposed to be protected by the NPPF and confirmed by the Planning Minister Nick Bowles so why is this site still being considered.

• Main justification for using this site appears to be that the development of the site for housing and a supermarket would deliver the A610 link road is not acceptable and is considered a low priority in the Derbyshire Local Transport Plan.

• Application in for proposed Morrison’s and has been subject to very strong objections and is clear that this proposal is in clear breach of AVBC’s own policy as well as the Local Plan and the NPPF.

• No mention of your own Retail Study commissioned by yourselves which clearly states that no further supermarkets are required in Amber Valley, let alone Ripley. Furthermore, the Ripley Masterplan prepared by AVBC with external advisors also states, that they too clearly reject any out of town development.

• The play area is a good idea.

• Morrison’s is not a good idea. There have been two independent surveys saying this supermarket is not needed within 100 yards of another supermarket. It will take jobs away from the town centre and Sainsbury’s.

• May be able to contribute to the delivery of the A610 link road.

• Retail studies concerning the need for a Morrison’s supermarket opposite the existing Sainsbury’s are contradictory; the study commissioned by AVBC in 2011 suggested there was no requirement for such a store. There is fear that the store will remove business from the town and threaten the existence of the town’s anchor trader, the Co-op.

• Retail need has not been demonstrated and an assessment of the impact of the new supermarket on the vitality of Ripley town centre has not been carried out, as the NPPF requires.

• There are 9 supermarkets within a 5 mile radius of Ripley and this does not include mini-markets. The building of out of town shopping centres is contrary to present government policy.

• Object to this site being included in the Core Strategy.

• Out of scale, but the northern side of the road would be a logical location for some development.

• Ripley and Heanor News conducted an online poll which showed 77% did not want the supermarket development. A petition was presented to AVBC by the ex-Mayor of Ripley with 2,600 signatures against building the supermarket.

• The retail study carried out by Tym and Partner in 2011 revealed there is no need for a new supermarket in the Borough until 2028 and then the store would most likely serve Alfreton.

• There will not be the demand for this scale of new housing as there are not enough people who want to live in the Ripley/Codnor/Waingroves area.

• The plans being described by AVBC as the new sports-hub masterplan are not those submitted for determination by the Planning Board.

• AVBC prepared a Ripley Masterplan that rejects out-of-town-centre development. The basis and outcomes of the applicant’s Retail Study have been challenged by the town’s anchor trader, the Co-op, which could not absorb an estimated 17.5% loss of revenue.

Response

Comments on Policy H1: Housing Type, Mix and Choice

• Need more affordable/social housing

• Specific note should be made about not allowing the ‘larger’ 3 storey housing near existing houses. Has happened too much in recent years were large houses have been built inappropriately close to existing dwellings.

• Should be a ‘buffer’ of green space between new housing & existing housing.

• Housing provision which reflects demographic change is to be welcomed.

• A good mix of tenure and house types.

Response

No changes to the policy are necessary in response to these comments.

Comments on Policy H2: Housing for Elderly or Disabled People

• More emphasis should be placed upon the provision of this type of housing

• Housing for elderly and disabled people is also timely but marooning these residents in very large housing developments with few shops and an infrequent bus service is likely to lead to social isolation. There must be awareness of people’s needs.

• This type of housing should be a priority.

Response

No changes to the policy are necessary in response to these comments.

Comments on Policy H3: Affordable Housing

• Need more affordable/social housing

• A greater proportion of affordable housing should be included in each site

• Despite the Derby HMA SHMA identifying a need for 61% of new housing to be affordable AVBC states ‘a more realistic 30% be an expected provision’. The reasons for this are not adequately explained.

• Affordable housing should remain ‘as long as a need exits’. How is this going to be monitored/assessed?

• Developers now state that they are unable to provide the percentage of affordable housing previously suggested. Legal precedents indicate that local authorities must accept this – in any case, housing developments in Amber Valley must not become a dumping ground for socially problematic people.

• Young people should be able to get on to the property ladder.

• Bending to the pressure of the development industry if 30% is realistic but 61% is needed.

Response

This policy reflects the existing policy in the Local Plan. The development industry alone can never meet the full needs for affordable housing and a balance has to be struck between ensuring that as much affordable housing as possible is secured but at the same time not having a target which is too onerous and would mean that housing developers will look elsewhere to provide market and affordable housing. Experience has shown that requiring more than 30% affordable housing would usually render schemes unviable and/or mean that other requirements such as developer contributions to improving educational facilities could not be obtained.

Comments on Policy H4: Viability of Proposed Housing Sites

• Houses that have already been approved are not being built and appears that developers are just saving up land for more profit.

• This Core Strategy Plan is looking to 2028, some provision must be made for an improvement in the economic situation over that period and expect developers to provide low cost housing.

• If the economic situation has not improved by 2028 there will be a huge need for low cost housing.

• Developers might be reluctant to build in a difficult economic climate. Equally, Council taxpayers must not be expected to shoulder additional financial burdens for development which many view as unnecessary or undesirable, particularly when they are struggling to cope with their own financial difficulties.

• Long overdue. This test has not been applied sufficiently to many of the current sites with extant permissions.

Response

It is not considered that these comments require any changes to the policy.

Comments on Policy R1: Reducing the Use of Non Renewable Energy Resources

• With reference to the ‘costly amendments’ to the Building Regulations ‘to achieve zero carbon development’ can it be specified which of these amendments are expensive and which can be incorporated at little cost? Also important to consider cost to community (both financial and environmental) if regulations are compromised to safeguard developers’ profits.

• Climate change does not wait for economic recovery (and allegedly the country is already on the road to recovery). And what if the economy does not recover? Do we continue to compromise? There is also a danger that developers will rush in their planning applications before the deadlines of 2016 and 2019. There also needs to be consideration of the long term cost to the community and the environment.

• The exceptions to achieving Good standards are too vague.

• Agree with the policy

• Disagree with c) and f) delaying until 2016.

• H) - is vague. If surrounding environment is already dense, does that mean that new development is to be equally dense or less dense (to balance out)?

• I) - Please add making use of solar panels if appropriate

• J) - Also consider need to ensure ventilation during heat waves/sunny conditions (so avoiding need for air conditioning/fans).

• The paragraph beginning ‘if it is considered that meeting criteria a) c) or f) ….. render a scheme unviable ….’ Please define ‘unviable’ – is this related to cost or feasibility with present technology?

• Amber Valley needs to campaign to increase recycling and composting rates and make people aware of programmes in place.

• This should read ‘In considering development proposals, the Borough Council will require that Development and the Design of, has regards to: e) re-using previously developed land and existing buildings within settlements in preference to developing greenfield sites’.

• Support this policy.

Response

It is not considered that any of these comments require any amendments to be made to the policy.

Comments on Policy R2: Renewable Energy Installations

• Wind power – concerned that Local Plan is over – zealous in its quoting of ministerial announcements. 1) The government will change between now and 2028. 2) Windpower technology will improve. 3) Climate Change marches on and will be accelerated further by backing off from viable renewable energy sources. 4) There needs to be room for manoeuvre in the Local Plan to respond to changing environment/climate in a proactive way.

• How can you argue that ‘environmental protections’ override the need for renewable energy, insofar that use of non-renewables will damage the environment in the long term.

• What are the guidelines on numbers of wind turbines? Noise etc? This is very vague (needs cross-referencing)

• See wind farms as a way forward

• The visual impact of wind turbines and large scale panel installations in particular can cause large detrimental impact.

• D) Significant is very vague & given the presumption in favour of ‘sustainable’ development is not likely to have much weight, therefore this in particular could be strengthened.

• Think there needs to be a section on Non-Renewable Energy (fossil fuel) and a Policy R3 giving planning guidelines/restrictions.

• How do you define ‘significant detrimental impact on local landscape’?

• Under point h) ‘deemed to be acceptable’ - this policy wording must ensure that the land will return to original land use and condition, or better and not lower of standard of land than was there originally.

• Renewable energy in development: in Amber Valley sources of renewable energy must be carefully sited. The eastern half of the Borough is to be increasingly built up if the proposed housing developments are carried out. Wind farms are not only visually and noisy, they are inefficient; Solar Panels are also visually intrusive. Biomass which relies on tree growth is dependent on slower replenishment of fuel than the rate of utilisation. Nevertheless, energy efficiency throughout the Borough is to be welcomed.

• Support this but would add – All schemes , whether within agreed areas or elsewhere, should be judges on their own merits using established objective criteria to assess impact, e.g. existing regulations, industry standards and best practice.

• h) Should be changed to more appropriate wording to ensure the site would be returned to its original state or better.

• Valuable landscapes outside the WHS need equal consideration.

Response

The criteria and requirements of this policy and the background text have been amended to address these concerns.

Comments on Policy E1: Managing Flood Risk

• Houses should not be built on flood plains.

• Could specific points be made e.g. encourage ‘green roofs’, planting of native trees/bushes within a development to reduce runoff / flood risk.

• This policy is endorsed – Amber Valley must take into account concerns raised in relation to potential flooding in the area between Marehay and Kilburn where much housing development is projected. The Environment Agency has previously raised such concerns.

Response

The policy has been amended to refer to the potential of ‘green roofs’ and the planting of native trees/bushes within a development to reduce runoff/flood risk.

Comments on Policy E2: Quality and Design of Development

• Could ‘adequate’ be a more realistic, central bin bank for multiple households? Support this policy but need to ensure it can be delivered.

• a, b and c are of major importance but objective standards need defining.

• Question how robust the policies would be in guarding against poor standard developments e.g. Asda, Langley Mill/ Tesco, Heanor/Malik Way, Heanor. If a supermarket wanted to build in Langley Mill again, would the Council consider that a standard ASDA would meet design policy aspirations? The policy should make reference to and encourage the use of standard floorplates and patterns where they suit the characteristics of the site and where the external form and appearance can be tailored to suit the characteristics of the site and/or the wider locality. Supermarkets will respond to this positively but only where there are clear policies promoting such an approach. Based on the draft E2 policy, I would understand that such a scheme would not accord with the aspirations of this design policy – however I cannot see how this policy would guard against this type of development that fails to:

• define spaces (instead being set back behind a car park).

• offer direct, convenient and attractive pedestrian connectivity (try walking from ASDA entrance to the Bus stop heading to Heanor via the most direct route, rather than the indirect route and the problems here will become clear).

• offer a sense of character or at least give a hint that it is located in Amber Valley. The scale of such buildings does not lend themselves to vernacular styles and materials and therefore the reference to local styles and materials within the policy would not necessarily achieve a good design solution when faced with a supermarket proposal at some point in the future.

• There is a subtle but important distinction between high quality and good design. An example of policy wording could be “As a minimum the Council requires all developments to meet a good standard of design, with high quality design promoted particularly in strategic and/or prominent sites and locations.” This would then be consistent with the NPPF that requires ‘good design.

• Reference is made to Homes for Life in the background notes. I believe this should refer to Buildings for Life. I would suggest that with respect to the reference to Building for Life, a direct policy commitment is made to the effect of, "the Council will expect residential developments to achieve 12 green indicators against Building for Life. Schemes that secure one or more red indicators will not be supported. The council strongly encourages applicants to use Building for Life as a basis for Pre- application discussions and as a method of structuring dialogue with the local community and other stakeholders".

• Policy E2(d) should include space for adequate waste storage.

• Sufficient parking provision must be sensitively integrated.

• Policy E2(h) does not appear to have any relevance to urban design practice with respect to the reference made to CCTV. Best practice would suggest that CCTV is unnecessary if places benefit from, for example, clearly defined public and private spaces, well lit and well-surveilled public, private and semi-private spaces, the formation or completion of perimeter blocks. The reference to CCTV has no relevance to quality design.

• There is a lack of emphasis on key principles of urban design in the policy, such as: - well-defined and well-managed public spaces; - spatial definition. i.e. the spatial enclosure of spaces to create well-defined streets and spaces. - connectivity, prioritising the need for direct, safe and attractive pedestrian and cycling routes (to encourage reduced use of cars, particularly for shorter journeys). - a local or otherwise distinctive sense of character.

• Support this policy but need to ensure it is delivered.

• A) – concerned with the word ‘scale’ (needs better definition here and elsewhere in the Local Plan, as developer could justify building something as high and broad as East Mill, on grounds that is the same scale).

• B) – This may need improvements in public transport (routes, times and frequency) – so could perhaps mention.

• C) – ‘Landscaping’ could be defied more clearly – e.g. using native species, to enhance biodiversity, reduce flood risk.

• D) – Agree, again specify what is meant by ‘adequate’ here (safe play areas for children?) Sitting areas? Communal gardens? ) Is there a policy defining area of amenity space per number of houses? (Over and above parking space).

• F) – What if local surroundings are awful (e.g. concrete slabs and corrugated iron roofs or nearby industrial sites)? Need wording to prevent justification of more of the same ugliness.

• G) – Agree, will these protected open land areas in Part 2 of the Local Plan?

• I) – Please leave out phrase ‘where appropriate’ as this doesn’t mean anything in this context (public transport, even when quite good, can always be improved further).

• J) – need to encourage free parking ( for 2 hours?) within town centres and reasonably priced day parking to encourage tourists (especially Belper!) and park and rise season tickets to encourage commuters to use trains/buses.

• N) How? Have a park and ride system?

• O) – Could mention water conservation schemes, installation of water butts, encouraging obtaining energy from communal anaerobic digesters (which safeguards land resource).

• The last paragraph of this policy is vague and ambiguous - is it encouraging high density in a high density area? (or the opposite) think there should be some idea of need for balance in the paragraph.

• Really needs to be enforced and not become just a ‘wish list’

• Seems good but (m) is not applicable in the countryside and ( r ) surely a better way of dealing with waste collection and recycling rather than providing everybody with lots of bins. Multiple bins outside every property are ugly and intrusive and large lorries in narrow lanes equally unsustainable.

• Para 5 needs to be split into two paragraphs and reworded so the statement about its positive contribution etc relates to all the aspects mentioned above not just wildlife sites or species. Also there is a need to recognise the ‘sensitivity’ of a landscape as well as its features and conservation interests.

• The natural environment is vitally important: trees, woodlands, wildlife and green spaces. Unfortunately the provision is often marginalised in relation to housing developments. Managed open space cannot be equated with a vital open landscape.

• The provision of footpaths and cycle lanes is welcomed.

• Trees and woodland should be protected (and please make sure that developers don’t accidentally fell protected trees on site).

• Support this policy and in particular point a) – that development proposals are in scale and character with their surroundings. The monitoring for this should be prospective and not retrospective.

Response

The policy and the background text have been amended to address these concerns and to take on board the suggestions made.

Comments on Policy E3: Historic Environment

• Need to protect all our ancient monuments and deer parks, especially Codnor Castle

• Agree with the policy

• The electrification of the railway is likely to become an issue – the Policy needs to ensure that the heritage of Belper is preserved.

• ‘Where there is evidence of deliberate neglect or of damage to a Heritage Asset…….’ – Agree but what about sites left derelict by the owners, what are the powers to restore historic buildings on these sites?

• Include Areas of Multiple Environmental Sensitivity (AMES)

• This is poorly written – would be better if the text was changed to fit in with the distinct areas of the Borough that reflect the differences in the coalfield to the east, the Peak Fringe and Lower Derwent to the west and the Needwood and South Derbyshire Claylands to the south west.

• Why not create a special category for the care or protection if non-designated locally important heritage assets?

• Encouraged to see that at last, some cognisance has been given to different characteristics of the west of the Borough. However this awareness does not seem to be reflected in the ensuing Policy E3 which seems to focus purely on the built heritage. Would like to see an addition to the policy to reflect the need to ‘continue to conserve the local distinctiveness through…… ensuring that new development respects the character of the locality’.

• Support this policy – local list of non-designated heritage assets is an excellent concept.

• Historic environment includes landscape e.g. Ecclesbourne Valley as well as the WHS.

Response

The policy and the background text have been amended to address these concerns and to take on board the suggestions made.

Comments on Policy E4: Landscape Character

• Possibility to be strengthened, one of the Borough’s assets is it’s landscape character.

• Support this policy

• There should be a map showing the National Character Areas and their subdivision into Landscape character types.

• The monitoring tool is extremely negative as the damage will have been done and cannot be rectified. It isn’t fit for purpose.

• ‘Development proposals that will have an unacceptable impact on landscape character, visual amenity and sensitivity will not be permitted’ what will the criteria be for unacceptable impact?

• There is little evidence that the Core Strategy is protecting local landscapes in the eats of the Borough from unsympathetic development.

• A supplementary planning document should be created to reflect Local Neighbourhood Plans where they have been adopted would be a way forward.

• The plan needs to fully recognise that many areas may not be of such quality to merit national designation but their importance is very high to the local community due to the cumulative denegration of the area by historic developments.

• A map would be useful. Last sentence of first paragraph could read “Development proposals that will have an unacceptable impact on landscape character, visual amenity and sensitivity, including (or especially) in the Special Landscape Area, will not be permitted.”

• Monitoring tool “Development approved that detracts from the character of the landscape’’ seems to suggest “shutting the stable door after the horse has bolted.”

• Private gain should not be allowed to override historic character of the landscape. Need to include old policy EN11 with regard to development within or alongside existing historic sites.

Response

The policy and the background text have been amended to address these concerns and to take on board the suggestions made. A map has been added for those who wish to view the Landscape Character Areas.

Comments on Policy E5: Special Landscape Area

• Special areas of landscape significance were removed before which was a mistake as it gave that land no protection.

• Support this policy

• Special Landscape Area designation has helped to preserve and enhance the very rural (western) side of Amber Valley making it a more attractive area not only for the residents by also an increasing number of visitors and is absolutely essential it is retained.

• This policy has achieved a great deal over the last 25 years but the evidence does not seem to be cited that would support it.

• In terms of the monitoring – who will decide this and what criteria will it be based? This monitoring tool is extremely negative as the damage will have been done which cannot be rectified.

• The western part of Amber Valley is protected.

• Hope that if in some time in the future the Government ceases to support the local designations, Amber Valley will retain protection of this area.

• A supplementary planning document should be created to reflect Local Neighbourhood Plans where they have been adopted would be a way forward.

• With special reference to Vision for Idridgehay, Alton and Ashleyhay it is essential that this category is retained, with adequate safeguards to prevent inappropriate development.

• Could the words “including agricultural proposals” be added to this policy, as per the background notes?

• Support this policy, but lack of evidence is a worry. The La must have more than a map to support this policy e.g. what damage has occurred in the areas just outside the SLA?

• Evidence for this policy needs to include evidence from the current landscape character assessments.

Response

The policy has been amended to include agricultural development as an example of a development proposal.

Comments on Policy E6: Biodiversity

• Should be reworded “all new development should” & remove “seek to”.

• If developments are to fully compensate for any loss of biodiversity then this needs to be really spelled out.

• Could you also add to the bullet list: ‘existing corridors that allow movement of wildlife between sites’?

• Agree with the idea of restoration and re-creation of habitats rather than just mitigation.

• Add Regionally Important Geological Sites and the SSSI at Mount Pleasant, Idridgehay & Alton.

• Practical measures to support biodiversity are welcomed – large buildings sites will of course eliminate wildlife habitats. There is no convincing evidence that wildlife corridors work.

• Paragraph 12.6 Biodiversity - ‘Other areas of land are also important in providing corridors of movement for wildlife between different habitats’ – This is a really important point.

• Support this policy. Pleased to see the Ecclesbourne Valley Restoration project as key evidence.

Response

The policy and the background text have been amended to address these concerns and to take on board the suggestions made.

Comments on where you think a ‘Local Green Space’ should be allocated

• Between settlements to protect each village or town with its own identity

• Should be something in each of the areas for housing development.

• Land to the north and south of Bailey Brook on the Newlands site.

• Belper has expanded to pull in many of its surrounding villages (Broadholme, Milford, and Openwoodgate) and would urge that those which remain separate from the town by green spaces are kept so, namely Bargate, Blackbrook, Farnah Green, Heage and Holbrook to retain the character of Belper and its surrounding villages.

• There is no policy here but the final paragraph suggests something might be forthcoming in the Site Allocations document. Surely there ought to be a short policy statement here to cover that.

• The designation of local green space should apply to a tract of land within or close to a community and which has been or is well used by the community and is valued for whatever reason. This is not big enough to support 500 houses. Ideally, it would also act as a buffer zone between communities, e.g. between Swanwick and Alfreton.

• Residents in Alfreton and Waingroves had all the areas they identified passed for development.

• Near any new estate. Young people say they have nowhere to go.

• The remaining area at Codnor Common is long overdue for protection by this or another designation. This would reflect the majority view of local residents and meet their aspirations, but the delay in doing so in this Plan is leaving it vulnerable to development which would destroy its value to the area. It needs to be done now.

• This needs a policy statement and then Neighbourhood Plans could address this issue.

• A new Policy to protect the remaining two fields, one to the north and one to the south of the proposed new Crematorium and Burial Ground on Derby Road, Swanwick needs to be established under Local Green Space. This could also be put into the Neighbourhood Plan, currently being produced for Swanwick.

Response

These suggestions will be considered when the Site Allocations and Development Management Policies DPD (part 2 of the Local Plan) is produced.

Comments on Policy IN1: Transport

• AVBC’s commitment to the A610 Bypass pre-empts transport assessments for the development for 600 and 560 dwellings respectively at Alfreton Road, Codnor and Nottingham Road, Ripley as per the requirement of Policy IN1 (c).

• Policies SG2 and SG7 directly conflict with Policy IN1 (e) which prioritises sustainable transport modes, because a new road to serve a substantial housing development will encourage more rather than less car use.

• Proposals for the A610 relief road do not allow debate on the need for the road or the most appropriate line of it. Consultants at exhibitions have only been willing and able to answer technical questions.

• Point C) – Is a lower limit allowable or could a lower limit be recommended, such as 10?

• Point D) – Could encourage the creation of safe routes using bridleways and disused transport routes.

• Point I) – Not all homes are usable for extensive work from home (kids, no spare room etc). So also encourage internet business centres and/or community rooms within each town where people can use internet/communication systems for work purposes to reduce need to travel to cities on daily basis.

• There is no viable funding information available

• Amber Valleys continued commitment to the A610 link road mentioned throughout the plan pre-empts that transport assessments for the development for 600 dwellings at Codnor and 560 dwellings at Ripley have been taken into account.

• The amount of proposed development plus the proposed supermarket will cause ‘severe’ traffic congestion on the A610 as all the local traffic from Ripley, Codnor, Waingroves, Loscoe, Heanor, Langley Mill and Ilkeston etc will carry on using the A610 as the proposed link road will be of no use to them.

Response

A planning application for the new A610 link road has been submitted which includes supporting evidence including a Transport Assessment that is currently being assessed. The policy has been amended to address other concerns that have been expressed.

Comments on Policy IN2: Green Infrastructure, Parks and Open Space

• Our parks must be enhanced especially the toilet facilities which are a disgrace.

• No mention made throughout the strategy of the intention to improve facilities and access for cyclists and walkers in Amber Valley.

• Need to retain and improve facilities for horse riders

• Our parks must be enhanced especially the toilet facilities which are a disgrace

• No mention made throughout the strategy of the intention to improve facilities and access for cyclists and walkers in Amber Valley.

• Need to retain and improve facilities for horse riders

• Also needs to give specific examples e.g. encouraging communal gardens and allotments, enabling environmental educations in it’s a) to h) list.

• Town centre shopping should be promoted over out of town facilities. Frequent and reliable bus services must be in place to combat car dependency. The provision of cycle lanes or footpaths would also be helpful. High speed broadband is desirable but not necessarily available in Amber Valley.

• Section is full of jargon that is meaningless – clarification is necessary.

Response

The policy and the background text have been amended to address these concerns and take on board the suggestions that have been made.

Comments on Policy IN3: Community, Leisure and Health Facilities

• Very good

• There is a need for a community centre for young people to meet up and where different activities and courses could be run cheaply.

Response

These comments do not require any changes to the policy.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

• The roads cannot cope with the traffic that we have now and the proposals of 2,500 houses within a 3 mile radius of Codnor will make it even worse.

• The commitment of DCC and AVBC has always been to a Codnor by-pass to complete the section of the A610 from Eastwood to its junction with the A38. This is not met by the support of a link road; the proposals need to upgrade the new section of road to the same standard as the Ripley and Langley Mill by-passes.

• The car will still remain the main method of transport; no amount of bus routes/cycle ways will change that. Look at provision of better roads etc.

• A610 impinges on ‘heritage assets’ and HER at Codnor Park and Butterley Park

• The building of the A610 link road between Ripley and Codnor is an issue which divides Amber Valley residents. It is moreover proposed for the Green Belt and its funding is partially dependent on the building of an out of town supermarket – this is unacceptable.

• Traffic will move from the 60mph Ripley by-pass to a 30mph road with at least seven exits before joining the 60mph Langley Mill by-pass. There is a grave danger that traffic for Heanor will use the first part of the relief road and then Alfreton Road which is unsuited for heavy traffic. As far as I’m aware there has been no transport study examining the effects of building a ‘relief road’ of this nature rather than a full 60mph by-pass to match those at either end of the road. In addition the ‘relief road’ will effectively restrict access from Codnor to the land to the east, including Codnor Castle.

• Unconvincing efforts have been made by the consultants employed by the AVBC to promote the scheme to suggest ways of crossing the road, but in effect little short of a pedestrian bridge will make it crossable. Four public footpaths cross the route of the relief road although plans produced by the consultants have repeatedly failed to show them.

• In addition to building on green land currently available to the inhabitants of Codnor, the proposals restrict their access to that land that is left.

• Traffic congestion occurs at only peak times on the A610 around Codnor, but not every day. This indicates that the problem is not the volume of traffic but obstructions in Codnor which affect traffic flow. If cars were prevented from parking on the main road at peak times, traffic would flow freely, even if a queue builds up to turn right onto Alfreton Road. The link road would only shift bottlenecks.

• AVBC has not carried out an up to date transport assessment for the proposed new road.

• There is ample evidence that bypasses usually create more traffic within a few years of opening, e.g. the Newbury Bypass.

• The so-called bypass is only a relief road for the proposed housing and has no support from residents. No traffic survey has been carried out to suggest there is any need for the road.

• As the road will include two roundabouts traffic congestion will merely increase due to an increase of 200% in the local population.

• Any transport modelling study will no doubt be a retrofitting exercise.

Response

A planning application for the new A610 link road has been submitted which includes supporting evidence including a Transport Assessment that is currently being assessed. The policy and the background text have been amended to address the other concerns that have been expressed.

Comments on Policy IN5: Infrastructure Delivery

• Not a total picture of how the infrastructure will be delivered

• Full information relating to costs must be provided for Amber Valley residents. There must be transparency over financial arrangements.

• 90% of the proposed building is in the third of the Borough east of the A38 and there are no plans to deliver the appropriate infrastructure to support the inhabitants of these houses.

Response

The Infrastructure Delivery Plan has been updated to provide additional information on what infrastructure will need to be provided to serve development and what the estimated cost of this infrastructure will be.

Comments on Policy IN6: Developers Contributions

• Not always to the benefit of the community who has the development

• Developers should pay, rather than residents. Any development should not impact on the existing community of Amber Valley.

• Developers should contribute, especially on large sites. But on really small sites this may make the project economically unviable.

Response

These comments do not require any changes to be made to the policy.

Any further comments you wish to make on the content of the plan

• The five year supply has been incorrectly calculated.

• Our traditional, proud and separate communities will be merged into one very unpleasant and enormous conurbation, reducing desperately needed green space, utilising Green Belt land rather than brownfield, and without consideration of limited infrastructure or the quality of life of current and future residents

• Transport and water infrastructure cannot cope. Water sewerage and drainage capacity is over burdened already.

• The highway infrastructure will not be able to accommodate the traffic being generated. There are no figures showing the accumulation of traffic from all of the proposed developments.

• The majority of the sites are on Green Belt or greenfield land, contrary to the NPPF

• Between 1,000 and 2,000 homes are standing empty

• The preferred sites are all, with the exception of the Mackworth development, within a 3.5 radius of the most impoverished part of the Borough.

• Critical of the process, calculations, viability and sustainability of such large-scale building proposals into the east side of the Borough where green space is at a premium and where there are no plan on how to create jobs for the new residents.

• The total process appears to be totally bias with no development in Swanwick, Belper or Duffield.

• Pleased that the other areas which were identified as possible housing development sites have been excluded.

• No Green Belt land should be used to build on.

• To support town centre vitality, I would favour a policy that promotes housing provision close to the town centre, including conversions of properties to housing.

• Concerned that the final draft should contain a statement to prevent over- development in the Borough.

• Pleased to note that the strategy makes a commitment to ‘Areas and buildings of architectural or historic interest and their settings, will be preserved and enhanced and protected from unsympathetic development’

• It is far too long and complicated for the majority of the population to be able to comment on in a useful and meaningful way.

• Section 6.9 – Economic Growth. The word ‘regeneration’ needs to be qualified. Elsewhere Belper is described as having vitality, above average employment etc. Suggest ‘regeneration and/or enhancement’ of the four market towns. Agree that we need to ensure local people benefit from growth and supporting community based projects, but also suggest the Local Plan specifies the type of business to be especially encouraged (i.e. businesses which offer good quality, secure employment opportunities for training, businesses that are sustainable and beneficial to the community and environment, and whose profits will go back into the community).

• A map of the whole Borough somewhere in the Core Strategy is a serious omission.

• The NPPF makes reference to light pollution at paragraph 25 : By encouraging good design, planning policies and decision should limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation – What about the south west and west of the Borough that has relatively dark skies due to the lack of settlement and street lighting. This should be protected.

• The NPPF makes reference to tranquillity, Para123: Planning Policies and decisions should aim to: Identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. – The Borough plan mentions tranquillity in relation to Green Space, the consideration and protection of tranquillity should be included in a separate policy relating to development in the countryside.

• There is a gulf between the stated objectives and the likely outcomes, between the vision and the reality. The NPPF is fundamentally flawed and is no basis for community development. The scale of proposed development is too large to allow assimilation within Amber Valley.

• Considering that such a large proportion of the Borough of Amber Valley is rural countryside it is of concern that, in a document of 102 pages, only 242 words are devoted to the Countryside

• The Core Strategy is unsound because the development strategy proposed is not justified and is not effective. This is because: -

1. Alternative options to sites proposed in the Green Belt have been dismissed without convincing reasons. 2. No strategic review or viability study of the Green Belt appears to have been carried out 3. The reasons intended to support policies SG2 and SG7 is not acceptable in trying to justify development proposals on specific sites in seeking to deliver a commitment to a new road is against the wishes of the local residents. 4. The Council claims that the new road will alleviate the existing road traffic congestion is not backed up by any evidence.

• Strong objections have been submitted to AVBC for SG7 in the form of petitions or the on-line poll carried out by the local newspaper which was strongly against this proposed development, so therefore the Draft Core Strategy is not providing a fair reflection of the local resident’s views in respect of their wishes.

• Amber Valley needs to re-think the proposed development strategy for Ripley and Codnor as the Core Strategy is not deliverable.

• This Draft Core Strategy is only too willing to quote great chunks of the NPPF when it suits the council’s agenda, in particular when it wishes to emphasise ‘presumption in favour of sustainable development’.

• Support for the re-designation of employment land that has not come forward, to be re-designated for housing land.

• Support for deletion of Hardy Barn, Heanor Site (AV15) – poor employment location as satellite conurbation of Heanor does not form an employment ‘hotspot’ in Amber Valley.

• No plans to create jobs for all the new residents from the six large developments

• Concerns about air quality from proposed growth.

• Water infrastructure will not cope with the growth – residents already have raw sewage in watercourses.

• Already flooding problems – surface water flooding at Steam Mill Lane and Codnor Market Place during last bad storm.

• Proposed link road will not be able to cope with extra traffic generated in the Steam Mill Road area.

• All strategic sites, except Mackworth, are in the poorest parts of the Borough least able to sustain jobs, transport or homes. Western half of the Borough has more land available with better transport links to Derby where job prospects are better, but growth is shoved to the east.

• Majority of sites are on greenfield when NPPF states brownfield sites should be prioritised. What about Butterley Engineering, Stevensons Dyers, Hanson Brick and American Adventure?

• Concerned about impact on schools – schools in Ripley, Codnor and Waingroves are near capacity, but AVBC have stated that the additional demand for school places can be accommodated without the need for any new schools.

• Concerned about loss of agricultural land.

• Codnor, Waingroves, Ripley and Woodlinkin will be merged together in an urban sprawl.

• Belper is untouched by strategic sites when future generations might welcome a small amount of development.

• Empty homes need to be occupied before new development – e.g. Farm View.

• The strategic sites are too large. Fewer large sites and more smaller ones would be more appropriate.

• Large schools/hospitals etc. are not always a good idea.

• Many of the sites have too many constraints which may make them an unviable proposition for developers; flooding, Green Belt, traffic congestion, ownership/boundary problems, access, wildlife issues, overhead lines.

• The views of local people have not been sufficiently taken into consideration. The consultations that have been conducted by AVBC, its consultants and the Parish Council have consistently shown 90% of respondents opposing the proposals.

• The lynchpin of the AV7 and AV8 developments is the ‘relief road’ and the lynchpin of that is the new supermarket, and the sale of land for it which we are (sometimes) told will fund the road. Here AVBC has sold its own land for development and given planning permission for it. It has tried to avoid conflicts of interest by employing an officer from Bolsover, Kevin Hopkinson, as manager of the Ripley Gateway Development, and by employing consultants DLP Design Ltd to run some consultations.

• If any strategic sites were not adopted within the Local Plan, please confirm that the re-allocation would be in the order of preference as per the SA analysis: firstly re- review the ‘Good’ performing sites to try to overcome the issues/challenges; secondly re-review the sites with ‘Moderate’ performance. In addition if the strategic site/s in Heanor is/are not adopted I would suggest a re-allocation of employment land should be considered to form a further strategic site, possibly adjacent to Adale Road and Heanor Gate Industrial Estate.

• The protection of tranquillity in Ashleyhay and Idridgehay should be included in the local plan. In fact, planners should aim to reduce noise and advance peaceful living in all parts of the Borough.

• The Plan does not take account of an appropriate level of protection of the countryside and important open areas.

• The Duty to Co-operate should be used such that neighbouring Councils help meet some of Amber Valley’s need in more sustainable locations.

• There are no policies specifically relating to agriculture and forestry.

• No policies relate to dark skies and light pollution (NPPF para. 125)

• No policies regarding tranquillity and noise pollution (NPPF para 123) • The Draft Core Strategy does not define the ‘improved facilities and services’ which development proposals at SG2 and SG7 are.

• The promotion and determination by AVBC of sites SG2 and SG7 shows a clear conflict of interest.

• Complete lack of evidence to support a rigorous assessment of the use of brownfield sites in preference to greenfield and particularly Green Belt sites.

• It is very difficult to respond to this questionnaire. The overall plan is weighted towards the urban areas of AVBC, although these take up less of the area. Nothing is mentioned that will encourage tourism in the area. More tourists in AV will take pressure off the more ‘honey pot’ areas in the Peak District.

• The weight of public opposition against the proposed housing, road and supermarket associated SG2, SG6 and SG7 is immense.

Response

The relevant policies and background text have been amended, where it was considered that the concerns are valid and should be addressed. A key diagram showing the whole of the Borough has been added to the document.

2.3 Summary of Comments from Parish/Town Councils

Comments on the Spatial Portrait

Horsley Parish Council: The proposal for focused development in local centres is supported.

Comments on the Spatial Vision

Horsley Parish Council: The PC is totally supportive of the proposals to protect the Green Belt.

Comments on the Spatial Strategy

Horsley Parish Council: The PC supports the proposals but are wary of the proposals to develop ‘rural villages’. Providing that this policy is measured against ‘economic, social and environmental conditions in the area’ rather than allowing opportunist gain, the PC is supportive.

Response

These comments do not require any changes to be made to the Spatial Portrait, the Spatial Vision or the Spatial Strategy.

Ripley Town Council: there are major contradictions re sustainability of developments, with sites dependent on the car. No relationship of housing developments to employment.

Response

These comments are not accepted. No changes have been made to the Spatial Strategy in respect of these comments.

Comments on Policy SS1: Housing Land Requirements and Distribution

Ripley Town Council: Empty properties are 2% of the housing stock in AVBC area but are not counted in the number of housing units that need to be supplied. This is perverse.

The proposals do not recognise that we need housing in rural areas too, especially affordable housing.

SHLAA sites heavily biased to big sites of 500 plus units; if smaller ones were considered too then coalescence could be prevented.

Response

The Core Strategy already explains why although the Council is committed to bringing empty properties back into use, they cannot make a significant contribution to meeting future housing needs.

Smaller sites in the SHLAA will be considered for allocation when the Site Allocation and Development Management Policies DPD is produced, which will form part 2 of the Local Plan. These will include sites in the villages and sites in rural areas that could provide affordable housing.

There seems to be a misunderstanding of what the SHLAA is. The SHLAA is a collection of numerous sites that might have the potential for development, and most of these sites are not capable of accommodating 500 dwellings.

Comments on Policy SS2: Business and Industrial Land Requirements

Horsley Parish Council: Concerns would be if this development took place in rural villages – in the PC area the development of the industrial estate at Lady Lea Rd, Horsley Woodhouse.

Response

This is a matter for when the Site Allocation and Development Management Policies DPD is produced, which will form part 2 of the Local Plan. However, it is unlikely that any business and industrial allocations will be made in the rural areas unless there is a clear local need.

Comments on Policy SS3: The Role of Settlements

Horsley Parish Council: Developments of the Towns detailed is supported. However new forms of retailing is required to bring vibrant trading back to these towns.

Response

No change to policy required.

Ripley Town Council: The market towns strategy is deeply flawed. There is a bias towards Belper getting all the attention; there is not an even-handed approach (if one takes tourism or heritage for example).

Response

This view is not accepted. No change to the policy is required.

Comments on Policy SS5: Town Centre Regeneration in Belper

Belper Town Council : Belper residents have been consistent in opposing another supermarket chain i.e. Asda or Tesco. Any planning application for a large national supermarket chain should be discouraged as it will damage the trade for some of the small established independent stores in the town centre.

Response

This comment does not require any amendment to the policy.

Comments on Policy SS8: Development in Town Centres

Horsley Parish Council: It is essential that town centres retain a varied retail offer - not championed by charity stores. The Council should work with Landlords to ensure sensible, practical rents apply.

Response

This comment does not require any amendment to the policy.

Comments on Policy SS10: Green Belt

Horsley Parish Council: The Council should not allow housing development purportedly to support agriculture unless absolutely necessary. The determination of landowners in Smalley Mill Rd, Horsley is indicative of the attempts to evade the Green Belt and build houses or convert barns for household use. Concerns over allowing developments in gardens. Any development in a garden in Church St. Horsley would almost certainly see a domino effect in applications from other owners. These developments would destroy the balance of village life.

Response

This comment does not require any amendment to the policy.

Belper Town Council: This Local Plan needs to ensure that no Green Belt land is lost where it will result in communities being joined together.

Response

This comment does not require any amendment to the policy. There are no allocations proposed on Green Belt land at Belper.

Ripley Town Council: There is no consideration of the wider strategic view for the Green Belt. There is no link with neighbouring authorities so a co-ordinated planned use is denied. Proposals encourage coalescence of communities.

Response

This view is not accepted and the areas proposed to be deleted from the Green Belt will not encourage the coalescence of communities. The reason why the Borough Council does not consider a Formal Green Belt Review as such is necessary is explained in the Core Strategy.

Comments on Policy SS12: Countryside

Idridgehay, Alton and Ashley Parish Council: Agree with the need to maintain extra stringent control on development in the countryside. Save policy EN11 could also be included here.

Response

The policy has been amended to incorporate the wording of existing Local Plan policy EN11.

Comments on Policy SS13: Presumption in Favour of Sustainable Development

Horsley Parish Council: The PC supports the proposal providing that:

• Individuals are not allowed to thwart the current local plan by using gardens for development for personal gain • That Green Belt agricultural land is not abused by allowing development by using ‘agriculture’ as the excuse to build large houses for personal gain.

Response

These comments do not require an amendment to the policy.

Comments on Policy SG1: Outseats Farm, Alfreton

Alfreton Town Council: The Town Council opposed the developments at both Outseats Farm and Eachwells Lane. A significant driver in the Planning Authority’s decision to approve was the apparent shortage of housing provision in the Borough, the case for housing need could have been argued more strategically had the Core Strategy been delivered earlier.

The Town Council believes that the failure in the delivery of a timely 5 year housing supply plan will lead to very little housing being built on ‘brownfield’ sites; essentially the question could be asked why the planning process, particularly the NPPF and its reliance on a 5 year housing need, leave an open door to building on greenfield sites.

Response

Outline planning permission has now been granted for this site and these comments do not require an amendment to the policy in themselves. However, changes have been made to add criteria to the policy to address concerns previously raised by the Town Council, other bodies and members of the public.

Comments on Policy SG2: Alfreton Road, Codnor

Codnor Parish Council: Is still not convinced that the case for desecrating the green belt and historic deer park attached to the Codnor Castle estate has been demonstrated. The original proposed ‘by-pass’ that was being portrayed as the reason for the policy change for this land has now become at best a ‘link road’ and now only a ‘service road’ for the potential 617 houses. This now makes the previous judgment flawed and is also contrary to the NPPF.

The village of Codnor does not have the schools, doctors or other relevant services to support this potential development, which would be on top of the 200 houses either approved or being processed on the land between Codnor and Waingroves on Codnor Common.

We also have grave concerns that only part of the ‘link road’ will actually be completed due to the number of developers that could be involved. This would the leave Codnor with an even more serious traffic congestion problem that it already has today.

We held our own consultation event and we also conducted an exit poll which both have shown that over 90% of residents attending are opposed to this scheme. The independent online survey by the Ripley and Heanor News was also strongly against the Ripley Gateway Scheme of which the ‘link road’ is a major part.

On the basis of all our involvement and of the consultations and representations to our Council meetings, Codnor Parish Council strongly object to this scheme and request that the proposed SG2 – Alfreton Road, Codnor should be removed from the Amber Valley Borough Local Plan.

Response

The policy has been amended to add criteria to address these concerns. The justification for the new A610 link road and the amendment to the Green Belt in this location have been covered in the Core Strategy. A planning application for the development of this site and the new A610 link road has been submitted which includes supporting evidence that is currently being considered.

Comments on Policy SG3: Land North of Denby

Horsley Parish Council: The PC supports this development. However –

1. Severn Trent should make public their proposals on how sewage will be dealt with and whether current facilities are sufficient. 2. Now that the County Council is responsible for water dispersal, a clear understanding of how matters will be dealt with to avoid risk of flooding at Bottle Brook and in Lower Kilburn. 3. Confirmation that the speed reduction to 30mph in Lower Kilburn with illuminated signs will be approved and installed.

Response

These are detailed matters to be considered when a planning application is submitted.

Denby Parish Council: As stated in all of the Parish Council’s previous consultation responses the tar pits must be remediated before any housing development takes place and the remediation work must be in accordance with assessments made by the relevant environmental consultant. To this end the remediation of the tar pits should not become a consideration once any application has been approved.

Suggest there should be on-going monitoring of the whole site for contamination which includes both the areas known as the tar pits and the Denby Disposal Point. Monitoring should not be excluded to these areas and samples should be taken from different locations around the site.

Tar pits should be remediated to provide a green open space for residents of the parish.

Are empty units at the Denby Hall Business Park further along Derby Road and suggest that this is because there is not need for the units or business cannot afford to move into the area. Also have concerns for residents living in the development as employment premises will undoubtedly cause noise, disruption and additional traffic. Consideration should be given to this and any employment premises on the development should adhere to strict working conditions during daylight hours only.

Suggest a traffic impact assessment is carried out before any development commences and all amendment and changes to the transport infrastructure should be made before any development takes place. The Parish Council also believe that direct access to the A38 via a slip road on and off from Derby Road is essential to the development.

If extension is made to John Flamsteed School a drop off zone should be included within the plans to alleviate both the current and expected increase in congestion and street parking along Derby Road. The Parish Council consider this to be especially important as the school is opposite the highway which will lead into the new development. Any extra provision at John Flamsteed should include an additional provision for 6th form places.

The Parish Council are concerned that a primary school within the proposed development site could be detrimental to Denby Free and Street Lane Primary Schools.

The proposed development will be, in terms of numbers of houses, the same size as Kilburn and would mean the whole Denby Parish would become three times its current size.

Suggest a number of services and facilities that they think should be included to support the development that should be located within walking distance to the existing settlement so they are available to all residents of the parish.

State that the greenway should be re-instated as a high priority. Footpath 74 which links Denby Bottles to Openwoodgate has been recognised as a site of historical interest and should be protected and all existing footpaths which run through the proposed development site should be protected.

It would be preferable that this land is sold as a whole and developed by one individual developer.

Concerns over flooding as the proposed buildings and roads will reduce the grounds ability to absorb rainfall. Flooding from the brook course along Derby Road has already significantly increased since the development of the Denby Hall site.

Work is needed to deepen and widen the brook course along Derby Road in the form of re- culverting to cope with the additional run off – these works will need to be undertook from Street Lane to the River Derwent at Little Eaton, this is needed to avoid moving the flood plain from Derby Road into the Kilburn area.

The delivery plan has a number of unknown costs associated with the development at Denby namely the remediation of the tar pits, the cost of introducing sufficient electricity and water resources to the area. These costs need to be ascertained as soon as possible so provision can be made for any anticipated shortfall. As mentioned in Policy IN6 Developer Contributions – any shortfall should be met by developer contributions.

If CIL is adopted by the Borough Council the charging rate needs to be sufficient to cover all infrastructure costs and if section 106 monies are used to bridge the funding gap these should form part of the planning obligations and be guaranteed without any option available to the developer to relieve them of the obligation.

Response

The policy has been amended to add criteria to address these concerns. Other comments made are detailed matters to be considered when a planning application is submitted.

Comments on Policy SG4: Newlands/Taylor Lane, Heanor

Heanor & Loscoe Town Council

Have serious concerns over Land at Taylor Lane, Loscoe and Land at Newlands, Heanor (AV14). Comments are as follows: -

• Increased traffic will be created by both sites. Heanor’s roads operate close to capacity already. Even if an access road to Taylor Lane was developed via Hogbarn Lane it would not be a total solution to the problem. • Both parts are comparatively isolated from the centre of town. • Both developments are sited in the Bailey Brook Flood Plain • Provision of school places in the area is already close to capacity, both primary and secondary schools would be struggling to take more pupils without significant development. • Medical provision in the Heanor area is at present at capacity • Local employment is at a premium in this area – these new housing developments would lead to an increase in commuter traffic.

The Parish Council are of the view that the housing component of the Amber Valley Borough Council Preferred Growth Strategy needs urgent re-visiting.

Response

The policy has been amended to add criteria to address these concerns. Other comments made are detailed matters to be considered when a planning application is submitted.

Comments on Policy H1: Housing Type, Mix and Choice

Ripley Town Council: The housing mix proposed appears acceptable, but enforcement of the mix is required.

Response

This comment does not require any changes to the policy.

Comments on Policy R2: Renewable Energy Installations

Ripley Town Council: Renewable energy should be encouraged better. Solar panels could be made compulsory on new builds (especially factory units).

Response

The Borough Council cannot insist on solar panels being fitted to new buildings.

Comments on Policy E1: Managing Flood Risk

Horsley Parish Council: Bottle Brook in Lower Kilburn is already a problem. A solution to the current problem should be found before any future development is approved.

Response

Derbyshire County Council is responsible for managing local flood risk.

Comments on Policy E2: Quality and Design of Development

Idridgehay, Alton and Ashleyhay Parish Council: Agree with the principles and consider a,c,e,f and g should be given priority especially in the Special Landscape Area.

Response

It is not agreed that priority should be given to the Special Landscape Area, or that these criteria should be given greater priority over the other criteria.

Comments on Policy E3: Historic Environment

Horsley Parish Council: Horsley village contains a ‘garage’ used in the 18th century for coaching purposes. The building is 150 cubic metres in size and is in the Conservation Area. This garage, formerly part of Coach and Horses PH, Should be preserved and added to the proposed ‘list’

Response

This comment does not require any amendment to the policy.

Belper Town Council: Belper Town Council members are concerned about the number of properties within the World Heritage Site and Conservation Areas that have been modified within the last two years with incorrect materials i.e. roof tiles have not been adhered to. Planning enforcement allowed the modifications to remain instead of insisting that the materials are changed to the appropriate materials that the World Heritage Site and Conservation insist.

Response

This comment does not require any amendment to the policy.

Comments on Policy E4: Landscape Character

Idridgehay, Alton and Ashleyhay Parish Council: Essential policy that needs to be retained but monitoring has to be at the planning stage. Planners need to be proactive and implement policies before development takes place. Retrospective action against inappropriate development in the rural environment is unacceptable – the damage is done and can be irreparable.

Response

This comment does not require any amendment to the policy.

Comments on Policy E5: Special Landscape Area

Response

This comment does not require any amendment to the policy.

Comments on Policy IN2: Green Infrastructure, Parks and Open Space

Ripley Town Council: Parks and greens should be properly protected not built on.

Response

This comment does not require any amendment to the policy.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Codnor Parish Council: There is still not been an all-embracing transport study undertaken to evaluate what the impact of an additional 2,500 houses within a three-mile radius of Codnor will have on the road system. The sites that make up this total are SG2 – Alfreton Road Codnor, SG4 – Newlands/Taylor Lane Heanor, SG6 – Coppice Farm and SG7 – Nottingham Road Ripley plus the 200 between Codnor and Waingroves on Codnor Common.

Response

The justification for the new A610 link road is included in the Core Strategy. A planning application has been received for the new road and the development of the sites at Alfreton Road, Codnor and Nottingham Road, Ripley. This is accompanied by a Transport Assessment which is now being considered.

Ripley Town Council: Strongly oppose re-routing of current A610 route.

Response

The justification for the new A610 link road is included in the Core Strategy. A planning application has been received for the new road and the development of the sites at Alfreton

Road, Codnor and Nottingham Road, Ripley. This is accompanied by a Transport Assessment which is now being considered.

Comments on Policy IN6: Developers Contributions

Ripley Town Council: S106 and CIL funding needs active reference to Derbyshire County Council infrastructure.

Response

This comment requires no amendments to be made to the policy.

Any further comments you wish to make on the content of the plan

Alfreton Town Council:

The Town Council is concerned that housing growth in Alfreton will have an alarming impact on the Town and in particular its transport infrastructure. The HMA seems to isolate some areas from consideration whilst focusing on towns like Alfreton.

The HMA seems to have glaring gaps in its strategy, particularly the level of identification and subsequent caution on the environmental impact those developments will have.

The Core Strategy is, in a sense already delivered in Alfreton, given the approval for 500 dwellings at Outseats Farm (it has struck residents of Alfreton that is was something of a waste of time to persist with the Core Strategy consultation exercise in Alfreton when effectively it’s a ‘done deal’) The Town Council feels that Outseats Farm and more recently Eachwells Lane have been approved, together with all the other approvals already on the books, Alfreton ought to be indemnified from any future approvals of that scale.

The Town Council is also concerned that the Core Strategy, as it stands, does not identify and reserve sites – notionally those where the build plan is less than 500 dwellings. In the Town Council’ view such sites should be identified when and if larger approvals fail to complete. Sites in the west of the Borough should be considered to meet that need. The Town Council has consistently taken the view that the Core Strategy should reflect a housing growth in the west of the Borough; the Core Strategy as it stands is skewed towards development in the already congested eastern areas.

Response

The reasons why the strategic sites proposed for allocation have been preferred over other potential strategic sites is already explained in the Core Strategy and other accompanying documents.

Ripley Town Council: Economic Impact Assessments appear to be lacking – mixed messages are being sent.

Response

No action is required in response to this comment.

2.4 Summary of Comments from Borough/County Councillors/MP

Comments on the Spatial Vision for Amber Valley

Nigel Mills MP: While I would agree with the majority of the vision set out I consider that there are some additions required, namely that: • The protection from unsustainable development is only set out for villages – this should be extended to towns, districts and local centres; • There should be an explicit vision of all areas of the Borough having access to high quality communications infrastructure fit for the 21st century. • The statement that growth will be concentrated at the four market towns strikes me as inconsistent with the proposed plan – both in terms of the lack of development proposed for Belper and the fact that a significant proportion is allocated to the Codnor area and the land north of Denby. • A specific commitment to protecting the Green Belt should be added – presumably this protection will be greater than that promised for ‘important green open spaces.’

Response

The Spatial Vision has been amended to take on board these comments.

Comments on the Strategic Objectives and state what (if any) changes you consider necessary

Cllr Emmas-Williams: The proposed plan has directed all the potential housing proposals to the East of the A38 with the maximum use of Greenbelt and green open spaces. This is totally against the spirit of the NPPF and the numerous consultation exercises, surveys and petitions which have all shown significant percentages who have visited and voted against these developments.

Response

These are general comments about the Spatial Strategy.

Nigel Mills MP: I am surprised there is no strategic objective to protect the Green Belt. I am concerned at the statement ‘whilst maximising opportunities for renewable energy generation and utilisation’ in objective 1 – this risks being inconsistent with policy R2 which clearly sets out criteria where such development would be inappropriate. Given the recent rejection of the solar farms applications I would suggest this wording should be amended. I am not sure why there is a need to mention any specific local communities in objective 4 – surely the aspiration to meet the needs of ‘all local communities’ is sufficient. It is also not clear how providing ‘decent, affordable and well-designed dwellings’ could meet the needs of travelling communities.

Response

The Strategic Objectives have been amended to take account of these comments. It is not considered that a specific objective to protect the Green Belt is necessary, as this is national policy and the Council’s commitment to protecting the Green Belt unless there are exceptional circumstances is an important part of the Spatial Vision and the Spatial Strategy.

Comments on the Spatial Strategy and state what (if any) changes you consider necessary

County Cllr Cox: The development of brownfield sites should be actively encouraged in the more urban areas.

County Cllr Williams: I support the strategies of maximising the use of brownfield land and re-using empty properties. However, whilst there is an identified list of strategic growth sites, a similar analysis of ‘brownfield’ sites has not been attempted. There is no identification and analysis of potential brownfield sites.

Nigel Mills MP: As set out in my comments in the previous consultation, I consider that the level of housing considered to be required over the period to 2028 is excessive and the chosen sites may not be appropriate for the following reasons:

• The overall number of houses proposed for the Derby Housing Market Area (HMA) is excessive compared to expected levels of growth, past performance and proposals for neighbouring areas; • The number of houses proposed for Amber Valley especially appears to be excessive compared to expected growth levels and as 27% of the proposed total for the HMA higher than indicated in 3 of the 4 options considered in the original assessment; • The preferred strategic sites exclude several brownfield sites in Amber Valley where significant numbers of houses could be constructed – and indeed where developers have proposals to do so; • The preferred sites still include the loss of Green Belt which should be a last resort; • The preferred strategic sites seem to be disproportionately in the east of the Borough despite other areas of the Borough having easier access to Derby.

I would urge the Council to reconsider whether this level of housing growth is necessary, desirable or achievable. I remain concerned that use of brownfield land has not been maximised despite the claims on para 6.2 of the Spatial Strategy.

Response

There are no available sites of a strategic scale that are brownfield in the Borough that could be used for housing, although parts of the sites proposed for allocation north of Denby and at Taylor Lane, Loscoe are brownfield. When the Site Allocations and Development Management Policies DPD is produced (which will form part 2 of the Local Plan), brownfield sites will take priority when deciding which sites to allocate. The level of housing growth proposed does meet the objectively assessed need for housing in the Borough.

Comments on Policy SS1: Housing Land Requirements and Distribution

Response

This is a general comment about the Spatial Strategy.

Cllr P Jones: The strategic site identified within the document set out below appear to show a bias towards developments to the east of the A38 and away from Belper.

Figures for developments and planning proposals since 2008 appears to substantiate this of the wards to the east of the A38 there is a commitment to build 1,334 houses yet the remaining wards only have 858 . There is a obsession to preserve Belper and its immediate environs to the detriment of the other parts of the Borough.

There is an expectation that the new residents will have to travel to work this does not support any aspect of having a green travel plan or reducing vehicle use. This seems in contradiction to IN1 transport section e) which states that the Council is '..seeking to ensure that development is located where the need to travel can be minimised and sustainable transport modes can be maximised and section f) goes on about ' minimising emissions for transport by reducing the need to travel..'

There seems a total lack of recognition of the need to affordable housing for rural communities.

Response

These are general comments about the Spatial Strategy. The need for affordable housing in rural areas will be considered when the Site Allocations and Development Management Policies DPD is produced (which will form part 2 of the Local Plan). In the meantime, saved Local Plan policy H11 will continue to be used to provide affordable housing in rural areas.

County Cllr S Freeborn: The Plan does not recognise that we need housing in rural areas too, especially affordable housing.

Response

The need for affordable housing in rural areas will be considered when the Site Allocations and Development Management Policies DPD is produced (which will form part 2 of the Local Plan). In the meantime, saved Local Plan policy H11 will continue to be used to provide affordable housing in rural areas.

Nigel Mills MP: The proposal is that 27% of the housing growth should be constructed in Amber Valley – a higher proportion than options 1,2 and 4 of the original consultation (15%, 23% and 24% respectively). Given that there has been far more demand in South Derbyshire in recent years and that the City represents the preferred area for growth given the availability of infrastructure and work opportunities, it is surprising that so high a proportion has been agreed for Amber Valley.

While I appreciate the issues with the World Heritage Site and the very rural nature of some of the western parts of the Borough, the preferred sites do seem to be disproportionately allocated to the east of the Borough. Given the ease of access to Derby for the southern and western parts of the Borough, it would seem sensible to reconsider whether any suitable options for housing developments are available in that area.

Response

This is a general comment about the Spatial Strategy. The amount of housing growth proposed does meet the objectively assessed need for housing in the Borough.

Comments on Policy SS2: Business and Industrial Land Requirements

Cllr Emmas-Williams: A lot of the old industrial sites are now looking tired but unless the Borough can attract new industry and businesses then the SA study is completely worthless. There should be at least one major business/industrial site within the Borough should the right developer approach the authority.

Cllr P Jones: The strategy fails to identify any significant site which can be developed for 'high tec' industry . I would suggest that the infrastructure at Lilly Street Farm provides a such a site which would bring in high quality employees and boost the local economy significantly This omission is a significant weakness in the strategy which should be about the economic drivers which will allow our communities to develop and flourish.

County Cllr S Freeborn: There is a lack of strategic thinking on employment sites.

County Cllr Cox: There seems to be lack of consideration regarding employment opportunities in relation to housing, leading to more dependency on the car.

Response

These issues will be addressed when the Site Allocations and Development Management Policies DPD is produced (which will form part 2 of the Local Plan).

Cllr Paul Smith: Considers that further efforts should be made to bring back into use the empty office and industrial units that are currently developed and have existing service/utility provision and proven access capability. Before any further land is allocated for industry, an empty warehouse/factory strategy should be developed.

Poor quality industrial land allocations should be removed from the strategy and land that was previously included, such as Birchwood Lane, Somercotes, should definitely be

67 removed, as the develop is requesting, because the site is no longer required and should be re-designated as a Green Belt buffer zone from the existing Cotes Park Industrial Estate.

Response

These issues will be addressed when the Site Allocations and Development Management Policies DPD is produced (which will form part 2 of the Local Plan).

Comments on Policy SS3: The Role of Settlements

Cllr Emmas-Williams: Settlements should be protected as they all have their own identities which need to be preserved. If residents wanted to live in towns they would buy their house there hence some people prefer the 'village' life and do not want to be swallowed up by a town.

Response

This is a general comment that does not require any changes to the policy.

Comments on Policy SS6: Town Centre Regeneration in Heanor

Cllr Emmas-Williams: 'Free parking' would possibly be a way of attracting shoppers and helping to re-generate the Market Place

Response

Car parking charges are not a planning policy issue.

Comments on Policy SS7: Town Centre Regeneration in Ripley

Cllr Emmas-Williams: If the Morrison’s store is built out of the town then more shops will close in the Town. The market is hardly supported by residents and there are very little of the big name shops left in Ripley. Charity shops, food outlets and chemists are all that is left.

Response

This is a general comment that does not require any changes to the policy.

Comments on Policy SS8: Development in Town Centres

Cllr Emmas-Williams: Bring in 'Free Car Parking' to try and attract the shoppers back it certainly seemed to work when the Co-Op dropped their prices for some months.

Response

Car parking charges are not a planning policy issue.

County Cllr S Freeborn: The market towns’ strategy is flawed. There is bias towards Belper getting all the attention; there is not even-handed approach (tourism or heritage, for example). So called Masterplans are set in isolation to wider strategic issues. The Plan acknowledges but ignores the evidence of Retail Impact Assessment regarding proposals for an out-of-town supermarket at Ripley.

Response

It is not accepted that the strategy is flawed, or that there is a bias towards Belper. The current proposal for a supermarket is not a matter for the Core Strategy.

Comments on Policy SS10: Green Belt

Cllr Emmas-Williams: If you look at what the planning documents say that only development in the green belt can be given in extreme circumstances. This is not evident in the Core Strategy. It is not justified and alternative to green belt sites have been dismissed without convincing reasons.

County Cllr S Freeborn: There is no consideration of a wider strategic view. There has been no link with neighbouring authorities so a co-ordinated planned use is denied. The proposals encourage coalescence of communities.

County Cllr Williams: The National Planning Policy Framework (NPPF) emphasises the importance of continuing to protect Green Belt from inappropriate development and that established Green Belt boundaries should only be altered in exceptional circumstances. Except for the purpose of the proposed A610 Ripley – Codnor link road, I do not agree with the proposals to delete Green belt land at Ripley and Codnor. ‘Exceptional circumstances’ have not been demonstrated.

This follows logically from the choice of the strategic growth sites SG2 at Alfreton Road, Codnor, SG6 Coppice Farm, Ripley and SG7 Nottingham Road, Ripley.

It is accepted that Coppice Farm has outline planning permission but the choice of all three as strategic growth sites – without considering brownfield sites, empty properties and currently existing planning permissions which have not yet been implemented – will lead precisely to problems which the introduction of the Green Belt in the 1930’s and 1940’s was intended to avoid.

The Draft Core Strategy in Policy SS10 rightly highlights the ‘longstanding commitment by both the Borough Council and Derbyshire County Council to securing the completion of a new A610 Link Road between Ripley and Codnor’ and mentions its advantage of relieving congestion on the current A610 route.

However, an A610 ‘bypass’ has needed to be constructed for the past 30 to 40 years, irrespective of whether any additional housing and business and/or retail park developments are built as part of the strategic growth sites SG2, SG6 and SG7.

Local authorities need to adhere to the originally designed route of the A610 bypass, without changing its route to accommodate deletions of the Green Belt.

Response

It is considered that exceptional circumstances have been demonstrated in respect of the proposals for the new A610 link road and the proposed allocation of the strategic sites at Alfreton Road, Codnor and Nottingham Road, Ripley. The new route for the A610 has been designed in consultation with the Highway Authority and the original route still involves development in the Green Belt.

Comments on Policy SS11: Amendments to the Green Belt

Cllr Emmas-Williams: AS I have mentioned above(Q16) certainly SG2 and SG7 should be replaced with other sites out of the earlier proposed list of sites. It would appear that the assessments have taken place after the selection and are now shown to justify why they have been selected not as part of a proper comparison exercise

County Cllr S Freeborn: Strong objection to the moving of the Green Belt ‘boundary’ to the north of Ripley and the ensuing proposals to build 1,100 plus houses to the north of Nottingham Road, Ripley and to the east of Codnor.

County Cllr Cox: I have major concerns regarding proposals to develop Green belt sites, particularly the Alfreton Road/Nottingham Road, Codnor area. I do not support the re-routing of the A610 if it is dependent on the loss of the Green Belt.

County Cllr Cox: I do not agree with the proposals to delete Green belt land at Ripley and Codnor

Response

Comments on Policy SS12: Countryside

Cllr Emmas-Williams: Green open space and countryside should be protected against development especially sites with heritage buildings on them. These should only be even considered when all the 'brownfield sites' and current approved un built properties have been exhausted.

Response

This is a general comment that does not require any changes to the policy.

Comments on Policy SS13: Presumption in Favour of Sustainable Development

Cllr Emmas-Williams: Sustainable development is a judgemental assessment which I do not believe has been evaluated correctly. Because a potential development is near to a current settlement does not mean that the new residents will fit into the current way of life. It does not take full account of the lack of current requirements for schools, doctors, police and dentists or the road infrastructure.

Response

This is a general comment that does not require any changes to the policy.

Comments on Policy SG2: Alfreton Road, Codnor

Cllr Emmas-Williams: This policy should be removed as the selection criteria is flawed. The number of houses would not keep Codnor sustainable as the school is at capacity, there is no resident doctor or dentist and the police are at full stretch. The potential increase would increase the size of the village by a third. The original by-pass is now no more than a service road and there is no guarantee that the road will be built which could leave Codnor with a worse traffic congestion should only the first part of the road being built. The NPPF states that Green belt should only be built on if there are exceptional circumstances ,the now proposed 'link road' is no longer an exceptional circumstance. This green belt is also part of the Codnor Castle estate which includes part of the ancient deer park. There are numerous public 'rights of way' footpaths which would be cut off if the green belt is desecrated by this potential development.

County Cllr Williams: The development of sites SG2, SG6 and SG7 collectively contradict Policy SS12: Countryside, and should not be permitted because:

• They are collectively of excessive scale; • Two or the three are in the Green Belt and one is farmland, outside the built framework of settlements; • They are not essential in conjunction with the requirements of agriculture, rather SG6 is built on former pastureland; • Any of the three could be reasonably be located within an existing settlement by use of brownfield sites, re-using existing empty properties and ensuring existing planning permissions are used; • The developments may incur further government expenditure on health facilities – GP surgeries, hospitals and dentists; public open space and outdoor sports facilities; community facilities for all age groups – leisure centres, community centres and libraries; preserving and enhancing historic buildings – e.g. Codnor Castle, conservation areas and the historic environment.

None of this is likely extra expenditure is mentioned or costed in the Draft Core Strategy.

Policy SG2 – with 600 dwellings planned for Alfreton Road, Codnor by deleting the Green Belt - in particular, will contradict policy SS3 for Codnor to continue to act as a local centre.

Codnor will no longer be considered as a ‘local centre’ as it will be another small town, having undergone a big increase in size, if these policies are implemented.

Nigel Mills MP: There is significant concern that the proposed A38-M1 Link-Road/Bypass may not be delivered

Response

Comments on Policy SG3: Land North of Denby

Cllr Emmas-Williams: For this development to succeed the tar pits need to be totally removed prior to any approval.

Nigel Mills MP: A similar issue with phasing of development arises with the proposed development on the land north of Denby. Again the original justification for allowing a reduction in the Green Belt at this site was the remediation of the tar pits, and so no development should be allowed on any part of this site without there being a clear and binding scheme in place to deliver this remediation.

Given the fractured ownership and the potential for a planning application for a small part of this site to come forward in the near future, the Council needs to be very clear how this phasing could be achieved and ensure that the proposed policy is sufficiently robust. I am concerned at the viability of this without there being a clear cost estimate for the decontamination available and would urge the Council to ensure this is obtained before Policy SG3 is adopted.

Housing development of this scale will clearly have a substantial impact on the existing community and will require extensive community facilities to be incorporated. While these are referred to in SG3(e), it would be helpful if more extensive comment could be made here on what will be required.

Similarly on SG3(c) the 1,800 houses plus employment land will lead to a significant increase in traffic flows. While the Infrastructure Plan includes some road improvement details, I am not convinced that these will be sufficient and would urge the Council to reconsider the viability of a new access onto the A38.

For SG3(d) this area is served by various primary schools currently (including in Denby, Street Lane and Kilburn). There may be need for investment in these schools also arising from this development and therefore it may be appropriate to amend the wording in policy SG3(d) to reflect that such investment may be required in addition to a new Primary School.

Response

The criteria in this policy have been amended to address these concerns. The Highways Agency have confirmed that they have no objection to the improvements proposed to access

72 the site and the improvements to highway infrastructure surrounding the site proposed, without the need for a new junction on to the A38. However, they will require further information when the planning application is submitted.

Comments on Policy SG4: Newlands/Taylors Lane

Cllr Emmas-Williams: Some of this development is on reclaimed land and with the correct infrastructure this would be acceptable.

Response

This is a comment supporting the policy.

Comments on Policy SG6: Coppice Farm, Ripley

Cllr Emmas-Williams: This site has already been approved. Correct usage of the 106 monies is vital to help with all the extra residents this will bring. The proposed road improvements associated with this approval will do very little to improve the current situation, without the increase in vehicular movements.

County Cllr Williams: The development of sites SG2, SG6 and SG7 collectively contradict Policy SS12: Countryside, and should not be permitted because:

• They are collectively of excessive scale; • Two are in the Green Belt and one is farmland, outside the built framework of settlements; • They are not essential in conjunction with the requirements of agriculture, rather SG6 is built on former pastureland; • Any of the three could be reasonably be located within an existing settlement by use of brownfield sites, re-using existing empty properties and ensuring existing planning permissions are used; • The developments may incur further government expenditure on health facilities – GP surgeries, hospitals and dentists; public open space and outdoor sports facilities; community facilities for all age groups – leisure centres, community centres and libraries; preserving and enhancing historic buildings – e.g. Codnor Castle, conservation areas and the historic environment.

Response

These are general comments regarding the proposed strategic allocations in this area. The criteria for each of these sites have been amended to address some of these concerns.

Comments on Policy SG7: Nottingham Road, Ripley

Cllr Emmas-Williams: Despite the Borough Councils own independent retail study that they commissioned, petitions, independent on line surveys and results from all the consultation exercises which clearly demonstrate that the out of town supermarket is not required they still plough on with trying to ignore the wishes of the local people and residents.

Response

The current proposal for a supermarket is not a matter for the Core Strategy.

County Cllr Williams: The development of sites SG2, SG6 and SG7 collectively contradict Policy SS12: Countryside, and should not be permitted because:

Response

These are general comments regarding the proposed strategic allocations in this area. The criteria for each of these sites have been amended to address some of these concerns.

Comments on Policy H1: Housing Type, Mix and Choice

County Cllr S Freeborn: The housing mix proposed appears to be okay, but enforcement of the mix is required.

Response

This comment does not require any amendment to the policy.

Comments on Policy H2: Housing for Elderly or Disabled People

Cllr Emmas-Williams: More ground floor accommodation should be perused to meet the perceived increase in elderly and disabled people.

Cllr P Jones: Lifetime Homes - The proposals within the plan to build lifelong housing is to be welcomed.

Response

These comments do not require any amendment to the policy.

Comments on Policy H3: Affordable Housing

Cllr Emmas-Williams: To meet the required of amount of social/affordable housing required in the Borough the current target of 30% will not even meet the requirement. The reduction agreed on the Coppice site should not be permitted.

Cllr P Jones: Within the strategy H1 the Council's own plan recognises that all new developments will have to have as a minimum 61% affordable housing up to 2038 to meet demand. However, there is nothing within the strategy to support this aspiration

Response

County Cllr Cox: There is emphasis on developing in already congested areas when rural areas are in need of affordable housing to maintain communities and road and other transport links are better in the west of the Borough.

Response

This is a general comment on the Spatial Strategy that does not require any changes to the policy.

Comments on Policy H4: Viability of Proposed Housing Sites

Cllr Emmas-Williams: This has to a major concern as at the moment already approved housing schemes are not being built with considerable 'land banking' taking place.

County Cllr Cox: Housing proposals appear not to take into account need and infrastructure.

Response

These are general comments that do not require any changes to the policy.

Comments on Policy R2: Renewable Energy Installations

County Cllr S Freeborn: Renewable energy should be encouraged in the Plan more explicitly. For example, solar panels should be made compulsory on new buildings (especially factory units).

Response

The Borough Council cannot insist that solar panels are fitted to new buildings.

Comments on Policy E1: Managing Flood Risk

Cllr Emmas-Williams: This is a major concern right across the whole of the Borough as demonstrated in the Draft Infrastructure Delivery Plan (pages 10 to 13) with very little confirmed initiatives to alleviate these problems.

Response

This is a general comment that requires no changes to the policy.

Comments on Policy E3: Historic Environment

Cllr Emmas-Williams: As I have stated earlier due care has not been taken with regards to Codnor Castle and its Deer Park. This is the only recognised mediaeval castle in the area and if the developments go ahead will be severed from the village that it is senominous with.

Response

The criteria in the policy for the proposed strategic site at Alfreton Road, Codnor (SG2) have been changed to address these concerns.

Comments on Policy E5: Special Landscape Area

Cllr Emmas-Williams: Special Landscape Area where removed at previous plans which has led to some of the current problems that we have had to endure.

Response

This comment relates to Areas of Local Landscape Significance defined in the previous Local Plan 1994, not the Special Landscape Area.

Comments on where you think a ‘Local Green Space’ should be allocated

Cllr Emmas-Williams: Why not just protect 'Green Belt' sites and look to the other sites to supply the housing stock that it is alleged to be required. There may be opportunities to 'swop' some small parts of green belt with green open spaces on a limited bias.

County Cllr S Freeborn: Parks and greens should be properly protected not built on.

Response

These comments do not suggest any areas that could be allocated as Local Green Spaces.

Comments on Policy IN1: Transport

Cllr P Jones: Alternative forms of transport - There appears to be no recognition within the strategy to links with potential extending the Tram system from Nottinghamshire into Derbyshire. If it is to be visionary document that surely this aspect of alternative, greener transportation needs to be recognised along with the potential for alternative employment such as transport in the Langley mill area with the marina development.

Response

This scheme has not yet been agreed, and is unlikely to be implemented during the plan period.

County Cllr Marshall-Clarke: There is no provision in the document that addresses the environmental impact of pollution created by the proposed sites. In particular, the impact additional traffic will have on the health of residents already residing in the target development areas. The Area Profile for Alfreton, Somercotes shows the life expectancy of male residents is the lowest in the Borough.

I fail to understand how a partial development of a Ripley-Codnor bypass would provide any benefit on highways grounds. We should be making it clear that we would need a completed bypass to come forward fully funded before we would consider approval of developments in that area.

We have previously supported developments from a highways perspective that have subsequently failed to deliver the outcomes we desire. The Core Strategy needs to focus much more on integrated transport issues. More weight needs to be given to walking, cycling and public transport infrastructure. A glaring problem with this Core Strategy is the access issues to train services for disabled users and cyclists on the Erewash Valley line. Developing sites in these areas should be declined until a properly thought out infrastructure plan is in place together with the appropriate funding to implement the plan.

This Core Strategy fails to look at areas that would have least impact on the existing infrastructure. There is better developed infrastructure in the west of the area with good access to rail services. This should be a priority area as it would relieve pressure on the highways network.

The highways network of the A52 and A515 are better placed to absorb the additional impact of increased traffic that the already congested areas identified in the Core Strategy.

Response

The criteria in the policy addresses some of these concerns. Other concerns have been addressed elsewhere in the Core Strategy. The Highways Agency have concerns with any further development off the A52.

Comments on Policy IN2: Green Infrastructure, Parks and Open Space

Cllr Emmas-Williams: We have to protect and increase the parks, open space and sports grounds to meet the increase in requirements for recreation and carry on the legacy from the success of the 2012 Olympics.

Comments on Policy IN3: Community, Leisure and Health Facilities

Response

These comments require no amendments to these policies.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Cllr Emmas-Williams: Without a complete total area travel/traffic study being completed then sites cannot be properly evaluated. Belper has suffered over many years as each planning application were decide on each merit which gave an overall unacceptable situation in Belper. This cannot be allowed to take place in the Borough again.

County Cllr S Freeborn: Strong objection to the proposed alteration to the long agreed line of the Ripley-Woodlinkin A610 by-pass.

Response

The new alignment for the A610 link road has been designed in consultation with the Highway Authority and the previously agreed line which would still involve development in the Green Belt was never the subject of any detailed investigation. A planning application has been received for the new A610 link road and the development of the strategic sites at Nottingham Road, Ripley and Alfreton Road, Codnor. This is accompanied by a Transport Assessment which is being considered.

Comments on Policy IN5: Infrastructure Delivery

Cllr Emmas-Williams: If this infrastructure is demonstrated then total guarantees on delivery needs to be enshrined in planning law.

County Cllr S Freeborn: The policies and background text relating to Section 106 Agreements and CIL needs active reference to the County Council’s infrastructure requirements.

County Cllr Williams: However, an A610 ‘bypass’ has needed to be constructed for the past 30 to 40 years, irrespective of whether any additional housing and business and/or retail park developments are built as part of the strategic growth sites SG2, SG6 and SG7

Response

These comments require no amendments to the policy.

County Cllr Williams: Local authorities need to adhere to the originally designed route of the A610 bypass, without changing its route to accommodate deletions of the Green Belt.

Response

The new alignment for the A610 link road has been designed in consultation with the Highway Authority and the previously agreed alignment which would still involve development in the Green Belt was never the subject of any detailed investigation.

Comments on Policy IN6: Developers Contributions

Cllr Emmas-Williams: Developers contributions should be ring fenced for the areas that will suffer from the development. All local members should be included in discussions from the earliest opportunity.

County Cllr S Freeborn: The policies and background text relating to Section 106 Agreements and CIL needs active reference to the County Council’s infrastructure requirements.

Response

These comments require no amendments to the policy.

Any further comments you wish to make on the content of the plan

Cllr Emmas-Williams: Many of the possible arguments put forward on SG2 & SG7 have been demonstrated to have been flawed and puts the Core Strategy reasoning at risk. No strategic reviews have been demonstrated for the Transport requirements, Green Belt and Sustainability assessment.

Cllr P Jones: Comments specific to Heanor - According to statistic from Derbyshire County Council the Heanor area has already demonstrated significant growth since 2001 l Greater Heanor 9.1% Heanor Central 7.9% against an average of 5.45% so it seems logical that any future growth should be in those areas which have failed to grow over this time scale rather than putting extra burdens on an already creaking infrastructure. The identified sites within Heanor do not take cognizance of other potential developments within the neighbourhood and whilst this is understandable it fails to recognise the impact of other potential developments. If the plans for Falls Road, Heanor and the former American Adventure site were approved the additional housing for the Heanor area would then be

1,072, It seems a major flaw within the strategy to recognise the potential that the Heanor area could have twice the development that the Council has identified within these strategic sites. The impact on the local highways and transport are covered in my earlier comments.

County Cllr S Freeborn: Economic Impact Assessments appear to be lacking resulting in mixed messages being sent. The use of Community Infrastructure Levy (CIL) in unclear. The use of brownfield sites is largely discounted without considering use of CIL to provide a cost balance between green and brown field sites. Empty properties area 2% of the housing stock in the AVBC area but are not counted in the number of housing units that need to be supplied. The sites proposed for allocation in the Core Strategy are heavily biased to big sites of 500 plus units. It should include smaller sites which could help to stop coalescence etc. There are big contradictions regarding sites dependent on the car. There is no relationship between housing developments and employment. There is no mention of the Ripley Neighbourhood Plan, which is being developed and proposes to provide the new housing required in Ripley without going north of Nottingham Road.

Response Most of these comments have already been responded to elsewhere in this document. The current proposals for Shipley Lakeside and Fall Road Heanor are still being determined and will be taken account of when calculating the need for housing if they are approved. There is no need to refer to Neighbourhood Plans in the Core Strategy.

County Cllr Williams: In Appendix B: Proposed Scale and Location of Housing Growth in Amber Valley, the overall requirement of homes from 1/4/08 to 31/3/28 is 9,400. There are also ‘just over 1,000 homes that have been empty for 6 months or more which are 2% of the housing stock in Amber Valley’. Nevertheless, empty properties are not included in Appendix B in the number of housing units that need to be supplied. This would seem to represent a significant under-counting of houses which can be supplied without resort to new-build.

Response The Core Strategy already explains why although the Council is committed to bringing empty properties back into use, they cannot make a significant contribution to meeting future housing needs.

County Cllr Williams: The Draft Core Strategy is not balanced when it broadly ignores the fact that the Ripley area has had an industrial history and heritage of its won since the 18th Century, stretching from Ambergate/Bullbridge/Sawmills, along the Cromford Canal to Ripley and the former Butterley Works. There has also been a history of industrial unrest with the Pentrich uprising in 1817 and of course, in the 20th century Barnes Wallis was resident in Ripley. None of this history is even referred to in the Draft Core Strategy, although the Cromford Canal merits a mention.

Response

The rich history of coal mining in the eastern part of the Borough and the Cromford Canal are mentioned in the background text to the historic environment policy.

County Councillor P Jones: The disproportionate identification of strategic housing sites to the east of the A38 will have significant infrastructure problems for highways and the education authority within these

80 communities and I would question if they have been evaluated to an acceptable and logical basis for inclusion. There is no identified strategic site for industrial development yet the site at Lily street Farm in Swanwick is the best connected site within the entire Borough for development of High technology businesses. The inclusion of homes for lives is a welcome development and fits in well with DCC’s accommodation strategy for Adult care There is no recognition of the development of a tram system within the Eastwood area which has the potential to develop towards Ripley through Heanor and Langley Mill.

Response

Responses to these comments are covered elsewhere in this document.

2.5 Summary of Comments from neighbouring Local Authorities and Derbyshire County Council

Comments on the Spatial Strategy

Erewash Borough Council: Notes and supports Amber Valley’s preferred spatial strategy which sets out the location and scale of development needed to meet long-term growth requirements. Focusing new development particularly in Amber Valley’s four market towns of Alfreton, Belper, Heanor and Ripley is considered sustainable due to the presence of a range of existing physical and social infrastructure which can help the Borough to absorb the impacts of growth. The strategy also largely maintains the openness of the Nottingham-Derby Green Belt. Erewash Borough Council strongly welcomes the planned retention of the Green Belt between the towns of Heanor and Ilkeston (as situated inside the Borough of Amber Valley) to ensure their continued separation in line with the purposes set out within the National Planning Policy Framework at paragraph 80.

Response

These comments are in support of the Spatial Strategy

Ashfield District Council: Notes and supports Amber Valley’s preferred spatial strategy which sets out the location and scale of development needed to meet the long term growth requirements of the Borough. The focusing of new development within the four market towns of Alfreton, Belper, Heanor and Ripley is considered sustainable due to the presence of a range of existing physical and social infrastructure.

Response

These comments are in support of the Spatial Strategy

Comments on Policy SS1: Housing Land Requirements and Distribution

Broxtowe Borough Council: Broxtowe Borough Council generally supports the housing figure within the context of the Derby HMA evidence set out, in that it provides for your objective assessment of Derby HMA housing need. It supports your intention to meet in full your housing need within the Borough.

Response

These comments are in support of the policy.

Erewash Borough Council: Amber Valley’s housing provision of a minimum of 9,400 new homes by 2028 is noted by Erewash Borough Council. This represents slightly less than a third of the overall Derby Housing Market Area (HMA) requirement of a minimum of 35,350 homes across the same period. Work that has been undertaken through the Council’s Housing Requirements Study (seen at Appendix A) has objectively assessed what the housing needs for both Amber Valley and the wider Derby HMA are. It is understood that Derby City Council and South Derbyshire District Council both continue to prepare separate, but nevertheless aligned documents which plan or their own objectively assessed housing needs.

If through these documents, the remaining minimum provision of 25,950 homes is adequately planning for then the housing need for the Derby HMA will have been met in full. This should ensure that there will be no consequential additional demand for housing in neighbouring Housing Market Areas, including the Nottingham Core Housing Market Area (which includes Erewash Borough) and therefore this approach is supported.

Response

These comments are in support of the policy.

Derbyshire County Council:

The comprehensive range of robust evidence and the extensive level of collaborative working between the four Derby HMA councils are considered to justify AVBC’s proposed housing target of 9,400 dwellings. The broad scale of proposed housing development is, therefore, considered appropriate and meets the requirements of Paragraph 47 of the NPPF, which requires local planning authorities (LPA’s) to objectively assess their housing needs and to meet those needs in full. In addition, much of Amber Valley Borough is covered by Green Belt, therefore, it is likely that a higher housing target would impact much more significantly on the Green Belt.

The broad distribution of housing growth is supported in principle, which seeks to focus the majority of growth in and surrounding the Borough’s four main towns with the remainder being accommodated on the strategic sites and within the district and local centres. This is considered to provide for a sustainable pattern of development as required by the NPPF. It is a continuation of the broad spatial strategy for growth in Amber Valley Borough set out in the former East Midlands Regional Plan (EMRP).

However, it is considered premature for the County Council to comment further on the acceptability of the Strategic Growth Sites until theses on going modelling works, discussions and planning application consultations have been concluded.

Response

These comments are in support of the policy.

Ashfield District Council: The housing provision of a minimum of 9,400 new homes within Amber Valley by 2028 is noted. This represents slightly less than a third of the overall Derby Housing Market Area (HMA) requirement for a minimum of 35,350 homes across the same period. It is understood that Derby City Council and South Derbyshire District Council both continue to prepare separate aligned documents which plan for their own objectively assessed housing needs. If through these documents, the remaining minimum provision of 25,950 homes is planned for, this should ensure there will be no consequential additional demand for housing in neighbouring Housing Market Areas, including the Nottingham Core Housing Market Area, which Ashfield District Council is included and therefore this approach is supported.

Response

These comments are in support of the policy.

Comments on Policy SS2: Business and Industrial Land Requirements

Derbyshire County Council: The approach to economic growth in the Borough is supported in principle. This seeks to focus economic growth and regeneration in the four

83 market towns of Alfreton, Belper, Heanor and Ripley; help businesses in the Borough to grow and develop, ensuring local people benefit from growth; and draw funding into the Borough to support community based projects. This is consistent with the aims of national policy in the NPPF.

The LPDCS proposes to allocate approximately 75ha of business and industrial land and was informed by the Derby HMA Employment Land Review (ELR) 2008 and the ELR update in 2013. The ELR and ELR Update concluded that, although the Borough has a sufficient quantity of existing and proposed employment land, many of the sites are of poor quality. Consideration, therefore, should be given to de-allocating some of the poorer quality sites. The LPDCS Part 1 proposes to allocate better quality employment land to attract new businesses to the Borough and the opportunity to consider the de-allocation of poorer quality employment sites will be addressed in the Site Allocations and Development Management Policies DPD (part 2 of the Local Plan). This broad approach to the provision of new employment land and de-allocation of poorer quality employment land is supported. In accordance with Councillor Smith’s concerns, it is also recommended that Policy SS2: Business and Industrial Land Requirements incorporates an appropriate policy criterion which seeks to bring existing empty office and industrial units back into beneficial employment use.

Response

These comments are in support of the policy. The policy has been amended to address Councillor Smith’s concerns, by adding that the Borough Council will also actively encourage the re-use of vacant business and industrial units.

Comments on Policy SS3: The Role of Settlements

Derbyshire County Council: The policy approach in policies SS3 to SS8 for the regeneration of, and development within, the four main town centres and Langley Mill District Centre is broadly supported. The policy approach to Langley Mill District Centre is particularly supported as this defines a new boundary for the District Centre, which was not defined in the adopted Amber Valley Local Plan (AVLP).

Response

These comments are in support of the policy.

Comments on Policy SS6: Town Centre Regeneration in Heanor

Derbyshire County Council: Similarly, the policy approach to Heanor Town Centre is particularly supported which recognises that the town centre has a poorer level of vitality and viability and needs to be improved. The exclusion of Tesco foodstore from the town centre boundary is supported.

Response

These comments are in support of the policy.

Comments on Policy SS8: Development in Town Centres

Derbyshire County Council: The main concern with the policy approach is in Policy SS8: Development in Town Centres. Whilst the policy appropriately seeks to direct new retails, leisure and other town centre related development to the Borough’s four main town centres

84 to sustain and enhance their vitality and viability, the policy does not adequately include the principles of the sequential test for edge-of-centre and out-of-centre retail developments. This is a key requirement of the NPPF. The policy should include additional criteria, therefore, to assess edge-of centre and out-of-centre retail developments and include the need to assess the availability of sites within town centres; the potential impact on the vitality and viability of town centres; and the accessibility of the proposed development to the town centre. It is suggested that Paragraph 4 of Policy SS8 should be amended to read as follows:

‘Where appropriate, planning applications for developments outside town centres will need to be supported by a retail impact assessment and/or a transport assessment’.

Response

The policy has been amended as suggested.

Comments on Policy SS10: Green Belt

Erewash Borough Council: Strongly welcomes the planned retention of the Green Belt between the towns of Heanor and Ilkeston (as situated the Borough of Amber Valley) to ensure their continued separation in line with the purposes set out within the National Planning Policy Framework at Paragraph 80. Response

These comments are in support of the policy.

Derbyshire County Council: The general approach to Green Belt policy is supported in principle, which sets out AVBC’s commitment to protect the Green Belt unless exceptional circumstances can be demonstrated. This continues the approach to Green Belt policy set out in the former EMRP, which recognised that, to accommodate future growth, some development was likely to be necessary in the less sensitive areas of Green Belt around the main towns. Policy SS10 in the LPDCS is a detailed policy to assess development in the Green Belt, which is consistent with the NPPF.

The only locations where the Green Belt is proposed to be amended is in Ripley and Codnor, in association with the development o the Strategic Growth Sites and proposals for the A610 Link Road between Ripley and Codnor. In light of the transport modelling works, the need for future evidence and on-going discussions between County Council and AVBC officers about the Strategic Growth Sites and A610 Link Road, it is considered premature to comment further on these matters in respect of their potential impact on the Green Belt.

Response

These comments are in support of the policy in principle.

Comments on Policy SG1: Outseats Farm, Alfreton

Derby and Derbyshire Development Control Archaeologist: Archaeological potential within the site relates primarily to its proximity to Carnfield Hall, a known medieval site. Geophysical and trial trenching evaluation was carried out pre-application on the northern part of the site only, and yielded no significant archaeological results. It was recommended therefore that archaeological evaluation of the southern part of the site could take place post-consent, as part of a conditioned scheme.

Response

Outline planning permission has now been granted for this site, which includes conditions relating to the need for an archaeological evaluation post-consent.

Derbyshire County Council: This site has an existing outline planning permission for 500 dwellings and a Section 106 Agreement in place. AVBC’s Draft IDP highlights expansion of local primary schools (Copthorne Infant and Leys Junior Schools) to serve Outseats Farm and accords this a medium priority. Policy SG1 and the IDP should reiterate these critical (high priority) infrastructure requirements, even though a Section 106 Agreement is in place. This would be helpful should planning permission expire or the developer seeks a revised Section 106 Agreement at the reserved matters stage.

Response

The policy has been amended to refer to the need for a financial contribution to be provided towards the expansion of the Copthorne Infant and Leys Junior Schools.

Comments on Policy SG2: Alfreton Road, Codnor

Derby and Derbyshire Development Control Archaeologist: There are numerous records for opencast coal extraction covering parts of the site (Derbyshire County Council dataset), and this is likely to severely limit archaeological potential in the areas affected. Archaeological potential on the site arises primarily from its proximity to the historic core of Codnor, and the potential of medieval/post-medieval archaeology on those parts of the site closest to the settlement, and also from a general potential for hitherto undiscovered archaeology on large greenfield sites.

The northern part of the site contains a small remnant (four fields) of fossilised ancient strips, and this area is therefore of enhanced historic landscape value, as well as being classified as of Secondary Sensitivity in the Areas of Multiple Environmental Sensitivity (AMES) defined by Derbyshire County Council – these constraints weigh against designation of the site for development.

Response

Criteria have been added to the policy to address these concerns.

Derbyshire County Council: It is proposed that 600 dwellings would be provided on this site. The IDP states that Mill Hill School could accommodate some secondary pupils associated with this development and the Aldercar Community Language College has some limited capacity and could be expanded. The IDP states that primary pupils could be accommodated through existing surplus capacity or the extension of existing primary schools, with funding secured via a Section 106 Agreement. Originally, the proposal for this site was to develop 500 dwellings. At that scale, the normal area school may have been able to accommodate the development through expansion (funded via Section 106 Agreement with the developer). The LPDCS is now proposing 600 dwellings. The County Council is of the view that it may be difficult to accommodate that

86 scale of development through expansion of the existing school. However, officers in the County Council’s Property Services Department are currently looking at the site and examining the feasibility of expanding the school. In the meantime, it is imperative that the LPDCS continues to identify the site as a notified site as it is the statutory playing field for the existing school. The roll-out of high speed broadband is a key Government priority and is a strategic priority project in the DIP. It should, therefore, be accorded high priority in the Borough Council’s IDP and Policy SG2 of the LPDCS should require the design of any development proposals to facilitate the on-site provision of high speed broadband connectivity. DCC has identified the area east of Codnor as being of Secondary Sensitivity in terms of Historic and Visual Sensitivity.

Impact on the landscape, landscape character and environmental sensitivity, and the need for appropriate mitigation of such impacts, will be an important consideration in assessing the development potential of the site and should be given a high priority in the assessment process.

The DIP states that Loscoe Household Waste Recycling Centre (LHWRC) is over capacity. This is acknowledged in the IDP. However, the LPDCS does not set out how this critical infrastructure issue will be addressed and this puts the deliverability of the Core Strategy into doubt. Policy SG3 of the LPDCS should state that development of this strategic site should contribute towards the provision of additional household waste recycling through expansion of LHWRC via a financial contribution secured through either a Section 106 Agreement or CIL.

Response

The comments regarding the position regarding the primary school and the notified site are noted. The policy has been amended to require the design of development to facilitate the on-site provision of high speed broadband connectivity. It is not considered appropriate for any Section 106 Agreement to require a contribution towards the provision of additional household waste recycling through the expansion of the Loscoe Household Waste Recycling Centre, but consideration will be given to including it as in infrastructure project to be funded through a Community Infrastructure Levy (CIL). Criteria has been added to the policy requiring any development to respect the classification of this site as being of secondary importance in DCC’s Areas of Multiple Environmental Sensitivity (AMES).

Comments on Policy SG3: Land North of Denby

Derby and Derbyshire Development Control Archaeologist: The site contains numerous HER records associated with historic industrial uses, in particular the site of the former Denby Ironworks (HER 18806) with potential for associated below-ground archaeology, and the routes of 19th century mineral tramways associated with the former mining and ironworking interests in the area.

The site has been subject to substantial opencast coal extraction, and archaeological potential would be limited to those areas not previously subject to extraction.

As noted in my original consultation response, the area AV13 contains numerous undesignated heritage assets.

Areas of heritage significance should be given weight when considering allocation and the associated policy.

Response

The policy has been amended to require appropriate design and masterplanning to protect and enhance heritage assets, both within and adjacent to the site.

Derbyshire County Council: The IDP identifies the need to provide a new primary school on-site as part of the development, and a contribution towards expanded secondary school provision, as a medium priority. Policy SG3 of the LPDCS states that the development will need to deliver improvements to the highway network, a new primary school on-site, an expansion to the existing John Flamsteed Secondary School (via financial contribution secured by Section 106 Agreement), a safeguarded route for a Greenway, and protection of existing footpaths. This is supported. The roll-out of high speed broadband is a key Government priority and is a strategic priority project in the DIP. It should, therefore, be accorded high priority in the Borough Council’s IDP and Policy SG3 of the LPDCS should require the design of any development proposals to facilitate the on-site provision of high speed broadband connectivity. The DIP states that LHWRC is over capacity. This is acknowledged in the IDP. However, the LPDCS does not set out how this critical infrastructure issue will be addressed and this puts the deliverability of the Core Strategy into doubt. Policy SG3 should state that development of this strategic site should contribute towards the provision of additional household waste recycling through expansion of LHWRC via a financial contribution secured through either a Section 106 Agreement or CIL.

Response

The policy has been amended to require the design of development to facilitate the on-site provision of high speed broadband connectivity. It is not considered appropriate for any Section 106 Agreement to require a contribution towards the provision of additional household waste recycling through the expansion of the Loscoe Household Waste Recycling Centre, but consideration will be given to including it as in infrastructure project to be funded through a Community Infrastructure Levy (CIL).

Comments on Policy SG4: Newlands/Taylors Lane

Derby and Derbyshire Development Control Archaeologist:

Newlands: There are no known archaeological or historic landscape constraints within the site.

Taylor Lane: The eastern part of the Taylor Lane site was formerly the site of the Ormonde Colliery (Derbyshire Historic Environment Record 20513).

Response

These comments do not require any changes to the policy.

Derbyshire County Council: The IDP states that Aldercar Community Language College has limited capacity and could be expanded and that Heanor Gate Science College, which is an academy, is at capacity, and would be difficult to expand. The IDP also states that local primary schools are at

88 capacity and that this is a constraint that will require further liaison with the Local Education Authority.

Development at this site may require education contributions towards both primary and secondary provision, but not for the whole scale of housing proposed. The roll-out of high speed broadband is a key Government priority and is a strategic priority project in the DIP. It should, therefore, be accorded high priority in the Borough Council’s IDP and Policy SG4 of the LPDCS should require the design of any development proposals to facilitate the on-site provision of high speed broadband connectivity.

The DIP states that LHWRC is over capacity. This is acknowledged in the IDP. However, the LPDCS does not set out how this critical infrastructure issue will be addressed and this puts the deliverability of the Core Strategy into doubt. Policy SG4 should state that development of this strategic site should contribute towards the provision of additional household waste recycling through expansion of LHWRC via a financial contribution secured through either a Section 106 Agreement or CIL.

Response

The policy has been amended to require a financial contribution towards primary and secondary school provision in the locality. It has also been amended to require the design of development to facilitate the on-site provision of high speed broadband connectivity. It is not considered appropriate for any Section 106 Agreement to require a contribution towards the provision of additional household waste recycling through the expansion of the Loscoe Household Waste Recycling Centre, but consideration will be given to including it as in infrastructure project to be funded through a Community Infrastructure Levy (CIL).

Comments on Policy SG5: Radbourne Lane, Mackworth

Derby and Derbyshire Development Control Archaeologist: The site was subject to archaeological evaluation at the pre-application stage and no remains of archaeological significance were identified. No archaeological work is therefore required at the post-consent stage.

Derbyshire County Council: This site has planning permission for 530 dwellings and a Section 106 Agreement in place. This policy is supported.

Response

These comments support the policy.

Comments on Policy SG6: Coppice Farm, Ripley

Derby and Derbyshire Development Control Archaeologist: The site has been subject to archaeological desk-based assessment and geophysical survey at the pre-application stage.

Derbyshire County Council: AVBC has resolved to grant outline planning permission for 360 dwellings on the site. This policy is supported. DCC has identified an area including this site as being of Secondary Sensitivity in terms of Historic and Visual Sensitivity.

This area is identified as being in the ‘Derbyshire Coalfield National Character Area’, and part of the finer landscape subdivision ‘Coalfield Village Farmlands’ landscape character

89 type where the settlement pattern is characterised by small villages expanded by red brick former mining terraces and ribbon development.

Response

Criteria has been added to the policy requiring any development to be designed to respect the classification of this site as being of secondary importance in DCC’s Areas of Multiple Environmental Sensitivity (AMES).

Comments on Policy SG7: Nottingham Road, Ripley

Derby and Derbyshire Development Control Archaeologist: The majority of the site has been subject to opencast coal extraction and therefore retains no archaeological potential over much of its area. The eastern boundary of the site is formed by the former course of a 19th century mineral tramway (HER 24708) associated with the Butterley Works site and retaining evidence for former cuttings along the route. Development in this location may therefore provide opportunities for conservation and enhancement of this route as part of the Green Infrastructure associated with the site, and any application for the relevant areas should contain a brief heritage appraisal in relation to the surviving fabric of the historic tramway and any proposed enhancement/management.

Response

The policy has been amended to require that development is of an appropriate design that protects and enhances heritage assets and their settings.

Derbyshire County Council:

The LPDCS states that the site needs to help deliver the A610 Link Road, additional open space, and enhancements to existing footpaths. The IDP states that Mill Hill secondary school could accommodate some pupils and that primary school pupils could be accommodated through existing capacity and expansion to existing schools, via Section 106 Agreement, if necessary. This is consistent with advice provided to AVBC previously by the County Council’s Children and Younger Adults Department (CAYA). The County Council’s Property Services Department is undertaking a feasibility study to look at the potential to expand the existing school. Policy SG7 should refer to the opportunity for enhancing existing footpaths in order to provide connections to and enhance the Derbyshire Greenway Network.

Response

The policy has been amended to refer to the opportunity for enhancing existing footpaths in order to provide connections to and enhance the Derbyshire Greenway Network.

Comments on Policy H3: Affordable Housing

Derbyshire County Council: The LPDCS requires development of 0.5ha or 15 dwellings or more to provide 30% affordable housing, in line with evidence in the Derby HMA SHMA. It must be acknowledged that affordable housing provision has a very significant impact on the viability of development. Requiring this level of affordable housing could impact significantly on the level of funding available for infrastructure.

Response

These comments are noted.

Comments on Policy H4: Viability of Proposed Housing Sites

Derbyshire County Council: Policy H4 provides AVBC with the ability to assess applications on a case by case basis and to consider waiving any requirements for developer contributions in order to ensure schemes remain viable. However, it is not clear how the critical infrastructure required to support development will be delivered in areas of poor viability where exceptions are made under this policy. Policy H4 should set out other potential sources of funding (potentially borrowing, Regional Growth Fund, capital programmes, CIL, etc) that can be used to fund infrastructure in areas of poor viability where developer contribution requirements under Section 106 Agreements are waivered. This will help to ensure the Core Strategy is flexible and deliverable.

Response

The policy has been amended to require that the Council will expect all other potential sources of funding to make a scheme policy compliant to have been investigated.

Comments on Policy E2: Quality and Design of Development

Derbyshire County Council: This policy allows for, amongst other things, developments to be designed to be adaptable and accessible and to adapt to changing lifestyle needs. The policy also requires the provision of space for increased recycling receptacles and access for refuse collection as part of the design of development. This is supported. The roll-out of high speed broadband is a key Government priority and is a high strategic priority project in the DIP. It should therefore be accorded high priority in the Borough Council’s IDP and Policy E2 of the LPDCS should require the design of development proposals to facilitate the on-site provision of high speed broadband connectivity.

Response

The policy has been amended to require the design of development to facilitate the on-site provision of high speed broadband connectivity.

Comments on Policy E3: Historic Environment

Derbyshire County Council: Whilst Policy E3: Historic Environment sets out AVBC’s commitment to support the Outstanding Universal Value, integrity, authenticity and significance of the Derwent Valley Mills World Heritage Site (DVMWHS) and its setting, it is recommended that: • There is a separate criteria based policy for the DVMWHS and its buffer zone. • The policy should require development proposals to demonstrate how they would contribute towards the achievement of the management objectives outlined in DVMWHS Management Plan and enhance the WHS.

• The policy should encourage the interpretation and promotion of the significance of the WHS and its assets.

It is considered important that a consistent policy approach is taken to the DVMWHS by AVBC and the City Council in their Local Plans.

Preservation of the route of the Cromford Canal and restoration of its features or stretches has the potential to significantly contribute to the objectives set out in the LPDCS, for example, by contributing to the landscape quality of Amber Valley (including the landscape character within the Green Belt), to flood risk management and the quality and design of development. The route of Cromford Canal is a direct link between Amber Valley and the DVMWHS.

By protecting and enhancing the canal route there is further potential to support the objectives to improve green infrastructure, parks and open spaces, community, leisure and health facilities and strategic transport infrastructure projects. In conclusion, it would be appropriate therefore if the route of the Cromford Canal was to be specifically named in ‘the areas and buildings of architectural or historic interest… which will be preserved and enhanced and protected from unsympathetic development’ and included in the local list of non-designated Heritage Assets.

Response

These suggested changes have been made to the policy. The existing saved Local Plan policy on the World Heritage (EN29) will remain and will be replaced and amended as necessary by a policy in the Site Allocations and Development Management Policies DPD, which will form part 2 of the new Local Plan.

Comments on Policy E4: Landscape Character

Derbyshire County Council: Extensive comments on the landscape and visual impact issues have been provided by the County Council’s Landscape officers. The salient points of the comments are outlined below which: • Fully support the environmental objectives, in particular, those related to conservation and enhancement of the Borough’s landscape, ecology and the promotion of quality design; • Express concern about inconsistencies in the identification of environmental base data (particularly Areas of Multiple Environmental Sensitivity (AMES), which would have been defined by Derbyshire County Council, and the omission in the Core Strategy to explain clearly its use in the decision making process; • Suggest amendments to the policy background text to improve clarity and consistency; and • Suggest amendments to the policy wording to improve clarity and ensure all relevant aspects are covered.

Detailed landscape character, visual impact and environmental sensitivity comments have been provided to AVBC on various Strategic Growth Sites and on a number of subsequent

92 outline applications, particularly relating to Ripley Gateway. These comments remain outstanding and relevant.

Response

The Core Strategy policies, site assessments and the Sustainability Appraisal have been amended where relevant to refer to Areas of Multiple Environmental Sensitivity (AMES).

Comments on Policy IN1: Transport

Derbyshire County Council: As the Highways Authority for the area, the County Council has concerns about the rate of progress on the development of the transportation evidence base, in particular, the identification of transport infrastructure needed to support development growth proposed in the Draft Core Strategy. A significant amount of new housing development on a number of the Strategic Growth Sites has already been consented by AVBC with minimal off-site transportation infrastructure. These include Outseats Farm, Alfreton and Coppice Farm, Ripley. Planning Permission has been granted for 530 dwellings on land at Radbourne Lane, Mackworth. This does, however, include provision of off-site infrastructure and a Travel Plan. Land is identified to the north of Denby as a Strategic Growth Site for around 1,800 dwellings. Whilst some traffic impact assessment work has been provided by an interested party promoting the site, this only sets out to establish that a new grade separated junction onto the A38 is not required. However, it does not consider either the impact of existing consented development in the area or the cumulative impact of other development that may emerge from the Core Strategy. Land is identified at Newlands and Taylors Lane, Heanor, as a Strategic Growth Site for around 500 dwellings. Again, little transport evidence has been provided apart from the submission of some traffic impact assessment work by an interested party promoting the sites. Key evidence is discussed on page 58 of the LPDCS, which refers both to the Derby HMA Transport Modelling that is taking place and a Derby HMA Transport Position Statement. However, at the time of writing, both transportation papers are concerned solely with the principal urban areas of Derby and say very little about the impacts of potential development over the wider highway and transport network(s) beyond Derby. The Transport Position Statement does not mention about Amber Valley. It is considered that AVBC’s Core Strategy would be greatly strengthened by a more comprehensive approach to transportation assessment and analysis to enhance the evidence base for land allocation and it is recommended that this is prepared in advance of the EIP.

Response

These comments are noted.

Comments on Policy IN2: Green Infrastructure, Parks and Open Space

Derbyshire County Council: There are a number of opportunities across the Borough to develop the Derbyshire Greenway network, helping to improve community access for disabled people, walking, cycling and horse riding. The County Council would like to see the Derbyshire Greenway network explicitly referenced by this policy (with an accompanying map).

Response The policy now refers to the Derbyshire Greenway network needing to be protected and enhanced, and a key diagram has been included in the Core Strategy which shows the location of the Derbyshire Greenway network.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Derbyshire County Council: Strategic Transport Infrastructure Priorities indicates that AVBC will support the provision of a new A610 Link Road between Ripley and Codnor in conjunction with other development proposals, which would include new housing, retails and employment development. At the current time, however, no evidence has been provided regarding feasibility, deliverability or impact of the scheme over the wider highway network or indeed its environmental impact. It is anticipated, however, that by the time the Core Strategy reaches EIP, a planning application would have been submitted for the A610 Link Road, which should include extensive evidence relating to these issues.

Response

A planning application for this scheme has now been submitted which includes extensive evidence relating to these issues.

Comments on Policy IN5: Infrastructure Delivery

Derbyshire County Council: Policy IN5 could be significantly improved by setting out exactly what items of infrastructure are required and seen as critical to delivery of the Local Plan Core Strategy and clearly stating how that infrastructure will be funded and delivered.

Response

The infrastructure Delivery Plan will set out what items of infrastructure are required and seen as critical to the delivery of the Local Plan Core Strategy. As this policy already states that infrastructure delivery will take place through the Infrastructure Delivery Plan, it is considered that no change to the policy is required.

Comments on Policy IN6: Developers Contributions

Derbyshire County Council: Policy IN6 could be improved significantly by identifying the key items of infrastructure that are critical to delivery of the LPDCS, what the funding gap is, and exactly what sources of funding will be sought to help bridge the gap. Clarity on AVBC’s position in introducing a CIL would be helpful.

Response

Any further comments you wish to make on the content of the Plan?

Greater Nottingham Growth Point on behalf of Broxtowe Borough Council, Erewash Borough Council, Gedling Borough Council, Nottingham City Council and Rushcliffe Borough Council: It is noted that the Core Strategy refers to a housing provision for the Derby Housing Market Area of 35,350 homes between 2008 and 2028, of which 9,400 are

94 provided for in Amber Valley. As this is based on an objective assessment of housing need, if both Derby City Council and South Derbyshire District Council plan for the remaining housing provision, the Core Strategies will accord with the National Planning Policy Framework requirement that local plans should meet objectively assessed needs. This should ensure that there will be no consequential additional demand for housing in neighbouring Housing Market Areas, including Nottingham Core Housing Market Area. This approach is supported.

I note references in the appendices to the level of growth in the Nottingham Housing Market Area, which appears to be taken from the Broxtowe, Gedling and Nottingham City Aligned Core Strategies, and therefore missed housing provision in Rushcliffe and Erewash Borough’s Core Strategies (assuming Rushcliffe make the proposed modifications agreed at their cabinet). For the avoidance of doubt, the Nottingham Core Housing Market Area housing provision is 49,950 new homes between 2011 and 2028.

Response

This reference has been deleted.

Broxtowe Borough Council: In the “Scale of Housing” section of Appendix A, it is stated that; “By way of comparison, this exceeds the increase in the housing stock being proposed in the Greater Nottingham aligned Core Strategies.” If this statement is to be retained, it should be made clear that the Aligned Core Strategies of Broxtowe, Gedling and Nottingham City cover only part of the Greater Nottingham HMA and that the figure for the whole of the Nottingham HMA includes figures in the Rushcliffe and Erewash Core Strategies, which, in combination with the Aligned Core Strategies, amount to provision for 49,950 new homes.

Response

This reference has been deleted.

Derbyshire County Council Officer’s: Overall, the LPDCS is broadly supported, although there are various outstanding issues that require further cooperative working between the County Council and AVBC, particularly relating to transport, education provision and other infrastructure requirements. Detailed comments on a number of issues, particularly town centres, heritage and strategic infrastructure planning and service delivery (particularly relating to the seven Strategic Growth Sites) are included.

Response

These comments are noted.

2.6 Comments from national bodies

Comments on the Spatial Portrait of Amber Valley

English Heritage: We welcome reference to historic environment attributes within the spatial portrait including the Derwent Valley Mills World Heritage Site (DVMWHS).

National Trust: Whilst quite brief the Spatial Portrait in most respects adequately summarises the key economic, social and environmental features of the Borough – the exception is the lack of any particular reference to its nature conservation resources which are also a valued feature, a small addition to the text would be appropriate. Apart from the exception noted above there is a reasonable balance within the Spatial Portrait; any other significant additional changes are likely to lead to requests to add more detail to the other areas.

Response

The text has been amended to refer to the high quality of flora and fauna in the Borough.

Comments on the Spatial Vision of Amber Valley

English Heritage: We welcome reference to historic environment attributes within the vision.

National Trust: Generally the proposed Spatial Vision is supported, with the section on the Historic Environment being suitably worded and supported accordingly. However, it is considered that the part relating to nature conservation is unambitious, especially so in the context of relatively poor levels of bio-diversity and the ambitions of strategies such as the bio-diversity action plan. It is therefore requested that the following addition is made: “All important green open spaces and areas of nature conservation interest in the Borough, including the Derwent Valley corridor, will be protected and enhanced wherever practical.” It is considered that such wording would also be consistent with the approach then taken in Strategic Objective 8.

Response

The text has been amended as requested.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: More thought needs to be given to the vision for Belper, ideally through a Neighbourhood Plan. Although tourism can contribute to the diversity and vibrancy of the town, its economy should not become reliant on tourism. Remaining manufacturing industries should be protected, and links with the creative industries promoted, e.g. design, fashion, film etc.

Response

A Neighbourhood Plan for the Parish of Belper is a matter for Belper Town Council to consider.

Sport England: Welcome the commitment to protecting important green open spaces, though clarity required about what constitutes ‘important green open spaces’. Also support the last element of the vision concerning the delivery of high standards and ease of accessibility in respect of all open space, parks, recreational areas, leisure facilities and community facilities (which is taken to include indoor and outdoor sports facilities), and their acknowledged contribution to the network of green infrastructure.

Response

This support is noted. It is not considered necessary to explain what constitutes important green open spaces, as examples are provided in the vision.

Natural England:

Natural England generally supports the vision particularly the paragraph that relates to the protection of nature conservation interests, green spaces and the Derwent Valley corridor. We also welcome the reference to the green infrastructure network.

Response

This support is noted.

The Woodland Trust: It is disappointing that the paragraph in the vision on greenspace is the last one. Also, it talks about parks and recreational areas but does not make any mention of natural greenspace or trees and woods.

The Forestry Commission's "Case for Trees" in 2010 said the following:

"there is a growing realisation among academics about the important role trees play in our urban as well as the rural environment. It has long been accepted and confirmed by numerous studies that trees absorb pollutants in our cities with measurable benefits to people’s health – such as reducing asthma levels. Yet trees also deliver a whole host of other extraordinary economic, environmental and social benefits"

Response

The paragraph on green open space is no longer the last one. The vision has been amended to refer to access to natural greenspace and woodland.

Comments on the Strategic Objectives

National Trust: This is a good, well-worded, set of Strategic Objectives that the National Trust is pleased to support.

Response

This support is noted.

Environment Agency: The EA agrees with proposed Strategic Objectives 1,8 and 13.

Response

This support is noted.

Sport England: Support objective 6 that aims to improve health and well-being but consider that express reference should be made to sport as one of the activities specified within the objective.

Welcome objective 9 relating to the ensuring availability of easily accessible space and facilities, but consider that sports facilities should additionally be expressly referenced.

Response

These objectives have been amended as suggested.

Natural England: We support objective 6 which encourages the health and well-being of local people but we would also suggest that it should note the importance of access to the natural environment as a leisure and cultural activity. We also support objectives 7 and 8 which cover our interests in landscape and biodiversity. Whilst we welcome objective 9 we would like to see green infrastructure specifically mentioned within the wording.

Response

These objectives have been amended as suggested.

English Heritage: We welcome the inclusion of a strategic objective relating to the protection and enhancement of heritage assets (SO7).

Response

This support is noted.

The Woodland Trust: Welcome in particular Objective 8 on nature conservation and in particular the emphasis on reversing fragmentation and improving connectivity. For the reasons outlined in the previous section, we would like to see this expanded to include a reference to trees and woodland.

Response

This objective has been amended to refer to woodland.

Comments on the Spatial Strategy

National Trust: The approach adopted is appropriate to the circumstances of Amber Valley and is supported. Arguably the terminology in Section 6.4 could be more positively worded – indeed the title could equally be “Safeguarding Key Amber Valley Assets.” This is especially

98 true in terms of the heritage resources (referred to in the NPPF as heritage assets)…so the sentence part way through this paragraph could be amended so as to more appropriately read: “Other important constraints assets are associated…”

Whilst a case might be advanced that turning this section around to refer to assets is not as appropriate in the context of flood risk, the case can in fact be made that the areas that are at risk of flooding are actually assets as these are the floodplain areas that temporarily accommodate excess run off and thereby protect built up areas away from flooding impacts; i.e. they are a flood prevention asset that benefits adjoin land and property. (NB there appears to be a small typographical error at the start of this Section (page 12): “The principal focus for new development across the Borough will be that of urban concentration…”)

Response

The title of section 6.4 has been changed to “Safeguarding Key Amber Valley Assets” as suggested. The suggested changes to the text in this section has also been amended as suggested and the typographical error has been corrected.

Environment Agency: The EA agrees with the focus on maximising the use of brownfield land, which provides an opportunity to remediate and clean-up sites contaminated by a legacy of industrial uses.

Response

This support is noted.

Comments on Policy SS1: Housing Land Requirements and Distribution

English Heritage: We note the proposed levels of growth and its distribution to be mainly in the market towns of Alfreton, Belper, Heanor and Ripley. We particularly support the reference to the need for development to respect areas of the Borough that are sensitive in terms of landscape and heritage assets and their settings. We feel that this reference here is essential given the heritage assets (including the World Heritage Site).

Response

This support is noted.

National Trust: The Policy as worded is supported. The specific references to respecting landscape and heritage are important and appropriate having regard to the particular circumstances that apply in Amber Valley.

Response

This support is noted.

National Trust: The sequential approach as set out in this Policy is supported, as is the hierarchy of settlements which clearly reflect their respective roles. The cross-reference in the individual centre policies SS4 to SS7 to Policy E3 is important and appropriate.

Response

This support is noted.

Comments on Policy SS4: Town Centre Regeneration in Alfreton

English Heritage: We welcome reference within this policy to policy E3 (The Historic Environment) and reference to assets within the supporting text.

Response

This support is noted.

Comments on Policy SS5: Town Centre Regeneration in Belper

English Heritage: We welcome the references made within the supporting text to the historic environment attributes within Belper, which falls within the World Heritage Site. We consider, however, that the policy requires amending in order to ensure its effectiveness and compliance with the NPPF.

Specifically, we consider that reference should be made within the policy itself to the protection of the Outstanding Universal Value of the World Heritage Site. We suggest the following amendment:

“Planning permission will be granted for development and uses in Belper town centre that will improve its attraction for tourists as well as maintaining and improving its historic character, appearance, and the Outstanding Universal Value as a World Heritage Site”

We also consider that reference should be made within the policy to the ‘Land between the A6 and the River Derwent SPD’ as this relates directly to the regeneration of the town centre for this area of land.

This document should also be added into the list under ‘Delivery’.

Response

The policy and background text have been amended as suggested.

Comments on Policy SS6: Town Centre Regeneration in Heanor

English Heritage: We welcome reference to policy E3 within the policy text.

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Response

This support is noted.

Comments on Policy SS7: Town Centre Regeneration in Ripley

English Heritage: We welcome reference to protection of character and appearance of this area as a traditional market town, as well as reference to policy E3 within the policy text.

Response

This support is noted.

Comments on Policy SS8: Development in Town Centres

English Heritage: We note the contents of this policy. We are not sure how this policy relates to Policy SS3 and the Retail Study (2011) which cites the need for comparison retail. We are also unsure why only policy SS7 (Town Centre Regeneration in Ripley) is referenced here – other policies SS3-SS6 are also relevant. Again we consider reference to the SPD for Belper is essential here.

Response

The policy has been amended as suggested.

National Trust: No objection to the approach set out here but would query two matters. Firstly, the Policy appears to relate to individual plans for each of the main centres, so presumably the first sentence of Policy SS8 should read: “Within the Borough’s town centres, as shown on the following maps, planning permission for…” Secondly, in the final paragraph the cross reference appears to be to the wrong policy number; i.e. should read: “…the criteria in policy SS79 (Primary Shopping Frontages) will also need to be satisfied”.

Response

The policy and background text have been corrected as suggested.

Comments on Policy SS10: Green Belt

English Heritage: We welcome reference within criterion c) in relation to the protection of heritage assets.

Response

This support is noted.

Derbyshire Wildlife Trust: We support this policy on Green Belt.

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Response

This support is noted.

Sport England: Broadly support paragraph b), but consider that it should be revised to state ‘appropriate’ rather than ‘essential’ facilities for outdoor sport and outdoor recreation…., thereby making it consistent with paragraph 89 of the NPPF.

Response

The policy has been amended as suggested.

Natural England:

Although we recognise that the green belt designation is not made for the purpose of natural environment protection as such, we nevertheless suggest that there is potential for it to deliver more positive benefits for the natural environment and people’s enjoyment of it and to play a role in climate change adaptation. We would therefore suggest that this policy should encourage the taking of any opportunities to link the green belt into green infrastructure and ecological networks both within the urban areas and with the open countryside, and should state that wherever possible the land should be used for positive purposes. This would be consistent with the advice in paragraph 81 of the National Planning Policy Framework (NPPF).

Response

The policy has been amended as suggested.

Comments on Policy SS11: Amendments to the Green Belt

National Trust: The National Trust has no specific comments to make upon these detailed proposals. However, more generally it is noted that there is an intention to remove land from the Green Belt and potentially at a later date the case might be made to review other land outside the current Green Belt limits to see if changes or new/improved information or understanding would warrant any additions to the current extent of Green Belt.

Response

This comment is noted.

Derbyshire Wildlife Trust: The proposed changes to the Green Belt will result in additional areas of countryside being exposed to future development. We consider that there could be greater impacts on wildlife associated with land east of Codnor that the land at the north and east of Ripley. However, we are not aware of any detailed ecological surveys of these two areas. Our own data suggests that brown hares could be displaced and a range of common woodland, hedgerow, garden and arable bird species could be affected.

Response

Criteria have been added to the policies SG2, SG7 and IN4 to address these concerns.

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Comments on Policy SS12: Countryside

National Trust: The approach set out in Policy SS12 is agreed and supported. However, the Policy does indicate that exceptionally development will take place in the countryside; but unlike other Policies it contains no stipulations or guidance on the form or appearance of such development. It is suggested that cross-references to other policies, such as E2, E3 and E4 would be appropriate, or alternatively the inclusion of a list of detailed criteria that any development would need to comply with.

Response

The policy has been amended to cross reference these policies as suggested.

Comments on Policy SG1: Outseats Farm, Alfreton

English Heritage: We consider that this policy, as present, is unsound in relation to the allocation of this site. Whilst we note that outline consent has been granted, no further policy guidance is given for which any future reserved matters consent should take into account.

As stated in our representation in December 2012, development at this site is likely to impact on the setting of the grade II* listed Carnfield Hall and the setting of Carnfield Hall Conservation Area. We consider that criteria for this policy should be included. This should make reference to the need to protect the setting of heritage assets through appropriate design and masterplanning.

Supporting text to the policy should also be developed and reference should be made to these issues.

Response

The policy and supporting text have been amended to address these issues.

Sport England: Evidence based approach should be adopted to determine form of open space drawing on Playing Pitch Strategy. The Infrastructure Delivery Plan should be updated as necessary.

Response

The Infrastructure Delivery Plan has been amended in accordance with this suggestion.

Comments on Policy SG2: Alfreton Road, Codnor

English Heritage: We provided comments with regard to this site and the proposed road in our last consultation response, dated 19th December 2012 in terms of impacts of the proposed allocation and road upon the setting of heritage assets associated with Codnor Castle, including listed buildings, a conservation area and scheduled monument. The remains of the Castle are on the 2013 ‘Heritage at Risk Register.’ In addition the grade II listed Castle Farmhouse is also on the buildings at risk register by Derbyshire County Council.

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We are therefore concerned that the policy makes no reference to the need to protect the setting of these assets and consider that without such a reference, the policy will be unsound as it is not justified in excluding this, it will be ineffective in the protection of historic environment considerations and not be in accordance with relevant historic environment paragraphs of the NPPF.

We consider that a further criterion is required in order to make this sound.

Supporting text to the policy should also be developed and reference should be made to these issues.

Response

The policy and supporting text have been amended to address these issues.

Derbyshire Wildlife Trust: Are concerned about the potentially adverse impacts on biodiversity and countryside locally. We would strongly urge a more detailed ecological appraisal of this area to provide greater clarity on potential impacts and help inform any decision on the number and scale of house buildings here.

Response

The policy has been amended to address these issues. Any planning application will be required to be accompanied by a detailed ecological appraisal of this area.

Sport England: Evidence based approach should be adopted to determine form of open space drawing on Playing Pitch Strategy. The Infrastructure Delivery Plan should be updated as necessary.

Response

The Infrastructure Delivery Plan has been amended in accordance with this suggestion.

Natural England: We note that the Sustainability Report (18.6.7) considers that the development of this site will have a significant impact on the character of the built and natural environment, and from our desk-based study we agree with this assessment as regards the natural environment. We therefore suggest that wording of this policy needs to be strengthened to ensure that settlement design protects and where possible enhances landscape character, habitat creation and connectivity and green infrastructure.

We acknowledge that the policy has identified the need for public open space and the protection and enhancement of footpaths. We would also expect to see, within the policy, a requirement for these to be linked to green infrastructure, to habitat provision, and explicit links to policies E4 on landscape and E6 on biodiversity.

Response

The policy has been amended in accordance with these suggestions.

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Comments on Policy SG3: Land North of Denby

English Heritage: We provided detailed comments in respect of this site allocation in our letter dated 19th March 2012. At this time, we identified impacts upon the setting of the grade II* listed Park Hall and grade II listed Gate Piers and Garden Walls. We also identified potential impacts on the World Heritage Site, as, although outside of this designation and buffer zone, views into this area are enjoyed from Park Hall due to its elevated position. Also of historic interest is the former industrial nature of the site, associated with the former Denby Colliery and a Brick and Tile Works.

Supporting text to the policy should also be developed and reference should be made to these issues.

Response

The policy and supporting text have been amended in accordance with these suggestions. It is not considered, however, that explicit reference needs to be made to the setting of the World Heritage Site, as those parts of the site that may be visible from the World Heritage site will remain undeveloped to protect the setting of Park Hall.

The Highways Agency: The majority of proposed housing sites on their own will have fairly limited impacts on the A38. The exception to this is the proposed strategic growth site to the north of Denby for some 1,800 dwellings. The Agency notes that Policy SG3 indicates that this development will involve ‘major improvements to the surrounding road infrastructure’ (SG3c). The Agency has previously engaged with the Council and the promoters of the Denby site, but the nature of measures required to enable the site to satisfactorily access the A38 have not yet been determined.

The Agency would like Policy SG3 (C) to be amended to specifically refer to the need for appropriate A38 improvements to mitigate the impact of the Denby site as follows: c) Major improvements to the surrounding road infrastructure, including either a significant upgrade to the A38 Coxbench junction or provision of a new A38 junction to serve the site.

Response

The policy has been amended in accordance with this suggestion.

Derbyshire Wildlife Trust: Part of the site is of exceptional wildlife value (designated as a Local Wildlife Site and supports European and UK protected species) and there may be conflict between the protection of wildlife and remediation followed by subsequent development. This policy also needs to satisfy policy E6.

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Response

The policy has been amended to refer to the need for development to be designed to protect wildlife and habitat connectivity, and enhance biodiversity. The need to also comply with policy E6 has also been added.

Environment Agency: The EA agrees with the requirement to remediate and clean-up this site, which has been affected by historic land contamination.

Response

This support is noted.

Severn Trent Water: We promoted a new sewer capacity project in January 2013 to start to look in more detail at what sewer capacity improvements would be required to accommodate the strategic development allocation at Cinderhill.

The timescales for this project will be dependent on when the developer is due to connect and phasing but at present improvements are planned for completion in 2017/18. This can however be brought forward if development phasing warrants capacity improvements to be provided earlier. At present we do not envisage any capacity issues which would delay development on the Cinderhill site but it would be useful if you could provide an indication on phasing if possible.

With regard to developer contributions, all off-site capacity improvements to the existing sewerage system will be wholly paid for by Severn Trent. The developer will be responsible for paying for all on-site new sewers within the development plus the cost of connection to the existing sewers. They will also be responsible for paying a connection charge per property, which is a standard charge for all new development connections.

Response

These comments are noted.

Natural England: We are concerned about the policy for development proposed for this allocation because the site incorporates a large part of a 14.6ha wildlife site, the Cinderhill Tar Pits and Morrells Brook Local Site (Habitat Mosaic). This is linked to the Morrells Wood Local Wildlife site and ancient semi natural woodland. These local sites are connected, and therefore make an important contribution to the wider ecological network, the protection and enhancement of which is a specific aim of the National Planning Policy Framework (NPPF).

We would like to see the policy for development on this site itself incorporate stronger protections for wildlife and habitat connectivity, and require developers to look for opportunities to enhance biodiversity, particularly in view of resilience to climate change.

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Response

Comments on Policy SG4: Newlands/Taylors Lane

Natural England: We note that the description of this site mentions there is a nature conservation site which is part of the Bailey Brook Marsh Local Wildlife Site. We would suggest that this advice is strengthened to include the requirement for the protection and enhancement of this nature conservation site.

Response

The policy has been amended to refer to the need for development to be designed to retain and enhance areas of nature conservation interest, including the adjoining Bailey Brook Marsh Local Wildlife Site.

Derbyshire Wildlife Trust: This policy also needs to satisfy policy E6.

Response

The policy now refers to the need for development to also satisfy policy E6.

Comments on Policy SG5: Radbourne Lane, Mackworth

This allocation sits away from designated heritage assets. In order to reduce impact on their setting, however, we still consider that criteria are required in order to ensure that setting of heritage assets is protected here.

Response

The policy has been amended by adding criteria that requires appropriate design and masterplanning to protect the setting of heritage assets.

National Trust: It is considered essential that any policy reference to this site, or alternatively any reference in the supporting text in the DPD, makes specific mention of development needing to be in accordance with the adopted SPD for this site.

Response

The policy has been amended to require development to comply with the SPD for this site.

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Comments on Policy SG6: Coppice Farm, Ripley

English Heritage: As per our other comments for sites, whilst we note that outline permission is likely to be granted here, policy criteria are required in order to guide any reserved matters consent.

Response

The policy has been amended to require development to be of an appropriate design to protect the setting of heritage assets.

Comments on Policy SG7: Nottingham Road, Ripley

English Heritage: We have previously made comment that this site may impact on the area in terms of its industrial interest and in relation to Butterley Park. A grade II listed milepost also lies adjacent to the site.

We are therefore concerned that the policy makes no reference to the need to protect the setting of these assets and consider that without such a reference, the policy will be unsound.

Response

The policy has been amended to require development to be of an appropriate design to protect the setting of heritage assets.

Derbyshire Wildlife Trust: Are concerned about the potentially adverse impacts on biodiversity and countryside locally. We believe that, should this proposal be taken forward, the policy should ensure that land is retained and enhanced for biodiversity especially along the former railway line and in relation to hydrology and drainage which could affect the Carr Wood LNR downstream.

Response

Sport England: Need to ensure existing playing fields are protected in line with NPPF paragraph 74 and Sport England’s Playing Fields Policy. Evidence based approach should be adopted to determine form of open space drawing on the Playing Pitch Strategy. The Infrastructure Delivery Plan should be updated to reflect the above as necessary.

Response

The Infrastructure Delivery Plan has been amended in accordance with this suggestion.

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Natural England: The development of this site will have a significant impact on the character of the built and natural environment and impact on the resilience of wildlife to climate change, Natural England believes that the policy for this development should be strengthened. Our comments on SG2, Codnor, apply equally here, and we would like to see the same requirements for enhancement of landscape character, habitat creation and connectivity, and maximising of green infrastructure benefits within this site. As with SG2, we would suggest that it is essential that the design of any proposed development is carefully landscaped, particularly at the edges, so that it is compatible with the surrounding countryside and that green infrastructure is incorporated at the early stages of the masterplan process. All opportunities should be taken to enhance the quality of the green infrastructure and wildlife habitat, possibly linking to Butterley Park Wood Local Wildlife Site, and increase the recreational connections into the surrounding countryside.

We acknowledge that the policy has identified the need for public open space and the protection and enhancement of footpaths but we would like the requirement for these to be linked to green infrastructure.

Response

The policy has been amended to require development to retain and enhance land for biodiversity and drainage, especially along the former railway line and in relation to hydrology and drainage, having regard to any impact on the Carr Wood Local Nature Reserve. It has also been amended to require development to enhance landscape character, habitat creation and connectivity and green infrastructure through appropriate design and masterplanning, and maximising of green infrastructure benefits within the site.

Comments on Policy H1: Housing Types, Mix and Choice

English Heritage: We note the contents of this policy. We consider that cross reference should be made within this to policy E2, regarding design and quality to ensure that types and mix, also reflects the character of the local area.

National Trust: a cross-reference to Policy E2 would be appropriate, but otherwise no comments to make.

Response

The policy has been amended to refer to the need for development to also comply with the criteria in policy E2.

Comments on Policy R1: Reducing the Use of Non Renewable Energy Resources

National Trust: Not convinced about either the overall approach or the detailed wording proposed for Policy R2. As it stands the Policy is intended to cover all forms of renewable energy (solar, hydro etc, not solely wind) and at all scales (i.e. including micro-renewables). In this context some of the criteria in the Policy appear to be lacking; in particular criterion d) appears to be directly related to wind turbine developments, but not to address specific

109 geology/hydrology/flood issues that could arise from hydro developments, or glare associated with solar arrays.

It appears to the Trust that this needs to be addressed by: a) a more general Policy approach that is backed up by detailed guidance in a separate document [Development Management DPD or Renewables SPD]; or b) the introduction of separate Policies for commercial scale renewables and micro-renewables – with the former sub-divided to give technology-specific criteria for wind, biomass, hydro, solar etc.

Response

The policy has been amended to address these concerns.

Environment Agency: The EA supports the content of this Policy on reducing the use of non-renewable energy resources, particularly in terms of water efficiency; reducing waste; promoting sustainable forms of drainage; and improving and protecting surface and ground waters.

Response

The support for this policy is noted.

Comments on Policy R2: Renewable Energy Installations

English Heritage: We note and welcome reference to World Heritage Site and protection of Outstanding Universal Value in criterion a. We are however concerned in relation to the latter part of this which states ‘in the case of adverse effect, there is no alternative solution and there are imperative reasons of overriding public interest’ Paragraph 132 states that substantial harm to World Heritage Sites should be wholly exceptional. Paragraph 133 sets out the tests against which this is assessed. This sentence within the policy does not accord with these paragraphs in relation to the harm being wholly exceptional. We consider that this sentence should be deleted.

We note reference to heritage assets in criterion b, however we are concerned in relation to the proposed wording. Specifically we are unsure to what ‘objectives of designation will not be compromised’ means. Significance of heritage assets and their setting should be assessed when considering impacts of proposals. The NPPF is clear in paragraph 132 that great weight should be given to the asset’s conservation and that substantial harm to significance should be exceptional or wholly exceptional. The wording of this criterion does not reflect this and therefore is not compliant with the NPPF. We suggest that this is amended to state: b) the significance of heritage assets, including their setting, is not harmed.

Response

This policy has been changed as suggested.

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The Woodland Trust: Welcome the reference to woodfuel on page 70 as a source of renewable energy and we recognise the need to ensure that this is obtained from sustainably managed sources.

Would like to see more use of wood as a fuel providing that harvesting is carried out sensitively and respects the biodiversity, scale and cultural importance of the site especially ancient woods.

Response

The support for this reference is noted.

Natural England: Natural England generally supports this policy and welcomes the protection that it gives to the World Heritage Site, SSSIs and local landscape character.

Response

The support for this policy is noted.

Comments on Policy E1: Managing Flood Risk

Environment Agency: The EA agrees with the content of this policy on managing flood risk. We would just highlight that SuDS now stands for Sustainable Drainage Systems. The acronym used to be SUDS – Sustainable Urban Drainage Systems but research shows that the methods are equally applicable to rural settings hence changing to SuDS.

Response

The policy and the supporting text have been amended as suggested.

The Woodland Trust: Would like to see the policy and text on managing flood risk include some recognition of the role which trees and woods can play in this if planted in appropriate locations.

The creation of short rotation coppice woodland can lead to a reduction in major and local flood events.

Response

The policy has been amended as suggested.

Comments on Policy E2: Quality and Design of Development

Crime Prevention Design Advisor for Derbyshire Constabulary:

The text of this policy makes a substantial reference to the provision of or contributions towards CCTV security systems, which I think is possibly historical, with the policy first coming into use at the time of the Governments CCTV challenge scheme where town centre systems were required to be match funded by locally sourced finance.

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I wonder whether this lengthy reference is still relevant, and may in fact be counterproductive, in that Policy E2 is looking for better design quality, but the CCTV references are leaning to a more engineered solution to designing out crime.

We would rather see more emphasis to design solutions within E2(H) referencing for example part 1 of the ACPO Secured by Design scheme and Community Safety SPD.

Response

The policy has been amended as suggested.

English Heritage: We welcome reference to heritage assets within the supporting text to this policy, however we are concerned that there is no further reference to these within the policy wording itself. Given the levels of growth proposed and the number and types of designated heritage assets, we consider that lack of such reference is unjustified here. We consider that a further criterion relating to the protection of heritage assets should be made here.

Response

The policy has been amended as suggested.

The Highways Agency: The Agency supports Policy E2, particularly E2 (b), (i) and (m).

Response

The support for this policy is noted.

Sport England: Support paragraph l) that seeks to ensure that there is capacity and availability of infrastructure to serve any new development that is in accordance with the objectives of Policies IN5 and IN6 and would not result in the loss of existing facilities, services or amenities unless provision is made for equivalent or improved provision. Welcome supporting comments accompanying this policy that recognise the important contribution and functions of open spaces. Also endorse recognition that new development can make a positive contribution to the level of open spaces and the connecting links between open spaces.

Support going beyond a ‘standards based’ approach to the provision of open space and exploring opportunities for additional provision where appropriate and making provision for future maintenance. Welcome the requirement to secure off-site open space provision where on-site shown not to be appropriate.

Support evidence based approach e.g. Facilities Planning Modelling Assessment and Playing Pitch Strategy.

Response

The support for this policy is noted.

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The Coal Authority: Given the presence of surface coal resources across the entire eastern half of the Borough, The Coal Authority is pleased to note that criterion (o) of Policy E2 seeks to safeguard mineral resources, to avoid their unnecessary sterilisation by other forms of development.

Given the extensive legacy of past coal mining activity within the Borough, which can result in issues of unstable land, The Coal Authority is pleased to note that criterion (p) of Policy E2 requires development proposals to have regard to site characteristics such as land stability.

It is therefore important that the policy in the Amber Valley Local Plan acknowledges this locally distinctive issue. Criterion (p) of Policy E2 provides an appropriate local policy hook to support the above risk-based approach to ensuring that coal mining legacy issues are, where necessary, addressed.

Response

The support for this policy is noted.

Natural England: Natural England generally supports this policy however we would suggest that the wording should be strengthened in (c) where it says that development should “have regard to distinctive landscape features and nature conservation Interests” it should say “should protect and enhance the“, which would reflect the wording in paragraph 109 of the NPPF.

We also suggest that this policy should make reference to policy IN2 on Green Infrastructure, parks and open space as GI should be integral to the design and quality of development and needs to be considered at the earliest stages of a proposal.

Response

The policy has been amended as suggested.

Comments on Policy E3: Historic Environment

English Heritage: We greatly welcome and support a specific policy on the historic environment, which helps towards the requirements of the NPPF to set out a positive strategy for the conservation and enjoyment of the historic environment (Paragraph 126) as well as having a strategic policy on this topic (Paragraph 156).

We consider, however, that there is scope for improvement to this policy and its supporting text in order to fully comply with NPPF paragraph 126 regarding a positive strategy.

Firstly, whilst the supporting text gives a basic overview of the areas historic environment character, no reference is given to scheduled monuments or registered Historic Parks and Gardens. Whilst we also welcome recognition of non-designated heritage assets, there is little description regarding historic landscape character, rural heritage and industrial heritage. Better demonstration of the plan area’s historic environment, is needed here in order to make the document sound.

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With regard to the policy wording, we welcome the first paragraph which deals with the Derwent Valley Mills World Heritage Site. We note, however, that reference to this here, means that Policy EN29 in the existing Local Plan is not to be taken forward (as stated within the appendix). We do not agree that this reference here as a strategic policy, provides adequate policy protection in development management terms and we would expect the existing Local Plan policy to be saved, as well as further detailed policy guidance to be provided for this area in the forthcoming DPD.

In terms of other heritage assets, we welcome reference to these here. In terms of the ‘strategy’ we welcome reference to the production of a local list, requirement to designate conservation areas and use of Article 4 Directions. However, we also consider that in order to fully comply with paragraph 126 of the NPPF, reference should also be made to other tools such as:

• The production of and use of Conservation Area Appraisals and associated management plans. • Use of the adopted SPD’s. • Encouraging the repair and reuse of heritage assets ‘at risk’ • Undertaking appropriate statutory intervention (for example enforcement action), where necessary.

Response

The policy has been amended as suggested and the existing Local Plan policy has been saved and will be amended as necessary when the Site Allocations and Development Management Policies DPD is produced.

The Woodland Trust: Welcome the inclusion of Historic Parks and Gardens in policy E3. This could be expanded to include reference to ancient and veteran trees.

Response

The policy has been amended as suggested.

Comments on Policy E4: Landscape Character

English Heritage: Within the supporting text, we note reference to the World Heritage Site in the forth paragraph, however we feel that this reference should be improved. Part of the identified Outstanding Universal Vale of the Derwent Valley Mills is its landscape setting and the juxtaposition between the industrial nature of the mills and resultant settlements against the rural landscape backdrop. We consider that reference here should be made more positive in this respect as it is a large factor of the historic landscape character in this area today.

We also consider that reference to other historic landscape character is required, both in the policy and the supporting text. We welcome reference to the AMES study, which does take into account historic landscape character.

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Response

The policy and supporting text have been amended as suggested.

The Woodland Trust: Welcome the reference on page 84 to the importance of woodland as a key element of landscape character.

Response

The support for this policy is noted.

National Trust: National Trust supports Policy E4. It notes that several references are made in the supporting text to the history of the landscape, but that there is no explicit reference to Historic Landscape Character in the Policy itself – such an addition would be appropriate.

Response

The policy has been amended as suggested.

Natural England: Natural England strongly supports this policy and is pleased to note that the Derbyshire Landscape Character Assessment and the National Character Areas have been referenced in the explanatory text.

Response

The support for this policy is noted.

Comments on Policy E5: Special Landscape Area

Natural England: We generally support the approach that this policy takes.

Response

The support for this policy is noted.

Comments on Policy E6: Biodiversity

English Heritage: We welcome reference to the protection of ancient woodlands and veteran trees within this policy.

Response

The support for this policy is noted.

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The Woodland Trust: Welcome your wording in policy E6 which gives strong protection to ancient woodland and ancient/veteran trees.

However, would like to see a stronger assertion of the need for all new development to include areas of natural greenspace including trees and woods as part of green infrastructure.

Ideally we would like to see the council use a standard for provision of natural greenspace and woodland, for example the Woodland Trust's Access to Woodland Standard and/or the Natural England Access to Natural Greenspace Standard.

Response

The policy has been amended as suggested.

Derbyshire Wildlife Trust: 12.6 Biodiversity – We recommend that the term Sites of Importance for Nature Conservation is deleted from paragraph 3 p88 under the above heading as the terms Local Wildlife Site and Local Geological Site are now used in Derbyshire.

With reference to the policy we recommend the terms Local Sites to include Local Wildlife Sites and Local Geological Sites. We recommend the wording is amended slightly to say “…damage must be kept to a minimum and any adverse effects fully mitigated against or compensated for …”.

We would suggest that the condition of Local Wildlife Sites could be used as a monitoring indicator.

Response

The policy and background text have been amended as suggested.

Environment Agency: The EA agrees with the content of this policy on biodiversity but asks that reference is made to the Humber River Basin Management Plan (RBMP) in the justification text. The RBMP implements the Water Framework Directive requirement for river basin planning and sets out the pressures on the water environment, including the impact of land use changes. Local authorities are charged with having regard to the RBMP in exercising their functions.

Response

Reference to this Plan will be made in the background text to this policy before the Core Strategy is submitted.

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Natural England: Natural England generally supports this policy and considers that it provides a strong strategic framework for the protection and enhancement of biodiversity and geodiversity. We would however suggest that it could be further strengthened by the addition of the following points:

In the first sentence of the policy wording we would suggest that it should state that it seeks to achieve net gains for nature to better reflect the advice in paragraphs 9 and 109 of the NPPF.

Reference should be made to the protection of biodiversity at a landscape scale and the importance of ecosystem services. This would better reflect the advice contained in the NPPF.

We note in the last sentence of the fourth paragraph in the explanatory text that English Nature is mentioned. Please could you update this to say Natural England.

We would also suggest that this policy should include safeguards for the long term capability of Best and Most Versatile agricultural Land (BMV - Grades 1, 2 and 3a in the Agricultural Land Classification) and make clear that areas of lower quality agricultural land should be used for development in preference to the BMV land. The plan should recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of BMV land. Avoiding loss of BMV land is the priority as mitigation is rarely possible. Retaining BMV land enhances future options for sustainable food production and helps secure other important ecosystem services.

Response

The policy and background text have been amended as suggested.

Comments on where you think a ‘Local Green Space’ should be allocated

Natural England: Natural England supports this paragraph that encourages Local Green Space designation. We believe that everyone should have access to good quality natural greenspace near to where they live. We particularly consider that there should be increased opportunities for natural and semi-natural greenspace. The provision of accessible semi- natural greenspace within green infrastructure in and around urban areas significantly contributes to creating places where people want to live and work. Its provision is therefore vital to sustainable development and communities.

Response

These comments are noted.

Comments on Policy IN1: Transport

The Highways Agency: The Agency broadly supports this policy. However, the Agency considered that the policy should refer to the key transport infrastructure projects required to support the totality of growth proposed in the Borough. This should include reference to a significant upgrade to the A38 Coxbench junction or provision of a new A38 junction to serve the site at Denby. Alternatively, such as statement should be included in Policy IN4: Strategic Transport Infrastructure Priorities.

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Response

Policy SG3 has been amended as suggested.

Comments on Policy IN2: Green Infrastructure, Parks and Open Space

English Heritage: We welcome reference to the protection and enhancement of heritage assets within this policy. Green infrastructure, parks and open space can include heritage assets (such as parks, cemeteries, etc) or contribute to the setting of heritage assets. With regard to the policy stating that exceptions may be made if the park or open space is “underused or undervalued” it is important to recognise the potential historic qualities of specific parks or open spaces, which may be underused or undervalued but still merit retention due to their historic significance.

Response

This reference has been removed from the policy.

National Trust: The Policy is welcomed and supported as a key element in the Borough’s approach to achieving sustainable development.

Response

The support for this policy is noted.

Sport England: Welcome the recognition of playing fields as a key component of Green Infrastructure, and the social, economic and environmental benefits of green infrastructure within the supporting text.

Support a strategic approach being taken to the delivery, protection and enhancement of Green Infrastructure and would emphasise the importance of preparing and drawing upon a robust and up to date evidence base to inform this strategic approach, including the cited sources.

The requirements within Policy IN2 are welcomed with regard to the protection and enhancement of Green Infrastructure assets (which would include sports facilities), presumption against schemes that would have an adverse impact on green infrastructure, and the requirement for development to enhance Green Infrastructure (on-site or off-site). Have concerns about the wording or paragraph b) in terms of weighing up the need for the development against the harm caused. This would not be consistent with paragraph 74 of the NPPF and should be replaced with clear criteria that would accord with paragraph 74. Broadly endorse the principle of prioritising new / enhanced infrastructure in areas of growth i.e. new residential development, although would emphasise the need to draw on appropriate evidence such as the Playing Pitch Strategy to inform decisions on the spatial distribution of provision. Also support ‘physical activity and well-being opportunities for local residents’ such as formal sports provision being included as one of the key aims of Green Infrastructure, although have some reservation about requiring multi-functional benefits being required in all cases where green infrastructure is provided because although this will usually be

118 appropriate there may be circumstances where this would not represent the optimum solution. Have concerns about exceptions being made to the above if a park or open space is shown to be underused or undervalued. Whilst the policy requires alternative scheme designs to be considered before mitigation, and requires the reasons for parks and open spaces being undervalued to be explored and where possible addressed prior to alternative schemes being permitted, it still provides the scope for open space, including sports facilities, to be lost to development without a case being made as required by NPPF paragraph 74. Instead of having an exception based on a notional idea of a space being underused or undervalued, it is recommended that clear criteria consistent with NPPF paragraph 74 are included within the policy, and that it is made expressly clear that sports provision/playing fields are covered by the policy protection.

Response

The policy has been amended to address the concerns expressed.

Natural England: Natural England strongly supports this policy and considers that it provides a strong framework to deliver the protection and enhancement of green infrastructure throughout the Borough. We would suggest that it would be useful if the Core Strategy included a concept plan of the Green Infrastructure Network to illustrate the linkages between the larger areas of accessible public and other open space and area of biodiversity value across the Borough.

Natural England would welcome recognition of the need for partnership working to deliver green infrastructure. Delivering GI will require local communities, organisations, landowners and developers to work towards agreed aims.

Response

The policy has been amended as suggested, and a key diagram has been included in the Core Strategy highlighting footpath/cycle routes.

Comments on Policy IN3: Community, Leisure and Health Facilities

The Theatre’s Trust: While Policy IN3 will protect existing community, leisure and health facilities, there is an inconsistency with SO9 as the word ‘cultural’ is not included either in the title or in the policy text. For continuity and consistency we suggest the word ‘cultural’ is included in the title as the word ’health’ does not appear in either SO 6 or 9.

The function of community facilities is to provide services and access to venues for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community. We therefore strongly suggest for clarity and so that guidelines are clear and consistent, that a description of the term ’community facilities’ be added to section 13.3 which would obviate the need to provide exclusive examples - community facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community.

Response

The title and content of the policy have been amended as suggested.

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Sport England: Support protection of existing facilities (that would include sports facilities), although would recommend tighter wording of first paragraph to make clear how need would be assessed and what would be a 'suitable' alternative (this would need to be something equivalent and or better in terms of both quality and quantity, and also in terms of accessibility, in line with NPPF paragraph 74). Also welcome positive approach to new facilities in the second paragraph, but would recommend adding clear criterion in relation to the strategic / local need for the facilities as informed by Infrastructure Delivery Plan and robust evidence base, rather than using the term ‘where appropriate’. Support going beyond the current SPD and ‘standards based approach’ using up to date evidence e.g. Facilities Planning Modelling Assessment, Playing Pitch Strategy.

Response

The policy has been amended as suggested.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Derbyshire Campaign to Protect Rural England: Amber Valley’s commitment to the A610 Bypass, reiterated throughout the Core Strategy, pre-empts transport assessments for the development for 600 and 560 dwellings respectively at Alfreton Road, Codnor, and Nottingham Road, Ripley. The process is back to front. Policies SG2 and SG7 directly conflict with Policy IN1 e) because providing a new road to serve substantial housing development will encourage more rather than less car use.

Amber Valley claim that the A610 Bypass will relive road traffic congestion by proving a new road link between the A6/A38 and the M1. This would be a first – a new link road which is hardly used by road traffic and therefore does not generate additional road traffic and congestion. There is ample evidence now that bypasses at most displace traffic and usually create more, and within a few years of opening. The Newbury Bypass is a case in point – traffic levels were back to before the Bypass within 5 years of opening. In fact, the extract in the Infrastructure Delivery Plan from such transport assessments as have been carried out expresses concern about the “severe” congestion expected to be generated by the A610 Bypass.

The Core Strategy is vague on sources of funding. While it is appreciated that detailed negotiation may need to be conducted once the Core Strategy has been agreed, the funding strategy is so vague at this stage that it constitutes real risks not only to delivery of the Core Strategy as Amber Valley envisage it but also potentially to services provided by Amber Valley. The Infrastructure Delivery Plan lists the costs of the Bypass as “unknown” and sources of funding as developer contributions and a range of others.

Without clarity about either total cost or sources of funding, there is a real risk that Amber Valley (or potentially Derbyshire County Council) will have to underwrite finance – with the negative implications this is likely to have on other services the Local Authorities would otherwise be able to provide.

Response

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A transport assessment has been submitted as part of the background evidence for a planning application that has now been submitted for this scheme which is being considered. The Infrastructure Delivery Plan refers to existing and potential future congestion, but not congestion being created by the proposed A610 link road between Ripley and Woodlinkin. One of the main reasons for implementing this scheme is to reduce congestion. A funding package for the scheme is being finalised.

English Heritage: We note the policy in relation to the A610 link road between Ripley and Codnor. The significance and setting of a large number of heritage assets may be affected by the bypass. We consider that criteria should be cited within this policy in order to provide guidance on issues which will need to be considered. We consider that the road will need to take into account impacts upon heritage assets and their setting here and reference should be made to this, within this policy.

Response

The policy has been amended, as suggested.

Derbyshire Wildlife Trust: We note that the proposed route of the A610 link road passes through part of a Local Wildlife Site. This has not been identified by the Sustainability Appraisal. Any adverse impacts on this site should initially be avoided or minimised, but where impacts remain there will need to be adequate mitigation and/or compensation. At this stage we are not aware of any ecological studies looking at potential impacts along the entire route and clearly these impacts need to be better understood.

Response

The policy has been amended, as suggested.

Comments on Policy IN5: Infrastructure Delivery

English Heritage: We note the infrastructure proposals within the Infrastructure Delivery Plan – consideration should also be given to the protection and enhancement of heritage assets under this.

The Highways Agency: The Agency supports this policy, which sets out the Council’s approach to ensuring a coordinated approach to delivery appropriate infrastructure in a timely manner.

National Trust: Infrastructure delivery should specifically include, in the Policy or more overtly in the supporting text, key environmental resources – especially bio-diversity and heritage resources.

Sport England: Support evidence based approach to infrastructure delivery. The Draft Infrastructure Delivery Plan will need to be updated based on up to date and emerging evidence including Playing Pitch Strategy and Facilities Planning Modelling Assessment. Up to date evidence and assessment of needs and opportunities, including those for sport need to feed into the Infrastructure Delivery Plan in the form of firm proposals, in accordance with

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NPPF paragraph 73. This may also require allocation of specific sites in order secure the delivery of the infrastructure where it is needed.

Response

These comments are noted and the policy, background text and the Infrastructure Delivery Plan have been amended, as suggested.

Comments on Policy IN6: Developers Contributions

English Heritage: Consideration should also be given to the protection and enhancement of heritage assets through such means – particularly where new development has an impact on historic environment considerations.

Response

Policy 1N5 has been amended to refer to developers contributions being required to protect and enhance heritage assets, where relevant.

The Woodland Trust: Would like to see a portion of developer funding used for green infrastructure, including woodland creation.

Derbyshire Wildlife Trust: We support this policy.

Response

These comments are noted.

National Trust: Potential developer contributions should specifically include, in the policy or more overtly in the supporting text, key environmental resources – especially biodiversity and heritage resources.

Response

Policy 1N5 has been amended to refer to biodiversity and heritage resources.

Sport England: Welcome a policy requiring developer contributions as set out. A broader evidence base providing greater detail beyond that within the Infrastructure Delivery Plan should be cited and used to underpin this including Playing Pitch Strategy and Facilities Planning Modelling Assessment.

Response

These comments are noted.

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2.7 Summary of comments from local groups

Comments on the Spatial Portrait of Amber Valley

Swanwick Residents Association: Question how many former industrial sites have been redeveloped for housing. Trust the balance to be struck between encouraging new development and protecting the environment will be strictly and strongly adhered to.

Response

These comments are noted.

Comments on the Spatial Vision

Belper Civic Forum: Belper Civic Forum believes that the final sentence of this section needs strengthening. The previous page talks of the need to support vibrancy of the local towns and their distinctiveness, and this paragraph ends on 'as many sectors of the local population as possible will have access to local facilities without having to use the car'.

In that case, the Council's Vision should also make explicit reference to ensuring developments such as housing and industry, as well as leisure, are based around minimising car journeys and supporting local economies, rather than providing high speed routes to large cities. This needs to be in complete conformity with Policy IN1.

Response

The Spatial Vision has been amended as suggested.

Swanwick Residents Association: Opening paragraph is too optimistic and needs to be tempered. The emphasis is being on more use of public transport, cycling routes and walking, but we do not see this happening in any great measure. Apart from the proposed A610 link road we see no plans to improve/change the current road networks in and around the market towns.

Response

It is considered that these aspirations should not be tempered.

Comments on the Strategic Objectives

Belper Civic Forum: Objective 11 needs strengthening to read, in addition, 'There will be a strong presumption against developments which run counter to this.'

Response

It is not considered necessary to amend this objective.

Swanwick Residents Association: Objectives 10 and 11 only refers to the A610 link road in terms of providing supporting improvements to the local transport network.

Response

This comment is noted.

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Derbyshire and Peak District Campaign for Better Transport: The thirteen strategic objectives listed on page 7 of the Draft Core Strategy are all very general with the exception of number 10, which states “To provide and support improvements to the local transport network, including a new A610 link road between Ripley and Codnor”. We do not think that a specific project can be a strategic objective. Returning to the Core Strategy’s strategic objectives, we consider that number 10 is, as written, incompatible with objectives 11 and 12: “To provide infrastructure that creates opportunities for non-motorised transport, increase public transport accessibility and mitigates against the creation of severe traffic congestion.” and “To aim to ensure that local services, facilities and employment opportunities in the Borough are accessible by as many sectors of the population as possible”.

Response

It is considered that the implementation of the A610 link road is a strategic objective and it is not incompatible with the other objectives.

Comments on the Spatial Strategy

Belper Civic Forum: The Civic Forum is interested that the Council is committing to a 'Garden City' approach to larger village type built-up development, and would like to see a reference in paragraph 6.6 to 'ensuring that housing developers respect the character of the local landscape, where possible preserving existing natural features and ensuring lower density development, providing generous green open space in any developments of over 25 houses'.

Response

These matters are covered elsewhere in the Core Strategy and it is unclear why these requirements should only apply to developments of over 25 houses.

Comments on Policy SS1: Housing Land Requirements and Distribution

Transition Belper:

In the context of Belper, this suggests new housing could be extensive and take place anywhere. In reality, this is not what is meant (see Appendix B and elsewhere in the Local Plan). Since this is important preamble for Policy SS1, We would like more care with the wording to avoid ambiguity/confusion.

Response

It is not considered that any changes are required to the background text.

Comments on Policy SS2: Business and Industrial Land Requirements

Belper Civic Forum: No sites have been identified in the plan. The Civic Forum would like to see specific reference to encouragement of use of sites in Belper like the Bullsmoor and ER1C mixed-use site.

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Response

The Core Strategy has only identified sites at a strategic scale. These sites will be considered for allocation when the Site Allocations and Development Management Policies DPD is produced.

Transition Belper: In this section it mentions de-allocating existing allocations and replacing with new allocations of higher quality. What is meant by higher quality?

Response

Sites that have good access to the strategic road network.

Derbyshire and Peak District Campaign for Better Transport: We do not believe that any land identified for employment development can be classified as a sustainable location if it requires a new road through the Green Belt.

Response

The justification for the proposed new A610 link road is not just to provide good quality employment land.

Comments on Policy SS3: The Role of Settlements

Transition Belper:

The word “appropriate” is too vague and open to many interpretations.

Regarding retail – we are concerned by the vagueness of the term “larger-format units”. These units need to be in keeping with the heritage of Belper and the fact that Belper is successful because of its many outstanding independent shops. Is it possible to limit the scale of these units e.g. per sq. metre and height within the local plan.

Although one aim of the Core Strategy is to “extend and improve the quality of the retail offer and provide a wider retail offer to ensure that spending takes place within the Borough” it needs to be clear in Policy SS3 that this will enhance, not conflict with the current retail on offer.

Response

It is not considered that aims of policy SS3 will conflict with the current retail offer.

Comments on Policy SS5: Town Centre Regeneration in Belper

Belper Civic Forum: Change wording of 6.11 Belper, last sentence to read ‘To continue its economic success, the Council will commission a Masterplan to ensure a co-ordinated approach’. Reword Policy SS5 so that 'To continue its economic success, the Council will consider if a Masterplan needs to be produced' to read 'To continue its economic success, the council will commission a Masterplan'.

Response

The Council has not yet decided if a Masterplan should be produced for Belper.

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Transition Belper:

We believe the council should proceed with the commissioning of a Masterplan for Belper.

One critical aspect of any Belper economic development is the A6/Bridge Street problem running through the centre of the town and needs to be addressed.

Response

The Council has not yet decided if a Masterplan should be produced for Belper.

Comments on Policy SS6: Town Centre Regeneration in Heanor

Heanor Regeneration Board

The Board are glad that a policy giving weight to the Heanor Masterplan was being put in.

Response

This comment is noted.

Comments on Policy SS8: Development in Town Centres

Heanor Regeneration Board

Feel that the proposed town centre boundary should be extended to cover the whole of the college site. It is an important development site within Heanor and the development on that site should be town centre orientated. By putting it in the town the plan would be encouraging town centre uses on the site.

Response

It is not considered that changing to town centre boundary to include the college site is necessary.

Comments on Policy SS9: Primary Shopping Frontages

Heanor Regeneration Board:

The Board felt that Ray Street should also be included in the Primary Shopping Frontage policy. This is because Ray Street has a lot of A1 uses that should be protected. This would then concentrate no A1 uses around Red Lion Square which would support the aims of the masterplan.

Response

This change would discourage non retail uses from becoming established in the town centre.

Transition Belper:

The drawing shows extension on western side of Strutt Street, not eastern side. Is the text incorrect?.

Response

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The text has been corrected.

Comments on Policy SS11: Amendments to the Green Belt

Belper Civic Forum: The Civic Forum would like to see the replacement of any Green Belt land lost to development, and is pleased that the Council is recognising the importance of 'using natural features such as streams and other barriers’.

Response

This comment is noted.

Stop 500: Site SG2 is in the Green Belt and enjoys very significant protection from inappropriate development, as re-established in National Planning Policy Framework (NPPF). Paragraph 84 does not present a carte-blanche for removing green belt designation to conveniently afford housing land provision.

In this overall strategic context and function of Green Belts, paragraph 87 of NPPF reiterates the well-established policy priority for inappropriate development to be permitted in the green belt only where there are very special circumstances. Moreover, should the release of green belt land be demonstrated as being essential to accommodate necessary growth across the Borough, the location and extent of such release(s) should be informed by transparent and systematic study of the functionality, amenity, heritage and environmental (landscape, biodiversity, ecosystems services) value of all existing Green Belt area, and not be solely pre-determined by the desire to expedite other council objectives where this is ‘convenient’ for the Council. As part of Local Plan evidence base, comprehensive and focused Green Belt Reviews (such as West Lancashire Council’s) have been carried out by many LPAs across the UK in considering the need for Green Belt releases or alteration. These then can be used to properly inform policy decisions, be open to public scrutiny and aid transparency. No such study appears to have been undertaken in identifying SG2 as a valid Green Belt release. This significant element of the plan’s spatial strategy is therefore not supported by robust evidence, and therefore likely to be found unsound at Examination.

To the council this may appear to be a win-win situation, but it is essentially flawed and must be rejected as an unsustainable form of development, as well as wholly against community opinion.

Even if need were established in part for congestion relief measures, the provision of such significant and expensive infrastructure would appear unreasoned and disproportionate to the degree of any problems arising from such congestion. Examination of alternative, more proportionate and significantly cheaper traffic management options do not appear to have been afforded proper consideration.

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Signage strategies, public transport enhancement, and localised highway improvements to the existing line of the A610 appear not to have been considered or investigated, and instead the most expensive and environmentally damaging option appears to have been prioritised from the outset.

The council’s flimsy justification for inappropriate development in the green belt is further undermined when consideration is given to the promotion that the by-pass would then present a valuable ‘defensible’ boundary to the Green Belt. It may present an obvious boundary should it be delivered, but on its own does not help justify development in the green belt and removal of the land from it as proposed by SS11. The presenting of a new defensible boundary as a benefit is misleading and disingenuous.

The Council has operated Green Belt policy using the existing boundary defined by properties along the Alfreton and Nottingham Roads for many years, without it seems undue difficulty, as is the case for the great majority of the Green Belt boundary across Amber Valley. The creation of a new easily defined boundary is not required for existing and future Green Belt policy to be properly applied and therefore no public benefit should be afforded to the achievement of such through delivery of the road.

Derbyshire and Peak District Campaign for Better Transport: We find it hard to see how an “east-west link between the A6/A38 and the M1” can count as local transport infrastructure. The road is already a “Primary Route”. If it is designed to enable new housing development, then it will not preserve the openness of the Green Belt. The main purpose of a Green Belt is to limit development within it. Despite the scheme being a “longstanding commitment”, the Council has not suggested a need to modify the Green Belt boundary in the past.

Response

There is a longstanding commitment by both the Borough and Derbyshire County Council to securing the completion of a new A610 link road between Ripley and Woodlinkin. The provision of this new link road will not only relieve traffic congestion on the current A610 route, but will also improve the east-west link between the A6/A38 and the M1 through the Borough, enabling the provision of new housing development and the development of high quality employment land, which will help to improve the local economy. The Council does consider that this represents exceptional circumstances for development in the Green Belt.

Comments on Policy SS12: Countryside

Transition Belper: Compensation for loss of green space must be within the immediate community.

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Response

This comment is noted.

Comments on Policy SG2: Alfreton Road, Codnor

Stop 500: This is the formal response to the consultation by Amber Valley Borough Council's draft Local Plan (part 1) by Stop 500. It has been prepared by Graham Bradford MRTPI, Director of the Planning and Environment Studio Ltd, in consultation and on behalf of the signatories of Stop 500.

Stop 500 is a Codnor-based community group formed by local residents. It has come together to strongly object in a co-ordinated and representative way to the emerging proposals of AVBC to allocate land east of the village for housing and mixed-uses and to deliver a new A610 relief road in its Local Plan. Many of the supporters of Stop 500 have individually expressed their strong objections to the emerging proposals over previous consultations in relation to the new plan since 2008, and will continue to do so should the proposals remain largely unaltered through the plan process.

In this respect Stop 500 is immediately concerned that the council is seeking to artificially and deliberately circumvent part of the purpose of this consultation, under Regulation 18 Town and Country Planning (Local Planning) (England) Regulations 2012. In short paragraphs (1) and (2) of the Regulation require plan making authorities to invite (amongst others) local residents to make representations about what a local plan 'ought to contain'. Very importantly, paragraph 3 of Regulation 18 states ...

'(3) In preparing the local plan, the local planning authority must take into account any representations made to them in response to invitations under paragraph (1) '.

In this context it is of very considerable concern to Stop 500 that the invitation to comment upon the draft plan presented on the Council's website is caveated by the statement –

'Please note that if you have already commented on the principle of developing the proposed strategic housing sites it is not necessary to repeat these comments, as they have already been recorded and taken into consideration.' (our emphasis).

Not only does this potentially fall foul of the legal requirements of Regulation 18, it clearly reinforces the view that the decision to take forward the strategic sites set out in the draft plan has been decided, that the very many and well considered objections prepared to previous non-statutory consultation have been dismissed, and that no opportunity to reconsider in light of future evidence will be taken! It is difficult to see how else can this statement be interpreted? It effectively says do not comment upon the strategic sites selection .... you may have objected but we want to avoid the inconvenience and discomfort of having to consider this any further. Unfortunately for the council, this is not an approach which carries any weight. It is Stop 500's right to maintain, enlarge upon and underline its strong objection to the proposals east of Codnor in this and future plan iterations and stages. It will do so, and this representation maps out our key and wholly valid concerns.

Stop 500 objects to the spatial strategy set out within the plan and specifically to the following draft policy elements of the consultation draft plan:

• Policy SG2: Alfreton Road Codnor • Policy 5511: Amendments to the Green Belt • Policy IN4: Strategic Transport Infrastructure Priorities

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Furthermore, Stop 500 objects to the process, findings and influence of the Sustainability Appraisal - prepared in great haste at this well-advanced stage of strategy and plan development.

In doing so it rejects the process of identification of this site as a reasonable and sustainable alternative option for strategic housing provision, absence of very special circumstances to justify green belt removal and a lack of transparency in relation to supporting evidence relied upon to drive the strategy.

Stop 500 consider the identification of this site to be based primarily on the council's opportunistic (and fanciful) approach to securing the road proposals through releasing a significant tract of green belt to development. In addition, Stop 500 considers that past engagement in the process has not been afforded due weight and suggests disregard of very considerable public opposition to the proposals at Alfreton Road. Such intransigence by the council in light of such community concern suggests that political support for the relief road and an engineered opportunity for development to deliver that road has resulted in a situation where there is real danger the preferred plan will support the proposals at Cod nor as a fait accompli.

Because of the intrinsic links between the 3 policies noted above, this consultation response has been prepared as a single objection statement, although each of these policies are objected to individually by Stop 500.

Strategic Site SG2: Alfreton Road, Codnor Stop 500's Case Against the Allocation

Stop 500 objects in the strongest possible terms to the inclusion within the draft plan of the strategic housing allocation for 600 dwellings across land east of Alfreton Road, Codnor, presently within the Derby and Nottingham Green Belt. In doing so, Stop 500 specifically objects to policies SG2, SS11 and IN4. Whilst SG2 refers to housing development only, other elements of the draft plan, notably in supporting text to SS11 and IN4 suggests that the site would deliver housing and 'high quality employment land', and in doing so immediately presents inconsistency and lack of clarity in the draft plan.

The Site General Characteristics and Community Value

The site is identified at SG2 as a strategic site for the delivery of around 600 houses. This area of countryside frames the eastern fringe of Codnor (defined by properties along Alfreton Road and along Nottingham Road (A610) and presents a clear and established delineation between the settlement and the open countryside across the site and beyond. The site is an extensive area overlying an attractive shallow valley of small fields and pasture with an open watercourse, mature hedgerows with hedgerow trees which form a strong landscape pattern and ecological network which adds to landscape and biodiversity value. The site is criss- crossed by at least 5 public rights of way and as such presents accessible, attractive and well used amenity value to the community, especially in relation to accessing Codnor Castle. It forms a significant element of the wider setting of Codnor Castle, a Scheduled Monument and Grade II Listed Building.

All such environmental, heritage and amenity qualities suggest the area is of considerable overall value and sensitivity in its own right, even before green belt status and functionality is considered. It is particularly significant to note the glaring inconsistency within the draft plan between the mostly commendable suite of draft environmental, green infrastructure and heritage specific policies, such as E3, E4, E6 and IN2, and the inevitable consequences of

130 delivering the by-pass and developing SG2 which will decimate those established valued characteristics and functions. It would seem that the council will seek to promote responsible environmental stewardship and protection, but only where it suits it to do so.

Green Belt

As part of the Derby and Nottingham Green Belt the site enjoys very significant protection from inappropriate development, as re-established in National Planning Policy Framework (NPPF). This is unequivocal. NPPF states:

79. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

80. Green Belt serves five purposes:

• to check the unrestricted sprawl of large built-up areas; • to prevent neighbouring towns merging into one another; • to assist in safeguarding the countryside from encroachment; • to preserve the setting and special character of historic towns; and • to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

81. Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Clearly, by proposing the strategic allocation at SG2, the unpinning principles of Green Belt policy, re-established as recently as 2012, have been given wholly insufficient regard by the Council. The role of the Green Belt to the east of Alfreton Road remains valid and significantly contributes to the achievement of the first, third and fifth functions set out in paragraph 80 of NPPF. These roles remain as valid today as when the Green Belt was originally established, if not more so. Paragraph 84 of NPPF recognises the need to consider the implications for sustainable patterns of development in reviewing Green Belt boundaries. In the context of Amber Valley, it must surely hold that the benefits of urban renewal remains a high priority across the borough, and that the intended function of the green belt in this respect continue to encourage robust and effective use of brownfield sites in preference to Green Belt loss. Paragraph 84 does not present a carte blanche for removing green belt designation to conveniently afford housing land provision.

The proposed convoluted justification for alteration of the Green Belt here (examined below) is confused and based upon absent or flimsy evidence and clearly fails to meet the government's primary objectives for Green Belts, that of openness and permanence. Stop 500 strongly contends that the proposals for the development of the site run counter to national policy and that aspirations of NPPF paragraph 81 should guide development plan policy, contrary to the draft plan's proposals.

131 pre-determined by the desire to expedite other council objectives where this is 'convenient' for the Council - as is patently the case in this instance. As part of Local Plan evidence base, comprehensive and focused Green Belt Reviews (such as West Lancashire Council's) have been carried out by many LPAs across the UK in considering the need for Green Belt releases or alteration. These then can be used to properly inform policy decisions, be open to public scrutiny and aid transparency. No such study appears to have been undertaken in identifying SG2 as a valid Green Belt release. This significant element of the plan's spatial strategy is therefore not supported by robust evidence, and therefore likely to be found unsound at Examination.

Absence of 'Very Special Circumstances' for a by-pass in the Green Belt

The Council's case for there being 'very special circumstances', and hence justifying the site coming forward as a priority strategic allocation is flawed and confused. It is essential to recognise that paragraph 88 of NPPF states that:

'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.'

Stop 500 considers the justification for the release of the site from the green belt is not properly evidenced, and even if it were, these would not outweigh the overall public benefit and value of protecting the site from development. Hence the provisions of NPPF 88 are not met.

Stop 500 considers that the justification for a relief road is being pursued, despite inadequate evidence of need or proportionality to perceived congestion problems, primarily so that a release of green belt can be justified and in doing so secure contributions which will fund a significant cost of the proposed road and help meet housing targets. To the council this may appear to be a win-win situation, but it is essentially flawed and must be rejected as an unsustainable form of development, as well as wholly against community opinion.

Stop 500 believes that the proposals for SG2 are now driven by the engineered opportunity to secure road infrastructure funding from developer contributions, rather than as a transparent process of evidence based appropriate and sustainable spatial planning practice for the settlement and community of Codnor. In doing so, integrated plan elements (policies SG2, SS11 and IN4) have been developed to be mutually supportive when in fact evidence is not available to meet Government policy for green belt release as proposed, nor to demonstrate any robust need for the relief road itself. Even if need were established in part for congestion relief measures, the provision of such significant and expensive infrastructure would appear unreasoned and disproportionate to the degree of any problems arising from such congestion. Examination of alternative, more proportionate and significantly cheaper traffic management options do not appear to have been afforded proper consideration. Stop 500 does not consider that a Codnor by-pass (for a 'bypass' is what it is) would or should be the only solution to address perceived congestion problems in the area. Signage strategies, public transport enhancement, and localised highway improvements to the existing line of the A610 appear not to have been considered or investigated, and instead the most expensive and environmentally damaging option appears to have been prioritised from the outset.

It is acknowledged that there is a protected line for a relief road within the 2006 Local Plan (Policy TP13) which is based upon a 'longstanding commitment to securing the completion of highway improvements along the A610 between Ripley and Langley Mill, including a by- pass for Codnor'. However it is most telling that the significance of any inferred (but not evidenced) suggested need, and the ability to secure the necessary funding, have clearly not

132 become any more pressing over the previous plan periods. The draft plan today sets out in parts a similar vague indication of 'desire' for the relief road rather than any significant evidence, convincing transport modelling or community engagement feedback to suggest that the draft policy response is proportionate or justified. Vague plan commitments, past infrastructure philosophies (supporting by-passes) or political preference for a relief road at Codnor cannot be maintained over such a significant passage of time without robust evidence and review, yet the best the draft plan can suggest at this stage (following significant earlier 'informal' consultations proposing the road and site) is reference to a 'longstanding commitment'. This is simply not a good enough basis on which to justify a major infrastructure and strategic housing allocation within the green belt.

There would appear to be a significant difference in interpretation between Amber Valley Borough Council and Derbyshire County Council as Highways Authority in relation to the need and priority afforded to the link road. Derbyshire's Local Transport Plan 3 2011-2026 (L TP3) identifies a nonspecific scheme at Codnor as being a 'long-term project with 'potential for appraisal in association with land use plans'. It does not identify the scheme as being sponsored by the Highways Authority. This very limited status within LTP3 clearly does not afford any significant priority to the scheme, does not recognise congestion along the A610 as a particularly pressing matter and further demonstrates that the case for the road remains a product of long-term plan inertia rather than evidenced need. Clearly the priority afforded the road proposals does not begin to justify a significant funding priority for the Highways Authority. The presence of the proposals would appear to be included within LTP on the grounds that the Borough Council is so strongly promoting the scheme, and not that the Highways Authority recognised need or priority.

It must be seen as pertinent that this scheme has been muted through various proposals and iterations of development plans for around 40 years! Patently, the need, desire and/or funding to deliver this infrastructure has not gained any significant further support or momentum. Indeed the Inspector's report to the 2006 Local Plan recommended that the road alignment be removed from the emerging plan and specifically referred to the Council's 'wishful, if not entirely unrealistic desire given the plan period to secure the provision of a Codnor bypass'.

Examination of the need for the road, justification for it being the most sustainable, economic and proportional solution to any problems identified, and hence it being seen as a 'not inappropriate' in the green belt as 'local transport infrastructure which can demonstrate a requirement for Green Belt location', (paragraph 90 of NPPF) and reasonable likelihood of its viability such as to secure delivery within the plan period are critical to the plan's overall spatial strategy and justification of SG2. Stop 500 strongly believes these tests are not met. The need for the road is no more established than ever before. The evidence-base referred to within the plan for policies SG2 and IN4 notes that traffic modelling is currently 'underway'. How then can such a significant and hugely emotive proposal be brought forward to this stage of the plan (and indeed have been so prominent in preceding documents) when the council has no independently verified evidence that the road is categorically essential to the sustainable development of the Borough? This clearly must demonstrate how the political priorities of the Council are serving to take priority over transparent, inclusive and sustainable land use planning within this part of the Borough. L TP3 itself emphasises how transport planning now prioritises shifts away from road building to sustainable transport solutions and modal choice. Notwithstanding the probable significantly detrimental effect a by-pass would have on day-to-day trade within Codnor's existing retail and services sector, the proposal would increase the convenience of car based movements for retail, employment and leisure activities, flying in the face of sustainable development principles and a sustainable spatial planning approach.

Green Belt Boundary 'Defensibility'

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The council's flimsy justification for inappropriate development in the green belt is further undermined when consideration is given to the promotion that the by-pass would then present a valuable 'defensible' boundary to the Green Belt. It may present an obvious boundary should it be delivered, but on its own does not help justify development in the green belt and removal of the land from it as proposed by SS 11. The presenting of a new defensible boundary as a benefit is misleading and disingenuous. The council has operated Green Belt policy using the existing boundary defined by properties along the Alfreton and Nottingham Roads for many years, without it seems undue difficulty, as is the case for the great majority of the Green Belt boundary across Amber Valley. The creation of a new easily defined boundary is not required for existing and future Green Belt policy to be properly applied and therefore no public benefit should be afforded to the achievement of such through delivery of the road.

Viability and Deliverability

In addition to the serious shortcomings in justification for the approach so favourably presented for SG2, IN4 and SS11, there would appear to be a huge assumption that the delivery of development within SG2 will serve to secure sufficient funding for the by-pass. No significant evidence as to whether this will be viable or not is offered. Even without detailed examination of the level of developer contributions to be secured per property permitted within SG2, it would appear that the costs associated with the new road provision must surely be so significant that delivery of it would be dependent on significant public investment, for which there is no priority in LPT3. With such significant local opposition to this proposal, is it reasonable that council tax should be used to deliver the by-pass, as suggested at IN4?

Moreover, policy within the emerging plan clarifies that developer contributions will be expected for delivery of a range of other significant social, community, transport and environmental provisions. Policy SG2 recognises the need for such provision within the site, whilst IN6 clarifies developer contributions will be necessary to contribute to costs of infrastructure proportionate to the scale of development. The scale of development expected within the site - having regard to the road's delivery, suggests this will render the housing development unviable without significant reduction in overall developer contribution. Policy H4 recognises that viability implications of 1 06 agreements in relation to housing demands a more flexible approach by the council subject to independent viability surveys.

Taken together, these matters would suggest that the viability of the road is seriously in doubt. The very real and predictable outcome in this regard is that planning permission for the development of SG2 and IN4 would be granted but that developer contribution will not be secured to the degree anticipated by the council in the draft plan. Consequently housing delivery will be stalled unless the council relaxes negotiated sums, or pressure mounts on the council for the development of SG2 to go ahead without the by-pass. This scenario would of course totally undermine the core approach of the council in relation to the site and proposed road.

Stop 500 therefore believes that there is a very real likelihood that the combined proposals are not deliverable within the plan period, and therefore would fail to be found sound at Examination. For this reason alone, the combined policies SG2, SS11 and IN4 should be deleted from the draft plan.

Stop 500 therefore challenges the council to present the robust evidence which categorically demonstrates the need and justifies the exceptionally significant costs (financial, environmental and community) for the scale of infrastructure provision that the local plan is

134 proposing. In doing so it must also demonstrate that the resultant destruction of the longstanding functional effectiveness of the Green Belt (contrary to national policy), and the not insignificant landscape, biodiversity, heritage and amenity value of the site is justified by the Council's anticipated benefits of the proposed road. Stop 500 does not believe the cost benefit analysis of this proposal is likely to stand close scrutiny. Had an impartial cost-benefit analysis study been conducted which demonstrated it was, the proposals for the road would have been implemented years ago. The case for the need and viability for delivering the road is at very best, weak.

Stop 500 considers that the primary justification for the allocation is driven by the council's stated commitment to the delivery of an A610 relief road between Woodlinkin, Codnor and Ripley, but supporting text to IN4 suggests that the delivery of the road is also being justified through allowing for the:

'provision of new housing development and the development of high quality employment land, which will help to improve the local economy.'

Hence there appears to be a 'cake and eat it' situation in relation to the council's promotion of the road. The justification of the infrastructure provision, i.e. 'long-standing commitment is promoted contrary to local opinion on the degree of severity of congestion at peak times. This statement - and hence the policy, is wholly un-supported by up-to-date and robust evidence including evidence that the local economy is in need of improvement. There is no evidence of significant vacancy within the industrial estate, nor of vacant shop units in Codnor (although that would be sure to change with the construction of the by-pass).

The Derby Housing Market Area study recognised that there is an over-supply of employment Land in Amber Valley, suggesting further allocations are of very limited value and should not be used as justification for environmentally constrained sites, such as those within the Green Belt. Evidence from many other studies suggests that by-passes of smaller settlements are likely to have negative implications on the village's economic well-being. This would surely apply to Codnor's local commerce and services community. The council have offered no evidence to suggest otherwise. Again the plan seems to adopt an unsupported case to justify the construction of the road and associated Green Belt release.

Stop 500 believes that the council is seeking to engineer a release of green belt land through delivery of road infrastructure, which would then serve as a 'defensible' boundary to an amended green belt, within which development could be permitted, which would supposedly 'pay' for the road.

On this basis, the proposed validity of integrated policy proposals of SG2, SS11 and IN4 fall. If the new by-pass is unjustified within the Green Belt, which we reiterate it is, then a new defensible boundary to an amended Green Belt would simply not exist. Therefore, whilst Green Belt boundaries may be varied through development plan reviews where very special circumstances exist, it would not follow that release of green belt specifically at 5G2 would be the automatic 'best' choice for accommodating proposed growth in the district.

In this respect the preceding consultation in relation to Preferred Strategic Sites (2012) was flawed, as the so-called justification for the allocation at SG2 as examined - and dismantled above, was used in those site identification processes and hence unreasonably and unfairly prioritised the site over many others. In a number of those cases the sites were rejected because of their Green Belt status (as well as environmental and heritage credentials significantly 'underplayed' at SG2) with the council's explicit acknowledgement that boundaries should be amended only in exceptional circumstances. As those exceptional

135 circumstances have been inadequately demonstrated at SG2, then a revision of those site assessments and prioritisation must surely be justified.

Moreover and more alarmingly, no sustainability appraisal process was undertaken to inform policy development at that (Preferred Strategic Sites) stage. Whilst this reflects poor spatial planning practice and again suggests the fait accompli which pervades the approach taken to SG2 and IN4, more importantly it reiterates that consistent and impartial appraisal of the sustainability credentials of alternative sites was not systematically undertaken or used to justify the draft plan's content. Political will to deliver the by-pass and for it to be paid for by releasing green belt land has clearly skewed the plan's spatial strategy, disregarded other important material considerations and resulted in a biased and blinkered approach to strategic site selection.

Consequences of the Proposed Spatial Strategy

Stop 500 has previously brought to the Council's attention that the emerging spatial strategy will result in a grossly skewed distribution of new development within the borough over the plan period. It is clearly evident that the focus for strategic development sites to accommodate proposed growth over the plan period is heavily biased to the communities in the east of the Borough. In particular there is a significant emphasis on sites in and around Codnor and Ripley. Basic GIS analysis shows that the strategy proposes the delivery of a total of 1,714 houses are proposed or with extant planning permission, within a 1 mile radius of Ripley and Codnor. This represents a huge proportion of the proposed growth for the district overall being focused into a very small geographic area.

Whilst it is acknowledged that sustainability principles generally support directing development to settlements where existing services help reduce motorised trip generation, unbalanced growth (such as that presented in the draft plan) which would result in strain on existing services, loss of settlement identity and degradation of its environmental context would not constitute sustainable development. This representation has already expressed deep scepticism that the delivery of necessary infrastructure from developer contributions will be able to meet demand generated from that development. In combination with the other strategic sites and extant permissions in and around Codnor, the ability for existing community and education services and utility infrastructure to accommodate population growth as proposed is even more unlikely. The focus for growth in and around Cod nor to such a degree is unreasonable, and the village's community has clearly expressed such concerns in consultation plan documents over the past 2 years.

Part of the reason for this unbalanced focus of growth around Codnor is a consequence of the undue support for the allocation at SG2. As argued in this representation, that allocation is unjustified as it is based on unreasoned assumptions and political bias for the road for which there is no strong evidence of need. Re-assessment of development site potential across the district on a systematic and transparent basis should be undertaken without such pre-existing favour, and in doing so a more reasoned strategic distribution sought around sustainable settlement growth for the whole borough.

Critique of the Sustainability Appraisal /Strategic Environmental Assessment Process to date.

Stop 500 recognises that the current plan draft has been prepared under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. Effectively this is the first statutorily required stage for public consultation of an emerging plan. In doing so it should represent a genuine opportunity for interested parties to influence and shape the plan before it evolves towards Publication under Regulation 19. Moreover it's content should benefit from the findings of early stages of a Sustainability AppraisalIStrategic Environmental

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Assessment (SA/SEA) process as required under the Environmental Assessment of Plans and Programmes Regulations 2004, which transpose into UK legislation the EU Strategic Environmental Assessment (SEA) Directive.

It is noted that a Sustainability Report has been prepared and published with this draft of the plan. However, Stop 500 is concerned that the evolution of the plan to this point has been undertaken without the benefit of such a systematic and what should be a hugely influential sustainability appraisal process prior to this stage. This is particularly significant because to all intents and purposes the current plan sets out the preferred spatial strategy and strategic sites as presented within the Preferred Growth Strategy 2012. That document was not influenced by a SA/SEA process at the time of drafting, and as such the full consideration of reasonable options and alternatives had not been independently, systematically and transparently assessed for sustainability credentials prior to being identified as the preferred approach. This is a significant failing and undermines the legitimacy of the current draft plan.

Stop 500 is concerned that the process now adopted and findings set out in the Sustainability Report 2013 is in effect an attempt to rectify such obvious shortcomings in process thus far. It effectively represents a 'retro-fitting' exercise as anticipated by Stop 500 signatories in previous consultation representations.

Examination of the SA/SEA report reveals that the process, instead of being integral to the emergence of options and alternatives from the outset, has been undertaken in considerable haste during the very narrow period between May and June 2013. This confirms that the sustainability consultants have been engaged by the LPA a considerable time after the preferred plan and its preceding iterations were drafted by the Council.

In doing so, shortcomings in best practice are identified in the way the SA has been developed, and in the way in which sustainability performance has been selectively relied upon in prioritising preferred strategy options. This is clearly demonstrated by the very minor proposed changes to the draft plan recommended by the SA report set out at Paragraph 19.2.2. Given the breadth and significance of the original draft plans prepared without concurrent SA process, this would appear to be a unreasonably low degree of added value in relation to sustainability performance.

It is noted that the 'scope' of the appraisal process was first drafted in 2008. The consultation bodies were consulted at the time. However, in preparing this Sustainability Report the council do not appear to have re-consulted Natural England, English Heritage or the Environment Agency, nor has it consulted upon the adequacy of the scope of the appraisal with other stakeholders before publication. It is noted that the sustainability consultants have sought to update the 'scoping' elements of the plan as an integrated part of the report with regards to identifying other plans, policies, strategies and initiatives which set an up-to-date context for developing sustainability objectives (the sustainability framework) of the SA/SEA. However no indication is given that the Consultation Bodies have agreed the adequacy of this update. Given the very considerable period since the initial scoping report was prepared, this would appear to represent a shortcoming in process which undermines the assessments credibility.

An important indication of how the underpinning scoping process for the SA/SEA may be seen to be flawed is the profile afforded to the Green Belt within it. A significant proportion of the borough is overlain by Green Belt designation. However, the 2008 Scoping Report barely mentions this and Green Belt considerations are not therefore embedded within the Sustainability Framework for the current plan draft. This surely represents a weakness on approach to the SA/SEA and its ability to properly consider pertinent sustainability outcomes. This failing has been maintained within the SA Report, and is particularly apparent in relation to the content of table 7.1 of it. This recognises at SA Objective 3 that loss of green spaces

137 and natural landscapes are urgent considerations across the borough (which is supported by Stop 500), but does not recognise that Green Belt is of even greater significance within this wider context. There are no 'natural' landscapes within Amber Valley as suggested by the SA at table 7.1, but local landscape character at a sub-landscape character area scales is of significant value to local communities. It must be remembered that the Green Belt is a planning tool designed to further environmental and sustainable outcomes. Matters of urban sprawl, countryside protection, settlement identity and urban regeneration are fundamental objectives of sustainable land use planning, and should be afforded far more weight within the SA framework than given. A defining characteristic of Amber Valley, is the settlement pattern of several large villages and the market towns which in places extend along main highways and suffer from a lack of distinctiveness and clear separation and display historic sprawl. In such circumstances, particularly across the east of the borough, green belt principles remain highly relevant.

The weight afforded to the various criteria adopted now by the SA report is also of concern to Stop 500. Regardless of how the council have engineered justification of preferred sites regardless of SA findings, it would appear that greater weight should be afforded to some sustainability criteria than others. For example, accessibility to bus routes is a significant factor in Appendix IV and V of the SA. This would appear to carry equivalent weight to Green Belt designation. Yet bus routes (and provision of and access to local services) are inherently transient, they come and go, and moreover, would respond to demand generated from strategic housing sites. Conversely the loss of Green Belt is permanent. In this respect Stop 500 consider that the sustainability criteria developed within the SA report is inherently biased so as to underplay the significance of Green Belt loss in comparison to other factors.

Criticism of the Sustainability Appraisal Findings and Resultant Plan Content

Notwithstanding the unreasonably low profile afforded to the Green Belt in the SA framework, it is acknowledged that Green Belt considerations have been included within the assessment of the plan and the retro-fitting of the process to previous consultation documents. However there appears to have been great inconsistency or selectivity in how the potential for the loss of Green Belt (amongst other matters) as a consequence of plan proposals has been factored into refining preferred plan options.

Section 11.4 of the SA Report highlights how the selection of preferred sites from earlier alternative sites has been inconsistent. From the outset, paragraph 11.4.7 identifies sites which have performed well with regard to sustainability criteria and have:

'no critical constraints such as Green Belt, habitat designation of flood risk ... '

However, it would appear that 'critical constraint' has been given somewhat flexible consideration. Tables 11.1 to 11.3 demonstrate this point, and can be traced to more detailed assessment tables in Appendix IV. Here it can be seen that selectivity has been afforded to the type of sustainability performance each of the consultation sites. For example, highways considerations and cross-LPA boundary considerations have resulted in nonselection of AV1 whilst being otherwise of strong sustainability credentials.

Yet AV8 has been selected despite poor performance in relation to the previously described 'critical constraint' of Green Belt allocation. It would appear that very significant highways infrastructure investment at AV8 is justified yet is not at AV1, despite its better overall sustainability credentials. AV9a has not been preferred because of issues of settlement coalescence - a key Green Belt objective, yet is not within the Green Belt. A number of other site alternatives have been rejected on amongst other issues Green Belt grounds (AV5, AV6 AV14a, AV15 amongst others), yet AV8 has not, despite poor performance in some other sustainability criteria.

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At a more detailed level Stop 500 challenges some of the SA report's specific detailed judgments and findings in relation to certain proposals, particularly IN4, SS11 and SG2. These are important because they provide support for some of the strategic choices made in the plan. Most significantly, proposals for the by-pass at IN4 are afforded a neutral sustainability score in relation to Sustainability Objective 10. That Objective seeks to reduce reliance on the car and increase opportunities for walking and cycling. It would appear perverse to suggest that a proposal to divert traffic through the borough more quickly and to access housing and employment sites through provision of major road infrastructure could serve to result in anything but a negative sustainability outcome for this objective.

Likewise S05 (biodiversity), S011, S012 and S013 (economy and employment) are afforded uncertain or positive outcomes when the impact of the proposals on the local habitats (including established woodland at Holborn Wood) would be patently negative, as would the impact for commerce and services in Codnor village centre.

Sustainability assessment for strategic development across SG2 similarly suggests a positive outcome in relation to S02- Community Well-being. This is challenged. The implications of massive settlement growth, loss of valued and well used green space, strain on local services and increases in local traffic would appear highly unlikely to result in a positive outcome for local community well-being. Despite the proposals for SG2 serving to obliterate an attractive and accessible area of open space crossed by well-used public rights of way, 18.4 of the SA report goes on to suggest a neutral impact upon green infrastructure - this despite paragraph 18.4.6 acknowledging such loss as a negative outcome. Moreover, it suggests the same neutral outcome for biodiversity. This cannot be the case. Stop 500 cannot reasonably see how losses to hedgerows, pasture trees and woodland can be mitigated such that a neutral outcome is achieved, as suggested by the SA.

As a prime example of the disparity between the findings of the SA report and the plans presentation of preferred options, it is appropriate to look at the assessment findings for IN4. Tables throughout section 18 of the SA identify 6 Sustainability objectives (of 13) where a negative sustainability outcome is predicted and only 5 positives (which include the perverse finding for community well-being, transport and local economy). Yet the plan seeks to support the proposals. How can this be a reasoned outcome?

Hence Stop 500 is deeply concerned that the sustainability appraisal has been carried out in such a way to have minimal influence on the critical emerging stages of the plan, application of the sustainability appraisal has been 'generous' in relation to over-playing positive outcomes of certain preferred elements of it and under-playing negative ones. More importantly the Council has taken a biased approach to how the SA findings – however imperfect, have been applied to the preparation of the draft plan. There are considerable discrepancies and lack of clarity in respect to strategic site prioritisation.

Conclusion

It is acknowledged that meeting the future development needs of the borough may be challenging, but the approach taken within the draft plan, and acquiesced to by the SA fails to present a consistent or reasoned approach to site selection or justification for major infrastructure. This reinforces the view held by Stop 500 that the selection of SG2 is a fait accompli, for the reasons criticised in this representation.

This representation outlines the concerns of the community of much of Codnor. It demonstrates that in Stop 500's opinion undue emphasis is being afforded to proposals for SG2, SS11 and IN4 for political reasons and in the absence of persuasive supporting evidence. Due process is being manipulated to serve to promote these proposals as being

139 necessary and sustainable. They are not. The approach taken to this point in plan preparation demonstrates considerable disregard for the clearly expressed public objection to the proposals made to this point by residents and businesses of Codnor. Such disregard has necessitated the need for such a lengthy and firm response to this consultation process. Stop 500 strongly urges the council to reconsider the sustainability, merits, viability and logic in relation to SG2, SS11 and IN4, and to abandon these elements of the plan in the preferred plan draft.

Response

It is considered that the development of this site will assist in delivering this scheme, but criteria have been added to the policy for this site to address the concerns expressed. It should also be noted that a planning application has been received for the development of this site, together with the new A610 link road and the development of the site at Nottingham Road, Ripley. The development of this site will not take place unless the whole of the new A610 link road is implemented, as required by the policy for this site. The application is accompanied by a number of accompanying documents which include a transport assessment and a variety of other supporting documents that consider the other impacts that the development of the new link road and this site may have.

Comments on Policy SG3: Land North of Denby

Belper Civic Forum: The Civic Forum would like to see the Council reduce the overall number of homes suggested for this site to 900, whilst retaining the boundaries suggested. This should be in keeping with our response to questions 6 and 36, requiring developers to demonstrate how they respect the landscape with less intensive development and provision/ retention of green open space.

Response

Development at this scale would not enable the site to be as self sustaining as possible.

Transition Belper: Need to ensure there is good frequent public transport between this site and Belper to avoid necessity to use the car.

Response

This comment is noted.

Denby Footpaths Group: Denby Footpaths Group has read the consultation document Local Plan Part 1 The Draft Core Strategy produced by Amber Valley Borough Council. Our response to the consultation refers to Policy SG3, Land North of Denby as follows:

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Policy SG3 (f) states ‘safeguarding of the disused transport route within the site as a potential public transport corridor or a multi-user route for pedestrians and cyclists’. Denby Footpaths Group are against the route being used as a public transport corridor. This route forms a key section of the Ripley to Little Eaton multi-user route already under development and any other use of this section of the route would compromise the overall scheme.

The inclusion of SG3(g) ‘protection and enhancement of existing footpaths within the site’ is welcomed by the policy. Policy E2(g) refers to ‘opportunities for walking, cycling… can be maximised’ and this statement is also encouraging.

However, although Policy E2 is referenced as a condition in SG3, this does not adequately cover the importance of safeguarding the heritage and historically important aspects of this area. Policy E3 Historic Environment goes some way to addressing this and should be included in SG3.

Whilst Denby Footpaths Group neither support or oppose the overall strategy, it was the group’s opinion that certain factors need to be taken into consideration in relation to the planned development in Denby:

Classification of land The land has been identified as 40% Greenfield and 60% Brownfield. Most of the area covered, although previously ‘developed’, has returned to a natural state and is Greenfield. Due to this, the figures quoted are misleading. Over the years, Denby residents have suffered much from large scale disruption from opencast mining and other industry. It is only now that they are able to enjoy this site as it returns to a natural state. The site is now rich in wildlife, and nature is recovering. It is valuable land for the biodiversity of the area. Nature conservation areas have been identified but will potentially be disturbed by development on such a large scale.

Historic and Heritage aspects The group were disappointed that officers present at public meetings knew little or nothing about the rich industrial heritage and history of the area. Listed are a few of the main features of the area: - The early railway developments in the area are of key historic importance. The routes are still evident today and their preservation is paramount. A key document written by Trevor Griffin (February 2012) has been received by Amber Valley Borough Council. It covers most comprehensively the history and development of the railways. “The railway is an important relic of a Derbyshire based industry that contributed to the worldwide development of railways as a major form of transport”. - Bassett Pit worked from 1817 to 1866 - Slater’s Brick and Tile Works operated from 1874 to 1977 - Denby Iron Works from 1860 to 1929 - Park Hall, a grade II listed building dating back to 1702 - In 1901, Tarmac was ‘invented’ changing road building around the world.

Denby Footpaths Group is working on a scheme to have this heritage recognised with installation of relevant signage boards and the possibility of a partial reconstruction of a railway section.

Link to Derwent Valley Mills World Heritage Site:

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The area identified for development falls on the border of the Derwent Valley Mills World Heritage Site Buffer Zone. The development of the Belper and Morley Park railway was critical to the success of the Derwent Valley Mills during their development. The route of this railway links the two sites physically along with the network of ancient rights of way running through the area.

Other opportunities for the land:

There is vast potential for this site to attract tourists into Amber Valley due to the key heritage and historic aspects identified already in this response. The development of Denby Pottery will bring in tourism and this site is easily accessible from the Pottery making a ‘day out’ in Amber Valley. Similarly, development of the Ripley to Long Eaton Greenway will bring in visitors as the route passes through the development site. Future development of greenways in the area as identified in the East Midlands Greenway Strategy (DCC) will link the area into Shipley Park and the Nutbrook Trail.

This area already meets the need for open space and could be further enhanced by developing the open spaces for recreation (nature trails, trim tracks and cycle paths for example). Preserving historic hedgerows and protecting the biodiversity of the area would further improve this much used public open space.

Leisure needs are met by the area which provides a green open space for walkers and riders. Denby Footpaths Group is carrying out much needed improvements to the path network to make the area accessible and enjoyable. Derbyshire County Council has recently assisted this work by carrying out major improvements along the key route opening the connection once more to the Derwent Valley Heritage Site through Openwoodgate.

Denby Footpaths Group feel that Amber Valley Borough Council need to consider in much greater depth whether this development is really in the best interests of the whole Borough bearing in mind the negative impact it would have on the area we have outlined.

Policy E6: Biodiversity should form part of the Policy SG3. Several ancient and historically important hedgerows exist on the development site. It is noted however, that hedgerows are offered no protection in E6 and ask that they be included.

Response

Criteria have been added to the policy for this site to address these concerns.

Comments on Policy H3: Affordable Housing

Transition Belper:

Why is only half of the needed affordable housing is being proposed (30% rather than the 60% required up to 2028)?

Funds used for affordable housing could be spent off site – empty properties, cheap properties for sale in poor condition, infill in villages etc. Retrofitting would upgrade the energy efficiency of older stock and having development sites with a higher proportion of market housing might have a changed economic dynamic.

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Response

This reflects the existing Local Plan policy. Experience has shown that requiring developers to provide more than 30% affordable housing would render schemes unviable and/or would result in order contributions not being provided for infrastructure such as open space and the expansion of schools. The Council does, when appropriate, require developers to provide a contribution for the provision of affordable housing elsewhere in the locality.

Comments on Policy H4: Viability of Proposed Housing Sites

Transition Belper: Does this mean that there can be a compromise on the 30% affordable housing guidelines? i.e. even less than 30%? Could the exact circumstances when this is allowed be made clear?

Response

Each planning application has to be considered on its own merits. If independent advice is received that advises the Council that requiring 30% affordable housing will render a scheme unviable, the Council has to consider if in that particular case a lower percentage of affordable housing should be permitted.

Comments on Policy R1: Reducing the Use of Non Renewable Energy Resources

Delaying Code 4 due to economic conditions is not acceptable; Climate Change is not waiting for improvement in economic conditions.

The exceptions to achieving Good standards are too vague. Why should a small site become an exception?

In particular in Belper we have the problem of the existing housing stock with solid walls, often in WHS corridor so we will not be able to fit current external wall insulation to improve energy efficiency performance. New properties need to be of highest standard immediately top compensate for difficult to treat properties in Belper.

Delaying BREEAM good and very good standards until 2016 and 2019 is not acceptable, we must act now.

Belper must be of a higher standard, therefore insist higher code immediately, possibly in Belper only.

Delaying the ‘water efficiency component’ of level 5/6 of the Code for Sustainable Homes until 2016 is not acceptable, we must act now.

Include consideration to ensure adequate ventilation during heatwaves/sunny conditions (so avoiding need for air conditioning/fans)

This whole chapter falls down when viability is challenged by a developer – considering the fairly insignificant additional costs of meeting the higher standards now it is disgraceful that a much tougher line is not being taken immediately.

Response

It is considered that the requirements of this policy are already at the limit of what would be viable at the present time.

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Comments on Policy R2: Renewable Energy Installations

Transition Belper:

Technology is improving the design of wind turbines all the time and there are many on the market now which are smaller in size, much less harmful to birds and much quieter. We should not write wind power off.

Can we include in the policy the balance explaining the positive reasons for installing wind turbines?

Should this strategic document taking us to 2028 be so specific about current government policy that may change in a couple of years?

Are the ‘identified’ sites in Amber Valley available and promoted to potential developers, particularly community groups or social enterprises (for the benefit of the local community)?

How can you argue that “environmental protections” override the need for renewable energy, insofar that use of non-renewables will damage the environment in the long term......

What about hydro and solar energy. Also, in new larger developments, anaerobic digesters could provide some energy whilst recycling.

Can you produce Policy R3 Non-Renewable Energy (fossil fuel) - including coal, oil and gas extraction).

Response

The policy encourages all types of renewable energy and is flexible enough to not become outdated in future years. It is not considered that a policy on non renewable energy is required. It has been amended to take account of some of these comments.

Comments on Policy E1: Managing Flood Risk

Transition Belper:

Do any of the policies or guidance require or encourage specific improvements such as green roofs, or the planting of native tress/bushes within a new development.

Response

The policy has been amended to refer to development involving the use of green roofs and/or the planting of native trees/bushes to achieve a net decrease in surface water run off.

Comments on Policy E2: Quality and Design of Development

Transition Belper:

Concerned with word “scale” (needs better definition here and elsewhere in Local Plan, as developer could justify building something as high and broad as East Mill, on grounds that is the same scale).

This policy may require improvements in public transport (routes, times and frequency) – so could perhaps mention “encouraging” this.

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Landscaping could be defined more clearly e.g. using native species, to enhance biodiversity, reduce flood risk.

With regard to the reference to the use of materials that reflect the identity of the local surroundings, what if local surroundings are awful (e.g. concrete slabs and corrugated iron roofs of nearby industrial sites)? Need wording to prevent justification of more of the same ugliness. Could use words/phrases such as “appropriate” and/or “locally sourced” and/or “traditional” and/or “good quality” materials.

Crime prevention and community security are not about CCTV only – providing better community cohesion through communal buildings & space which will increase a sense of ownership & community spirit.

Leave out phrase “where appropriate”. in the phrase “secure, where appropriate, improved accessibility to the town centre by improvements to the public transport facilities”

Could free parking (for 2 hours?) within town centres (AVBC car parks) and reasonably priced day parking to encourage tourists (especially Belper) and park and ride season tickets to encourage commuters to use trains/buses. Paid for by edge of town supermarkets.

Could the Ripley branch of the Midland Railway be re-opened, or park and ride facilities be provided.

Should the policy refer to the installation of solar panels at the time of building the properties?

What about other providing other communal facilities such as water collection butts, composting, anaerobic digesters, renewable energy installations and food growing areas.

The reference to density is a vague statement. How about small local shops provided on the larger sites to eliminate the need to drive a distance for small provisions? A nursery/child care service also? A supervised community room for young people to gather in, rather than hanging around the shops? This would increase safety and employment opportunity. Also could 1 plot be left empty & made into allotments? Preferably next to the young people’s community room so as to integrate ages & interests.

Is it encouraging high density in a high density area? (Or the opposite). We think there should be some idea of need for balance in this paragraph.

Response

The policy has been amended to take account of some of these comments. However, some of these issues such as parking charges are not matters for the Core Strategy.

Comments on Policy E3: Historic Environment

Transition Belper:

Specific mention should be made about the Climate Change adaption required around the World Heritage Mills adjacent to the Rivers, liable to be impacted by flooding.

Response

This is not an issue for a policy on the historic environment.

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Comments on Policy E4: Landscape Character

Belper Civic Forum: The Civic Forum would like to see encouragement given to less intensive development of sites by housing, and evidence that developers have provided generous green space in keeping with the ‘Garden City’ principles where possible.

Response

This comment is noted.

Comments on Policy E6: Biodiversity

Transition Belper:

Should this also say rivers to include fish passages?

We very much agree with idea of restoration and re-creation of habitats (rather than just mitigation).

Developments should have a mandatory 50%-75% green space to ensure and maintain bio diversity. Green Roofs can be used to achieve this for larger developments.

Response

The policy has been amended to refer to fish passes. A mandatory amount of Green Space at this level would involve an inefficient use of land and would not be in accordance with government policy.

Comments on where you think a ‘Local Green Space’ should be allocated

Transition Belper:

Is it feasible through the Local Plan or through the neighbourhood plan to designate part of the Meadows area as Local Green Space for provision of sports facilities and community gardening projects accessible to all members of the community?

Response

This will be considered when the Site Allocations and Development Management Policies DPD is produced.

Comments on Policy IN1: Transport

Belper Civic Forum: There should be a direct reference to Policy IN1 in the Spatial Vision for the Borough.

Response

It is not appropriate to include references to policies in the Spatial Vision.

Transition Belper:

Is a lower limit possible for when a Transport Statement or a Transport Assessment will be required?

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Encouragement should be given to reinstating school buses, especially for secondary schools, which would reduce school-run traffic congestion and pollution etc. Utilise community transport to link main transport corridors as per Notts CC Titan Project Work with community transport partners to deliver more frequent flexible services. Enterprise, incubation or community rooms could be provided to offer a few ‘hot desks’ high speed broadband and communication equipment in a central location, possibly utilising brownfield site. There is no mention of any evaluations or plans to put into use the Ripley Branch or the Midland Railway either as a cycleway/bridlepath, or reinstatement for light or major rail use linking key parts of Amber Valley and potentially being a significant benefit to the Cinderhill project. The problem of the A6 running through the centre of Belper has been ignored and must be addressed. Should a Masterplan be developed for Belper including the problems of the A6. Review partial one ways etc. A Masterplan could also help find a practical solution to the coach parking problem. Review of Rail Transport required urgently looking at Electrification of current line through the World Heritage corridor, including Belper, or alternatives around Belper, access to the HS2 and re-suing closed lines such as the Ripley Leg of the Midland Railway. Extend DVM through Derby to employment locations such as Sinfin and Burnaston All new developments – Roads to include cycle ways, Developments to include Cycle Park provision. Build in a location for a Car Share Scheme in Belper.

Response

Many of these comments relate to matters that are not related to a planning policy document or are matters that are covered elsewhere in this document.

Comments on Policy IN3: Community, Leisure and Health Facilities

Transition Belper:

This should include a statement about working with local organisations, community groups and social enterprises to achieve this.

Additional provision for Doctors and NHS Dentistry (local to reduce transport) required in Belper.

Response

It is not considered that the policy needs to be amended in response to these comments.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Stop 500: It is acknowledged that there is a protected line for a relief road within the 2006 Local Plan (Policy TP13) which is based upon a ‘longstanding commitment to securing the completion of highway improvements along the A610 between Ripley and Langley Mill, including a by-pass for Codnor’. However it is most telling that the significance of any inferred (but not evidenced) suggested need, and the ability to secure the necessary funding, have clearly not become any more pressing over the previous plan periods. The draft plan today sets out in parts a similar vague indication of ‘desire’ for the relief road rather than any significant evidence, convincing transport modelling or community engagement feedback to suggest that the draft policy response is proportionate or justified. Vague plan

147 commitments, past infrastructure philosophies (supporting by-passes) or political preference for a relief road at Codnor cannot be maintained over such a significant passage of time without robust evidence and review, yet the best the draft plan can suggest at this stage (following significant earlier ‘informal’ consultations proposing the road and site) is reference to a ‘long-standing commitment’. This is simply not a good enough basis on which to justify a major infrastructure and strategic housing allocation within the green belt.

This very limited status within LTP3 clearly does not afford any significant priority to the scheme, does not recognise congestion along the A610 as a particularly pressing matter and further demonstrates that the case for the road remains a product of long-term plan inertia rather than evidenced need. Clearly the priority afforded the road proposals does not begin to justify a significant funding priority for the Highways Authority. The presence of the proposals would appear to be included within LTP on the grounds that the Borough Council is so strongly promoting the scheme, and not that the Highways Authority recognised need or priority.

The Inspector’s report to the 2006 Local Plan recommended that the road alignment be removed from the emerging plan and specifically referred to the Council’s ‘wishful, if not entirely unrealistic desire given the plan period to secure the provision of a Codnor bypass’.

The evidence-base referred to within the plan for policies SG2 and IN4 notes that traffic modelling is currently ‘underway’. How then can such a significant and hugely emotive proposal be brought forward to this stage of the plan (and indeed have been so prominent in preceding documents) when the council has no independently verified evidence that the road is categorically essential to the sustainable development of the Borough? This clearly must demonstrate how the political priorities of the Council are serving to take priority over transparent, inclusive and sustainable land use planning within this part of the Borough. LTP3 itself emphasises how transport planning now prioritises shifts away from road building to sustainable transport solutions and modal choice.

Notwithstanding the probable significantly detrimental effect a by-pass would have on day- to-day trade within Codnor’s existing retail and services sector, the proposal would increase the convenience of car based movements for retail, employment and leisure activities, flying in the face of sustainable development principles and a sustainable spatial planning approach.

The justification of the infrastructure provision, i.e. ‘long-standing commitment’ is promoted contrary to local opinion on the degree of severity of congestion at peak times. Evidence from many other studies suggests that by-passes of smaller settlements are likely to have negative implications on the village’s economic well-being. This would surely apply to Codnor’s local commerce and services community.

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Response

When the last Local Plan was produced, there was no funding identified for the new A610 link road and it is referred to as a scheme with potential for appraisal in association with land use plans in the Local Transport Plan.

A planning application has now been submitted for this scheme which is accompanied by a number of accompanying documents which include a transport assessment and a variety of other documents that consider the other impacts that the development of the new link road and this site would have.

Comments on Policy IN6: Developers Contributions

Belper Civic Forum: There should be a presumption towards developer contributions benefitting and being retained for infrastructure improvements close to the site where the Section 106 levy is applied.

Response

Section 106 agreements cannot require contributions towards infrastructure that is not related to the site.

Any further comments you wish to make on the content of the Plan?

Stop 500: Stop 500 is immediately concerned that the council is seeking to artificially and deliberately circumvent part of the purpose of this consultation, under Regulation 18 Town and Country Planning (Local Planning) (England) Regulations 2012. In short paragraphs (1) and (2) of the Regulation require plan making authorities to invite (amongst others) local residents to make representations about what a local plan ‘ought to contain’.

Very importantly, paragraph 3 of Regulation 18 states…

‘(3) In preparing the local plan, the local planning authority must take into account any representations made to them in response to invitations under paragraph (1)’.

In this context it is of very considerable concern to Stop 500 that the invitation to comment upon the draft plan presented on the Council’s website is caveated by the statement -

‘Please note that if you have already commented on the principle of developing the proposed strategic housing sites it is not necessary to repeat these comments, as they have already been recorded and taken into consideration.’ (our emphasis).

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Not only does this potentially fall foul of the legal requirements of Regulation 18, it clearly reinforces the view that the decision to take forward the strategic sites set out in the draft plan has been decided, that the very many and well considered objections prepared to previous non-statutory consultation have been dismissed, and that no opportunity to reconsider in light of future evidence will be taken! It is difficult to see how else can this statement be interpreted? It effectively says do not comment upon the strategic sites selection…. you may have objected but we want to avoid the inconvenience and discomfort of having to consider this any further. Unfortunately for the council, this is not an approach which carries any weight. It is Stop 500’s right to maintain, enlarge upon and underline its strong objection to the proposals east of Codnor in this and future plan iterations and stages. It will do so, and this representation maps out our key and wholly valid concerns.

Response

The Borough Council is fully committed to full engagement with the public and other stakeholders when producing its plans, in accordance with the relevant regulations. The comment in respect of not repeating comments was only intended to advise stakeholders that the Council are aware of the issues previously raised in respect of the principle of developing the proposed strategic sites and they do not need to repeat them, as the comments previously made will be forwarded to the Secretary of State when the Core Strategy is submitted prior to the public examination taking place. The focus of this consultation was on the proposed policies to be included in the Core Strategy.

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2.8 Summary of comments from developers, landowners and consultants

Comments on the Spatial Portrait of Amber Valley

Comments on the Spatial Vision

Savills: The Spatial Vision and Spatial Strategy do not appear to accord. The Vision states that the concentration of new development will be at Alfreton, Belper, Heanor and Ripley, however the Strategy states that development will also take place on the edge of Derby, a mixed use site north of Denby and other locations that will accommodate the bulk of the housing need. It appears that an attempt is being made to retrospectively justify site selection to the Spatial Vision.

Response

The Spatial Vision and Spatial Strategy have been amended to make it clearer where it is proposed that development will take place.

Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Generally supported except worth adding to the second paragraph: ‘The creation of a new housing led development at Land North of Denby will be very well advanced, making a significant contribution to meeting the Borough’s housing needs.’

Response

The Spatial Vision has been amended to add similar wording to that which has been suggested.

Gladman Developments:

The Draft Core Strategy states that “Villages and rural areas in the Borough will be protected from unsustainable development.” This statement is misleading, as it suggests that by their nature villages are unsustainable. To the contrary directing growth to sustainable villages within the Borough will be necessary and should be welcomed. This will help to sustain and enhance the existing facilities and services and provide housing for local needs within these villages. Gladman therefore recommend that this sentence should be deleted from the Core Strategy.

Response

This statement was not meant to imply that villages are unsustainable. The Spatial Vision has been amended to make it clearer that the intention is that all areas of the Borough will be enhanced and protected from unsustainable and unsympathetic development.

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Comments on the Strategic Objectives

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Unclear how prioritisation of the A610 scheme is evidence based or consistent with other sustainable development objectives.

Response

Responses to similar comments about this scheme can be found elsewhere in this document. A planning application has now been submitted for this scheme, which is accompanied by supporting evidence documents.

Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Support Objective 4 in relation to the Council enabling sufficient housing to be provided and the cross-reference to SG3.

Strategic Objective 1 appears unduly onerous and is inconsistent with policy R1,that refers to carbon reduction (and NPPF approach at para.11.1). Wording of S.O.1 to be amended accordingly.

Response

The words “where appropriate” have been added to this objective.

Marrons: We note and support Objective 1 and the need to achieve sustainable development and Objective 3 to promote the growth and viability of the market towns, including Belper.

In respect of Objective 11, we support the need to create opportunities for non-motorised transport and to increase public transport accessibility. In the light of the Strategic Objectives of the Draft Core Strategy, it is difficult to see how reliance on a single greenfield housing allocation in open countryside on land north of Denby (SG3) can be considered to meet these three objectives – how it is sustainable, how it promotes the vitality and viability of Belper and how it can possibly create an opportunity for non-motorised transport.

We therefore propose an alternative pattern of development which allocates additional sites closer to Belper, able to take advantage of the existing infrastructure of the town in a more sustainable manner.

Response

These comments do not require any amendments to the Strategic Objectives.

Comments on the Spatial Strategy

Fisher German on behalf of the Trustees of Locko Estate: The identification of land to the north of Denby as a principal focus for development is specifically supported.

Response

This support is noted.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Penultimate paragraph of 6.6 suggests that strategy is driven by procedural convenience

152 rather than the conclusions of an evidence based enquiry into the optimum pattern of development.

Response

This paragraph has been deleted.

Savills: The acknowledgement that other towns including Somercotes can play in the delivery of housing to meet locally assessed housing needs is welcomed and supported.

6.1: The text reads in such a way that it is acceptable to simply release land from the Green belt in order to accommodate development proposals. There is no specific justification provided as to why sites at Ripley and Codnor represent exceptional circumstances. If the release of land for development is required to provide or fund the A610 link road, that should be clearly stated.

6.5 & 6.7: The Core Strategy continues to provide no definition of what a Strategic Site is, nor justification of why only sites that meet the unspecified criteria are identified.

6.6: Section 6.6 identifies an advantage of Strategic Sites being the potential for earlier housing delivery without having to wait for a separate Site Allocations Document. This is an inaccurate statement, as the only reason non-strategic sites (whatever they are) are not being allocated now is because the Council is choosing not to.

Response

The text referred to in paragraph 6.6 has been deleted. The sites adjacent to the A610 will not be developed unless the new A610 link road is not implemented in its entirety. The proposals are interlinked.

Capita on behalf of Wheeldon Brothers Ltd: We broadly agree with the spatial strategy.

The revocation of the Regional Plan provides a freer hand to the HMA authorities to guide development to the most sustainable locations and where growth will have the maximum regeneration benefit. A core strategy that directs a disproportionate level of growth to Derby risks abandoning the rest of the HMA to a fate of structural decline, where opportunities for new investment in local services, new infrastructure and environmental improvements are missed. A core spatial strategy which directs significant growth to both extension locations within the city boundary and the main towns of the HMA, has the best chance of delivering growth alongside regeneration benefits and affordable housing directly where they are most need to local people.

The ‘Amber Valley Regeneration Strategy 2005-2015’ (Amber Valley Partnership 2005) notes that the District’s ‘greatest challenges are found in the east of the Borough where some industrial communities contain pockets of dereliction, deprivation and social exclusion’. In respect of market towns, the Strategy notes that ‘most of the population of Amber Valley live in its four market towns. These also act as service centres for the nearby rural economy’.

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The strategy seeks to reposition each market town to become more competitive places that are: better balanced local economies; better able to attract and retain spending and investments; better able to attract and retain skilled and talented people; more distinctive and sustainable places.

Both the strategy and the more recent Amber Valley Retail Study note that Alfreton town centre has declining footfall and ‘has the highest (i.e. worst performing) prime commercial yield of any of the centres in the Borough’. The recent retail study notes that ‘this suggests the town centre is failing to attract satisfactory levels of footfall, and the vitality and viability of the centre is likely to be compromised as a result’. Heanor is said to be ‘struggling’ and a ‘cause for concern’, while Belper ‘exhibits generally good signs of vitality and viability’ and Ripley ‘presents a number of positive signs of vitality and viability’. The Amber Valley Partnership and the Retail Study recognises that the key to addressing Alfreton and Heanor’s town centre issues is investment. In the current economic climate, this will need to be private investment through growth, directed through the Core Strategy.

The regeneration needs of Amber Valley’s main towns require investment and growth in order to direct regenerative resources to areas of deprivation. A core strategy that does not direct significant growth to the main towns in the District will not only be unsound, but in the current economic climate, risks abandoning the main centres of population in Amber Valley to a fate of structural decline, where opportunities for new investment in local services, new infrastructure and environmental improvements are missed.

Dispersing growth among smaller settlements will not create a sustainable pattern of development. Smaller settlements do not have the range and scale of local services and resources necessary to sustain their communities fully. To be genuinely sustainable a settlement must be able to educate its children to working age i.e. have a secondary school; must provide suitable employment opportunities; and must provide a sufficient level of local services e.g. banks, supermarkets etc, to cater for the needs of its population. While smaller settlements may contain a few local services, they will generally require a significant proportion of the population to travel (usually by private car) to higher order centres for employment opportunities, secondary and further education and supermarkets.

Response

This support is noted.

William Davis Ltd: A further policy is required outlining the more detailed strategy on delivering the 9,400 dwelling figure. A separate policy clearly outlining the information identified in Appendix B is necessary. Without such a change the main text and policies of the document do not outline the overall development strategy, including the strategic site allocations and the fact that the residual housing target of 720 dwellings will be allocated through a Site Allocations and Development Management Policies DPD.

William Davis Ltd object to the overall strategy for meeting the housing target identified in the draft document. We consider the strategy to be too reliant on the significant strategic development sites. Such an approach is likely to constrain the delivery of new housing, particularly in the early phases of the plan period.

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Response

It is not considered that these comments require any changes to be made to the Core Strategy.

Marrons: Whilst the objective to maximise the use of brownfield land reflects a core principle of sustainable development, which is to encourage the efficient use of land by re-using brownfield sites, this must be seen in the context of ensuring a viable and deliverable plan (see paragraph 173, NPPF). In identifying and allocating brownfield sites, the Local Planning Authority will therefore need to demonstrate conclusively, as part of the evidence base for the plan, that these sites are deliverable in the terms of the advice set out in paragraph 173 of the NPPF. We note the Council’s acknowledgement that the availability of such sites is diminishing. Our clients therefore support the inevitable recognition that increasingly greenfield sites will have to come forward for development over the plan period.

Response

These comments are noted.

Gladman Developments: Objections relate to the priority which is being placed on development on previously developed land, the spatial distribution and the limited growth that is being directed outside of the market towns and Strategic Growth Sites.

Gladman raise significant concerns with the spatial approach proposed by the Council. The spatial strategy should be based on the findings of the evidence base and should not be a politically driven strategy to put a disproportionate amount of housing in areas where people do not want and will not live. If the spatial distribution does not reflect need/demand as shown through the evidence base, then the housing will not be delivered and the plan will not be implemented.

Prioritising brownfield sites is contrary to the whole ethos of the Framework as it could act to restrict otherwise suitable and sustainable development from coming forward.

The Core Strategy is placing an overreliance on the delivery of the Strategic Growth Sites. In the event that any of these sites do not deliver to the scale and timescales proposed through the Core Strategy this would jeopardise the delivery of the plan as a whole due to the reliance that is placed on these strategic sites. The Council need to be able to demonstrate, through robust evidence, that delivery of these sites are viable and consequently that these sites are credible options to be included within the Core Strategy.

This viability evidence appears to be absent from the evidence base which is a fundamental flaw. Gladman note that large scale housing sites such as the seven Strategic Growth Sites will have significant lead-in times (both with regards to gaining full planning permission, but also site preparation, provision of necessary infrastructure improvements, or remediating contamination). This means that the delivery of housing on these sites will not happen for a number of years, these are effectively medium to long term housing sites.

Gladman note that the Council are yet to produce a housing trajectory to support the Core Strategy. Following discussions with Council officers it is understood that this will be prepared in advance of the next stage of public consultation. Without the housing trajectory which covers the whole plan period it is not possible to assess the assumptions the Council

155 are placing on delivery of these Strategic Growth Sites across the whole plan period and whether or not these are realistic. Gladman therefore recommend that the Council allocate a greater proportion of growth to be delivered outside of these Strategic Growth Sites, within and adjacent to the sustainable settlements in the Borough, as this would have the potential to increase housing delivery in the short to medium term (as these smaller sites are likely to have shorter lead-in times). This could help the Council to ensure a rolling five year supply of deliverable housing sites and work towards the Governments objectives of boosting significantly housing delivery.

Response

These comments are noted, but it is not felt that any changes need to be made to the contents of the Core Strategy.

Comments on Policy SS1: Housing Land Requirements and Distribution

Signet Planning: The draft Core Strategy indicates a small increase in housing numbers from the Preferred Growth Strategy position of 33,700 to the current position of 35,354 across the Derby HMA. Of these 25,950 will be provided in South Derbyshire and Derby City. It is unfortunate that these Authorities have not issued consultation documents contemporaneously with Amber Valley so the complete‖ picture can be established.

The level of housing provision proposed across the Derby HMA is below the RSS figure and very significantly below the ONS (2008-based SNPP) projection. Cambridge Econometrics (CE), custodians of the Chelmer Population and Household Model were commissioned by Signet Planning to review the Derby Housing Market Area Population and Household Projections Explanatory Note (July 2011). The Chelmer analysis confirmed that the SNPP scenarios put forward by the Councils in the Explanatory Note were the best fitting - the dwelling requirement under the 2008-based SNPP scenario over 2008-28 is 47,900. It is important to note that Amber Valley Borough Council did not contest CE‘s analysis. Furthermore, the Council has never formally commented on the CHELMER analysis or presented it to their consultants for assessment.

In Amber Valley the current consultation indicates an objectively assessed need of 9,400 dwellings 2008-28 of which 4,236 are still to be allocated. 3,529 of these are identified on 5 sites with 716 to be identified in the Site Allocation DPD.

Policy SS1 states that a minimum of 9,400 houses will be required over the Plan period and that these will be located in and surrounding the 4 market towns of Belper, Ripley, Heanor and Alfreton. Strategic Objectives also reflect that distribution. However, the proposed distribution does not follow the Policy (SS1) neither does it accord with Strategic Objective 2 and 3. Whilst there is a housing allocation at Cinderhill this cannot be considered as part of the Belper sub housing market, it has its own sub market. The proposed distribution does not take this into account.

By revising the migration assumptions, GL Hearn is questioning a methodology that the ONS considers to be fit for purpose and makes use of the most up-to-date data that is available. GL Hearn’s assumption that that migration will stagnate must be treated with caution. Whilst Government policy is to reduce non-EU migrants, many of these will continue from Eastern Europe. Furthermore, as the economy recovers further in migration will occur. The NPPF is clear that account has to be taken of migration and suggests that it is not open to an

156 authority to simply make whatever assumptions it chooses. As a consequence, the Borough Council will need to clearly demonstrate that in co-operation with other adjacent authorities that it will accommodate unmet housing need and has taken account of migration.

The GL Hearn report also revised the CLG headship rates downwards. This undermines the Derby HMA’s ability to provide sufficient levels of housing once the economy improves and people have the financial security to form new households.

The draft Core Strategy also has a major part to play in developing the economic power of the HMA. Therefore. the 2010 based assumptions should be adjusted to create a higher growth target that is clearly needed to overcome historic shortfalls in housing provision and improve the economic performance of the Derby HMA. The adopted approach for calculating the proposed quantum of housing represents minimisation and containment and ignores the potential of the HMA to attract jobs and in migration. Such a position is not tenable and the Council’s are urged to model a Pro-Growth scenario.

For the reasons set out above, the draft Core Strategy does not meet the tests of soundness as set out in paragraph 182 of the NPPF. It has not been positively prepared, the strategy is not justified, it is not effective and it is not consistent with national policy.

Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the objectively assessed housing needs in the Borough.

Antony Aspbury Associates on behalf of Omnivale Limited: We object to the overall level of housing provision proposed for Amber Valley for the period 2008-2028 as this level of housing is considered to be way below the full objectively assessed needs for the Borough and as a consequence contrary to the provisions of paragraph 47 of the NPPF. It is our view that that this minimum threshold is inadequate and should be increased to a minimum of 10,000 dwellings for the period and potentially 11,000 dwellings to be more reflective of the Government’s ONS assessment of housing need.

Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley and the Derby HMA that does meet the full objectively assessed housing needs in the Borough and the HMA.

Fisher German on behalf of the Trustees of Locko Estate: There should be specific reference to Land to the north of Denby being a key growth area within Policy SS1.

Response

The policy has been amended to include specific reference to this site.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: The policy states that strategic housing development will take place in Alfreton, Belper, Heanor and Ripley, to support the local economies of the four towns, but no strategic growth is assigned to Belper. Development of land to the south east of Belper could help to sustain economic growth in the town and improve local infrastructure, including public transport links to existing residential estates.

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Response

This is a matter for consideration when the Site Allocations and Development Management Policies DPD is produced.

Catesby Estates Limited and Kedleston Estate: The policy sets out the minimum number of 9,400 homes to be built in Amber Valley Borough between 2008 and 2028. We welcome inclusion of ‘minimum’ housing numbers as this provides the necessary flexibility within the policy to provide sustainable development to meet demonstrable housing need. However, it is not clear from the policy whether the 9,400 dwellings is to meet the housing needs of Amber Valley only or includes unmet housing needs from Derby; the policy omits any reference to this important point. We consider that the 9,400 dwellings should relate to the Borough and urban extensions to meet Derby City’s needs should be in addition to this number. The ‘minimum’ reference provides flexibility to the policy to accommodate this, however given its strategic importance there should be some policy steer to acknowledge the need to meet Derby’s needs within the Borough and reference the planning mechanisms to which these sites will be considered.

The NPPF states that the local planning authorities must “boost significantly the supply of housing” and “use their evidence base to ensure that their local plan meets the full, objectively assessed needs for market and affordable housing in the housing market area” (paragraph 47). In order for the Draft Core Strategy to be found sound, the Council needs to ensure that this policy can be robustly justified in order to demonstrate that it identifies an objectively assessed housing need in accordance with paragraphs 47 and 159 of the NPPF. Clarification and justification of the housing numbers will help ensure that the Council can demonstrate this.

Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough.

Home Builders Federation: Policy SS1 proposes a minimum of 9,400 dwellings primarily distributed around the four market towns of Alfreton, Belper, Heanor and Ripley. It is not clear from Policy SS1 whether or not the housing requirement figure of 9,400 dwellings is for the housing needs of Amber Valley only or includes unmet housing needs from Derby. The Council should provide greater clarity.

The Housing Requirement Study uses 2008-based ONS/DCLG statistics as its baseline figure, fertility and death rates are as ONS based on SNPP. However household formation (headship rates) and migration are adjusted. The adjustment of household formation rates and migration pattern are questionable. The resultant effect is to reduce the unadjusted figure from 47,900 dwellings to 35,354 dwellings over the period 2008-2028 for the Derby HMA.

Appendix A also states that the Housing Requirement Study uses a vacancy rate of only 2.5% rather than the more usual vacancy rate of 3%. This variation requires explanation and justification by the Council.

The NPPF expects local authorities to take account of migration. It follows that an authority would need good reasons to depart from the projected migration flows. These ought to include an explanation of where the households affected are going to live and the results of consultations with other authorities concerned under the Duty to Co-operate.

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The NPPF requires that local plans provide for objectively assessed demand unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits.

Amber Valley Council will need to demonstrate that whilst three of its market towns (Belper, Heanor and Ripley) are largely surrounded and constrained by Green Belt, this has not unduly influenced the proper assessment of housing needs.

When the “What Homes Where?” and 2011 interim household growth figures are converted into dwellings using the NHPAU demographic method, these alternative projections would equate to housing requirements of 11,708 and 9,577 dwellings respectively without the addition of any constrained demand nor any unmet need from Derby, illustrating housing requirement figures above the 9,400 dwellings proposed in the Draft Amber Valley CS.

Under Paragraph 47 of the NPPF the Council must “boost significantly the supply of housing” and “use their evidence base to ensure that their local plan meets the full, objectively assessed needs for market and affordable housing in the housing market area”.

The Amber Valley Draft Core Strategy is currently unsound because it fails to identify an objectively assessed housing need as required by Paragraphs 47 and 159 of the NPPF.

Paragraph 47 of the NPPF emphasises that Local Planning Authorities should continue to demonstrate a 5 years housing land supply, which is to be supplemented by an additional buffer of 5% to ensure choice and competition in the land market or where there has been a record of consistent under delivery of housing an additional buffer of 20%. Indeed Paragraph 49 of the NPPF goes on to state “relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites”.

With a housing requirement of 9,400 dwellings (470 dwellings per annum) the Council will need to identify 5 year supply of land equal to 2,350 dwellings (470 x 20). At this time there is no evidence whether or not the Council has identified such a supply of deliverable sites neither is there any indication of the application of a 5% or 20% buffer to this land supply. The Council should provide further information.

In the Draft Plan there are a number of references to prioritising brown-field land, which is contrary to the NPPF. Paragraph 17 of the NPPF encourages the re-use of brown-field land it does not advocate a brownfield before greenfield policy. The Council should consider deleting the following references to prioritising “The Council will ensure brown-field land is considered first and Green Belt protected” and “6.2 Maximising use of brown-field land priority”.

Response

Further clarification has been provided in the Core Strategy regarding the 5 and 15 year housing supply in the Borough. It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough.

It is considered that the strategy of prioritising brownfield land, which is fully supported by Amber Valley residents, is in accordance with the NPPF.

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Capita on behalf of Wheeldon Brothers Ltd: We support the housing numbers and land requirements set out which aim to meet objectively assessed needs. The distribution is appropriate.

Response

This support is noted.

William Davis Ltd: William Davis Ltd note that the Housing Target in the Draft Core Strategy are essentially the same as the numbers Pegasus objected to previously and consequently consider said objection to remain valid in terms of the current consultation. We do not consider it necessary to repeat the objection made on the housing numbers to the Growth Strategy consultation, but urge the Council to reconsider the position and review the previous objection.

Whilst William Davis clearly identify our objection to the over reliance on large strategic sites and the need for further information to be included in the Local Plan document, we do not object to the urban concentration strategy identified in Policy.

We consider the policy for most of the growth in the Borough to take place in and around the market towns is a sustainable one, with development being delivered in the most sustainable locations within the Borough.

Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough.

Marrons: Para 6.7 of the Draft Core Strategy confirms that, currently, a minimum of 9.400 dwellings are proposed to be provided in Amber Valley, which represents only 26.6% of the adopted Derby HMA figure of 35,350 dwellings over the period 2008 – 2028. The proposed minimum provision of 39,350 is itself below the Government’s official projection of 47,900 and also less than the former East Midlands Regional Plan requirements of 36,600 for 2006 to 2026 (Appendix A confirms). Our conclusion is that the 9,400 dwelling minimum requirement should be regarded as just that – the minimum and that the Draft Core Strategy should provide for a higher figure of, at least, 9,900 (28% of 35,350).

In the event that the plan is found sound and adopted on the basis that the minimum level of provision of housing provision to be met over the plan period is 9,400 homes, then Policy SS1 will require two further additions to the text. a) Housing provision should be expressed as a net figure, so that any replacement homes arising from the demolition of dwellings within the existing stock, are not then counted towards the additional provision. b) After paragraph two of Policy SS1 the following new paragraph should be inserted to explain that over the plan period ultimately more than 9,400 homes could be provided, if appropriate sites, consistent with the policies in the Core Strategy, come forward.

“Over the plan period the Council will grant planning permission for the development of new homes on sites that are appropriate for residential development, meet the requirements of Policy SS13 and other relevant policies in the Core Strategy. The delivery of new homes in this way will not be constrained by reference to the minimum level of housing provision.”

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Appendix B refers to a projected level of development from windfall sites, between April 2013 and March 2028, in the order of 795 dwellings. Paragraph 48 of the NPPF sets out advice on the inclusion of windfall sites in the assessment of a five years housing land supply. Any allowance for windfall sites should be based on compelling evidence that such sites will continue to provide a reliable source of supply. The advice in the NPPF on Plan Making and policies for housing, however, includes no reference to windfall allowances and, instead, focuses on the preparation of a SHLAA to establish assumptions about delivery from land to meet the identified needs. Recent appeal decisions, including for example, Bugbrooke, Northamptonshire indicate that the reliance on past rates of delivery from windfall sites does not of itself amount to compelling evidence. Furthermore, in this instance, the Council acknowledge, in the Preferred Strategy Paper, that the forward supply of brownfield sites is diminishing.

We therefore consider that any allowance for the delivery of new homes from brownfield windfall sites must be deleted from the estimate of the existing recorded land resource in Amber Valley. The resulting plan will be more robust as a result of this, and, indeed, would not preclude in any event applications coming forward for development on windfall sites.

The Council is faced with a problem of securing the delivery of new homes in the short term; the five years of the plan period between 2013 – 2018. This is an issue which my clients consider should be addressed in the Local Plan and through decisions taken by the Council to approve applications for the development of appropriate sites for new housing in the short term. To some extent, we believe this will be achieved by adopting the modification to policy SS1, as noted earlier in this submission. It will also be remedied to a lesser extent through the allocation in the Core Strategy of additional sites. This would encourage landowners/developers to bring more land forward in the short term and provide a necessary boost to the forward supply of land.

We note in that regard that on two of the strategic sites identified in the Core Strategy (Mansfield Road, Alfreton, and Rabourne Lane, Mackworth), permissions have been granted to facilitate commencement of the developments.

However, the shortfall in provision is so great that these sites, of themselves, will not make any substantial “inroads” into the persistent under-provision of a five years supply of housing land. We consider that the sites which have been identified would not deliver in total the assessed number of new dwellings over the plan period. Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough. The policy has been amended to refer to a minimum of 9,400 homes (net) being required from 2008 to 2028.

It is not considered necessary to add the paragraph that has been suggested, as the Council is already granting permission for non strategic sites in sustainable locations on the edges of settlements that are not allocated in the existing Local Plan, in accordance with the advice in the NPPF.

Gladman Developments:

The Barton Wilmore report, commissioned by Gladman Developments concludes that based on the latest population projections and applying the 2008 based headship rates in order to estimate household numbers, the housing requirement across the Derby HMA for the period 2008-2028 is 48,397 of which the requirement for Amber Valley is 11,391. This is

161 significantly higher than the emerging Local Plan requirements of 35,345 and 9,400 respectively. For Amber Valley, the requirement increases to 11,660 when account is taken of the additional number of jobs that are projected to be created over the period 2011-2028.

Gladman raise significant concerns with the proposed Strategic Growth Sites, in particular the land north of Denby and the sites at Ripley and Codnor which require a new link road. In relation to these strategic sites the Council need to provide evidence of their viability to demonstrate that they represent credible and realistic options.

In relation to these large scale sites the Council need to ensure that they are applying realistic timescales (including lead-in times and delivery rates). The Council should allow for a mix of sites (in terms of size) within their Core Strategy to ensure delivery of housing numbers across the plan period.

The Council, along with the other Derby HMA authorities (Derby City and South Derbyshire), need to reconsider the scale of housing growth required across the HMA, ensuring that this provides an accurate assessment of the full, objectively assessed housing needs and does not constrain housing growth through an over reliance on trend based assumptions that have been conditioned by a period of recession and development constraint. Significant concerns have been raised in relation to the scale of growth proposed and these would render the plan in its current form unsound.

Linked to the tests of soundness outlined in paragraph 182 of the Framework it cannot be considered that the plan has been ‘positively prepared’, as it is not based on a strategy which seeks to meet in full the objectively assessed development needs including the unmet requirements from neighbouring authorities.

The Council claimed objectively assessed needs is based on the Derby HMA Housing Requirements Study (September 2012) and the Derby HMA SHMA update (July 2013). The migration and headship rates assumptions used in their trends based projections are questionable. Trends based assumptions that have been conditioned by a period of recession and development constraints are a wholly inappropriate basis for plan making. They will result in a sub optimal population and household growth projection which, if it becomes the basis for plan period housing requirements, will do great harm to prospects and plans for economic recovery and growth.

In respect of realising economic growth aspirations, it is evident that the housing requirement agreed by Amber Valley, Derby and South Derbyshire will not supply sufficient labour to fulfil the ‘policy on’ objective of adding 20,000 jobs to the HMA economy over the plan period. The requirement identified in the Barton Wilmore report will broadly match the jobs target with labour force growth.

The implications of not planning to meet a housing requirement based on the latest demographic projections are that economic growth within Amber Valley and across the HMA will be constrained. This will result in failure to achieve local, HMA and LEP economic goals and wholly contradicts the government’s growth agenda.

Furthermore, the agreed HMA housing requirement fails to address backlog affordable housing need, which stands at 3,924 households. Moreover, it is unlikely to address current and future housing need in full.

Taking affordable housing need into account, the housing requirement for the HMA will be up to 3,924 greater than our objective assessment of 48,397. Accordingly the minimum

162 housing requirement for the HMA is between 48,397 and 52,321 and for Amber Valley is between 11,660 and 12,574.

Despite stating within Appendix A, that an element of Derby City’s unmet need is accounted for within the proposed 9,400 dwellings, the Draft Core Strategy provides no further details or clarity regarding this. The Core Strategy should express clearly the overall housing requirement, any element of this which is addressing unmet need in neighbouring authorities and the spatial strategy for delivering the proposed scale of growth.

Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough. The Strategic Housing Market Assessment (SHMA) for the Derby HMA produced in 2013 recommended the provision of a minimum of 8,326 dwellings in Amber Valley from 2008 to 2028. The figure of a minimum of 9,400 dwellings referred to in the Core Strategy is 1,074 greater than this figure, to meet the unmet housing needs of Derby and to plan for greater economic growth than that which is currently projected to take place in the Borough during the plan period.

Heaton Planning on behalf of Waystone Developments: The Government has a clear agenda to deliver growth and significantly increase housing supply nationally. This is evident from the NPPF, which seeks to promote sustainable development and the delivery of new housing and a mix of housing to meet the needs of society, both present and future. Whilst the Council is not proposing to radically lower their housing targets from that contained in the RSS, we consider the housing targets contained in the Draft Core Strategy to be insufficiently ambitious to ‘boost significantly the supply of housing’ (NPPF, paragraph 47). Given the clear intent of Government and National Policy, local authorities should be seeking to increase housing provision rather than reduce it.

Amber Valley does not have a five year housing supply. Paragraph 47 of the NPPF states that ‘to boost significantly the supply of housing, local planning authorities should...identify a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with an additional buffer of 5% to ensure choice and competition in the market for land. Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20%’. Due to the Council’s lack of a five year housing supply, there is an even greater onus on the Council to identify suitable and deliverable housing sites in their Core Strategy to make up for the housing shortfall during the Plan period.

Given the above, we consider Policy SS1 and the Council’s proposed housing target to be unsound. The Council should be looking to identify a supply of deliverable sites sufficient to provide five years’ worth of housing against their housing requirements with an additional buffer of either 5% (as a minimum) or 20% (where there is a history of persistent under delivery of housing). Therefore, for the Plan to be sound and, given the historic low levels of housing supply, we recommend an increase in the supply of homes to at least 11,260 (i.e. the baseline requirement plus 20%).

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Response

It is considered that the work carried out by GL Hearn has produced a housing target for Amber Valley that does meet the full objectively assessed housing needs in the Borough.

Comments on Policy SS2: Business and Industrial Land Requirements

Signet Planning:

The Council has not provided a proactive and positive response in its policy framework with regard the provision for new employment and growth in Amber Valley. Specifically the plan does not make provision for the allocation of a strategic employment site (SES) to provide potential for employment growth in Amber Valley in the Plan period.

In these terms the Plan fails the tests on the following basis:

• It has not been positively prepared. The Council’s employment strategy is based on a negative/pessimistic view of existing and projected employment needs. It ignores the opportunities which exist in Amber Valley because of its geographical location, juxtaposition with the A38/M1 and potential attractors to business/investors for a SES. The non allocation of such a site represents a missed opportunity to provide for significant future employment growth both for the existing residents of the Borough (many of whose wards suffer from relatively high levels of deprivation) and for inward investment.

• The employment strategy is not justified. The employment land reviews carried out by the Council’s consultants (BE Group & GL Hearn) acknowledge there are significant deficiencies in the quality of the existing employment land supply – emanating from previous allocations and unimplemented permissions. The Council’s strategy however is for ‘more of the same’. This will not lead to a step change in the delivery of sites for employment development that will generate employment growth rather than periods of inactivity followed by applications for housing.

• The plan will not be effective in delivering a positive employment strategy for Amber Valley in line with Government policy. Furthermore it will not meet the Council’s Strategic Objectives and specifically 2 and 12.

The lack of policy is not consistent with the National Planning Policy Framework (NPPF) regarding the allocation of appropriate land for business and employment development and the deliverability of sustainable growth.

Amber Valley has the potential to make the Core Strategy sound by introducing a policy which sets out the intention to allocate a SES.

To ensure success a SES should have the following qualities:

1. A suitable size to deliver employment growth throughout the Plan period. Thus a site of at least 30 hectares should be brought forward.

2. Be in a strategic location attractive to existing employers and inward investors and having good accessibility to important transport routes.

3. Be located within an attractive high quality environment.

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4. Have the ability to provide employment and related uses over a phased development.

5. Relate well to existing settlements/population and workforce in Amber Valley.

6. Have the ability to provide a link with the local economy through its location and type of site potentially provided (including for local businesses expansion).

7. Have the ability to provide a ‘unique selling point’ in terms of either location, the provision of support services on the site and other uses that may not be employment in nature that would be associated with employment and growth, e.g. education, health and recreation.

The potential to accommodate a SES has not been looked at in sufficient detail by the Council. The Council’s consultants responded to an earlier representation made by Signet Planning regarding a potential SES.

The response to that representation identifies an opportunity for a ‘top-tier’ quality employment site but revealed a lack of understanding of how a SES in Amber Valley would fit alongside other SESs in other local planning authorities. In particular, the following comments can be made:

• Any site of a strategic nature takes a considerable period (often 18-24 months) to obtain planning permission and bring forward for development. It need not have (indeed typically does not have) an ‘end user’ attached to it. Examples of other strategic sites (including in the East Midlands) demonstrates that one does not need an initial end user at the start of an allocation process. The timescale for those end users wanting to be accommodated on a particular site is far less than the policy and allocation process being contemplated. They need “oven ready” sites.

• An SES needs to provide good quality employment land throughout the Plan period. It is therefore unrealistic to require a strategic site to have an end user attached to it. Precedent of a number of sites elsewhere indicates that where a site is allocated and brought forward plots are taken up in response to national and regional requirements that change over time.

• There seems to be an acceptance that Amber Valley would not be able to provide a successful SES simply because there are other sites in other local authorities in the East Midlands that have been brought forward. That is a highly negative approach. If the other authorities in which those now successful sites had taken a similar view (i.e. the competition was too tough) those sites would not have been brought forward and investment would not have taken place in areas such as Nottingham City, Gedling, Bolsover etc. Notwithstanding it is clear from the analysis in these representations that neither of the two named “competitor” sites – Markham and Castlewood will affect or be affected by a SES in Amber Valley. The concerns of GL Hearn have been dealt with. There is the opportunity to raise the economic profile of Amber Valley and generate much needed jobs in an area of high deprivation and across the broader Borough where out-commuting is high.

• The provision of a quality strategic employment site should take place outwith local quantitative assessments of employment land in the Borough.

The planning arguments in favour of SESs have been set out and are considered to be particularly strong and will address the failed tests of soundness which the Core Strategy currently does.

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The experience of both Knight Frank and Rigby & Co commercial agents reveals the following:

• Certain parts of Amber Valley possess the qualities of good accessibility, environment and workforce availability that could enable a strategic site to develop successfully.

• There are a regular list of national and regional requirements from employers and development organisations that Amber Valley currently could not provide for. Assuming those requirements will continue into the future the provision of a strategic employment site would allow the opportunity for investment in the Borough that has not been able to happen before.

• The Borough has had a large employment site potentially available in the past – at Cinderhill. However, the high cost of bringing that site forward resulted in it never being viable or deliverable. The policy allocation for a strategic employment site needs to emphasise deliverability.

• The location of part of Amber Valley is in an area where local business and economic organisations – most recently the Local Enterprise Partnership (LEP) – have identified as a potential area of search for significant new investment, Amber Valley should respond to those initiatives.

Overall there is significant potential over the course of the plan period for economic investment in Amber Valley based around strategic employment needs (which could now be generated more quickly due to the recovery from the recession; related local economic community and educational investment) and the attractive location of parts of Amber Valley to meet such requirements.

There has been no analysis of these requirements or how strategic employment sites work in the Council’s Core Strategy. This is a significant omission. A policy should therefore be included within the Core Strategy for the Council to identify a strategic employment site as part of the next stage of the policy evolution. Such a site should have an area of at least 30 hectares and have the qualities of accessibility, deliverability, environmental quality and relationship to existing settlements and workforce. The lack of an end user in this regard is an irrelevant consideration as the policy will be extant on the timeframe of the Core Strategy.

These representations identify the need for a SES and the suitability of the A38/ Alfreton corridor as a location for a Strategic Employment Site where benefits to the Borough will be maximised. The Council is therefore urged to reconsider its strategy in terms of employment (which is considered to fail at least three of the test of soundness of the strategy) and include an appropriate policy for the identification of a SES.

These representations have examined the Council’s evidence base to the Draft Core Strategy including reports prepared by GL Hearn and the 2008 BE Employment Land Review and consider that the Draft Core Strategy is unsound as it is not justified, positively prepared, effective or compliant with national policy as outlined in the National Planning Policy Framework.

The representations raise a number of issues

1. The draft Core Strategy has not satisfactorily addressed the need to promote sustainable economic growth in the Borough over the Plan period. It does not plan proactively to “B It

166 does not set out a clear vision and strategy for the area that proactively encourages sustainable growth. Furthermore it does not respond positively to the evidence base which indicates both a qualitative and quantitative need for employment land.

2. The Representations establish a need for a Strategic Employment Site in the Borough; it is a misinterpretation of the market and the evidence to take the view that to develop such a site in the Borough would affect and would be affected by the two “competitor” sites identified by G L Hearn at Castlewood and Markham. Knight Frank has demonstrated that would not be the case.

3. The draft Core Strategy indicates that 75 hectares of employment and business land is required over the plan period (2008-28); this must be considered as a minimum in view of the more rapid take up of the “competitor sites” than anticipated, the unattractiveness of some of the “committed and allocated” sites (51 ha) within Amber Valley, the need to address the high and increasing levels of out-commuting, the need to provide jobs and training opportunities close to areas of deprivation where personal mobility is more restricted and to ensure maximum financial benefit for the local economy.

4. Irrespective of the quantitative need a qualitative need has been identified by both GL Hearn and the BE Group. To bring forward a high quality site there needs to be the right qualities; qualities as set out in these representations that can only be met by the allocation of a single Strategic Employment Site.

5. Taking account of the qualities for establishing a Strategic Employment Site and the opportunities and constraints within the Borough an area of search along the A38/Alfreton corridor has been identified. This area has the following benefits:

• Lying outside the Green Belt

• Lying outside the World Heritage Site

• Being adjacent to the strategic highway network – A38 and M1

• Being adjacent to areas of highest multiple and employment deprivation where greatest benefits would accrue.

• Provide a very significant economic multiplier effect on areas of highest deprivation.

• Lying within the area of “development potential in the east of the Borough close to the A38/Alfreton” as highlighted in para 5.26 of the GL Hearn July 2013 report

6. A Strategic Employment Site would create its own identity and the delivery of B1, B2 and B8 uses and with the ability to accommodate ancillary uses such as education/training, hotel, restaurant, crèche etc.

7. Development of a Strategic Employment Site cannot be dependent on identifying an end user ahead of allocation and planning consent. This has been clearly demonstrated by both Knight Frank and Rigby & Co. Local examples at Markham, Castlewood and Sherwood Business Park have all developed successfully without any identified users. Roads and sewers have been constructed and development has followed. The draft Core Strategy neither reflects the process or the market when it states “insufficient interest has been

167 demonstrated by potential employers to require a site of this scale to be allocated”. This demonstrates a lack of understanding of the reality of commercial investment.

In view of the above it is considered that the current draft Core Strategy is unsound as it is not justified, effective, positively prepared or compliant with National Policy. It is considered that an additional policy is required.

Response

Policy SS2 has been amended to state that when looking to allocate new business and industrial sites in the Site Allocations and Development Management Policies DPD, a review of existing business and industrial land allocations will take place, in order to ensure that a minimum of 75 hectares (net) of business and industrial land will be provided between 2008 and 2028 for economic growth and future employment needs and to ensure that sufficient high quality sites are included in the overall provision.

Comments on Policy SS3: The Role of Settlements

Savills: The identification of Somercotes as a local centre at which the draft policy seeks to encourage a balanced approach to the planned level of housing and employment growth is supported.

Response

This support is noted.

Gladman Developments: Gladman note that the Draft Core Strategy refers to more locally focused development occurring in Langley Mill, Duffield, Codnor, Leabrooks, Swanwick and Somercotes and the rural villages – however the Draft Core Strategy does not provide any further details or clarity regarding the scale of growth that should be going to these settlements. Gladman submit that the Core Strategy needs to be more specific on the level of growth that will be apportioned to these villages.

Gladman note that the Core Strategy evidence base does not include a settlement hierarchy or any detailed assessment of the settlements below the four market towns of Alfreton, Belper, Heanor and Ripley. This is a significant concern, these lower tier settlements will need to take a degree of housing growth over the plan period.

Due to the absence of a settlement hierarchy Gladman have undertaken a brief and initial assessment of settlements in Amber Valley. Following this initial review Gladman submit that there are a number of settlements within Amber Valley that when assessed in relation to the scale of services and facilities that are available are sustainable settlements and should be subject to further consideration with regards to the scale of housing growth directed to them.

An example of a sustainable settlement within Amber Valley is Crich. This settlement currently offers a primary school, food/convenience store, post office, medical centre, pharmacy and opticians (this is not an exhaustive list). This settlement is not heavily constrained and does not fall within the Green Belt. Gladman therefore submit that through the Core Strategy the Council should be directing further housing growth to sustainable settlements such as Crich. This would help meet local needs but also play an important role helping to sustain and strengthen the existing services and facilities in these locations.

These types of settlements, for example Crich should through the Core Strategy proposals be directed a greater degree of housing growth. This would help meet localised needs but

168 also play an important role helping to sustain and strengthen the existing services and facilities in these locations.

Response

The allocation of non strategic housing sites in villages will be considered when the Site Allocations and Development Management Policies DPD is produced.

Comments on Policy SS4: Town Centre Regeneration in Alfreton

Capita on behalf of Wheeldon Brothers Ltd: We endorse the policy as set out.

Response

This support is noted.

Comments on Policy SS5: Town Centre Regeneration in Belper

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: The strategy for regeneration in Belper should be much broader than promotion as a tourist attraction and maintaining the market town quality. A broad range of employment opportunities is needed, with potential for quality office development and encouragement of creative and productive industries. A masterplan or Neighbourhood Plan is certainly required to coordinate the complex constraints on the numerous potential redevelopment sites and achieve the optimum distribution of retail, service sector and other employment development, and new community facilities (sports, library, adult education etc.) which are under consideration.

Is this the place to mention the opportunities which would arise from diverting mainline rail services away from Belper Station (HS2 and/or a new electrified Midland Mainline) and freeing up capacity for much more frequent local services to Chesterfield, Sheffield, Derby, Nottingham, Leicester and Birmingham?

Response

The Borough Council will consider if a masterplan is required for Belper, as stated in the policy. The comment regarding opportunities which would arise from diverting mainline rail services away from Belper Station is noted, but the text in the document has not been changed.

Comments on Policy SS8: Development in Town Centres

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Belper town centre boundary should include the railway station and the temporary extension to the Field Lane car park (proposed leisure centre site, which was in residential use when Roger Tym report was produced).

Response

The town centre boundary has been amended to include the proposed leisure centre site.

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Comments on Policy SS9: Primary Shopping Frontages

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Belper: Include both sides of Bridge Street between King Street and Derwent Street in primary frontage. This part of the town centre has some good and lively shop-fronts, a high pedestrian footfall due to car parking in Derwent Street, and forms the key impression of the town to visitors passing on the A6. Consider excluding the return frontages on Campbell Street and Green Lane.

Response

It is not considered that these changes are required.

Capita on behalf of Wheeldon Brothers Ltd: We would question whether the policy is reflective of the realities of the high street and changing patterns of shopping and town centre use. Primary shopping frontages should have an active mix of high street uses not just A1 retail. The nature of retailing and shopping is also changing with increase in online retailing. The high street must be able to adapt to these changes and to seek new active uses. The policy risks encouraging vacancy rather than active uses.

Response

It is considered that primary shopping frontages play an important role in retaining and enhancing the vitality and viability of the most important shopping areas in town centres.

Comments on Policy SS10: Green Belt

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Consider removing SHLAA site AVBC/2008/0153 (Far Laund, Belper) from Green Belt to enable modest (non-strategic) ‘rounding off’ development in an area surrounded by existing development on three sides and thus not of importance to the purposes of the Green Belt.

Response

The allocation of this site will be considered when the Site Allocations and Development Management Policies DPD is produced.

Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Addition of reference to safeguarded land could be added to Policy SS11/associated plan instead of SS10.

Response

It is not considered that there is sufficient evidence to justify a need for Green Belt land to be safeguarded.

Fairgrove Homes Limited: A considerable proportion of the Borough is designated as Green Belt. Many smaller settlements and villages are washed over by the Green Belt in which development will be severely constrained by Policy SS10. This seems completely contradictory to proposals under Policies SS1 and SS3. Policy SS1 proposes that growth outside the four market towns will take place “within the settlements of villages at the most accessible and sustainable locations, that promote the vitality and viability of communities” whilst Policy SS3 states “development will be encouraged to support a balanced approach to the planned level of housing”.

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Response

The policy allows limited infilling in villages.

Home Builders Federation: A large proportion of the Borough is designated Green Belt. Many smaller settlements are washed over by the Green Belt in which development will be severely constrained by Policy SS10 - Green Belt. This seems contradictory to proposals under Policies SS1 and SS3. Policy SS1 proposes growth outside the four market towns taking place “within settlements of villages at the most accessible and sustainable locations, that promote the vitality and viability of communities” whilst Policy SS3 - The role of settlements states “development will be encouraged to support a balanced approach to the planned level of housing”.

Since the revoked EMRP recognised the difficulty in finding land not designated as Green Belt to meet the objectively assessed housing needs of the Borough, it is incomprehensible that the Council is not proposing a comprehensive review of the Green Belt as part of the Local Plan process. Paragraph 83 of the NPPF states that “LPAs with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy”.

Whilst under Policy SS11 the Council is proposing to amend the Green Belt boundaries for the strategic sites at Ripley and Codnor, it would be appropriate following a comprehensive review of the Green Belt for the Council to consider establishing boundaries around individual settlements within the Green Belt rather than continuing with the existing policy of the Green Belt washing over these settlements. The washing over of settlements in the Green Belt does not fulfil any of the five purposes of the Green Belt as defined in Paragraph 80 of the NPPF. Such a review of Green Belt boundaries would be in compliance with Paragraph 84 of the NPPF, which promotes sustainable patterns of development by channelling development towards towns and villages inset within the Green Belt, as well as fulfilling the stated objectives of Policies SS1 and SS3 in the Draft Local Plan.

Response

171 the Green Belt where no exceptional circumstances could be demonstrated were not selected as preferred sites, as they would involve a significant reduction in the distance from nearby settlements and the new boundaries created would not be permanent in the long term and capable of enduring beyond the plan period.

Capita on behalf of Wheeldon Brothers Ltd: Policy SS10 is wholly unnecessary in the context of the NPPF which it significantly repeats. It is not a strategic level policy. Policy relating to the re-use of existing buildings should not go further than the NPPF guidance and should not inhibit a pragmatic approach to sustainable re-use of existing buildings.

Response

The policy is not any more restrictive than the NPPF in respect of the re-use of existing buildings and reflects the wording of the existing Local Plan policy.

John Church Planning Consultancy on behalf of David Bradbury: The policy does not follow and is inconsistent with the wording set out succinctly in paragraphs 89 and 91 of the NPPF and it should be simplified accordingly, unless it can be demonstrated that the circumstances in Amber Valley justify the changes. It is not accepted that such a situation arises.

Response

The policy has been amended to better reflect the wording in policy 89 of the NPPF.

Comments on Policy SS11: Amendments to the Green Belt

Barton Willmore on behalf of Taylor Wimpey UK: We object to this Policy on the basis that there appears to be no robust evidence base in the form of the Green Belt Review that underpins the decision to release land from the Green Belt at two allocated housing sites at land to the north and east of Ripley and land to the east of Codnor. The evidence that was used to form this policy suggested on page 46 of the Draft Local Plan (the NPPF and the former East Midlands Regional Plan) is not considered to be sufficient evidence. The East Midlands Regional Plan was revoked in April 2013 and no longer forms part of the Development Plan and as such none of the policies contained within it no longer apply. Furthermore paragraph 80 of the NPPF clearly states that the fundamental aim of the Green Belt policy is to prevent urban sprawl and paragraph 83 states that once established, Green Belt boundaries should only be altered in exceptional circumstances. We therefore consider this Plan fails the test of soundness as it is not justified based on proportionate evidence or is it consistent with national policy.

Response

No other strategic Green Belt sites in the Borough can demonstrate exceptional circumstances and other sites in the SHLAA that are not in the Green Belt are deliverable and can fulfil the full, objectively assessed housing requirements in the Borough during the plan period. Therefore, no formal Green Belt review as such is considered to be necessary.

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Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Any land removed from the Green Belt should be replaced by extending the Green Belt between Heage and Ambergate, to prevent a net loss of Green Belt area and to prevent coalescence of settlements.

Response

This is not considered to be necessary.

Savills: The justification for the A610 link road and the housing at Ripley and Codnor appears to be circular. 6.15 states that the road will enable new housing development, presumably in the area around Ripley. It is stated in the Strategic Sites Policies SG2 and SG7 that the housing development must support the delivery of the link road. The release of land for the link road and the housing appears to be a self-fulfilling prophecy. An adequate case for neither has been made in the Core Strategy.

Response

As stated elsewhere in this document, the Borough Council considers that the provision of the long awaited A610 link road between Ripley and Woodlinkin does represent exceptional circumstances for the land between the new road and the settlements of Ripley and Codnor to be taken out of the Green Belt. It would not create urban sprawl, as no other settlements exist to the east of where the new link road would be located. The new road would also provide a new clear permanent boundary for the Green Belt. No other Green Belt sites in the Borough can demonstrate exceptional circumstances and other sites in the SHLAA that are not in the Green Belt are deliverable and in sustainable locations that can fulfil the full, objectively assessed housing requirements in the Borough during the plan period. Therefore, no formal Green Belt review as such is considered to be necessary.

Fairgrove Homes Limited: Since the revoked East Midlands Regional Plan recognised the difficulty in finding land that is not designated as Green Belt to meet the objectively assessed housing needs of the Borough, it is completely unbelievable that the Council is not proposing a comprehensive review of the Green Belt as part of the Local Plan process. Paragraph 83 of the National Planning Policy Framework states that: “LPAs with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy.”

Whilst under Policy SS11 the Council is proposing to amend the Green Belt boundaries for the strategic sites at Ripley and Codnor, it is therefore completely appropriate following a comprehensive review of the Green Belt for the Council to consider establishing boundaries around individual settlements within the Green Belt rather than continuing the policy of the Green Belt washing over these settlements and villages. The washing over of settlements and villages in the Green Belt does not fulfil any of the five purposes of the Green Belt as defined in Paragraph 80 of the NPPF.

A review of Green Belt boundaries such as this would be in compliance with Paragraph 84 of the NPPF, which promotes sustainable patterns of development by channelling development towards towns and villages inset within the Green Belt as well as fulfilling the stated objectives of Policies SS1 and SS3 in the Draft Local Plan.

Response

173 to be taken out of the Green Belt. It would not create urban sprawl, as no other settlements exist to the east of where the new link road would be located. The new road would also provide a new clear permanent boundary for the Green Belt. No other Green Belt sites in the Borough can demonstrate exceptional circumstances and other sites in the SHLAA that are not in the Green Belt are deliverable and in sustainable locations that can fulfil the full, objectively assessed housing requirements in the Borough during the plan period. Therefore, no formal Green Belt review as such is considered to be necessary.

Oxalis Planning: We agree that relatively minor changes to the Green Belt boundary will be identified in the Site Allocations document. However, we object to the S11 proposed restriction which will prevent smaller housing or other development sites coming forward in locations where positive and beneficial impacts could be demonstrated. The Core Strategy should make explicit the opportunity at Site Allocations stage that the Green Belt will be amended where development sites are identified and allocated.

Response

There are a number of sites in the SHLAA that are not in the Green Belt and are deliverable and in sustainable locations that can fulfil the full, objectively assessed housing requirements in the Borough during the plan period. Therefore, there is likely to be no need for Green Belt land to be allocated in the Site Allocations and Development Management Policies DPD, unless it can be demonstrated that the existing boundary has been incorrectly drawn.

Capita on behalf of Wheeldon Brothers Ltd: We endorse the amendments as necessary to accommodate the growth needs of the Borough, recognising wider constraints. The policy should not restrict boundary amendments in the site allocation document to ‘minor’ and should allow a contingency and flexibility or more significant revisions if necessary.

Response

John Church Planning Consultancy on behalf of David Bradbury: Land at Kilburn Lane, Belper to which SHLAA reference AVBC/2008/0181 applies should have been considered to justify an amendment to the Green Belt boundary.

By determining that any minor changes to the boundary in the proposed Site Allocations and Development Management Policies document will be confined to very narrow criteria, Policy SS11 represents an insufficiently robust assessment of the advantages to be gained in this and other highly sustainable locations by relaxing an inappropriately delineated Green Belt that is not justified in present circumstances. This will lead to increased pressure to release greenfield sites for development that could be more appropriately located if slightly greater flexibility is demonstrated.

Such a situation would then be compatible with the requirements set out clearly in paragraph 83 of the NPPF.

Response

There are a number of sites in the SHLAA that are not in the Green Belt and are deliverable and in sustainable locations that can fulfil the full, objectively assessed housing requirements

174 in the Borough during the plan period. Therefore, there is likely to be no need for Green Belt land to be allocated in the Site Allocations and Development Management Policies DPD, unless it can be demonstrated that the existing boundary has been incorrectly drawn.

Gladman Developments: Through the Core Strategy the Council are proposing to remove land from the Green Belt at Ripley and Codnor without undertaking a full, comprehensive and strategic review of the Green Belt. Without this robust evidence base the Council cannot know that these sites are the most appropriate sites to be removed when considered against the five purposes of the Green Belt (outlined in paragraph 80 of the NPPF). The Council need to undertake a full, comprehensive review of the Green Belt to inform the choices made within the Core Strategy otherwise the plan will be found unsound.

Gladman note that the sites in Ripley and Codnor, which are proposed to be removed from the Green Belt, have not been subject to a review assessing the role and purpose they play as part of the Green Belt.

Response

Comments on Policy SS12: Countryside

Antony Aspbury Associates on behalf of Omnivale Limited: This policy is inconsistent with the provisions of paragraph 28 of the NPPF in respect of supporting a prosperous rural economy. The first bullet of paragraph 28 seeks to support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well-designed new buildings.

Policy SS12 does not determine between residential development and economic development and indicates that new development will only be permitted if it is essential in conjunction with the requirements for agriculture or forestry.

National Policy however has moved on and paragraph 28 specifically refers to supporting all types of business and enterprise in rural areas. This policy is not therefore consistent with national policy. If SS12 is intended to relate to new residential development, then the policy wording needs to be clear in this regard.

Response

This policy is very similar to the existing Local Plan policy and it does support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well-designed new buildings. Criteria b) states that new development will be permitted in the countryside if it is necessary and cannot be reasonably be located within a settlement and criteria c) states that development will be permitted if it will improve the viability, accessibility or community value of existing services

175 and facilities in settlements remote from service centres provided by the towns and larger villages. It should also be noted that existing Local Plan policy ER6 (Diversification of the rural economy) has been saved and will be amended if necessary when it is included in the Site Allocations and Development Management Policies DPD.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Settlement boundaries should be defined so that it is clear where this policy applies.

Response

It is the intention that settlement boundaries will be defined when the Site Allocations and Development Management Policies DPD is produced.

Savills: Whilst the intent of the policy may be justified in the context of a complete Local Plan, it is unclear at this stage what the settlement boundaries are to which the policy will apply. There should be consultation on the settlement boundaries together with the draft policy in order to properly consider whether the policy is appropriate in the circumstances to which it will be applied.

Response

It is the intention that settlement boundaries will be defined when the Site Allocations and Development Management Policies DPD is produced.

Comments on Policy SS13: Presumption in Favour of Sustainable Development

Gladman Developments: Gladman welcome the inclusion of Policy SS13, which provides the presumption in favour of sustainable development policy as required by the Framework. However the Council need to ensure that the other policies in the Core Strategy do not contradict with this.

Response

This comment is noted.

Heaton Planning on behalf of Waystone Developments: Whilst we support the content of Policy SS13, we consider the policy should be given greater prominence in the DPD and should feature earlier in the document. The NPPF has a strong emphasis on the presumption in favour of sustainable development and the need for Councils to proactively engage with developers to facilitate sustainable development. At present, we consider that this is not sufficiently reflected in the Core Strategy.

Response

It is not considered that there is a need for this policy to feature earlier in the document. All policies have the same importance regardless of where they are placed.

Comments on Policy SG1: Outseats Farm, Alfreton

Capita on behalf of Wheeldon Brothers Ltd: We fully endorse the identification of Outseats Farm, Alfreton as a Strategic Growth Site. The site has planning permission for up to 500 dwellings by virtue of planning permission AVA/2012/0084.

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Response

This support is noted.

Comments on Policy SG2: Alfreton Road, Codnor

Barton Willmore on behalf of Taylor Wimpey UK: We strongly object to this location for a suitable location for housing growth.

Paragraph 47 of the NPPF clearly sets out the objectives to boost the supply of housing. The NPPF states that local planning authorities should identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged.

We do not consider that the Alfreton Road, Codnor site is deliverable as all of it lies within the Green Belt. The NPPF places great importance on protecting the Green Belt. Paragraph 84 of the NPPF emphasises that sustainable development should be directed towards urban areas outside the Green Belt. For this reason we consider that the Local Plan is unsound as it is not consistent with national policy. Allocating a site that is entirely in the Green Belt, when there are other less contained sited outside of the Green Belt, such as land off Chesterfield Road, Alfreton, is unsustainable and does not conform to the growth objectives set out in the NPPF.

Response

The reasons for allocating this site have already been covered in this document.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Object to this development in the Green Belt, which is poorly connected to the four towns. This site does not form a Sustainable Urban Extension but will promote car-based commuter development serving Greater Nottingham rather than contributing to local economic development.

Response

The reasons for allocating this site have already been covered in this document.

Gladman Developments:

Gladman raise concerns with the provision of the new A610 link road and the impact this will have on the delivery of this site over the plan period. A new link road such as this would take a significant time to deliver and have considerable financial implications.

The Council needs to have clarity on the funding arrangements for the new link road (and whether this will include any Government funding), the need for an inquiry in relation to this and any necessary CPO’s. These considerations should all be factored into the timescales for the delivery of this Strategic Growth Site.

Gladman note that the Council had historic proposals for a similar link road, Ripley to Codnor bypass; these proposals were planned and protected for over 40 years. The Council claims that the current proposals differ from the previous ones and that they are more attainable.

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However, again there is a lack of clarity regarding why these current proposals are deliverable.

Response

The reasons for proposing the new A610 link road have already been covered in this document. A planning application for this scheme and supporting evidence have now been submitted and a funding package is being finalised.

Comments on Policy SG3: Land North of Denby

Fisher German on behalf of the Trustees of Locko Estate: Policy SG3 is supported as a strategic site that will deliver significant housing, education, community and infrastructure development on a brownfield site. The allocation of Land to the north of Denby offers real opportunities to consolidate the existing community; improve education facilities; provide new shops, healthcare and other services; to improve recreation facilities; provide new public open space and public footpaths; improve infrastructure and provide employment development. The strategic site would also provide the opportunity to create a community using high quality design and environmental standards delivering a mix of housing types and tenures including family homes, elderly person’s accommodation and affordable housing. Notwithstanding the overall support for the allocation of this strategic site at Denby, there should be some flexibility to allow a phased development of the site particularly given the five year housing land supply shortfall experienced by AVBC at present. The significant shortfall in the housing land supply is increasing pressure to release sites, some of which may not be favoured as housing allocations.

An immediate ‘Phase 1’ development could be delivered on the area between Derby Road and the former railway line, which would bring about 130 dwellings, including affordable homes as well as provide open space, contributions towards education, improvements to the highway network and remediation of this area of land.

Response

These comments are noted.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Question whether this site is deliverable, given the failure of previous attempts (in more favourable economic circumstances) to bring development forward on the land. Any new local centre should not compete with surrounding town centres. Risk that local centre will draw east Belper residents away from Belper town centre. Public transport improvements required to connect any development to Belper town centre.

Response

These comments are noted.

Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Support the policy. However, there are a couple of issues raised which we request officers revisit. We note that the boundary of the Strategic Growth site Policy SG3 ‘Land North of Denby’ excludes the adjoining Green Belt land from the Draft Core Strategy. Officers will recall the previous consultation document for the Preferred Growth Strategy confirmed that “…the development of this Green Belt land would provide a further 1,200 dwellings to create a development of 3,000 dwellings in total, but this would not be deliverable by the end of the plan period in 2028” (Appendix A, page 26). CEG does not object to this conclusion and timescale as a matter of principle, however, the current approach (which does not identify

178 the Green Belt land), fails to address the need to fix Green Belt boundaries that are capable of enduring beyond 2028. In reviewing Local Plans the National Planning Policy Framework (para 85) advises local planning authorities to, amongst other things and where necessary, identify areas of ‘safeguarded land’ in order to meet longer-term development needs stretching well beyond the plan period. In this context, and given the already identified comprehensive sustainable development at Land North of Denby, CEG reiterates that the adjacent Green Belt land should be identified as ‘safeguarded land’, with an individual policy or added to SS10 or added to SS11.

Response

It is not considered necessary to identify safeguarded land at this site.

Marrons: The main strategic allocation is the land north of Denby. The site is allocated for development in the adopted Local Plan and was recognised as a strategic site during the preparation of the plan. However, whereas this was allocated as a mixed use development, including 300 dwellings, in the Local Plan, the Draft Core Strategy now proposes to allocate the site for 1,800 dwellings. Our clients support the Council’s reliance on the development of this site.

However, the site would be unlikely to deliver 1,800 dwellings over the plan period to 2028, for the following reasons:

• This is a substantial strategic site with a number of different owners. Part of the site requires remediation from contamination. These factors alone suggest that the development and occupancy of the first dwellings, following the grant of permission, the satisfaction of pre-development conditions, conclusion of agreements/obligations under Section 106, and the approval of reserved matters, will not take place until 2016/17, at the earliest. This is a year later than the Council’s estimate of first completions, as set out in Five Years Land Supply Statement; Large Housing Sites Projection.

• Our clients, who own a large part of this site, have still not been approached by the Council or the proposed developer. Their collaboration is essential for a comprehensive scheme

• Under a 12 year development programme, with increasing numbers of housebuilder participants from year one onwards, the site would yield, in our view, no more than 1,050 dwellings, with three housebuilders in place 2019/20 onwards. The projected build rate is set out in the following table:

Table 1. Projected House building Rate – Cinderhill 2016/17 – 2027/28 2016/17 25 dwellings 2017/18 50 dwellings 2018/19 75 dwellings (2 x developers/housebuilders) 2019/20 100 dwellings (3 x developers/housebuilders) 2020/21-2027/28 100 dwellings per annum Total: 2016/17-2027/28 1,050 dwellings

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• The need to address certain thresholds of necessary service and infrastructure provision to be secured during the development programme in order to progress the later phases of the scheme.

• On the basis of a potential capacity to provide up to 1,800 homes from this site, then we estimate some 750 dwellings will not be provided during the plan period (1,800 – 1,050 = 750). We therefore calculate that sites to accommodate an additional 1,430 dwellings need to be allocated.

Response

These concerns are noted.

Gladman Developments: Gladman note that the current proposal is a large site (85.2ha) that is not well related to an existing sustainable settlement and is fundamentally in an unsustainable location. Gladman raise concerns with the approach taken by the Council to roll forward and amend this old Local Plan allocation. Old allocations such as this may not have been delivered due to the presence of significant constraints or the requirement for new infrastructure that makes the site unviable. This site should be assessed in detail, particularly due to its failure to deliver previously (despite the allocation) and the Council need to have a significant degree of certainty regarding its delivery. Through the Draft Core Strategy significant reliance is being placed on the delivery of this Strategic Growth Site. A ‘new town’ or development of this scale will be a long time in gestation, there may well be significant planning issues to overcome and infrastructure will need to be in place prior to the delivery of any housing on site. The proposal of 1,800 dwellings at the land north of Denby is not a credible option until it has been tested and demonstrated through a viability assessment that it has a realistic prospect of being delivered.

Response

These concerns are noted.

Comments on Policy SG4: Newlands/Taylors Lane

Antony Aspbury Associates on behalf of Omnivale Limited: We support the identification of land at Newlands/Taylor Lane as a strategic growth site in accordance with the development areas identified in the Draft Core Strategy. The two separate development areas and connecting areas of Green Space comprising the Bailey Brook corridor and adjoining open land are within one ownership and the owners are committed to bring the sites forward for development within a comprehensive scheme.

Response

This support is noted.

Comments on Policy SG7: Nottingham Road, Ripley

Barton Wilmore on behalf of Taylor Wimpey East Midlands: We strongly object to this location for a suitable location for housing growth. Paragraph 47 of the NPPF clearly sets out the objectives to boost the supply of housing. The NPPF states that local planning

180 authorities should identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. We do not consider that the Nottingham Road, Ripley site is deliverable as the northern part of the site lies within the Green Belt. The NPPF places great importance on protecting the Green Belt. Paragraph 84 of the NPPF emphasises that sustainable development should be directed towards urban areas outside the Green Belt.

Allocating a site that is entirely in the Green Belt, when there are other less contained sited outside of the Green Belt, such as land off Chesterfield Road, Alfreton, is unsustainable and does not conform to the growth objectives set out in the NPPF.

Response

The reasons for allocating this site have already been covered elsewhere in this document and in the Core Strategy.

Gladman Developments: Gladman raise concerns with the provision of the new A610 link road and the impact this will have on the delivery of this site over the plan period. A new link road such as this would take a significant time to deliver and have considerable financial implications. The Council needs to have clarity on the funding arrangements for the new link road (and whether this will include any Government funding), the need for an inquiry in relation to this and any necessary CPO’s. These considerations should all be factored into the timescales for the delivery of this Strategic Growth Site.

Response

These concerns are noted. A planning application for this site and the A610 link road has now been submitted and a funding package is being finalised.

Comments on Policy H1: Housing Type, Mix and Choice

Antony Aspbury Associates on behalf of Omnivale Limited: We fail to see how a bold case policy setting out such a precise and cumulative Borough wide ‘requirement’ for property size and tenure can be effectively applied and justified in the consideration of individual sites and significantly question the worth of such policy. The supporting paragraph is far more justified and is the approach that developers would undertake in any event.

The policy table is again very prescriptive and confusingly introduces percentages of affordable housing in each bedroom size category. Any Affordable housing requirements / aspirations should be confined to the separate affordable housing policy H3 and not set out at this detailed level of specification as there will be considerable variances of need from location to location and site to site.

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For the policy to be justified, effective and consistent with national policy, the word “require” should be replaced by “expect” or “seek” and the supporting paragraph promoted to bold text to form part of the formal policy H1. The table should be deleted.

Response

The policy is only intended to be Borough wide and not site specific. It is not considered necessary to remove the table.

Savills: The policy as drafted is imprecise and unworkable. It requires applicants to have complete knowledge of all housing developments that have and will come forward during the plan period. A policy which applies a blanket mix to all sites is inappropriate in both market terms and in delivering housing to meet local needs. The need for and merit of this policy should be reconsidered.

Response

The policy is only intended to be Borough wide and not site specific.

Catesby Estates Limited and Kedleston Estate: This draft policy seeks to ensure a specific mix of housing is provided on new developments by specifying the percentage of types and tenure of housing required. This has been informed by the Strategic Housing Market Assessment Update 2013 (SHMA). We welcome recognition within the background text at page 59 that an appropriate mix will depend on viability, the local circumstances, and information on local need in a particular part of the Borough, however it is disappointing that this flexibility is not reflected in the actual policy wording which provides a more rigid and onerous requirement.

The SHMA sets out the suggested indicative affordable and open market mix requirements in Figures 135 and 136. However these have been applied as specific targets within Policy H1 and if the policy is adopted, will be applicable to any planning applications made in the Borough. This would include planning applications on sites adjacent to a neighbouring authority boundary where they are being brought forward to address a different need. This would be an issue given the affordable and open market mix requirements in Amber Valley are different to Derby and South Derbyshire. This policy has been informed by the SHMA only and we therefore consider that the policy should be re-worded to provide additional flexibility to account for market trends.

The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and ‘chime’ with their funding constraints.

For the reasons set out above, we feel that the mix specifics should be omitted from the policy altogether. However if the local planning authority are minded to retain these then the policy should be re-worded to ensure that any mix specifics are noted as ‘indicative’ and a mechanism is provided to agree a different mix with the local planning authority if it can be justified.

Response

The policy is only intended to be Borough wide and not site specific. However, the policy has been amended to make it clear that the table is only indicative.

Home Builders Federation: The table contained in Policy H1 – Housing Types, Mix and Choice is too prescriptive. The table should be deleted or revised to give percentage ranges

182 rather than specific percentage numbers. If the Council insists upon such prescriptive percentages perhaps incorporation as specific policy requirements for individual strategic site allocations is more appropriate.

Response

The policy is only intended to be Borough wide and not site specific. However, the policy has been amended to make it clear that the table is only indicative.

Capita on behalf of Wheeldon Brothers Ltd: The Policy takes its lead from the SHMA update. This might be justifiable for the delivery of affordable housing, but it is not justifiable for market housing, which must be determined by the market.

The NPPF is clear that the mix of housing should be based on market trends as well as demographic trends. The SHMA update also notes that its findings are based on demographic trends only and do not take into account market information or supply side constraints. To direct the proportionate mix of housing in this way would be disastrous for delivery and would not meet the actual needs of the market. At worst, the overall requirement and the requirement for market housing should be removed and the split for affordable be set out as a guide.

Response

The policy is only intended to be Borough wide and not site specific. However, the policy has been amended to make it clear that the table is only indicative.

William Davis Ltd: William Davis Ltd considers the requirements established in Policy H1 to be far too prescriptive and believe that such a policy would constrain housing delivery in the Amber Valley. This is particularly relevant to the table included in Policy H1 which includes detailed percentage requirements for housing in the Borough. Such a prescriptive mix policy is not likely to be suitable on all development sites in the Borough and an element of flexibility is needed to allow for consideration of specific site circumstances including local character context. Flexibility is also required to allow for consideration of private market demand. Private market demand does not directly relate to household size and household need with smaller households not necessarily wanting to buy smaller house types. It is essential that a more flexible approach is included within the policy, as without it there is a real danger the size and type of housing being required by Policy H1 will not meet market housing purchaser requirements. Paragraph 50 of the NPPF makes it clear that LPA’s should “plan for a mix of housing based on current and future demographic trends, market trends, and the needs of different groups in the community”.

Response

The policy is only intended to be Borough wide and not site specific. However, the policy has been amended to make it clear that the table is only indicative.

Gladman Developments: The requirement set out in Policy H1 is too prescriptive and should be removed from the Draft Core Strategy. Gladman recommend that the Councils approach to housing mix should be to determine this on a site by site basis, ensuring this reflects local characteristics and evidence of local housing need. Housing type and mix should be led by the market and need. Sites should deliver the types of units that best meet the needs of the communities outlined in the evidence base.

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Response

The policy is only intended to be Borough wide and not site specific. However, the policy has been amended to make it clear that the table is only indicative.

Comments on Policy H2: Housing for Elderly or Disabled People

Home Builders Federation: The wording “should be” is inappropriate and it should be amended to “encouraged”. Lifetime Homes standards is not a mandatory requirement so the Council is imposing such a requirement as a local standard, which must be correctly viability tested. The Council should refer to the document “The DCLG Assessing the Cost of Lifetime Homes Standards July 2012”, which shows the average additional cost for complying with the 12 criterion relating to internal specification is £1,525. There are also further additional costs associated with the remaining 4 criterion for external specifications.

Response

It is not accepted that the policy needs to be amended in this way.

William Davis Ltd: Policy H2 includes the requirement for new developments to be designed in accordance with the Lifetime Homes Design Criteria. Paragraph 173 of the NPPF considers viability and deliverability when plan making and encourages Local Planning Authorities (LPA’s) to avoid policy burdens that would threaten the ability of sites to be developed viably. We consider Lifetime Homes standards to be a prime example of an unnecessary policy burden that could constrain development. Building homes to Lifetime Homes standards would in our opinion have significant cost implications on potential residential schemes and should be considered in any viability analysis done on plan requirements.

In addition to this the Government has shown no sign of supporting or encouraging Lifetime Homes standards as a planning requirement, putting the policy at odds with national policy. The revised ‘Code for Sustainable Homes: Technical Guidance’ (2010) indicated Lifetime Homes Standards were not a mandatory element of the Code until level 6, targeted for 2016 and the Code itself also remains non-mandatory.

In the meantime the Government has pursued accessibility and mobility standards via building regulations, making Lifetime Homes policy requirements effectively redundant.

Response

These concerns are noted, but the Borough Council considers it important that new development is designed to cater for the needs of those people who are disabled and have restricted mobility.

Comments on Policy H3: Affordable Housing

Catesby Estates Limited and Kedleston Estate: The affordable housing requirement set out in this policy is generally acceptable in terms of the triggers and quantum at 30% of the total number of dwellings. In respect of tenure we do not consider that a requirement for 90% social rent with the balance (10%) being intermediate housing will provide an appropriate mix of housing. The definitions of different types of affordable housing is made clear in Annex 2 of the NPPF, which defines social rent, affordable rent, and intermediate housing options. We are concerned that restricting the level of intermediate housing to just 10% (of the 30% overall provision) with no provision of affordable rent, will result in a shortage of this much needed provision across the Borough for the plan period. Without an appropriate mix

184 across the three types of affordable housing, this policy would be contrary to paragraph 50 of the NPPF.

There is also an emerging trend for requiring a greater need of smaller affordable housing units further into the introduction of bedroom tax, which could have implications for demand, particularly when considering the required mix of affordable housing under draft Policy H1 requiring a degree of larger dwellings.

The recognition within the policy of the need for viability testing in certain instances is welcomed in accordance with paragraphs 173 and 174 of the NPPF.

Response

These concerns are noted, but it is not considered necessary to amend this policy, given that this is the existing Local Plan policy and that it refers to the need for viability testing in certain instances.

Home Builders Federation: Policy H3 - Affordable Housing proposes 30% provision of affordable housing on sites of more than 15 units with the preferred affordable housing tenure split of 90% social rent and 10% intermediate housing. This overall proposed level of affordable housing provision and affordable housing tenure split should be viability tested.

Response

William Davis Ltd: Paragraphs 173 and 174 of the NPPF clearly identify that development identified in the plan should not be subject to policy burdens, including affordable housing, which could threaten their ability to be developed viably. The affordable housing requirement established in Policy H3 has not been subject to a viability assessment, with the ‘Key Evidence’ section of text supporting the policy not including an affordable housing viability assessment. Without this assessment the requirement cannot be proven to be viable and policy H3 cannot be considered to be consistent with the policy of the NPPF. No evidence is available to demonstrate that the Borough Council have done the further viability analysis of the policy costs indicated as necessary by the Strategic Level Viability Assessment. Until this is undertaken the 30% affordable housing target must be judged unsound as it has not been adequately justified.

Response

Gladman Developments: Gladman note that the affordable housing issues in Amber Valley remain acute. The Derby HMA SHMA (2013) identifies a substantial requirement for affordable housing in Amber Valley and indicates that 61% of new housing provided would need to be affordable up to 2028 to meet the needs of all households in need. The proposed 30% requirement would fall significantly short of meeting the affordable housing need. Therefore the plan will in effect exacerbate an already large affordable housing issue. It is unclear whether the proposed 30% affordable housing requirement is set at a viable level.

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The Council do not appear to have any viability evidence, which demonstrates that this 30% requirement is set at a realistic level.

Policy H3 states that “normally, 90% of the affordable homes should be for ‘social’ rent (or equivalent), with the balance being ’intermediate’ affordable housing.” The mix of affordable housing tenures should be based on an assessment of local needs. This proposed requirement is too prescriptive. Gladman recommend that this element of the policy is removed, and determined on a site by site basis.

Response

Comments on Policy H4: Viability of Proposed Housing Sites

Antony Aspbury Associates on behalf of Omnivale Limited: We fully support the principle of open viability assessment and recognise that in many cases the appointment of an independent expert is important to reach a satisfactory position on the extent of S106 obligations and the parameters for any subsequent review. However, this approach is not justified in every situation and in this context the first line of section 2) of the policy should be modified to read:

“An independent chartered surveyor is instructed if required by the Council and /or the developer ....”

Response

This policy will only be applied in those instances when a development is not policy compliant, and it is not therefore considered necessary to amend it in this way.

William Davis Ltd: William Davis Ltd welcome Policy H4 but believe that the flexibility to consider viability at the planning application stage does not absolve the Council from its responsibility to consider the viability of its affordable housing target and other policy burdens.

Response

These comments are noted.

Fisher German on behalf of the Trustees of Locko Estate: This policy is supported as it is critical to the delivery of housing development in the strained economic climate.

Response

This support is noted.

Savills: The principle of a policy which acknowledges the viability constraints of delivering affordable housing and provides a mechanism for reconsideration of policy requirements for affordable housing is supported. The policy as drafted is unclear in its application and operation. Specifically, if the independent surveyor is appointed by the Council and applicant, it is presumed that the costs are to be shared, but this is not stated and should be.

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The use and application of the independent surveyor opinion once obtained is not stated and should be consulted upon as it is a vital component of the operation of this policy.

Response

The policy has been amended to make it clear that the costs of employing the independent chartered surveyor will need to be met by the developer.

Catesby Estates Limited and Kedleston Estate: The proposed mechanism set out in within this policy is a significant requirement for any applicant to provide which takes time and resources to carry out, notwithstanding the potential exposure of commercially sensitive information. It should therefore be requested by the local planning authority as a last resort and in exceptional circumstances. Indeed, paragraphs 173 and 174 of the NPPF seek to ensure that local planning authorities viability test their Core Strategy policies so that the majority of developments are viable in the first instance anyway. The local planning authority should therefore ensure that all of the policies in the Draft Core Strategy have been viability tested.

Response

These concerns are noted.

Home Builders Federation: At this time it was not possible to find any viability assessment reports on the Council’s website so a full analysis has not been undertaken.

However the proposed mechanism set out in Policy H4 – Viability of Proposed Housing Sites should be a policy of last resort. The Council in compliance with Paragraphs 173 and 174 of the NPPF whereby development should not be subject to such a scale of obligations and policy burdens that viability is threatened should have viability tested its CS policies so that the majority of development schemes are viable. Policy H4 should only be used in exceptional circumstances.

Response

These concerns are noted.

Gladman Developments: Gladman state that it is now necessary for the local planning authority to ensure that the plan as a whole is viable. Paragraph 173 of the Framework relates directly to ensuring viability and delivery. “Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable. Therefore, the sites and the scale of development identified in the plan should not be subject to such a scale of obligation and policy burdens that their ability to be developed viably is threatened” (paragraph 173). If the Council have adequately considered viability within the preparation process and the policy requirements are realistic based on up- to-date viability evidence then there should be no need for policy H4.

Response

These concerns are noted.

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Comments on Policy R1: Reducing the Use of Non Renewable Energy Resources

Antony Aspbury Associates on behalf of Omnivale Limited: The policy sets out the target requirements yet recognises that viability may be an issue constraining the full policy compliant level of securing energy efficiency and sets out a procedure for viability considerations to be examined and addressed.

Response

These comments are noted.

Catesby Estates Limited and Kedleston Estate: The policy should make reference to the Government’s recent announcements on revisions to Part L of the Building Regulations. It is inappropriate to reference meeting the Code for Sustainable Homes Level 4 by 2016. The Draft Core Strategy will also need to remain flexible to respond to the outcome of the Housing Standards Review in the coming months once the consultation has closed on 22nd October 2013.

Response

These comments and concerns are noted.

Home Builders Federation: Paragraph 154 of the NPPF emphasises that “local plans should be aspirational but realistic”. This is re-enforced by the document “Viability Testing Local Plans Advice for Planning Practitioners” chaired by Sir John Harman and published in June 2012, which states “If the assessment indicates significant risks to delivery, it may be necessary to review the policy requirements and give priority to those that are deemed critical to development while reducing (or even removing) any requirements that are deemed discretionary. The planning authority may also consider whether allocating a larger quantity of land, or a different geographical and value mix of land, may improve the viability and deliverability of the Local Plan”. This emphasis is particularly relevant to the final paragraph of Policy R1 - Reducing the use of non-renewable energy resources.

• the wording “reaching higher standards of sustainability” is too vague and unspecific. The expression has no real meaning and therefore it could be open to misinterpretation.

• reference to meeting Code for Sustainable Homes Level 4 for energy efficiency and carbon emission reductions by 2016 is inappropriate the policy should refer to the Government’s recent announcement on revisions to Part L of the Building Regulations. This is a higher standard than the national standard, therefore the Council should justify the reasons for imposition of such a higher local standard.

• the water efficiency requirement for any home built after 2016 to achieve the water efficiency component of CfSH Level 5/6. Part G of the Building Regulations April 2010 requires water usage of 125 litres per person per day. CfSH Level 5/6 requires a maximum water consumption of 80 litres per person per day. Therefore the Council is setting its own local standard, which should be clearly justified by evidence and appropriately costed in viability assessments.

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• the use of Sustainable Urban Drainage systems can have substantial implications on gross to net developable land ratios. The Harman Report emphasises “One error that has a very large impact on the outcome of viability testing is overlooking the distinction between the gross site area and the net developable area (the revenue- earning proportion of the site that is developed with housing). The net area can account for less than half of the site to be acquired (that is, the size of the site with planning permission) once you take into account on-site requirements such as formal and informal open space, sustainable urban drainage systems, community facilities and strategic on site infrastructure etc. On larger sites, sometimes the net area can be as little as 30%” (page 36 and Appendix B(1).

Response

These concerns are noted.

William Davis Ltd: The current proposals included in policy R1 require climate change and carbon emission standards that go well beyond current Government regulations and seeks to enforce specific levels and requirements of the Code for Sustainable Homes which the Government has not made mandatory. Whilst the NPPF endorses the setting of local requirements they are required to be viability tested, under the terms of paragraphs 173 and 174 (as with affordable housing policy as described above) to ensure they will not adversely affect the delivery of development.

Response

These concerns are noted.

Comments on Policy E2: Quality and Design of Development

Antony Aspbury Associates on behalf of Omnivale Limited: This policy requires that all development proposals meet 21 policy criteria to ensure high quality design, sustainability and achieves an inclusive and accessible environment that respects and enhances local distinctiveness. It is highly unlikely that all development proposals will meet all 21 policy criteria and so this policy as worded is not positively prepared, justified or effective.

The introductory text to the policy should therefore be revised to reflect a more realistic aspiration that most of the policy criteria should be reflected in individual scheme proposals. The following modification to the last paragraph of the introductory paragraph is suggested to make the policy more effective and positive:

“ Therefore all new development proposals should: ...”

This wording places expectation but not outright compulsion on developers to meet the policy criteria and allows flexibility for applicants to justify why a specific proposal cannot meet one or more of the 21 policy criteria. Failure to meet one or more of the criteria does not necessarily mean that the Council’s aspirations for high quality and design are prejudiced.

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Response

The policy has been amended as suggested.

Home Builders Federation:

• the wording “adequate amenity space for each dwelling unit” is imprecise.

• involving financial contributions to the operation of CCTV security systems is inappropriate as well designed development should not require such systems.

• designed to enable solar panels to be added to buildings without difficulty is also imprecise. The exact requirement of the Council is not obvious, it is unclear the interpretation given to such a policy requirement by Development Control officers when assessing a planning application, therefore the policy requirement is inappropriate.

The above mentioned sub clauses of Policies R1 and E2 should be deleted. If the Council retains these policy requirements, it will need to justify with appropriate evidence the necessity of these local standards and viability test these policy requirements in financial assessments including the cost of mandatory national standards plus additional costs for local standards. The Harman Report (page 26) states “The one exception to the use of current costs and current values should be recognition of significant national regulatory changes to be implemented, particularly during the first five years, where these will bring a change to current costs over which the developer or local authority has little or no control. A key example of this is the forthcoming change to Building Regulations arising from the Government’s zero carbon agenda”. The Council should refer to the document “DCLG Cost of Building to Code for Sustainable Homes (CfSH) Updated Cost Review 2011”. Table 2 of this document shows that the cost of building to Code 5 represents an increase of 28-31% on build costs dependant on the type of site and its location. As 80% of the additional costs for the CfSH relate to energy efficiency and carbon emissions, this represents a significant cost increase.

Response

The policy has been amended to take account of some of these comments.

William Davis Ltd: William Davis has concerns on several of the requirements established in Policy E2. Firstly we object to point h) of the policy which requires the provision and operation of, or financial contributions towards the provision and operation of CCTV security systems. We do not consider that such a requirement would be necessary on well-designed developments. We also object to point t) of the policy which requires developments to be designed to enable solar panels to be added to buildings without difficulty. This requirement is overly vague and imprecise and it is very unclear on how such a policy requirement would be interpreted at a planning application stage. In addition to these specific points, it is also important that the requirements in Policy E2 are justified by credible and robust evidence and are suitably assessed in terms of their impact on development viability.

Response

The policy has been amended to take account of some of these comments.

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Comments on Policy E3: Historic Environment

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Supporting text should include reference to the historic remnant landscape of the Duffield Frith and its continuing impact on distinctive settlement patterns.

Response

The background text has been amended as suggested.

Comments on Policy E4: Landscape Character

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Specific reference required to interplay between natural landscape character and historic enclosure and settlement patterns in the Duffield Frith. It would be good to see Derbyshire County Council’s work developed into a more detailed, local SPD.

Response

The importance of the surviving historic landscape in the Borough is referred to in the background text to the policy. The comment regarding producing a SPD is noted and will be dependent on staff and financial resources.

Comments on Policy E5: Special Landscape Area

Antony Aspbury Associates on behalf of Omnivale Limited: The Special Landscape Area designation covers large parts of the rural area of Amber Valley within which countryside polices generally control the nature and scope of new built development that can take place. The conversion of and or modest extension to existing buildings is normally accepted as a more appropriate/ acceptable way to secure modest development in rural areas in particular without adverse visual and environmental impacts. This policy sets out a negative approach to conversion/extension as a starting point and could potentially stifle economic and sustainable initiatives in large rural parts of the Borough. This policy, by its tone does not sit comfortably with paragraph 28 of the NPPF – Supporting a prosperous rural economy , particularly where the paragraph seeks to support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well designed new buildings.

We consider that the emphasis of the policy needs to be changed to be more supportive of the principle of conversion and extension to be in accordance with the NPPF , albeit it is appropriate to require high standards of design so that proposal will not have an adverse impact on the visual quality of the Special Landscape Area.

The policy should therefore be amended to read:-

“Development proposals including conversions of existing buildings and extensions to existing buildings will be supported where they demonstrate high standards of design and construction and do not have an adverse impact on the visual quality of the landscape”

Response

It is not considered that the suggested change to the wording of the policy is necessary, as it already allows development proposals, conversions and extensions to buildings providing they do not have an adverse impact on the visual quality of the landscape.

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Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Concerned that an approach which states that some parts of the landscape are intrinsically more valuable than others (without saying why) is contradictory to the Landscape Character Approach advocated by Policy E4. Essential development in the countryside should be informed by an interpretation and understanding of that landscape, not a merely visual approach.

Response

These concerns are noted.

Comments on Policy IN1: Transport

Antony Aspbury Associates on behalf of Omnivale Limited: We generally support the provisions of Policy IN 1 but are concerned in respect of criterion c) that the threshold level of 25 homes 0.5 ha of employment land requiring the submission of a Transport Statement or Transport Assessment to support development proposals is a very low starting point. We are more concerned that unrealistic expectations of improvement of, or securing access to “sustainable transport” opportunities could come out from this policy impacting upon the viability and deliverability of development schemes . A threshold of 50 dwellings or 1.0 ha of employment land may be more appropriate to reasonably request a Transport Statement or Transport Assessment but if this current threshold is pursued, the wording of criteria c) should be revised to reflect a more pragmatic approach to improving sustainable transport accessibility. The revised policy could read:

“requiring in respect of all development proposals over 25 homes or 0.5ha of employment land that a Transport Statement or Transport Assessment is provided to show how the opportunities for sustainable travel have been considered and taken up where reasonably available , depending on the nature and location of the site”

Response

The policy has been amended to state that a transport statement or a transport assessment will be required in those instances where the highway authority consider it to be necessary.

Comments on Policy IN4: Strategic Transport Infrastructure Priorities

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Unclear why a road scheme is the one strategic infrastructure priority, when Policy IN1 stresses the need to achieve a sustainable pattern of development which minimises the need to travel. Surely the provision of new road infrastructure to deal with perceived existing problems should be the responsibility of the highway authority and Highways Agency rather than funded through new development in the Green Belt.

Response

This comment is noted.

Comments on Policy IN6: Developers Contributions

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: There should be a commitment to introducing CIL, in the interests of transparency and uncertainty.

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Response

The Council has commenced work on introducing a CIL.

Catesby Estates Limited and Kedleston Estate: This policy needs clarification in respect of the payments towards the cost of infrastructure collected through Section 106 contributions and/or the Community Infrastructure Levy to minimise the risk of double counting.

Response

This comment is noted.

Home Builders Federation: Policy IN6 Developer Contributions refers to payments towards the cost of infrastructure collected through S106 and/or CIL. The policy is unclear so there is a risk of actual or perceived double dipping. The Council should provide more clarity by reference to DCLG CIL Guidance dated 2013 Paragraphs 84-89 “The interaction between the CIL and S106 Agreements”.

Response

This comment is noted.

Any further comments you wish to make on the content of the Plan?

Barton Willmore on behalf of Taylor Wimpey East Midlands: Taylor Wimpey own land east of Chesterfield Road, Alfreton. The site is included within the Derby HMA Strategic Housing Land Availability Assessment (SHLAA) (2008 Review), which identifies sites that have the potential for residential development. The SHLAA concludes that land east of Chesterfield Road, Alfreton (Site Ref: AVBC/2008/0079, land adjacent to Derby Road, Alfreton) is potentially suitable for housing. The site extends to approximately 17.4 hectares of greenfield land located to the north west of Alfreton. Taylor Wimpey is committed to the delivery of this site and confirms that the site is available for development immediately. It is in a suitable and sustainable location immediately adjacent to the northern edge of Alfreton and within walking distance of the town centre and could be delivered within the next five years.

Response

The allocation of this site will be considered when the Site Allocations and Development Management Policies DPD is produced.

Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Land off Mill Lane and Kilbourne Road, Belper (AV12): The assessment is flawed as it excludes land at Cherry House Farm which is available for development and would enable a comprehensive development site to be assembled. Land adjacent to Cherry House Farm is available for development, and the owners are in discussion with the adjacent owners to the north and south (Pottery Farm and land off Pinchoms Hill Road) with a view to entering into a consortium agreement should the land be allocated for development. It is agreed that land at Hill Top Farm is not suitable for development due to the adverse impact on the Derwent Valley Mills WHS. We anticipate that the site would be developed in conjunction with the adjacent allocated employment site at Bullsmoor, and this is included on the plan to illustrate a mixed use development.

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Most of the land proposed for development is screened from views from the WHS by the land form. The highest parts of the site are the most remote from the WHS, where development would be seen in the context of existing housing development and would not impinge on views into or out of the WHS.

Inclusion of the land at Cherry Farm House enables a contiguous development area to be proposed and a new through road to be provided. This will also provide a much needed link to the isolated Parks Estate. The new road would fit into the existing landscape and take account of strategic footpath links as segregated cycle/bridleways connecting with the new road.

Response

The allocation of this site will be considered when the Site Allocations and Development Management Policies DPD is produced.

Catesby Estates Limited and Kedleston Estate: Land at Kedleston Road, Quarndon, Derby, a sustainable site that sits within Amber Valley Borough adjacent to the administrative boundary of Derby. Amber Valley Borough council has eight neighbouring authorities and forms part of the Derby Housing Market Area with Derby City Council and South Derbyshire District Council. Clearly the consideration of cross boundary issues in the Borough is important and should be reflected in the emerging Draft Core Strategy. Catesby Estates Ltd is particularly keen to ensure that the Draft Core Strategy appropriately takes into account the requirements of the HMA.

It is worth noting that the existing urban area of Derby City is not able to accommodate more than 10,000 dwellings. The Draft Core Strategy needs to make clear what proportion of the urban extensions for 7,200 dwellings will be located within Amber Valley Borough.

It also needs to clarify that these urban extensions are in addition to the 9,400 dwellings to be provided in Amber Valley. In light of the above, it is clear that there are unresolved issues across the HMA which need clarification within the Draft Core Strategy under the legislative and policy requirements of the duty to co-operate.

We are concerned that there is no reference to potential broad locations for growth to meet the needs of neighbouring authorities, an omission which we feel is significant. There are appropriate sites on the boundary of Amber Valley and Derby City which should accommodate housing growth. The land at Kedleston Road, Quarndon is a good example of an unconstrained site located outside of the Green Belt with capacity to accommodate up to 300 dwellings in a sustainable and appropriate location to meet the identified housing needs of Derby. Given the strategic importance of such sites, we consider this should be addressed as the Draft Core Strategy progresses in order to provide the framework for the subsequent identification of sites through the Site Allocations and Development Management Policies document. Indeed this is common practice elsewhere in the country where broad locations are identified for cross boundary purposes.

Response

The allocation of this site will be considered when the Site Allocations and Development Management Policies DPD is produced.

Home Builders Federation: Duty to Co-operate: Whilst the three authorities in the Derby HMA including Amber Valley are working on separate but aligned Core Strategies, when the Amber Valley Core Strategy (CS) is submitted for examination, the Council will have to demonstrate collaborative working within the wider context of its eight neighbouring

194 authorities and not just those authorities within its own HMA. The Council should co-operate with all its neighbouring authorities to ensure that housing needs are addressed.

Response

A Duty to Co-operate statement has been produced explaining how the Council has engaged with adjoining local authorities when producing the Core Strategy.

Marrons: Our clients’ site at Kilbourne Road, Belper would provide a sustainable urban extension to the town. It extends to 14 ha (35 acres) and could accommodate 250 – 300 dwellings, allowing for the upper slopes of the site to remain undeveloped. The development site lies outside the Green Belt. It is one of the few opportunities around Belper to provide a sustainable urban extension site without recourse to Green Belt land. The NPPF advises that once established Green Belt boundaries should only be altered in exceptional circumstances. Therefore, in the first instance, in seeking to secure sufficient land for housing, the Council should have recourse to sites that lie outside current Green Belt designations, as set out in the Local Plan. Other previously identified land to the north west of Belper, but which is outside the Green Belt, is in a Special Landscape Area, and/or falls within the Derwent Valley Mills World Heritage Site.

Part of the evidence base for the Local Plan is the Derby HMA Strategic Site Options Study. The study considered 25 broad locations to assess their potential for accommodating future housing growth. Within these broad locations the study identified 61 potential strategic sites, including the land at Kilbourne Road as part of a wider Mill Lane/Kilbourne Road site. In commenting on Belper as a broad location for growth the study noted: “Belper could accommodate significant new development in the form of an urban extension and offers a wide range of services that will be able to accommodate new development. Scale and mass of development may be constrained by the historic environment of Belper.”

Our clients consider that the development of the site we are now putting forward would be progressed via the preparation of a development that would have regard to the World Heritage Site buffer zone and the possible impact of the development on that area and the Belper and Milford Conservation Area, the relationship between the development and the Pottery Farm buildings, landscape and topography and how the new housing would be distributed across the site in relation to those factors.

The site is deliverable and developable in the terms of the advice set out in paragraph 47 of the NPPF. The landowners are willing to release the land for development and it is considered that the site is in a suitable location for residential development. There are no environmental constraints to the development of the site. There is every prospect that this site will be available and could be viably developed during the plan period.

In addition to the above site, our clients also consider that the plan should include a further site at Bottles Farm, Denby Bottles (3.2 ha, 7.9 acres). This is an area of white land, outside the Green Belt adjacent to the settlement of Denby Bottles, a suburban satellite to Belper. The Council have been previously referred to this site in our clients’ response to the Options for Housing Growth. The settlement includes a primary school, local shops and employment uses. This site is available for development in the short term and could therefore provide a necessary boost or stimulus to housing provision in this part of the Borough, in line with Government policy. It could accommodate 100 - 120 dwellings. The former Amber Valley Borough Local Plan (November 1991) showed the site as a proposed housing allocation (H1 – 39) within the development limit of the village. The Draft Amber Valley Borough Local Plan also showed the site allocated for housing, but it was taken out of the Plan following the Local Plan Examination, for reasons primarily related to the reduction in housing provision.

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Response

The allocation of these sites will be considered when the Site Allocations and Development Management Policies DPD is produced.

Heaton Planning on behalf of Waystone Developments: Whilst we do not object to any of the individual sites allocated as part of the Strategic Growth Site Policies, we wish to register our objection to the overall approach, including the omission of the Shipley Lakeside site.

The Shipley Lakeside development is of strategic importance and should, therefore, be allocated in the Local Plan Core Strategy, for the following reasons:- 1) Shipley Lakeside is a unique development site. This is evident from the existence of a site-specific policy in the extant Amber Valley Local Plan and a Development Brief dealing with its future redevelopment. 2) The proposed development would make use of a parcel of previously developed brownfield land in the Borough, which has remained vacant and derelict for many years. 3) The development would contribute positively to housing delivery in the Borough (providing up to 400 homes phased over a ten year period). 4) The development would contribute positively to employment provision in Amber Valley. 5) The development of the site would reduce the pressure to release Greenfield sites elsewhere in the Borough for housing and employment growth.

The Amber Valley Local Plan (2006) contains a specific policy in respect of the future development of the former American Adventure Theme Park site, ‘Policy EN3: Major Developed Site in the Green Belt at the American Adventure Theme Park, Shipley’ (saved by the Secretary of State in 2009).

In 2011, a Development Brief was prepared in respect of the site entitled ‘The Shipley Lakeside Development Brief’ to provide a framework against which detailed development proposals for the site will be considered. The existence of this site-specific policy and development brief clearly demonstrates Amber Valley Borough Council’s intent for the Shipley Lakeside site to be re-developed and brought back into beneficial use.

Given the above, we object to the omission of a specific policy in the Local Plan Core Strategy dealing with Shipley Lakeside’s future development.

Response

This site was not previously promoted as a strategic site for inclusion in the Core Strategy. It is the subject of a current planning application which will be determined shortly.

Signet Planning:

The Council is inconsistent in how it deals with green belt release. Its strategy for green belt release is based on a need to construct a new access (A610) through the Green Belt to the east of Ripley/Codnor. As a consequence a considerable amount of housing (1,520 dwellings including Coppice Farm which is not green belt) is proposed in this general locality. This represents some 35% of the total of the non PUA residential allocations in the Borough. Belper has none. This is an inconsistent position with the Spatial Vision outlined in Section 4

196 of the consultation which seeks to concentrate new growth in the four towns of Belper, Ripley, Heanor and Alfreton.

Such a distribution does not reflect the stated Spatial Vision and Strategy; a strategy that was encompassed in the now revoked Regional Spatial Strategy. If the Council is now seeking to opening state one Spatial Vision but pursue another in the draft Core Strategy then it needs to be very transparent and publish robust evidence to support that position.

Belper is one of the four principal towns in Amber Valley Borough. The Local Plan Part 1 Draft Core Strategy does not allocate any housing sites in or adjacent to the current urban boundaries of the town.

It is recognised that the town is constrained by Green Belt and countryside designations but the consultation document does not recognise the strong sub-housing market area of Belper. At a recent planning appeal against the refusal of the Council to approve housing on a site immediately adjacent Far Laund it was recognised that Belper was a strong sub housing market area within Amber Valley. It is then perverse not to allocate sites where people want to live.

In the Preferred Strategic Site Assessment within Appendix E of the consultation document it appears that the Council is considering the proposed land at Cinderhill site (AV13) as the site which will support Belper. However, in the townscape and integration section of the analysis it states that the site is poorly related to services in Belper, Ripley, and Derby. This potential site of 1,800 dwellings is located some distance from Belper and will create its own sub housing market. There is demand to live in Belper itself and the Local Plan Part 1 Draft Core Strategy does not address this issue.

A recent appeal at land off Mill lane, Belper was dismissed due to the potential impact on the World Heritage Site. There are no designated housing sites to the south of Belper. To the east the land falls away quite steeply such that development would be highly prominent. To the west is the Derwent Valley and the main World Heritage site.

To the north is land within the Green Belt but in an area where topography lends itself to development, it lies outside the World Heritage Area buffer zone and out of the River Derwent Floodplain.

It is against this background that this representation is put forward for land off Chesterfield Road/Far Laund as an option for growth in Belper. Concerns have previously been expressed regarding the diminution of the gap between Belper and Heage and it is considered that this can be addressed and the gap strengthened.

This site is to the northeast of Belper which is situated approximately 8 miles north of Derby and 12 miles west of Nottingham. The A6 runs through the heart of the town linking Derby and Manchester via the Peak District.

The site itself is relatively close to the A38 which provides access to the M1. The site is within reasonable walking distance of several bus stops and the town as a whole is served by regular bus services to surrounding towns and villages as well as longer routes to Derby and Manchester. Regular trains between Derby and Matlock on the Derwent Valley Line stop at Belper station centre which is 1 mile to the south west of the site.

The town benefits from a significant number of shops and services including supermarkets, schools, leisure facilities and medical facilities. This comprehensive range of provision and the aforementioned access to public transport presents an opportunity for additional housing in a very sustainable location.

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Overall, the settlement of Belper is considered to have a very strong housing market, it is a place where people aspire to live and a place where people who are seeking to move properties wish to remain in.

The site, which has the benefit of being outside of the World Heritage Site buffer zone, is located within Green Belt. Parts of the Green Belt in this area have only average landscape quality and at the present time there is no defensible boundary to the Green Belt between Heage and Belper.

This site provides a very sustainable extension to Belper in view of its proximity to a full range of facilities and has the added benefit of enabling the creation of a clear boundary to the Green Belt on the north-eastern side of the site.

Land at Far Laund/Whitemoor is referenced as AV11 in the Draft Core Strategy. The Environmental Considerations section demonstrates that the site is largely free of such constraints. Green Infrastructure would be integrated into the scheme as is demonstrated later in this representation.

The need for infrastructure is fully recognised and this is a matter for discussion with the Council. Thus far it has not been possible to establish the precise needs and consequently such is not shown on the illustrative scheme. The Appeal with regard land to the south established that that site was sustainable. Furthermore public transport services could be extended through the site

Overall the draft Core Strategy is unsound and the Council is urged to reconsider its strategy of significant allocation east of Ripley and provide a more balanced approach that also delivers housing in Belper. There should be a full green belt review of sites with a view to releasing green belt land for housing in the plan period or designate it as safeguarded land to meet the future needs of the town.

It is acknowledged that land at Far Laund is located within the Green Belt but as an integral part of the Core Strategy process the Council should review its green belt boundaries to ensure that settlements can grow in sustainable areas. It is maintained that the site represents a sustainable extension to Belper and that its value in green belt terms is not significant. The Council should also give consideration to identifying safeguarded land to ensure that any revised green belt boundaries endure well beyond the Plan Period.

The illustrative plan for Far Laund demonstrates that the identified constraints can be overcome and that overall there is a clear benefit to allocating the site for development not only to secure the delivery of a high quality design residential community but also to seize the opportunity to provide a defined and defensible Green Belt boundary on this side of Belper and allow the town to grow.

Response

The Spatial Vision and Strategy have been amended to make it clearer where new growth is proposed. The reasons why development of land in the Green Belt at Codnor and Ripley are considered to demonstrate exceptional circumstances have already been explained in this document and the Core Strategy. The site at Far Laund, Belper is within the Green Belt and it is considered that exceptional circumstances have not been demonstrated. This site is also particularly sensitive, given its close proximity to Heage. It should also be noted that it is one of the sites that has poor performance against the SA criteria.

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Signet Planning:

In 2008 the Derby HMA authorities commissioned the BE Group to assess the supply, need and demand for employment land and premises in the Derby HMA. There were three elements to the study:

An assessment of the study area‘s economy that will inform the amount, location and type of employment land and premises required to facilitate its development and growth. A review of the current portfolio of employment land and premises. Recommendations on the future allocation of employment land and premises to maintain the study area‘s economic growth.

In the body of the report with regard to Amber Valley it stated:

“There is a shortage of available, immediately developable employment land in attractive locations – much of which exists is poor quality”; and “Amber Valley suffers from generally poor quality land resource, with few obvious opportunities to improve (i.e. with new allocations)”.

It recognised that Amber Valley “really needs to address its land supply, to find better allocations that are more related to key access routes. However, it is accepted that this is difficult and reflects the nature of Amber Valley as much as anything else – dispersed settlements and employment areas divorced from key access routes”.

With regard to Belper it stated:

“There is a real issue in Belper. The viability of Bullsmoor is severely questioned because its access is poor, it is poorly located and situated and lacks prominence; while remaining sites are also small and poor quality”

The BE report scored each of the sites in Amber Valley providing each with a total score of a maximum of 100 and a market-led subtotal of a maximum of 50. Bullsmoor falls at the lower end of the grading system with a score of 46 out of 100 for the total score and just 23 out of 50 for the market-led subtotal. The BE report graded Bullsmoor as low quality.

The draft Core Strategy states that the local authority considers that:

“Taking into account existing allocations, planning permissions granted and development that has taken place since 1 April 2008, there is no quantitative need for any additional businesses and industrial land to be identified, but there is a need to address the qualitative issue, by considering which existing allocations to de-allocate and replace with new allocations of a higher quality”.

The consultation document goes on to indicate that this issue will be addressed in the Site Allocations and Development Management Policies document which will form part 2 of the Local Plan.

The sustainability appraisal of the Amber Valley Local Plan Part 1 – The Core Strategy was published in June 2013. In section 10 it considers the spatial approach to employment growth and distribution. At paragraph 10.3 is refers to the preferred economic strategy for the Core Strategy. This looks to prioritise the areas that need economic regeneration and support existing businesses.

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As with the draft Core Strategy is indicates that the issue of the quality of business and industrial land will be addressed through the allocation of new good quality employment sites‖ and the de-allocation of various employments sites of poor quality. The sustainability appraisal concludes that such an approach would provide the greatest opportunity to attract high quality investment in the Borough.

Appendix III of the Sustainability Appraisal outlines the appraisal findings. It concludes that Option 3 (delete poor quality allocations and identify new high quality sites linked to existing and proposed housing sites) would be the most beneficial approach. It states:

“Option 3 offers a more positive approach for redistributing some of the employment land to more attractive locations. As such, it could have a significant positive impact on the local economy”.

The BE report is clear that Bullsmoor is a low quality employment site. It is unlikely to be attractive to inward investment and so deliver any economic benefits for the Borough if it continues to be allocated for employment purposes. Paragraph 22 of the NPPF goes on to state:

“Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be readily reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities”.

This is very clear advice that where long term protected employment sites have not delivered economic development and benefits in the past, they should not be retained and allocated in that use for the future. Alternative uses should be considered and this representation provides an opportunity to provide housing on a non-Green Belt site which is allocated for development immediately adjacent the settlement boundary of Belper.

Land at Bullsmoor has long been allocated for employment purposes. The site has not been delivered and advice within para 22 of the NPPF is highly material. This is particularly the case in the light of the low BE “Total” and “Market” scores first the site and the overall lack of need for such localised sites. Following discussions with Vaillant there is now an ability to open up the site for housing development and provide benefits and certainly for Vaillant.

There are a number of benefits:

A. Provision of a housing site in a strong sub housing market area. B. The delivery of much needed market and affordable housing in Belper. C. Development outside of the Green Belt. D. Ensure Vaillant has the ability to operate without hindrance, can improve internal circulation and accessibility, improve parking and release land to meet operational needs.

The illustrative plan for Bullsmoor demonstrates that the identified constraints can be overcome and that overall there is a clear benefit to allocating the site for housing development not only to secure the delivery of a high quality design residential community but also to seize the opportunity to provide a defined and defensible Green Belt boundary on this side of Belper.

The Council should review its housing distribution and allocate land at Bullsmoor for housing.

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Response

Consideration of this site being allocated for housing will take place when the Site Allocations and Development Management Policies DPD is produced.

Savills:

Suggests the allocation of part of site AV3 - Land South of Birchwood Lane, Somercotes as a site for approximately 250 dwellings.

Response

Consideration of this site being allocated for housing will take place when the Site Allocations and Development Management Policies DPD is produced.

Freeth Cartwright:

We consider that land at Somercotes Hill, Lower Somercotes is suitable, appropriate and available as a strategic housing allocation for consideration. The site is clearly in a sustainable location on the edge of the existing settlement of Somercotes with good access to local facilities and public transport. Employment opportunities also exist in the immediate vicinity of the site which would further reduce the need to travel by unsustainable means. The land itself is of no particular landscape or ecological merit and preliminary evaluations suggest there are no constraints to its development in this respect. Infrastructure is generally available in terms of drainage etc. and although there may be need to increase capacity and to address surface water, the site is large enough either in its own right or in combination with other land to address these issues viably.

Response

Consideration of this site being allocated for housing will take place when the Site Allocations and Development Management Policies DPD is produced.

DPDS Ltd (Midlands and North): Land at Market Place, Codnor currently supports established employment uses including offices, workshops and associated builders’ yard.

Representations are submitted with regard to the builders yard area of the site which is currently subject to saved Local Plan policy LC9. It is understood that this site has been subject to continued planning consent for its current use for over 20 years. Planning permission was originally granted on a temporary basis via appeal on 21 September 1991. This permission was renewed on 7 January 1998 (AVA/1097/0855) for 5 years and 19 May 2003 (AVA/2003/0178) for a further 5 years.

The current planning permission (AVA/2009/1110) establishes further temporary use of the land with regard to the storage of building materials, plant and equipment and is due to expire 31 December 2018. The reason for limiting the permanence of the use relates to the “safeguarding” of the site for a new primary school. The policy context for this is provided through saved Policy LC9 of the Adopted Local Plan. This states that “The Borough Council will safeguard land, as shown on the Proposals Map, from any development that could prejudice the provision of new schools at ……… b) Mill Lane, Codnor”.

It is noted that Policy LC9 of the Adopted Local Plan is intended to be saved through the transition from Local Plan to Core Strategy with Appendix C of the Pre Submission Core

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Strategy confirming that Policy LC9 is “To be considered for inclusion in the Site Allocations and Development Management Policies DPD”.

Whilst it is recognised that this consultation does not directly relate to the Site Allocations and Development Management Policies DPD, representations are submitted here as it is considered that aspects of the Core Strategy which directly relate to the overall retention of Policy LC9 cannot justify the continued “safeguarding” of my clients land.

The Core Strategy identifies a strategic growth site for around 600 dwellings on land off Alfreton Road, Codnor to be delivered before the end of the plan period. It is noted this figure is substantially below the normal indicative level of dwellings required to justify the building of a new primary school (1,000 dwellings).

Given the Core Strategy proposes the allocation of no further strategic growth sites around the town, there are prospects that the proposed retention of saved Policy LC9 in its current form could not be considered sound as the delivery of a new school would require a much higher level of development to be “justifiable”.

Response

Officers in the County Council’s Property Services Department are currently looking at the Primary School site and examining the feasibility of expanding the school. In the meantime, they have advised the Borough Council that it is imperative that the Local Plan continues to identify the site as a notified site as it is the statutory playing field for the existing school. Further consideration of this issue will take place when the Site Allocations and Development Management Policies DPD is produced.

3. Regulation 20 – Summary of the Main Issues Raised

530 representations were made pursuant to regulation 20. The summary of the main issues raised in those representations are as follows:

Is the Plan sound?

• Considering and facilitating Self Build to provide housing should be included in the Core Strategy. The NPPF requires Councils to measure the local demand for self- build and make provision for this demand (para 50 & 159, NPPF). • The SA report was inadequate. • SA/SEA was not applied to Issues and Options, but started at the Preferred Strategy stage as a retro-fitting exercise. Sites have not been assessed consistently and objectively against the chosen sustainability indicators. • Lack of evidence to support policies. • Doubts about the selection of the 7 sites (SG1-7) from the original 17. Land drainage is a problem and some sites may not be viable due to poor ground conditions caused by past coal mining industry. • None of the strategic sites have been assessed for sustainability. Codnor and Waingroves sustain half the required deficit of 4,000 homes while the market towns of Alfreton, Heanor and Ripley have 500 homes and Belper has none. However, Belper is the most sustainable town. • Most of the sites are in one small area of 3.5 mile radius where roads and sewers are already to capacity.

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• One third of the strategic sites are in the Green Belt. • Amber Valley Borough Council has only identified strategic sites in the east of the Borough. Is the Council introducing compulsory birth control in the west of the Borough? • Exceptional circumstances have not been demonstrated to support development of Green Belt strategic sites. • Maximisation of the use of brownfield land for development has not been pursued vigorously enough. • Regulation 19 Statement of Consultation and Publicity focuses on the promotion of SG2, SG7, SS11 and IN4 rather than reflecting the true nature of objections to SG2, SG7, SS11 and IN4. • SG3 is not making full use of the major route through the site and will overwhelm the local roads with traffic. • SG3 is an ‘urbanisation’ policy of a semi-rural area. It will overwhelm Denby and not integrate into it. • No need for new houses on the Green Belt when many new built houses in the local area are not selling. • Political motivation appears to explain the disparity between the east and west of the Borough in terms of housing distribution. Not based on sound planning arguments. • The Plan consultation was not advertised in the local press. • The Plan is unsound as it has not taken full and appropriate account of the responses to previous consultations. • I am challenging the information presented regarding the scale of housing needed to meet the requirements for predicted economic growth in Amber Valley. The evidence provided does not support the numbers being used to justify the scale of house building proposed. • The objections to policy SG1 Outseats Farm relate to the inclusion of a greenway that would form part of the Derbyshire Greenway Network, and also maintaining a strategic open break, between the two authorities. An objection to the supporting text concerns the protection of a wildlife site on the eastern boundary of the site. An objection relates the potential impact on the capacity of the strategic highway network (in particular the A38 and M1 Junction 28). • There is no identified strategic site for industrial development. The site at Lily Street Farm in Swanwick is the best connected site for high technology businesses. • There is no recognition of a tram system in Eastwood which has the potential to develop towards Ripley through Heanor and Langley Mill. • Empty properties are not included in Appendix B in the number of housing units that need to be supplied. This represents a significant under-counting of houses which can be supplied. • It is not clear that development delivered in accordance with the current wording of Policy SG7 requires the replacement of a significant area of playing field provision. This is not consistent with the Council's playing pitch strategy and national policy (NPPF Paragraph 73). • The plan does not make provision for a five year housing land supply in accordance with the NPPF and is not based on a thorough Green Belt Review. • The site on Land North of Denby is not currently considered to be a sound allocation; this is a major development that will take some years to complete. Policy SG3 must

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ensure flexibility and enable this to be implemented as a phased development which should be reflected in the wording of the policy. • The plan does not provide guidance to deal with applications for Gypsy and Traveller sites. Paragraph 8.5 acknowledges the need for a policy to provide for the "needs of Gypsies" but offers no commitment to allocate sites in accordance with an up-to date assessment or to establish a policy to deal with planning applications even where no need has been established. • The statements and policies in the plan are inconsistent insofar as they deal with development within villages and with "windfall" sites. Paragraph 6.2 implies that all windfall provision will be on previously developed land. Whilst the NPPF says windfall provision will normally comprise previously developed sites, that is not necessarily always the case and, development on unallocated greenfield sites in villages can be regarded as windfall. • There needs to be recognition that in order to 'significantly boost housing supply' in low value, low demand, more deprived areas, the Plan must be viable. In a number of key areas the plan places an unjustified burden on developer requirements without evidence. • Sites within the larger villages could make a significant contribution to housing provision and help to sustain services within those villages. Concentrating most provision in large sites on the edge of the main towns will not be as sustainable. A site at South Wingfield to the south of Church Lane and west of the Primary school would provide a contribution to housing provision in a sustainable location. • Various strategic infrastructure issues raised on the Draft CS remain outstanding that require further co-operative working between Derbyshire County Council and AVBC, particularly relating to transport, education provision and other infrastructure requirements. • The Plan fails to identify a full, objectively assessed housing need in accordance with paragraphs 47 and 159 of the National Planning Policy Framework. • Many issues on housing numbers, unmet housing needs and cross boundary migration patterns between Amber Valley and its neighbouring authorities remain unresolved. The potential under-provision of housing against objectively assessed housing needs in neighbouring authorities could have significant implications. Whilst these issues remain unresolved the Duty to Co-operate has not been satisfied in the preparation of the Amber Valley Pre Submission Local Plan and therefore the plan is unsound. • The Plan is unsound because it has not been viability tested in accordance with Paragraphs 173 and 174 of the NPPF. • Duty to Cooperate – Given that at its Council Meeting of the 16/10/13, Derby City Council resolved to object to the reserve sites in the South Derbyshire Local Plan to fulfil its housing need, it calls into question whether Amber Valley have complied with the Duty to Cooperate as the Council may be required to take additional reserve sites if South Derbyshire cannot deliver appropriate sites to cater for Derby City growth. • The way the housing need has been calculated is questionable with migration and headship rates being adjusted away from official ONS data. • The Local plan ignores the role of a planning authority to write policies which help create a prosperous rural economy.

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• The omission of Shipley Lakeside as a strategic site in the Draft Core Strategy is unsound. • Loss of agricultural land to housing. • The Spatial Strategy states that “the principal focus for new development across the Borough will be that of urban concentration in and surrounding the four urban areas of Alfreton, Belper, Heanor and Ripley”, yet the proposed Strategic Growth Sites include sites remote from these urban areas (SG2 and SG3).

What changes are needed to make the Plan legally compliant or sound?

• The Council should be supportive of self-build in its Core Strategy by measuring local demand and making provision for it. • Policies SG2, SG7, SS7 SS11 and IN4 should be removed from the plan. • Need a change in attitude at County Highways towards traffic congestion. • Need more dialogue with the Education Department and the NHS about new housing estates. • Housing should be placed on brownfield sites in sustainable areas which already have infrastructure in place. • Compliance with the National Planning Policy Framework Chapter 9: Protecting Green Belt land. • SG3 – the tar pits are not low risk, but high risk, and need more than capping. This must be done before any work is carried out elsewhere. • The Core Strategy should be revisited. This Plan significantly fails to meet the aspirations of the local community as expressed in previous consultations. • Evidence to support the percentage of employment growth that is being used in the calculation needs to be provided. • The intent behind Policy R2 appears to be satisfactory but the detailed wording needs further consideration to ensure that the settings of all heritage assets, not just the WHS, are adequately protected. • Amend the policy SG7 to clearly state the requirement for replacement of playing field provision. Suggested wording is set out under policy SG7. • Recognition in policy that a Green Belt Review will take place to identify suitable sites on the edge of existing settlements to meet the housing land supply shortfall. • Accept a modification that would enable exceptional minor amendments to the boundary of the Green Belt to be pursued through the proposed Site Allocations and Development Management Policies document. • Introduce a policy which commits the Council to making adequate provision for Travellers and establishes criteria for dealing with applications. • The plan needs to be fully justified through a detailed and methodical understanding of viability issues. The policies identified need to be reworded to impart greater flexibility. • Include a policy relating to provision of housing sites in larger villages. • Removal of the phrase “including a new A610 link road between Ripley and Codnor” from Strategic Objective 10. • Modification of SG3 to allocate 1200 additional dwellings at the Denby site.

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• The Derby HMA Strategic Housing Market Assessment Update (July 2013), will need to be updated to ensure that a full, objectively assessed housing need can be demonstrated.

Is the Plan legally compliant and sound?

• The Introduction states that previous representations and how they have been considered are contained in Appendix D - this is not correct. D is about Saved Policies.

Response

The error has been corrected.

• It refers to the need to protect other interests (green belt, landscape and countryside for example) but the Plan fails to adequately identify those areas which it will protect. • It can be seen that SA/SEA undertakings have had no meaningful influence upon the plan’s strategy or strategic allocations and infrastructure priorities. Previous iterations of the plan were prepared up to the Draft Core Strategy stage (2013) without the benefit of Sustainability Appraisal/Strategic Environmental Assessment SA/SEA) and as such the full consideration of reasonable options and alternatives had not been assessed for sustainability credentials prior to being identified as the preferred approach. This is a significant failing and undermines the legitimacy of the Submission Plan. An important indication of how the underpinning scoping process for the SA/SEA may be seen to be flawed is that the 2008 Scoping Report barely mentioned the Green Belt. This failing has been maintained within the Submission draft SA Report, and is particularly apparent in relation to the content of table 7.1. This recognises at SA Objective 3 – ‘Green infrastructure’ that loss of green spaces and natural landscapes are urgent considerations across the borough, but does not explicitly recognise that Green Belt is of even greater significance within this wider context. Matters of urban sprawl, countryside protection, settlement identity and urban regeneration are fundamental objectives of sustainable land use planning, and should be afforded far more weight within the SA framework than given. Accessibility to bus routes is a significant factor in Appendix IV and V of the Submission SA. This would appear to carry equivalent weight as areas with Green Belt designation. Yet bus routes (and provision of and access to local services) are inherently transient, they come and go, and moreover, would respond to demand generated from strategic housing sites. Conversely the loss of Green Belt is permanent. It would appear that very significant highways infrastructure investment at AV8 is justified yet is not at AV1, despite its better overall sustainability credentials. Proposals for the by-pass at IN4 are afforded a neutral sustainability score in relation to Sustainability Objective 10. That Objective seeks to reduce reliance on the car and increase opportunities for walking and cycling. It would appear perverse to suggest that a proposal to divert traffic through the borough more quickly and to access housing and employment sites through provision of major road infrastructure could serve to result in anything but a negative sustainability outcome for this objective. Likewise SA5 (biodiversity), SA11, SA12 and SA13 (economy and employment) are afforded uncertain or positive outcomes

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when the impact of the proposals on the local habitats (including established woodland at Holborn Wood) would be clearly negative, as would the impact for commerce and services in Codnor village centre. Sustainability assessment for strategic development across SG2 similarly suggests a positive outcome in relation to SA2 – Community Well-being. This is challenged. The implications of massive settlement growth, loss of valued and well used green space, strain on local services and increases in local traffic would appear highly unlikely to result in a positive outcome for local community well-being. Despite the proposals for SG2 serving to obliterate an attractive and accessible area of open space crossed by well-used public rights of way, 18.3 of the SA report suggests an uncertain impact upon green infrastructure – this despite acknowledging such loss as a ‘significant negative effect’. Tables throughout section 18 of the SA identify 6 Sustainability objectives (of 13) where a negative sustainability outcome is predicted and only 2 positives. Yet the plan seeks to support the proposals. Other concerns are raised in relation to the outcomes afforded to SG2 at Table 3 of appendix IV partly because Codnor appears to be wrongly classified as a ‘deprived area’ and hence significant sustainability ‘benefit’ afforded. Codnor is not classified as a deprived area in the Index of Multiple deprivation. The nearest such areas (Ironville, Heanor and Ripley West) are between 2.5 and 3 miles from the site.

• The formatting of the Submission Plan is such that no paragraph numbers are used. This does not make it easy for specific comments to be made in respect to the plan, and generally results in comments being difficult to cross-refer. This is seen as a significant shortcoming that should have been simply remedied.

Spatial Portrait of Amber Valley

• Objection to the final paragraph which could be interpreted as ‘keep dumping development in what is perceived as the spoilt bit’. • The Spatial Portrait should be a clear and correct representation of the Borough. Belper is very different in its character to Alfreton, Ripley and Heanor. The SP should specify the countryside in the Borough; former Coalfield in the east, Peak Fringe and Lower Derwent in the west, and Claylands in the south west.

Spatial Vision for Amber Valley

• The statement on page 6 "Improvements to the transport infrastructure WILL have been carried out, including a new A610 link road between Ripley and Woodlinkin" should be deleted as AVBC cannot guarantee that the road will be built by 2028.Therefore this statement should be removed as it is misleading. • No assurances, around the protection of the consultation zones associated with EPC-UK, a major hazard site for the manufacture of explosives at Rough Close Works, Carnfield Hill, South Normanton, are provided. Any development within close proximity of Rough Close Works may well result in a reduction in the operations on site, with potential impacts on existing employees

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Strategic Objectives

• The Plan fails to deliver objectives 4 - 9, particularly in respect of the proposals for Ripley/Codnor area. The new housing allocations are based on a high level of in- migration and not on 'meeting the housing needs of all local communities'. The allocations for the area do not respect the local distinctiveness or environmental quality and the scale of new development would be contrary to the stated intention of improving the health and wellbeing of the community. • Objective 8: The Core Strategy document has not as yet identified and mapped an ecological network for the Borough as described within the NPPF Paragraph 117.

5.1 Policy Objectives Matrix

• AVBC are still pursuing the sale of land to Morrisons for a supermarket that is NOT required in Amber Valley or indeed Ripley as outlined in the independent report by Roger Tym & Partners (2011) which states "there is NO immediate requirement for further convenience goods provision in the Borough until 2026/28" and the latest report states the same.

Spatial Strategy

• The Spatial Strategy is underpinned by the stated need to protect the green belt and maximise the use of brownfield land. Again the proposals for the Ripley/Codnor area wholly conflict with these fundamental principles. • It is evident that the settlement of Codnor is seen in policy as a local centre. If SG2 remains as a strategic site the scale of Codnor’s community will increase significantly and the existing function of Codnor is being expected to meet this extra demand. It is interesting to note that the outline planning application AVA2013/0966 submitted for the development of greenbelt land to the east of Codnor contains no indicative plans for a new local centre. The new community of Codnor arising from SG2 will clearly be expected to drive to meet their service requirements and this is not a sustainable option for travel. • The report by the Pegasus Group to examine the Housing Target used by the Derby HMA authorities identifies the figure the Derby HMA target and the Amber Valley figure as insufficient to meet the needs of the HMA and the Borough. The HMA housing target should increase from 35,360 dwellings to 47,000 dwellings. The target for the Amber Valley should increase in line with the report’s recommendations from 9,400 to 14,688.

6.1 Protecting the Green Belt

• Compliance in full with the NPPF is required regarding releasing Green Belt land. Exceptional circumstances have not been demonstrated in respect of Policy SG2 and Policy SG7. • With so much of the District within the Green belt development of all types is unduly restricted. The green belt designation should be removed from within villages and

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small settlements which would permit the natural infilling and growth of these communities. • This objection relates specifically to land at the rear of 43 Kilburn Lane, Openwoodgate, Belper where the Council has previously been requested to promote a minor boundary amendment that would enable a small-scale housing development to be permitted. The site lies in a highly sustainable position on Belper's urban periphery. It is accessible to busy public transport routes and it is very close to a wide range of public amenities. Most particularly, this relatively small site has built development on three of its sides, that to the north being of recent construction. A minor amendment to the Green Belt boundary here would facilitate relocation of a non-conforming commercial use with its ancillary open vehicle storage, so bringing considerable local benefit to the neighbourhood, without detriment to the wider openness of the Green Belt.

6.2: Maximising the Use of Brownfield Land

• There are problems with using brownfield land; listed buildings, historical relics, wildlife and unpredictability. Some brownfield sites in Amber Valley may not be suitable for housing, e.g. parts of Butterley Engineering Works and Stevenson’s Dye Works, and West Mill at Belper. • Full maximisation of all brownfield land should be pursued before both greenfield and Green Belt sites are identified. • I questioned in a previous consultation as to how Amber Valley Borough Council can achieve the regeneration of brownfield sites if simultaneously and very proactively it promotes the development not only of greenfield sites but green belt land. A freedom of information request by the local community to Amber Valley Borough Council revealed that 80% of future necessary growth within the Borough could be accommodated on brownfield sites. • The references to prioritising brown-field land are contrary to the NPPF. Paragraph 17 of the NPPF encourages the re-use of brown-field land but it does not advocate a brown-field before green-field policy.

6.3 Empty Properties

• Most empty properties do not remain vacant for very long and there are only about 200 hard cases in Amber Valley. • The conclusion that empty properties cannot make a significant contribution to the overall housing supply is not supported. Properties undergoing refurbishment or conversion at the time of writing the Core Strategy would be available for occupation within the first 5 years of the Plan.

6.4 Safeguarding Key Amber Valley Assets

• It identifies green belt, areas of high quality landscape and sensitive areas of countryside as some of the key assets to be safeguarded but the proposals for some areas completely fail this test. The A610 and associated development allocations involve a significant area of green belt, sensitive countryside (part of the historic

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Golden Valley), a designated wildlife site and ancient woodland. It also breaches the ridge line to the north of Ripley. This aspect has not been tested appropriately in the Sustainability Appraisal - as the decision to make this allocation was made well before the SA was commissioned. • It is noted that no mention of Codnor Castle, one of only two medieval castles surviving in Derbyshire is made at all.

6.5 Identification of Strategic Growth Sites

• Not convinced the best sites have been selected. Not clear that supplies of drinking water are adequate for the strategic sites. Problems with flooding could develop off- site as a result of the new estates. No confidence that the necessary school places will be provided. • Extensive transport modelling works have been commissioned and discussions between Derbyshire County Council and AVBC are on-going on the infrastructure planning and service delivery implications of the seven Strategic Growth Sites. The County Council wishes to be consulted further on the acceptability of the Strategic Growth Sites once the transport modelling, on-going discussions about strategic infrastructure are concluded. Detailed landscape character, visual impact and environmental sensitivity comments have been provided previously to AVBC in various Strategic Sites and on a number of subsequent outline applications, particularly to the Ripley Gateway scheme. These comments remain outstanding and relevant. • The 4.5 years land supply position in Appendix C is incorrect. Firstly the Council has used the Liverpool method when considering the previous shortfall from 2008 to 2013, spreading this shortfall over the remainder of the plan period and not over the first 5 years (Sedgefield Method) as is supported by recent inspector’s decisions and national guidance. The result is a land supply position of 2.9 years using the Sedgefield Method and applying the 20% buffer. 1,025 dwellings identified for projected windfalls in Appendix C translates to 205 windfall dwellings per year over the next 5 years, a figure only slightly lower than the Council has delivered in total per year over the last 5 years. This figure is clearly too high and should be reduced. A more balanced approach to housing delivery should be incorporated into Part 1 of the Local Plan so that smaller development sites are allocated alongside the larger Strategic Sites. This is supported by paragraph 2.77 of the Derby HMA Joint Viability Assessment (PBA – March 2013) which states that “The Derby HMA authorities should not rely on the delivery of the SUEs, to ensure there is a sufficient supply of deliverable housing land to meet the requirements of the first five years housing target. Land South of Amber Heights in Ripley (SHLAA Ref: AVBC/2008/0043) should be allocated within the plan as one such smaller development site. The site is in a sustainable location with no significant constraints to development. The site could be delivered in its entirety (up to 60 dwellings) within the first 5 years of the plan.

Response

The Housing Land Supply has been updated.

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6.6 Housing Growth

• In the Derby HMA Strategic Housing Market Assessment Update Final Report July 2013, prepared by GL Hearn Limited there is a massive mis-match between what the Hearn document forecasts for employment growth (2.8%) and the target that continues to be used by Amber Valley Borough Council (10%). No additional evidence is provided that would indicate either an evidence based, objectively assessed need, nor that would justify a forecast of 10%; it is simply stated as a Council ambition. On this basis, the need for the volume of housing proposed overall, and for key strategic sites to be identified, is not proven, so the Strategy cannot be sound.

Policy SS1:

• Strategic sites are biased to the east of the Borough. Approximately 2000 houses are proposed or have planning permission within a 1 mile radius of Codnor and Ripley. This will adversely affect the viability of the rest of the Borough where the demand for affordable housing is greater. • Evident that the bulk of development is not designated for the market towns but for the rural villages of Waingroves and Condor. Villages of Codnor, Waingroves Codnor Gate, Marehay and Ripley will become one conurbation without the infrastructure. The drains are currently overcapacity and regularly leak neat sewage into local brooks. • Contrary to the NPPF in terms of Green Belt development and protecting the countryside. • There is not the demand for the level of housing growth which is proposed in the east of the Borough. • The Core Strategy should recognise the importance of pockets of open, rural space in the east of the Borough. • Reference needs to be made as to why brownfield sites have been dismissed as suitable sites for re-development. • It is not clear from the policy and supporting text the extent of which the 9,400 dwellings to be built in the Borough is to meet the needs of Amber Valley and unmet housing needs from Derby. • There may be a cap on the maximum number of units delivered per annum from one location. As a consequence the Council’s housing trajectory may be overly ambitious illustrating 272 dwellings in 2013/14 up to 939 dwellings in 2017/18. • In order to meet the shortfall in housing land supply and to make the Core Strategy sound the Council should allocate further sites. One such site is land east of Chesterfield Road, Alfreton. • The Pre Submission CS includes a commentary that the proposed level of growth is at the upper limits of what’s deliverable. This comment suggests that the Council is mixing supply and demand factors.

Policy SS2: Business and Industrial Land Requirements

• Policy SS2 could be amended or added to as indicated below:

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Policy SS2A

“To deliver Core Strategy objectives 2 and 12 the Borough Council will allocate a Strategic Employment Site (SES) within the A38/Alfreton corridor as identified on the proposals map. Such a site should have the following qualities:

• A suitable size to deliver employment growth throughout the Plan period. • Be in a strategic location attractive to existing employers and inward investors and having good accessibility to important transport routes. • Be located in an attractive, high quality environment. • Have the ability to provide employment and related uses over a phased development. • Relate well to existing settlements/population and workforce. • Have the ability to provide a link with the local economy through its location and type of site, including providing for the expansion of local businesses. • Have the ability to provide a unique ‘selling point’ in terms of either location, the provision of support services on the site and other uses that may not be employment in nature but will be associated with employment and sustainable growth, eg education, health and recreation.”

• The de-allocation of employment land and the adaption of 75 hectares of Green Belt land for employment purposes is potentially wasteful. It also brings the prospect of 75 hectares of brownfield sites which would scar Amber Valley. Developers are reluctant to build on them. The former Butterley Works on Butterley Hill, Ripley remain an undeveloped brownfield site after many years.

6.10 The Role of Settlements

• Small communities within AV are dying because the emphasis for new development and services is on the main towns. Villages such as Horsley, Lower Kilburn and Coxbench should be designated for small scale development to support local services such as schools, bus services, pubs and village shops. • This section fails to address the issue - it effectively looks at the existing role, performance and function of town centres only.

Policy SS3: The Role of Settlements

• To reflect the Spatial Vision, the policy needs to include the following additional sub- paragraphs (f) and (g) in paragraph 6: ‘Where appropriate to the function and role of each identified centre, development will be encouraged to: (f) Positively contribute to the urban character, and (g) where appropriate, positively contribute to the urban rural interface and landscape character. • It would appear that the settlement hierarchy has been carried forward from previous Local Plans and is not sufficiently based upon up-to-date evidence which looks at the sustainability of villages within the borough to accommodate further growth. It is considered that the Policy is not Justified seeing that it is not based upon up-to-date evidence as well as not in Conformity with National Policy.

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• The site at Roes Lane, Crich should be allocated for housing within the emerging Local Plan. It exposes the flaws in the settlement hierarchy in that the settlement is restricted to “limited Growth”, and yet the settlement of 3,000 persons could easily accommodate more than “limited growth.”

Policy SS5: Town Centre Regeneration in Belper

• Belper town centre is directly adjacent to open countryside, which has been identified as of primary sensitivity in relation to Areas of Multiple Environmental Sensitivity (AMES). The policy needs to address the potential impact regeneration/development in Belper town centre could have on the wider area, including sensitive countryside to the west. The following re-wording is recommended: ‘Development, where appropriate, should consider Areas of Multiple Environmental Sensitivity (visual, historic, ecological) and positively contribute to the landscape character and visual aspects of the urban rural interface. • It is recommended that an amendment to Belper’s town centre boundary is made as per the Certificate of Lawfulness (LPA reference: AVA/2009/0046) which relates to the B&M Bargains Home Store site.

Response

This amendment to the defined town centre of Belper is supported.

Policy SS7: Town Centre Regeneration in Ripley

• Construction of an out of centre supermarket would counter Ripley town centre regeneration as an objective of the Local Plan. • Current definition of the high street in Ripley is too narrow. There are shops on Church Street, Grosvenor Road, and Nottingham that are equally valid as Oxford Street.

Policy SS8: Development in Town Centres

• To be in conformity with paras 26 & 27 of the NPPF, paragraph 3 of the policy needs to be additionally worded as such: ‘When considering edge-of-centre and out-of- centre proposals, developments should not have an adverse impact on existing, committed and planned public and private investment in the centre or the vitality and viability of the town centre as a whole.’ • It is considered that criterion a) is not Justified as there is no requirement or evidence base which supports the requirement for uses to sustain or enhance the viability of a town centre. Given that town centres are already accessible by a range of private and public transport, it is considered that criterion b) is not necessary. • Policy SS8 also needs to take into account the current national policy which gives new PD rights for office use to change to residential use via prior approval, as well as PD rights for no more than 2 dwellings above A1 and A2 uses. The policy as currently worded would imply that planning permission is required in these cases.

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Policy SS10: Green Belt

• There are too many exceptions listed for ‘appropriate development’. • The extent of the Greenbelt and the constraints imposed by its designation on settlements within it, prevent the Plan being prepared positively. The Plan should provide policies which encourage small scale development within existing settlements, even if they lie within the Green Belt. The reference to limited infilling in Policy SS10 is not defined. Does the council have a limit for each settlement? (1 dwelling, 1 workshop??). This should be amended to state: "Infilling in villages will be permitted subject to Policy E2." This Policy is contrary to Policy SS12 that supports development which improves viability, accessibility and community value. This Policy should include text under SS12 (c) to ensure the economic and social fabric of smaller settlements is not irreversibly damaged by Green Belt designation. • In criteria (a) farm and rural diversification needs to be added to agriculture and forestry to allow for growth of rural businesses in the Green Belt.

6.15 Amendments to the Green Belt

• Appendix C sets out the housing land supply position within Amber Valley. It concludes that, as of April 2013, Amber Valley have a 4.5 year supply of deliverable dwellings against the housing requirements set out in the Core Strategy. It also falls short of having enough identified sites to meet requirements for the next 15 years. While certain strategic sites are identified within the Core Strategy, it is considered that policies in the Core Strategy are not robust enough and do not provide sufficient flexibility to demonstrate that the housing land supply requirements of the NPPF can be met. With regard to robustness, it is considered that the major strategic sites identified for development have not been sufficiently justified. For example, the major sites proposed at north and east of Ripley and east of Codnor are on land to be released from Green Belt but this release has not been based on a comprehensive Green Belt review. Similarly, the release of this land is highly dependent on the extension to the A610. There are, therefore, doubts about the suitability and deliverability of this housing proposal which would increase the already identified shortfall within the Amber Valley District. It is considered that it will be appropriate to undertake a limited Green Belt review of the boundary around existing settlements, where the opportunities can be provided for sustainable development as set out in paragraph 85 of the NPPF. The specific sites can be identified at the Site Allocations stage. In light of the presumption in favour of development where there is a shortfall in terms of five-year housing land supply, this will ensure that any release of Green Belt land has been subject to a full assessment of the suitability of the site and has been subject to public examination before being released for development.

SS11: Amendments to the Green Belt

• By proposing the strategic allocation at SG2 the underpinning principles of Green Belt policy, as per paragraph 80 of the NPPF, have been given insufficient regard by the Council. There is no hard evidence to justify alteration of the Green Belt. No review of the Green Belt has taken place outside the immediate area of Derby to

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inform release of Green Belt across the wider Borough. Therefore proposing release of Green Belt at SG2 is unsound. • The creation of a new easily defined boundary by way of the A610 link road is not required for existing and future Green Belt policy to be applied. • Not justified – should be using empty homes and brownfield land, such as the former Butterley Engineering Works and land near the Police HQ on Coach Road. • The role of the Green Belt to the east of Alfreton Road remains valid and significantly contributes to the achievement of the functions of the greenbelt set out in paragraph 80 of NPPF. • This Policy fails to include the amendments to the Green Belt which will be required for the infrastructure works to service the Denby housing development of 1800 dwellings. The Plan mentions possible off site works in the A38 / B6179 corridor. • The Council’s response to Barton Willmore’s objection to the Draft Core Strategy (Reg 19 Statement of Consultation and Publicity, page 175) claims there are no other sites in the SHLAA that are not in the Green Belt are deliverable and can fulfil the full, objectively assessed housing requirements in the Borough during the Plan Period. The Council’s own SHLAA assessment concludes that land east of Chesterfield Road, Alfreton (Site Ref: AVBC/2008/0079, land adjacent Derby Road, Alfreton) is suitable and available for housing and not within the Green Belt.

Response

Due to highway limitations, the site at Chesterfield Road, Alfreton is not being proposed as a strategic site. It will be considered for allocation in the Site Allocations and Development Management Policies DPD.

6.16 Countryside

• What purpose does this policy serve? It would be better that the text of this policy and the Green Belt policy be combined. The intention to permit development which will improve the viability accessibility or community value is welcomed.

Policy SS12: Countryside

• The Policy is unduly stringent and is not reflective of National Planning Policy guidance as set out at paras 28 and 55 of the NPPF. The Policy as set out is more restrictive than Green Belt Policy. As such the policy will not be effective and is not consistent with national Policy. It needs to more closely reflect paras 28 and 55 of the NPPF which aim to support and encourage the rural economy, and recognise that some countryside development - including conversions can assist in support service and improving the environment. • The diversification of the rural economy is a key missed opportunity which is absent from this document. It would be advisable to include a rural economy policy which is broader than agricultural growth in order to guide and diversify growth. This would benefit areas such as home working, food and drink production, agriculture, broadband improvement, and allowing rural businesses, local shops and pubs to extend and diversify into alternative, but ancillary uses.

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• Development control within the countryside should require proposals to be of an appropriate use, scale and character, especially in areas within close proximity to hazardous sites, such as EPC-UK. • Phrasing like "farm and rural diversification projects will be encouraged which do not have an adverse impact on the locality" should be used rather than the "will only be permitted if it is essential" language.

Policy SS13: Presumption in Favour of Sustainable Development

• The policy needs to make it clear that the principle in favour of sustainable development does not apply in green belt as established by Appeal Decision APP/B1605/A/11/2164597. • The Policy is not sound as the wording is not Consistent with National Policy. The Policy should be re-written taking into account the template provided by PINS in relation to the insertion of this policy within the Core Strategy. There are also inconsistencies between the wording and para14 of the NPPF in that additional text has been added to the phrase “where the development plan is absent, silent or relevant policies are out-of-date, granting permission unless” to state “unless material considerations indicate otherwise” which is not reflected in the NPPF.

7. Strategic Growth Site Policies

• Should include a requirement that the development of the sites should contribute towards the provision of the Loscoe Household Waste Recycling Centre. Reference needs to be made on some of the Sites to the need for development to facilitate the provision of high speed broadband. • Concerns regarding the omission of the Shipley Lakeside site as a Strategic Growth Site. Shipley Lakeside proposal is a strategically important development for the future of Amber Valley and, as such, it should be included in the Council’s Strategic Growth Policies. The existence of site-specific policy EN3 in the Local Plan (2006) and a development brief clearly demonstrates Amber Valley Borough Council’s intent for the Shipley Lakeside site to be re-developed and brought back into beneficial use.

Response

The site at Shipley Lakeside is not considered to be of a strategic importance.

• Strategic site AV12 land at Cherry House Farm was rejected on the basis that it is within the World Heritage Site Buffer Zone. This is a flawed assessment in that the site assessed comprised three non-contiguous areas in three different ownerships. It was also based on appeal decision APP/M1005/A/10/2142571 which refers to an adjacent site which if viewed from the ground is clearly prominent and visible from the WHS. The site in question is far less conspicuous. The three land owners are working together to demonstrate deliverability of the proposal. • The Highways Agency recommends the GDTM or the Derby HMA model to consider the cumulative impact of development on A38 junctions to increase the robustness of

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the evidence base. It is not aware that the transport evidence base has fully considered the risk to the performance of the A38/A610 junction.

Policy SG1:

• This is Alfreton’s only piece of open space natural land. The lack of open space in Alfreton already results in the highest deprivation in terms of health. • The Pre – Submission Core Strategy does not include any mention of the opportunity for the Outseats Farm site to link into greenway connections that will form part of Bolsover District Council’s strategic network of cycle routes as envisaged by Derbyshire County Council, where part of a strategic greenway link between South Normanton and Westhouses is proposed to go through the Outseats Farm site. The site could provide a greenway within its general layout that connects into Bolsover District at its southern end that could also address any potential barrier presented by the rail line. If such matters are not clearly stated in the Pre – Submission Core Strategy then opportunities could be missed to include the route within the scheme. The bridleway that runs through the site follows a diagonal path (north west to south east). The route identified by Derbyshire County Council in their proposed cycle network and by Bolsover District Council in its Strategic Green Infrastructure Network follows a different route, along the eastern boundary of the site, next to the railway line and has been included within the outline permission. In order that this route is reflected in the policy, it is proposed that the policy includes a further criterion that states - e) the inclusion of a greenway alongside the eastern boundary of the site providing connections to and the enhancement of the Derbyshire Greenway network.

Response

The inclusion of this further criterion is supported.

• At officer level Bolsover District Council has approached Amber Valley Borough Council about the need to maintain a strategic open break between South Normanton and adjacent settlements. This open break could also be used to encourage green infrastructure in the area. The need for the open break reflects concern about the possible coalescence of settlements, the lack of opportunities for public recreation and the need to enhance the setting of South Normanton and Pinxton. If a 500 dwelling strategic site at Outseats Farm was developed right up to the shared boundary it would result in the open break between our districts being much reduced. It is considered that a site allocation at Outseats Farm should include green space / green infrastructure along the site boundaries with the A38 and the East Midland Mainline. This would help to keep the eastern boundaries of the site open, and contribute to an open break that would benefit the setting of both towns and districts. It is noted that the site plan in figure 12 that accompanies policy SG1: Outseats Farm, Alfreton still shows the strategic allocation to be allocated tight up against the district boundary with Bolsover District. The following change of wording is proposed in order to include green space on the eastern boundary. Amend the wording of criterion a) of policy SG1: Outseats Farm, Alfreton. a) the protection of the setting of Carnfield Hall and the Carnfield Hall Conservation Area

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through appropriate design and masterplanning, which includes the provision of new green space, trees, bushes and hedgerows on the eastern boundary.

Response

This proposed change to the policy is supported.

• It is considered that the wildlife site that straddles the border between the two Council’s areas should be mentioned within the supporting text. Amend the following sentence to the supporting text to Policy SG 1 “The eastern boundary is bordered by dense woodland, a local wildlife site and a railway line.”

Response

This proposed change to the supporting text is supported.

• The site can be considered to be a sustainable, strategic level site, which is suitable, achievable and available.

Policy SG2:

• The strategic housing allocation is based on a political desire to see the construction of a by-pass to overcome occasional congestion at rush hour at Codnor market place. It is not based on evidence from traffic surveys or modelling to demonstrate a need for the road. No alternative solutions have been tried as per DfT guidance. • The site consists of attractive and ecologically valuable countryside which provides the setting for Codnor Castle, a Scheduled monument and Grade II listed building. • The EIA which accompanies Amber Valley Borough Council’s planning application (AVA/2013/0966) for the A610 link and associated development admits ‘there are a number of major cumulative negative impacts associated with the project’. • It is not clear that the A610 link road can be delivered through developer contributions alone. This undermines the exceptional circumstances for removing this land from the Green Belt. • There has been no review of the Green Belt to establish which areas are most sensitive. The East Midlands Regional Plan which is still a material consideration states the principle of the Derby/Notts Green Belt should be maintained and areas of growth around Amber Valley towns should avoid the most sensitive areas of the Green Belt. Derbyshire County Council’s Areas of Multiple Environmental Sensitivity identifies SG2 as a sensitive area of Green Belt. • The A610 link road will not provide a by-pass, as per the Council’s long-standing commitment, but a single carriage way road with a 30 mph limit. It will be no better than the current road. • The development will cut Codnor off from its Castle and destroy ancient woodland and ridge and furrow. There is no provision for walkers getting across the road in current plans. • Clarity needs to be provided as to whether the houses or link road will come first.

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• No mention of a new school or doctor’s surgery. Codnor and Waingroves schools have no capacity. It is hard to get to see a doctor in the local area. • The Council has failed to engage the public in open debate during the consultation period. The online system for comments was unwieldy and complicated. • Sustainability Appraisal Concerns for SG2: Table 3 (p.106) for SG2(AV8) for the indicator ‘Priority Species’ this is assessed as green yet Ecological Assessment to support the outline planning application relevant to SG2 has identified priority species present. Similarly for the indicator ‘Ancient Monument’ which is shown as green which appears to suggest that Codnor Castle SAM and its setting have not been correctly taken account of. The table assess ‘Contamination’ as green yet the EIA submitted with the planning application requires further testing for contamination – the fact that a historic tannery was sited within SG2 does suggest that contamination from this former use maybe present. The indicator for ‘Agricultural land ‘ is shown green yet a large proportion of SG2 is used for agricultural purposes, ‘Deprivation’ is shown as green and yet Codnor is not an area identified in the Index of Multiple Deprivation relevant to the Borough, ‘ AMES’ classification shown as yellow yet known to be in AMES (admittedly not primary). Further evidence of skewed assessment of SG2 is revealed in SA Table 1 Summary findings page 110. Site AV8/(SG2) is incorrectly assessed. The significant constraints column does not include reference to Codnor as not being in area of low deprivation (as shown for AV4, AV5, AV6 AV9 and AV9B – note: last 2 sites are in Codnor). The 4th column ‘Other Potential issues’ highlighted by SA should include reference to priority species (as evidenced by EIA for planning application) only 3 other sites have priority species listed as a constraint – (AV2 which says they are nearby, AV5 and AV10). • It is noted the figure of 600 dwellings is substantially below the normal indicative level of dwellings required to justify the building of a new school (1000 dwellings). Given the Core Strategy proposes the allocation of no further strategic growth sites around Codnor, there are prospects that the proposed retention of saved Policy LC9 Safeguarded Land for Educational Facilities (Mill Lane, Codnor) in its current form could not be considered sound. I suggest a revision to the schedule relating to the proposed retention of Policy LC9 with the addition of the footnote: “except for land at Cattermole Contractor’s Mill Lane, Codnor”. • The site is on the border of both the Borough and the HMA. A conversation at the recent Planning Application Exhibition confirmed that the developers of this site would aim properties at those commuting along the (existing) A610 towards Nottingham. Development here would thus meet the housing requirements of the Greater Nottingham HMA rather than those of the Derby HMA.

SG3: Land North of Denby

• Concerns that SG3: Land North of Denby is not viable and will throw out the figures for housing land supply. • The site is under consultation for the HS2 Northern section Birmingham/Leeds. Derby City Council has submitted an alternative to the original proposed route, i.e. a station at Toton. • The previous view of the Council has been that full restoration of the tar pits and a link road to the A38 is necessary before any development can take place. This does

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not appear to be the case under new plans put forward. Brickyard Lane as the new link onto the A609 is totally inadequate. A traffic island at Kilburn Toll Bar will only make matters worse. • Capping of the tar pits is a cheaper option and is not adequate for full remediation. They have affected many people’s health, including my own. There was a report submitted to Council on the 4/02/2007 stating that the tar pits were a high risk to health. Under the Environmental Protection Act of 1990 the site was classified as a ‘special site’. The problem needs tackling to the satisfaction of the local residents. • The view of the Council is solely on viability and I do not think a link to the A38 will be pursued because of the cost. Housing will be constructed first and the resulting commuting, mainly to Derby, will make congestion worse. Reference to employment being available on site is misleading. This was the view of the Inspector in his Report on the current Local Plan (File 1, 14.10.2003. Page 38): “Only a small proportion of new residents would be likely to find employment at Cinderhill. Based on past trends identified in the DDJSP many of the remainder are likely to commute to Derby.” I also quote the same report regarding Brickyard Lane (Page 41. Paras 2.7.64 & 2.7.65): “Presently the access via Brickyard Lane is poor by any standards and serves a considerable amount of development. The Cinderhill proposals, as evidenced by the notional plan offered by Banks would not alter that situation……It makes little sense to create an area of housing isolated from the main development area proposed for Cinderhill whilst creating additional traffic at Rawson Green (A609) which is, in my opinion, ill-suited to providing access to some 130 additional houses.” The traffic situation on the A609 has become worse since 2003 with the east of Belper housing expansion which also uses this road to commute to Derby. The only highway proposal is for a new roundabout construction here which will only make congestion worse. The Council should insist on an A38 link from the development to also cater for commercial traffic to employment areas and expansion of housing. • Concerned to see in the SA Technical Appendix A, page 4, that “Part of the site has been identified as being potentially contaminated and/or the site has a lower risk ranking.” If find this astounding when the tar pits area of the site has been registered as a ‘special site’ under the EPA 1990. Part of this site contains carcinogenic material – PCBs. On 4/02/2007 the Council’s Director of Environmental Services submitted a report to Full Council (Agenda Item 12A) which stated in para 4.12 “The Report proved that there is a significant risk of significant harm to health. This demonstrates that an area within the site should be determined as ‘contaminated land’ as defined in the legislation and guidance.” • It is particularly surprising and worrying to note that no guidance on how Items (g) – (m) will be delivered or cost implications are included within the delivery plan. • There should be on-going monitoring of the whole site for contamination which includes both the areas known as the tar pits and the Denby Disposal Point. • Clear guidelines should be made publicly available as to who will be held accountable and responsible in the event of any contamination from the site which results in a risk to public health. • The remediation of the tar pits is noted as a high priority in the draft infrastructure delivery plan yet the timescale indicated in the plan is 2028. These are clearly contradictory.

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• No indication of how remediation will be funded is provided in the draft infrastructure delivery plan. Denby Parish Council believe these costs should be borne by the developer as stated in the schedule 11 of the planning officer’s report for the previous planning application. (AVA/2008/0865). • No indication of how the figure of £16.5million in the IDP has been calculated or what work this would enable. i.e capping or complete remediation by way of removal of the tar. The notes included in the delivery plan contradict this costing as they state that no financial appraisal has been carried out, which suggests that this aspect of the report is unsound. • More information should be provided on how the need for 6 hectares of employment land has been assessed. The Parish Council note that there are empty units at the Denby Hall Business Park and suggest that this is because there is no need for the units or businesses cannot afford to move into the area. • This should be a comprehensive scheme and there should be no piecemeal or part development of Cinderhill site. A deliverable plan for the whole site should be in place before any development starts. • There is no reference in the core strategy document (page 53) to notes on page 14 of the delivery plan regarding the need for water resources to be improved, which is unsound. • We are concerned about the lack of consultation with Mr Roger Ford and Mr David Ford who own part of the site. • The promotion of the strategic site under Policy SG3 should not preclude the development of non-strategic opportunities at Pottery Farm, Kilbourne Road, Belper and Bottles Farm, Danesby Crescent, Denby Bottles. Pottery Farm was included within unallocated strategic site AV12 in the Draft Core Strategy. We would suggest that this strategic site is disaggregated and that Pottery Farm is considered in its own right as a non-strategic site as outlined above. • This site is too large and the delivery of housing in the Plan is too dependent on this one site. The housing allocation for the site should be reduced and spread throughout and adjacent to existing settlements. What is the phasing for this site? At 1800 homes how can it contribute to the 0-5 year or 6-10 year periods if contamination and major access issues have to be addressed? This development delivers no benefits to the surrounding communities along the B6179 and yet it is the settlements along this route which will experience the traffic implications and overwhelming of local services (schools, doctors surgeries, nurseries, social welfare and community services). • Amend Policy SG3 as follows:..‘The site is estimated to have potential for around 1800 dwellings, although and any proposals should not prejudice will need to the comprise a comprehensive mixed use nature of the development scheme. Where planning applications come forward these, which will also need to have due regard to involve:...’ • It is considered that certain sections of the site, including the land immediately adjacent to Derby Road, could deliver housing in the short term whilst allowing further development to follow. This initial phase would provide contributions to the relevant criteria identified within Policy SG3 subsections a – m and would importantly open the access required to the wider site.

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• The preamble does not mention the presence of a 14 ha Local Wildlife Site within the area. The vision for this development should seek to enhance and expand the current Local Wildlife Site centred on the ‘Tar Pits’ and Morrell Brook to establish a coherent ecological network that links into other semi-natural habitats to the north and east. This would significantly help to meet the needs of local communities within the new development, Denby and Belper for access to a 20ha site within 2km as recommended by Natural England and set out in their Accessible Natural Green space Standard (ANGst). • The Highways Agency recommends an amendment to section c) as follows: ‘Improvements to the surrounding road infrastructure, including the provision of traffic signals on the A38 northbound off-slip and a parallel merge on the southbound on- slip at the A38 Coxbench junction.’ • Commercial Estates Group has the following comments to make in respect of the detailed wording of the policy, and some suggested minor amendments. Whilst these do not go to the heart of the soundness of the policy, they are nonetheless important to ensure clarity of drafting. • It should be noted that Park Hall Farm, a grade II* listed building, is not in the site but adjacent to it. The supporting text should be amended to reflect this. • It would be prudent to amend criterion e) to refer to John Flamsteed school “or an agreed alternative” in case it transpires that there are other, better ways of meeting the requirement for secondary school places, given that demand for such places is likely to evolve over time as the scheme is implemented. • In respect of criterion f), we support the designation of a Local Centre at this site and consider this necessary to support the sustainable development of the site. • For criterion g), the disused route in question should be identified on the site plan and confirmation given that this route should be safeguarded, “with the precise alignment to be agreed” since for a number of reasons it may not be possible or desirable to follow the exact alignment of the current route.

SG4: Newlands/Taylor Lane

• Criterion b) - Object - Omnivale considers that a secondary contribution is not justified in this situation. There is a 400 place surplus at the Aldercar Community Language College which is in the ‘normal area’ for the Newland part of the site. This substantial level of surplus is sufficient to accommodate the secondary school requirement from Loscoe and Newlands as the Aldercar Community College is within 2km walking/ cycling distance of the Loscoe landholding (these linkages are proposed for enhancement as part of the green infrastructure strategy). Criterion c) - Object - The policy as currently drafted does not specifically reference contributions to the installation of Broadband and leaves much to interpretation which will require clarification from the Borough Council if it is to be deemed sound.

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SG5: Radbourne Lane, Mackworth

• Concern is expressed about potential surface water flooding impacts on adjacent County Council land, namely the Mickleover Greenways. • There is the potential to severely impact upon the A38 as a result of the cumulative development of this site and other growth west of the A38 as set out in Derby City and South Derbyshire Local Plans if delivered prior to the Derby Junctions Scheme (due to be delivered around 2021). The Highways Agency would prefer to see development of this site phased towards the latter part of the Plan.

SG6: Coppice Farm

• This land separates Waingroves from Ripley and Marehay and is abundant with wildlife. The infrastructure downstream of Coppice Farm consists of ancient combined sewers and results in neat sewage and flooding on a regular basis.

SG7: Nottingham Road

• We don’t need a new hotel, any more pubs or restaurants or a new industrial estate when there are empty units that need regeneration in the local area. We don’t need a new supermarket. Ripley town centre needs help to attract people to go there, not a reason to not go. • Although Sport England are aware that the principle of replacement playing field being required has been established through planning application AVA2012/1085, at this site, we propose the following additional criteria under the text "....which will also need to involve"- At least equivalent or better playing field provision in the catchment area with regard to quantity, quality and accessibility. The replacement provision is to be delivered prior to the loss of the existing site. • The draft allocation and removal from green belt is supported and the land is unconstrained and readily available for development. Additionally, the landowners’ land is also capable of independent development as an urban extension in its own right. The disused railway line to the eastern boundary of the site forms a more defensible long term green belt boundary and the allocation of the area for development would make a useful contribution to the Council’s need for a supply of land for new housing. The landowners consider that the draft policy should be modified so that in the event of the A610 link road being delayed or not proceeding as currently anticipated, this allocation for strategic mixed use development should remain to facilitate the planned urban extension of Ripley. It is therefore suggested that the wording of policy SG7 is amended to reflect such circumstances and allow for safeguarding of the general route of the link road rather than requiring implementation of the whole of the length of this new road as a prerequisite to commencement of development of this mixed use urban extension. • Key evidence as discussed on page 64 refers both to the Derby HMA Transport Modelling that is taking place and a Derby HMA Transport Position Statement. However, at the time of writing by Derbyshire County Council, both papers are concerned with the Principal Urban Area (PUA) of Derby and say little about the

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impact of development over the wider highway and transport networks beyond Derby. • Concern is expressed about potential surface water flooding impacts on adjacent County Council land, namely Ripley Greenways. • The SG7 policy (under g and h) needs to demonstrate a stronger commitment to the provision of habitat creation and enhancement to establish high quality accessible natural greenspace at a sufficient level that mitigates and compensates for adverse impacts. The current application does not appear to reflect this need.

Policy H1: Housing Types, Mix and Choice

• The policy uses the words 'contribute to' and would seek reassurance that the balance of house types will not be a mandatory requirement on individual sites. It must be recognised that the majority of housing will be delivered by the market, and the policy needs - in accordance with the NPPF guidance - to respond to market trends as well as demographic ones. As it stands the policy is overly prescriptive and will not be effective because the market will not deliver on this basis. The policy needs to be worded more flexibly for the plan to be considered sound. • The last paragraph should be the headline paragraph of the policy and the proportions of house types sought across the Borough as a whole should follow as a qualifying informative statement to make the policy more effective. The word “require” remains in the policy text as opposed to our recommended substitution with the terms “expect” or “seek” . In respect of the table - Indicative Affordable and Market Housing Mix, any affordable housing mix requirements / aspirations should be confined to the separate affordable housing policy H3. The table should be deleted or relegated to a supporting informative.

Policy H2: Housing for Disabled People

• The requirement for new development to be in accordance with the Lifetime Homes Design Criteria is not consistent with the NPPF. Accessibility and Mobility standards are included in building regulations, making any Lifetime Homes policy requirement effectively redundant.

Policy H3: Affordable Housing

• As it stands, the plan is unsound as it is inconsistent with National Policy and the level of affordable housing is entirely unjustified without a full and detailed settlement by settlement viability assessment. The draft plan seeks 30% affordable housing from development sites, apparently based on the existing local plan policy. Affordable housing and local standards requirements should be assessed on the basis of costs current at the Plan making stage - the NPPF sets out that Plans can be reviewed as and when appropriate to reflect changing circumstances.

• The requirement for 90% social rent with the balance (10%) being intermediate housing will not provide an appropriate mix of housing. The definitions of different

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types of affordable housing is made clear in Annex 2 of the NPPF, which defines social rent, affordable rent, and intermediate housing options. We are concerned that restricting the level of intermediate housing to just 10% (of the 30% overall provision) with no provision of affordable rent, will result in a shortage of this much needed provision across the Borough for the plan period. There is also an emerging trend for requiring a greater need of smaller affordable housing units further to the introduction of bedroom tax, which could have implications for demand, particularly when considering the required mix of affordable housing under draft Policy H1 requiring a degree of larger dwellings.

Policy H4: Viability of Housing Sites

• The proposed mechanism set out within this policy is a significant requirement for any applicant. It should therefore only be requested as a last resort and in exceptional circumstances. Paragraphs 173 and 174 of the NPPF seek to ensure that local planning authorities viability test Core Strategy policies so that the majority of developments are viable in the first instance. • The first line of section 2) of the policy could be modified to read “An independent chartered surveyor is instructed if required by the Council and /or the developer ....”

8.5 Gypsies, Travellers and Travelling Showpeople

• I suggest a site in Shipley Park which is run by the County Council. There have been short-term unofficial encampments there in the past.

Policy R1: Reducing the Use of Non-Renewable Energy Resources

• The policy should make reference to the Government’s recent announcement on revisions to Part L of the Building Regulations. It is inappropriate to reference meeting the Code for Sustainable Homes Level 4 by 2016. The Draft Core Strategy will also need to remain flexible to respond to the outcome of the Housing Standards Review in the coming months. • Criterion e) specifies that previously developed land and existing buildings within settlements will be reused in preference to greenfield land. This statement of giving preference to previously developed land is contrary to para 17 of the NPPF which “encourages the effective use of previously developed land, provided that it is not of high environmental value”. Criterion e) should be reworded to reflect the wording of para 17 of the NPPF.

Policy R2: Renewable Energy Developments

• The revisions to Policy R2 are mostly helpful but National Trust has some concerns about the detailed wording of section a). The current wording, i.e.: "in the World Heritage Site, Conservation Areas, Listed Buildings and Scheduled Monuments and other designated or non-designated Heritage Assets including SSSIs, the Outstanding Universal Value of the World Heritage Site and significance of the asset,

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including its setting, would not be harmed"...only refers to the setting of the WHS and not to other heritage assets - often, for example when considering the special significance of a Listed Building it is development that impacts upon its setting (e.g. a turbine interrupting a key vista over 'borrowed landscape' that is likely to result in harm or substantial harm. The following wording is suggested as a more suitable alternative that is both justified and effective, and which in addition accords with the advice in the NPPF: "development affecting the World Heritage Site, Conservation Areas, Listed Buildings and Scheduled Monuments and other designated or non- designated Heritage Assets including SSSI’s, the Outstanding Universal Value of the World Heritage Site and significance of the asset, including the setting(s) of any heritage assets, would not result in harm".

Response

This suggested amendment of the wording of this policy is supported.

• Given that other policies in the Local Plan such as Policy E2 deals with amenity and landscape issues, and Policy E1 with flood issues, it is questionable whether there is need for Policy R2. It is considered that the majority of this policy can be incorporated into other policies in the document and its inclusion as such would not be in Conformity with National Planning Policy objectives which aims to streamline the planning system.

Policy E2: Quality and Design of Development

• In respect of the reference to SPD, we would question the justification of this in the light the most recent advice of The Town and Country Planning (Local Planning) (England) Regulations 2012 on the form and content of SPD. • Could be improved by setting out the types of critical infrastructure including highways and transport, flood management, education, household waste recycling centres, green infrastructure, broadband, libraries and other social infrastructure. • Object to the requirement that residential development in the Borough achieve 12 green indicators against the Building for Life (BfL) criteria. BfL was created as an informal design tool and not as something to been enforced by development plan policy. • Criteria (b), (l) and (o) indicate that there should be no development off a bus route. Most farms are situated away from bus routes. The policy needs to be re-worded to be much more supportive of rural development especially.

Policy E3: Historic Environment

• The route of the Cromford Canal should be specifically named in the local list of non- designated Heritage Assets. • The last paragraph should be amended as follows: ‘The Borough Council will continue to conserve local distinctiveness by ensuring that new development respects the character of developed areas and rural landscapes that are of historic importance, including the Ecclesbourne Valley, the Derwent Valley and Areas of Multiple Environmental Sensitivity (AMES).

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• The wording should explicitly reference undesignated archaeology and archaeological potential, e.g. at para 3, in the list of assets ‘including Listed Buildings, ….., known archaeological sites and areas of archaeological potential’. • In setting out factual information for numbers of heritage assets, reference to numbers of scheduled monuments and registered parks and gardens have been omitted. These should be included in order to set out the facts for all asset types found within Amber Valley. • The reference to ‘enforcement action’ in the context of tackling heritage at risk within the 6th paragraph of the policy is incorrect. Enforcement action typically relates to breach of planning control. Heritage which is deemed to be ‘at risk’ can arise from a number of issues and is not restricted to instances where there is a breach of planning control. Tools to address heritage at risk come in many forms such as statutory intervention by way of serving formal notices (such as Urgent Works) being used. We therefore suggest that the word ‘enforcement’ is replaced by ‘appropriate’.

10.4 Landscape Character

• The introductory text should accurately reflect the three distinct National Character areas in the Borough. • The Council should work collaboratively with the Peak District National Park in order to avoid any adverse impacts on the Peak Park designation.

Policy E4: Landscape Character

• This policy appears to apply to all development not just major development so those building an annex must submit a landscape character assessment which appears to be completely over the top.

Policy E5: Special Landscape Area

• There is no apparent evidence base which supports this policy position which mimics, but is not an AONB. Taking this into account, the policy is not Justified and as such is unsound. The Council should seek AONB designation before such a position or policy can be sustained in a Local Plan. • All development has an adverse impact in some way from some angle and this policy must be made much more development friendly and conducive to the growth of farming and rural businesses. • This policy sets out a negative approach to conversion/ extension as a starting point and could potentially stifle economic and sustainable initiatives in large rural parts of the Borough. The policy should therefore be amended to read:- “ Development proposals including conversions of existing buildings and extensions to existing buildings will be supported where they demonstrate high standards of design and construction and do not have an adverse impact on the visual quality of the landscape”.

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Policy E6: Biodiversity

• The policy strays into the realms of seeking benefit over and above the need to mitigate the impacts of development contrary to the CIL regs. As such it is not consistent with national policy and is not justified. • The Environment Agency states that the Humber River Basin Management Plan should be removed as a monitoring indicator and from Table 19.1 of the Sustainability Appraisal Report. This is because it is a business plan used for reporting purposes, the indicator “the ecological health of water bodies in the Borough” and the target “water bodies achieving the required standard under the Water Framework Directive” should be used instead. Reference to the Humber RBMP is best placed in the explanatory text under the heading of ‘key evidence’ to Policy E6.

Response

These suggested amendments have been made to the background text to this policy and the SA.

• It will be impossible for all development in rural areas to comply with the last paragraph on page 97, "All new development should ....", followed by 9 bullet points which must be complied with.

Local Green Space

• Areas which merit protection is a fundamental strategic function and the Plan is unsound because it fails to address this matter.

11. Infrastructure Policies

• It is unclear at present how the impact of all Amber Valley’s proposed growth (9,000 dwellings from 2008 – 2028) will affect capacity on the strategic highway network. From our own evidence base work with Derbyshire County Council, Chesterfield Borough Council and North East Derbyshire District Council, we are aware that the strategic road network is currently over capacity, in particular the M1 Junction 28, and is forecast to get marginally worse by 2031. It would be useful to understand if the proposals in Amber Valley would have any significant impact on such forecasts. There does not appear to be any recognition within the text of the local plan that the impact of new developments in Amber Valley Borough will put further stress on the A38 and Junction 28 within Bolsover district. • The issue for Bolsover District is that during periods of congestion drivers try to circumnavigate their way around junction 28 through the minor roads of Pinxton and South Normanton. Whilst it is appreciated that Junction 28 is not in Amber Valley’s administrative area, this is a cross boundary issue that does not appear to be clearly reflected anywhere within Amber Valley’s Core Strategy, or Local Strategy Statement or transport evidence. The Derby HMA Transport Position Statement exclusively addresses the Derby urban area. The other transport modelling reports also address the Derby urban area. Bolsover’s transport evidence and the Highways Agency confirm that the managed motorway scheme between junctions 28 and 30 will

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manage the increase in traffic generated by new developments in the three north Derbyshire districts. However, developments in other districts including Amber Valley will directly impact upon levels of congestion on Junction 28. The issue is mentioned in Bolsover’s Transport Topic Paper where from discussions with the Highways Agency (whilst noting that J28 is already a fully signalised scheme) potential solutions to this would be to pursue a Grade Separation scheme to create an ‘at-grade junction’. However, this would involve significant spend and land acquisition and currently does not feature in any Infrastructure Investment Plan. It is considered therefore that the improvement of Junction 28 needs to be identified as a national project within a national infrastructure investment plan, and wording is suggested to be added to the plan to reflect this. This is a key issue that should be reflected in the Plan. Proposed Change to Plan: “Notwithstanding the outcome of further transport studies, the Council recognises that the development of all its proposed sites alongside those of neighbouring Districts will have a significant cumulative impact on the strategic road network (the M1 Junction 28 and A38 in particular). Amber Valley Borough Council is committed to working constructively with neighbouring authorities and the relevant bodies to find mutually compatible solutions.”

Response

This proposed change to the Plan is supported.

11.1 Transport

• There is concern from Derbyshire County Council about the rate of progress on the development of the transportation evidence base, in particular, the identification of transport infrastructure needed to support development growth proposed. It is considered that AVBC’s Core Strategy would be greatly strengthened by a more comprehensive approach to transportation assessment and analysis to enhance the evidence base used to inform land allocation. It is therefore recommended that such transportation assessment is completed, particularly with regard to the identification of transport infrastructure needed to support the development proposed at the Strategic Growth Sites before the Core Strategy is subject to Examination in Public. The Derbyshire Transportation model provides a suitable assessment tool.

11.4 Strategic Transport Infrastructure Priorities

• The A610 Codnor Bypass should be built using public funds instead of relying on property developers. • More car parking is required in town centres.

Policy IN1: Transport

• 9,000+ houses = around 18,000 cars. Apart from the Ripley – Codnor Relief road, no improvements to the existing roadwork are proposed. Significant expansion of the bus network will be essential.

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• The policy should refer to the key infrastructure projects to support the totality of growth in the Borough including the need for an improvement of the A38 Coxbench junction.

Policy IN2: Green Infrastructure, Parks and Open Space

• The policy is compromised by the map on page 113 which shows routes described as ‘Derbyshire Cycle Routes’. These routes are completed sections of the Greenway Strategy; some are on-road cycle ways and others are off-road multi-user routes. This map would be more powerful if it also showed the proposed sections of the Greenway Strategy. The Local plan should ensure that the Greenway routes are safeguarded on the Strategic Growth Sites. Developer contributions to the construction and maintenance of the Greenway network should not be overlooked. • ‘Open, Space, Sports and Recreation Facilities’ is the correct terminology to be used, and the different typologies of open space, sports and recreation facilities are defined in the saved companion guide. Green Infrastructure corridors are a typology of open space, and by reference to Green Infrastructure as the overarching term causes confusion. There is also a lack of reference to the other typologies of open space, such as local amenity green space; civic open space; indoor sports facilities; cemeteries and churchyards; and by stating ‘woodlands’ fails to capture all the different types of open spaces which are not woodlands, but are identified as natural and semi-natural areas. There is also confusion between how sports pitches are dealt with. In the supporting text to Policy IN2, sports pitches are referred to with the policy seeking their protection. Policy IN3 also covers sport and recreational facilities, which under the companion guide, the definition of sport and recreation also covers sports pitches. Taking this into account, sports and recreation facilities such as sports pitches are subject to two policies seeking their retention and criteria for their loss. • Need to consider ecological corridors that are cross-boundary.

Policy IN3: Community, Leisure, Health and Cultural Facilities

• 9,000 houses =around 36,000 additional residents. Existing medical and dental facilities are inadequate for such an influx. Little or no additional provision appears to have been planned. • Policy IN3 should be more focussed on community facilities such as the dual use of schools for community events, and seeking the protection of pubs and village halls in the rural areas which may be a community meeting place. It is recommended that these policies are separated to “IN2 – Open Space, Sports and Recreation” and “IN3 – Social and Community Facilities.” Both policies require re-writing in order to separate the issues between open space, sports and recreation and community facilities. • The policy provides criteria for the redevelopment and change of use of facilities, but does not reflect the National Planning Policy Framework with regard to protection and enhancement. The opening sentence of Policy IN3 should read: ‘The council will protect and enhance existing community, leisure, health and cultural facilities unless there is a requirement for their redevelopment or change of use which will be supported providing ………..’

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IN4: Strategic Transport Infrastructure Priorities

• With regard to the viability and deliverability of the A610 link road, it is considered by many that the £10 million cost is a substantial under estimation. The delivery would be dependent on, in the main, public money which brings into question the basis for exceptional circumstances for the release of Green Belt land for development. • The £10 million quoted in the IDP is to be treated with great caution as the history of road scheme implementation consistently shows that costs rise by at least a third over the original estimate. • There is no evidence in the form of a transport study that the A610 link road is required and there has been no examination of the alternative, more proportionate and significantly cheaper traffic management options. Derbyshire Local Transport Plan 3 does not afford significant priority to the scheme and emphasises how transport planning now prioritises shifts away from road building. • The recent planning application (AVA/2013/0966) submitted by Amber Valley Borough Council states that the prime purpose of the A610 link road is to serve the development that is taking place. The supporting traffic assessment accompanying the application only looks at the impact of the new housing on the highway infrastructure and not the existing situation. This seriously brings into question the exceptional circumstances to justify release of Green Belt land. • A road by-passing Codnor may have a significant detrimental effect on the vitality and viability of Codnor’s existing retail and services sector. A retail study should be undertaken for Codnor. • There is the likelihood that the proposals cannot be delivered within the plan period due to viability and the fact that there is no developer interest in the site. • There is a real danger that sections of the A610 link road will remain as roads into pockets of housing estates as no one developer will be responsible for joining it up. Needs to be clarity that the road will be completed first before the housing is considered. • Recent studies show that Ripley town centre does not need the Ripley Gateway Development and that there is not the capacity for it. • The Draft Plan states that by building an A610 link road between the A6 and A38 to the M1 would improve traffic through the Borough. But traffic from the A6 to the M1 North would use the A38 to Junction 28 of the M1. Traffic south would use the A38- A52 to M1 so again reasoning for the relief road cannot be justified only to build houses on Green Belt. • Page 107 the plan states "The DCC Local Transport Plan 3 (LTP3) 2011-2026 has identified A610 Ripley - Codnor - Woodlinkin Improvements as one of the 'priority' schemes….” My main strong objection to this statement is that you appeared to have omitted the word 'LOW priority' schemes as I understand it. • There is no mention in the proposals for SG2 that a developer contribution is required towards the construction of the road only towards extensions to two schools. There is no mention of other infrastructure developments. Codnor Parish Council believes that the proposed housing developments at SG2, combined with others within one mile of Codnor, would eventually result in a doubling of the population of the village, yet no other infrastructure plans (for health care, recreational facilities or shops for example) have been put forward.

231

• The A610 link road needs to be funded out of local and central government taxation revenues and not developer contributions. • Derbyshire County Council recognises that the potential impacts of this scheme are not yet known and further testing is required.

IN5: Infrastructure Delivery and IN6: Developer Contributions

• These policies should specify the key items of infrastructure that are crucial to delivering the Core Strategy, and when and how they will be delivered.

IN6: Developer Contributions

• This policy needs clarification in respect of the payments towards the cost of infrastructure collected through Section 106 contributions and/or the Community Infrastructure Levy to minimise the risk of double counting. • Object to some of the infrastructure items proposed: Broadband Infrastructure - The current funding shortfall should therefore be borne by the commercial providers of the service and not the consumers who are already paying for their service; Health and Emergency Services – may not pass CIL Regulation 122 tests; and Arts and Cultural Facilities – may not pass CIL 122 tests.

Appendix C: 5 Year Housing Land Supply

• In respect of applying an appropriate buffer in accordance with bullet 2 of paragraph 47 of the NPPF, it is noted that the Council have determined they are currently a 5% authority. The housing trajectory demonstrates that past completions since 2008 (i.e. the last 5 years) have fallen well short of the identified housing land requirement, therefore the 5% buffer is highly questionable.

Infrastructure Delivery Plan

• The Highways Agency suggests that the Derby Junctions scheme should be included in the IDP. • The Highways Agency suggest that reference to A38 infrastructure to support SG3: Land North of Denby should be re-worded to: ‘a parallel merge on the A38 southbound on-slip at the Coxbench junction’ and ‘traffic signals at the A38 northbound off-slip junction with the B6197 Derby Road.’ • Western Power Distribution seeks to engage with the developers all strategic sites to underground or divert 33kV wood poles where possible. WPD cannot have a planning condition that requires their removal as this will affect people’s electricity bills.

Sustainability Appraisal

• Table 19.1 proposes to use residual waste per household to monitor effectiveness of the Local Plan to deliver Objective 8 of the SA. The Environment Agency advises the following indicators should be included “Percentage of household waste sent for reuse, recycling or composting” and “Municipal waste landfilled.”

232

Response

The SA has been amended in accordance with this advice.

233

Bodies invited to make representations Appendix A

1-2 PlayDay Nursery Alfreton & District Heritage Trust Amber Valley Borough Council Action for Children - Youth Reach 1st Alton Manor Scout Group (Alfreton Alfreton Community Association Amber Valley Community Transport

1st Choice Dental Laboratory Ltd Adlington Planning Team Alfreton Further Education Centre Amber Valley Consultation Panel

1st Horsley & Kilburn Scout Club Adrian Heapy Alfreton Golf Club Ltd Amber Valley Council for Voluntary Services (CVS) 1st Horsley & Kilburn Scouts Adullam Homes Housing Association Alfreton Grange Arts College Amber Valley Disability Sports & 1st Openwood Scout Group Advance Land & Planning Limited Alfreton Hall Leisure Development Group

2nd Swanwick Scout Group Advanced Lifestyle Solutions Alfreton Heritage Centre Amber Valley Engineering

3663 African Caribbean Community Alfreton Leisure Centre Amber Valley Gymnastics Club Association 3rd Alfreton Boys Cubs & Scouts Alfreton Library Amber Valley Housing Ltd Age Concern Derby & Derbyshire A Hingley & Son (Timber Ltd) Alfreton Methodist Church Amber Valley Methodist Church Aim High A Robinson & Sons (Garages) Ltd Alfreton Model Railway Society Amber Valley Production (South) Ltd AIMS Accountants For Business A W Birch Alfreton Nursery School Amber Valley Riders AJ Fabrics & Crafts A Walters & Sons Alfreton Park School Amber Valley Scaffolding Alan Bentfield Ltd AA Computers Alfreton Party in the Park Amber Valley SOS Alan Newton Associates Ltd AAA Private Hire Alfreton Shop Mobility Amber Valley Sure Start Aldercar & Langley Mill Parish Abbey Tree Care Council Alfreton Town Council Amber Valley Sure Start Project

Abru Ltd Aldercar Community Language All Saints Church Ambergate Caravan Centre College Academy Book Services Alton Manor Day Nursery Ambergate Carnival Aldercar Infant & Nursery School Acanthus Stoneware Ltd Amber Sound FM Ambergate Neighbourhood Aldergate Properties Ltd Association A-Chem Ltd Amber Trust Alderwasley Parish Council Ambergate Primary School Acorn Training Consultants Ltd Amber Valley Access c/o DCIL Alfreton & District Funeral Services Amberol Ltd ACT Services

Bodies invited to make representations Appendix A

Ambivet Belper Meadows Bowls Club Association of Indian Women Barton Willmore Anchor Trust Belper Meadows Cricket Club Atis Real Barton Willmore LLP Andrew Large Surveyors Ltd Belper Mental Health Centre Atlas Building & Civil Engineering Barton Willmore on Behalf of Taylor Andrew Martin Associates Wimpey East Midlands Belper Minibus Association Autism Helpline (National) Anthony Aspbury Associates BATS Belper News Axess Systems Ltd Applied Electronics Ltd BDS Assist Ltd Belper North Mill B & B Products Architechtural & Building Design Bellway Homes Belper Poetry Group Servies Ltd B & J Carpets Belper & District Neighbourhood Belper Pottery Bowls Club Archway Interiors B & K Structures Ltd Watch Belper River Gardens Arden Court Group BA Recruitment Ltd Belper Amateurs Cricket Club Belper School Armstrong Burton Planning BAFA (Bullbridge and Sawmills Area Belper Amateurs Cricket Club Civic Society) Belper Town Council Arrow Recruitment Agency Belper Army Cadets Bagshaws Belper Town Football Club Arthur Medical Centre Belper Bridge Club Bailey Brook House Business Centre Belper Town Juniors Artists Belper Care & Mobility Centre Bailey Construction (Derby) Ltd Belper Traders Association Arup Belper Coal Supplies Baileys Printers Belper Travel Ashfield District Council Belper District 50+ Forum Bakewell & Partners LLP, Chartered Belper Youth and Community Centre Ashfield land Architects & Town Planners Belper Drop Inn Benzbavarian Service Centre Ashland UK Balvac Belper Golf Centre Better Metal Store Ltd Ashover Parish Council Banks Development Belper Historical Society Biggin by Hulland Ashtton Associates Ltd Bankwood Belper Leisure Centre Birchwood Equestrian Centre Asian Association of Chesterfield Baptists - East Midlands Regional Belper Library and North East Derbyshire Association Birchwood Lane Allotment Belper Local History Group Association Ass. Of License Multiple Retailers Barnardo's

Bodies invited to make representations Appendix A

BM Contractors Briggs Sayer & Co Burnsides (Marketing Aids) Ltd Cateby Estates Limited & Kedleston Estate. Bolsover District Council Brinard Joinery Ltd Butler Cook Cattermole Technical Services Booth & Stirland Ltd Brinsley Parish Council Butterley House CBI Border Office Equipment & British Chemical Distributors and C & P Structural Engineers Ltd Stationery Traders Association CED Ltd C B Plant Services Ltd Bow Distribution & Warehousing Ltd British Geological Survey Cedar & Co C Blount Bowers Electricals Ltd British Heart Foundation Cedar Doors Ltd C W George, Painting & Decorating Bowmer & Kirkland Ltd British Horse Society Celebrity Motion furniture Ltd CAB Boyer Planning(obo Bellway & British Ports Association Central Driveline Services Clowes) CABE British Red Cross Central Trains Ltd Boyer Planning, Environmental Cadenza VM Ltd Planning & Development British Telecom Centre for Ecology and Hydrology Consultants British Waterways (Central Shires Callow Parish Council CERDA Planning BPS Waterway) Camland Developments Ltd Chair of Arthur Medical Centre Bradfield Storage Handling Ltd British Waterways East Midlands Patients Group Campaign for Better Transport Brailsford and Ednaston Parish Broadbents Solicitors Chapel Studio Council Campaign for the Protection of Rural Broadholme Lane Caravan Park England Chapman & Chubb Solicitors Break Time Vending Brooklyn Medical Practice CamTAD Campaign for Tackling Charapak Ltd BREEAM Technical Consultant: Acquired Deafness Government Focus Broxtowe Borough Council Charnwood Management Centre Ltd Canlin Castings Ltd Brian Twigg Planning BTH (UK) Ltd Chartered Surveyors Capita Symonds Brian Wolsey (Planning) Ltd Buckingham Insurance Consultance Chartex Ltd Ltd Care For Independence Bridge Kitchens Chatsworth Settlement Trustees Bullbridge & Sawmills Civic Society Carousel Craft Group Bridgeshire Packaging Ltd Chesterfield Borough Council Burchell Edwards Carter Construction (Derby) LTD Chevin Fleet Solutions

Bodies invited to make representations Appendix A

Chevin House Farm Cottages Coldharbour Marine Country Land & Business D B Brooks Electrical Engineers Ltd Association Childrens Leukaemia & Cancer Colin Buchanan D Clark Support Country Scales Ltd Colin Jewkes D G Scott Ltd Chiltern Mills Country Tiles (East Midlands) Ltd Colliers CRE D I Blow Opticians Chris W Roads Ltd Country Work Studio Collis Engineering Ltd D J Redfern Christ Church Ironville Cow House Dairy Ltd Commercial Estates D S Smith Cinderhill OG Cox's of Belper Commission for Architecture and Dalbury Lees Parish Council CISWO (Miners Welfare) Built Environment Cresta Gems Dales Housing Cito (UK) Ltd Community Care Systems Crich Parish Council Dalesmen Male Voice Choir Citroen Services Community Transport Crich Patient Participation Group Dannah Farm Country House Ltd City Electrical Factors Ltd Concept Plastic Packaging Ltd Crich Tramway Village Danwood Group Civil Aviation Authority Connexions Derbyshire Criton Electrical Services Dash Homes ltd Clarke International Contract Planning Services Croft Infant School Dave Clark Clayton Engineering Co Co-op Cromford Parish Council Dave Knowles (Warm Air) Sales Cleaver Thompson Co-op Supermarkets Crosshill Garage David Beard Music Production Clowes Developments (UK) Ltd Co-operative Retail Logistics Crown Estate Office david lock associates Coal Merchants Federation Ltd Cope Sticks ct planning David Sharp Studio Codnor Boys Football Club Cooper Research Technology Ltd Curiosity Interiors David Wilson/Barratt Homes North Codnor Community Primary School Coppice Primary School Custom Cruisers (UK) Ltd Midlands

Codnor Horticultureal Ltd Corfield C Of E Infant School Customer Plus Ltd DCC Corporate Property

Codnor Parish Council Corporate College CX Automotive DCC Housing Strategy

COG - Community On-the Go Council for British Archaeology D A Spray Ltd DCC Older People's Forums

Bodies invited to make representations Appendix A

Department of Communities and Deaf Equality Forward Local Government Derbyshire Archaeological Society Derbyshire Economic Partnership

Deb Ltd Department of Health Derbyshire Association For The Derbyshire Federation of W.I.s Blind Ripley District U3A DEB Town Planning Derby & Derbyshire Constabulary Derbyshire Association of Local Derbyshire Federation of Women's Delta Business Solutions Ltd Derby & South Friends of the Earth Councils Institutes

Denby Cricket Club Derby City Council Derbyshire Autism Support Derbyshire Fire & Rescue Service

Denby Footpath Group Derby City Council - Children and Derbyshire Building Society Derbyshire Friend LGB Transgender Young People Support Group Denby Free C of E VA School Derbyshire Business Against Crime Derby City Estates Derbyshire Green Party Denby Free School Derbyshire Campaing to Protect Derby City Housing Strategy Rural England Derbyshire Gypsy Liaison Group Denby Institute Derby City NHS Derbyshire Childrens Holiday Centre Derbyshire Housing Aid (affiliated to Denby Parish Council Derby Community & Law Centre Derbyshire Chinese Welfare Shelter) Association Dennis Mowers Derby Diocesan Board of Finance Derbyshire Investments Ltd Derbyshire Coalition for Inclusive Department for Business, Innovation Derby Hospitals NHS Foundation Living Derbyshire Learning and Skills and Skills Trust Council Derbyshire Community Foundation Department for Children, Schools Derby Mobility Services Ltd Derbyshire Lohana Community and Families Derbyshire Community Partnership Derby Race Equality Council Derbyshire Mental Health Services Department for Culture, Media and Derbyshire Constabulary NHS Trust Sport Derby University Derbyshire County Council Derbyshire Police Department for Environment Food Derbyshire & Nottinghamshire and Rural Affairs (DEFRA) Chamber of Commerce Derbyshire County Council - Derbyshire Police Authority Children And Young Adults Department for Innovation, Derbyshire & Peak District Derbyshire Positive Support University and Skills Campaign for Better Transport Derbyshire County PCT Derbyshire Pre School Learning Department for Transport Derbyshire County Primary Care Alliance Trust Department for Work and Pensions Derbyshire Acute Hospitals NHS Derbyshire Primary Care Trust Trust Derbyshire Dales District Council

Bodies invited to make representations Appendix A

Derbyshire Probation Service DPDS Consulting Group East Midlands Family Placement EON Project Derbyshire Rural Community DPP EON Central Services Council East Midlands Housing Association Dr Malcolm Bell Ltd EP Industries Ltd Derbyshire Sport East Midlands Planning Aid Drainstore.com EPC-UK C/O Leith Planning Ltd Derbyshire Stroke Club Network East Midlands Trains DTZ Equality and Human Rights Derbyshire Toy Library Eastmidlands Japanese Association Commission Duffield & District Crown Green Derbyshire Voice Bowls Eastwood Town Council Equip Outdoor Technologies Ltd

Derbyshire Wildlife Trust Duffield Community Association Easy Accounts Ltd Erewash Borough Council

Derbyshire Youth Forums Duffield Cricket Club Eaton and Hollis Erewash Canal Preservation and Development Association Derek Latham & Co Ltd Duffield Parish Council EDF Erewash Partnership Ltd Derwent Living Duffield Village Forum EGNIOL Consulting Ltd Eric Madeley Ltd Derwent Mills World Heritage Site Duncan Residential LTD Ekard Ltd Partnership Eurocell DW Ball Prospect Management LTD Elastogran (UK) Ltd Derwent Theatregoers Evergreen Computer Consultants DW Motors Elim Pentecostal Ltd Derwent Valley Visitor Centre E & R Timber Products Ellis Fermor & Negus Excelpress Ltd Dethick, Lea & Holloway Parish Council E Surv Emery Landscapes Ltd Exercise for Health

Diocese of Derby Anglican Church East Midlands Airport England and Lyle Ltd Face to Face Financial Solutions Ltd

Diocese of Nottingham Catholic East Midlands Ambulance Service English Churches Housing Group Fair Play Church NHS Trust English Heritage Fairfield Sure Start Disability Direct East Midlands Councils Enigma Spa Fairgrove Group Ltd DMS Bookkeeping Services East Midlands Development Agency Entec (consultants for National Grid) Fairgrove Homes Ltd East Midlands Electricity Dove Valley Plant Hire Environment Agency Fairhurst

Bodies invited to make representations Appendix A

Federation of Small Businesses Fusion Online Ltd Godwin Developments Hall & Benson (Notts and Derby) Future Homescape Ltd Going Places Hall & Partners Fibromyalgia Group G S Worth Goseley Dale Farm Hall Pastures Farm Fields In Trust Gadsby Orridge Gough Planning Services Hallam Land Management Ltd Fisher German LPP Gatepost Theatre Company GraceMachin Planning & Property Hallprint Fisher German on behalf of the Trustees of the Locko Estate Gavin Kenning Engineering Graham Daws Associates halsall lloyd ltd

Fishermans Rest Gayton Luncheon Club Granite Connection Ltd Hamer Associates

Fleet Arts GE Equipment Grant MSM Ltd Hanson Aggregates

Florence Nightingale Derbyshire Gee Security Ltd Granwax Products Ltd Hanson Building Products Association Gem Vending Graphic Results Hardy Miles Titterton Forestry Commission Genesis Business & Conference Grays Interiors Harlite Installations Ltd FPCR Environment & Design Ltd Centre Greasley Parish Council Harris Lamb Freeth Cartwright LLP Geoffrey Prince Associates Ltd Green & May Ltd Hartshorne (East Midlands) Ltd Friends of Ambergate George Shipman & Son Ltd Green 2k Design Harvest Meadow Friends of Belper Parks George Wimpey Green Hillocks Fellowship Haslam Homes Friends of Belper River Gardens Gerald Eve Griffith Laboratories Haworth Estates Friends of Cromford Canal Girl Thing Griffiths Superior Homes Ltd Hayward Electrical & Mechanical Friends of Cromford Canal GL Hearn Services Ltd Groundwork Derby & Derbyshire Friends of Markeaton Brook Gladman Developments Hazelwood Bowling Club Guildford Europe Friends of Shipley Park Gleeson Developments Hazelwood Parish Council GVA Grimley Friends of Swanwick Hall School Go Mobile Ltd HCA

Friends of the Earth Godkin Holdings Halifax Estate Agents HCM Electrical Ltd

Bodies invited to make representations Appendix A

Heage Road Allotment Association Heaton Planning Ironville Parish Council Horsley Bowls Club Heage Village Hall Heaton Planning Ltd J & A Engineering Horsley Parish Council Health and Safety Executive Help the Aged J C Balls & Sons Horsley Woodhouse Parish Council Healthier Communities Herbert Strutt Primary School J C Balmforth Ltd Horsley Woodhouse Primary School Heanor & District Local History Heritage Heating (Midlands) Ltd J F Neville Society Housing Corporation Hickton Construction Ltd J K S Boyles UK Ltd Heanor & Loscoe Town Council Howard Sharpe and Partners High Peak Borough Council J S Bloor ltd Heanor 50+ Forum Hulland Ward Highedge Historical Society J Tech Roadshow - The Party Heanor Antiques Centre Idridgehay Community Centre People Highways Agency Heanor Baptist Church Idridgehay, Alton and Ashleyhay J W Andrews (Builders) Ltd Historical Model Railway Society Parish Council Heanor Carnival Committee JAG Communications Hives Planning Impala Stone Ltd Heanor Gate School Project James Beresford & Sons HLE Test & Service Centre Indian Friendship Society Heanor Gate Youth Club James Engineering Construction Holbrook Miners Welfare Football Indigo Planning Ltd (Alfreton) Heanor Green Belt Action Group Club Industrial Diamond Services Ltd JB Planning associates Heanor Historical Society Holbrook Parish Council Inland Waterways Association JCT 28 Heanor Lions Junior Football Club Holbrook Parish Plan Innes-England Jem Transport Heanor Memorial Hospital Holmes AntilHolme Farm Barnl Insight Town Planning Jessop Monument Trust Heanor Police Youth Project Home Builders Federation Ltd Institute of Directors JF Planning Associates Heanor Pre-school Home Farm International Council on Monuments JG Land and Estates Heanor Running Club Home Office & Sites UK JKW Refinishing Supplies Ltd Heanor Swimming Club International Shromani Akali Dal Home Start Amber Valley JMW Planning Ltd Hearing Help (AV) Ironville 1860 Homes and Communities Agency Jobs 2 Do

Bodies invited to make representations Appendix A

Kirk Langley Parish Council John A Clarke Kam Servicing Network Lightspeed Derby Kirkwells - town planning and John Carr Motorcycles Ltd KAS Designs sustainable development consultants Limes Medical Centre

John Church Planning Consultancy KDW Ltd KJD Little Eaton Parish Council Limited Kedleston Park Golf Club Knight Frank Living Stones Sculpture Workshop John Day Decorators Ltd Keepsafe Security Services Ltd KVM (UK) Ltd Liz Portas John Dobbs Developments Ltd Kelvingrove Medical Centre Kyleburn Historical Society Loscoe C of E Primary School John Flamstead School Govonor Kevin Palmer Media Services LA Engineering Belper Ltd Losoce Dam Project John Flamsteed Community School Key Property Solutions Ltd Lambert Smith Hampton LPG Conversions John Martin & Associates Keyclad Ltd Lynx Motor Co Ltd John Smedley Ltd Langley Corporate Wear Ltd Kilburn Area Preservation Group M & C Hunt Johnson Diversey UK Langley Mill Baptist Church Kilburn Infant and Nursery School M A Broughton Electrical JPK Engineering Ltd Langley Mill Junior School Kilburn Nursing Care Centre M D & W Buxton Ltd JS Bloor (Services) Langley Mill United Cricket Club Kilburn Osteopaths M J Maillis UK Ltd JS Environmental Ltd Langridge Homes Limited Kilburn Parish Council M R Booth JT Marketing Research Leedale Ltd Kilburn Post Office M T Buxton Industrial Services Ltd Jubilee Wedding Cars Leonard Cheshire Disability Kilburn Preservation Group Mackworth Estate Community Judy Mallaber MP Leonard Miles & Son Association Kinetika Just 30 Ltd Les Hutchinson Transport Ltd Mackworth Parish Council King Sturge LLP Just Bandits Ltd Les Riley & Sons Ltd Maintenance Painting Systems Ltd Kirk Hallam Building Company Ltd Just Jigsaws Ltd Lester & Nix Ltd Kirk Ireton Parish Council Malcolm Judd and Partners JVH Planning Life Matters Kirk Langley Community Orchard Malcom Scott K & A Cox Ltd Lighthouse Charity Shop

Bodies invited to make representations Appendix A

Manthorpe Engineering Ltd Melfort Construction Services Ltd Milford & Makeney Community Morley Parish Council Manx Engines Merebrook Consulting Ltd Group Morley Primary School Maple Arenas Merriman Plant Milford House Morris Homes East Midlands Ltd Mapperley C Of E (Controlled) Metmachex Engineering Ltd Milford Pre-School Primary School Mortgage Force Metropolitan Housing Trust Mill Systems Mapperley Parish Council Mortgageline Services Ltd Michael Blake - Personnel Miller Homes Ltd Marathon Thread (UK) Ltd Consultant Moss Office Services Ltd Mills Computer Products Marehay Bowls Club Michael Goodall Homes Ltd Internationsl Ltd Motor Neurone Disease Association (Derbyshire) Marlpool Infant School Michael House Steiner School Milward Construction (Belper) Ltd Mowhawk Laboratories Marrons Ministry of Defence Micro Connect Ltd MPC Services (UK) Ltd Marshall & Till Mitech Joinery Microbial Innovations Ltd MT Refrigeration Marston On Dove Estates Ltd MMA design Ltd Mid Derbyshire After Care Project Mundy School Martineau MMD Mining Machinery Middlebrook Transport LTD Development Ltd Nathaniel Lichfield & Partners Massive Youth Project Midland Building Design Practice Model farm Nathaniel Lichfield and Partners Mather Jamie Midland Railway Trust Ltd Mono Consultants National Federation of Gypsy Liaison Matlock Bath Parish Council Groups Midland Structural Services Montague Architects Ltd Matthew Montague Architects Nationwide Ceramics Midland Tree Management Montague Architects Ltd Maypole Promotions Natural England Midlands Association for Amputees Monty's McDonalds (Alfreton) and Friends (MAAF) Natural England Moorgreen Flexible Packaging Ltd Meadow Farm Studio Midlands Co-op Travel Natural England Moorwood Moor Angling Club Meadowstone (Derbyshire) Ltd Midlands Co-Operative Funeral Natural England Services Morecrofts Electrical Medequip Assistive Technology Ltd Natural England Midway Fencing Contractors Ltd Morgan & Co (Belper) Ltd

Bodies invited to make representations Appendix A

NBE Fire & Security Ltd North East Derbyshire District Council Page Whelan Design & Print Ltd Pearsons Engineering Services Ltd NBE Fire Prevention Ltd Northern Counties Pakistan Cultural Association Pegasus Planning Group Nealies Nottingham City Council Paragon Financial Consultants Pennine Plant & Tool Hire Ltd NEDCASH Nottingham Community Housing Parfetts Cash & Carry Pentalpha Exhibitions Ltd Neeco Engineering Ltd Association Park Hall Timber Buildings Pentrich Parish Council Nelson Distribution Nottinghamshire County Council Parker Design Associates LTD Permaroof (UK) Ltd Nelson Distribution Ltd Nottinghamshire Wildlife Trust Parkinsons Disease Society Personnel Support Services (Derby) Nether Heage Methodist Church Nuthall Valve Services Ltd Ltd Parkside Surgery Network Rail NY Garden Services Peter Diffey Associates Ltd partially deaf and partially blind Network Rail property Office of Government Commerce Past Times Peter Swan Associates New Bengal Balti & Tandoori Oldroyd Associates Restaurant Patients Group, Arthur Medical Peveril Homes Omnivale Limited C/O Antony Centre New Life Church Aspbury Associates PFD Flooring Ltd PCS Edmundson Electrical Ltd New Street Accounting Optima Financial Planning Ltd Phase Print & Design Peacock and Smith ng nattrass giles Opun - Regeneration East Midlands Pidcock & Beastall Ltd Peacock and Smith on behalf of Wm NHS East Midlands Orange Personal Communications Morrison Supermarkets Ltd Pilkington Architecture Limited Services Ltd. NHS Logistics Peak District National Park Authority Pinxton Parish Council Ormonde Fields Golf & Country Club Nigel Davis Solicitors Peak District Rural Housing Planning Design Practice Ltd Ornamental Engineering Association NLP Planning Planning potential Our Vision, Our Future Peak Oil Products Ltd Noise & Vibration Consultants Ltd Planning Potential P & A Finishes Ltd Peak Plastics Ltd Norder Design Associates Ltd Plant Equipment Ltd P J Hamson & Co Ltd Peak Vending Systems Ltd Norseman Holdings Ltd Planware Ltd Padley Hall Peakweb Ltd

Bodies invited to make representations Appendix A

Plastick Windows Right 4 Staff Roper Avenue Allotments Raglan Housing Association Polymerlink Ltd Ripley & District U3A Rosehips of Duffield Rail Freight Group Post Office Ltd Ripley & Heanor News Rotrex Winches Ram Furniture Powrie-Smith Architects Ripley Academy of Dance & Drama Royal Mail Ramblers Association Press for Change Ripley Business Forum Royal Mail Group Rapleys LLP Pride of Place Ripley Greenway Play Area Royal Society for the Protection of Reach Out, Dignity, Womens Zone Birds Prime Precision Ripley Heritage Trust Red Line Cars Royal Society for the Protection of Princess Royal Class Locomotive Ripley Historic Society Birds Trust Redrow Homes Ripley Methodist Church RPS Engineering Ltd Print Scene (Print & Signs) Ltd Resco Railways Ltd Ripley Music Festival RPS Group Promopac K Digital Studios Rethink (Mental Health) Ripley Neighbourhood Care Scheme RPS Planning and Development Prosign Print & Production Richard Mullard Ripley Printers Ltd RPT Engineering Ltd PW Services Loscoe Ltd Richard Savidge Ripley Town Council RPT Rewinds QA Associates Richard Savidge Chartered Surveyors RMA Ltd Rudolf Chemicals Quality Direct Office Supplies Ltd Richardson Endowed Primary Road Haulage Association Ltd S & K Antcliffe Quarndon Parish Council School Robert Clarke Chartered Surveyors S H Field Ltd Quiltex Ltd Richford Motor Services Ltd Robinsons Solicitors Safety Deck R D Geeson (Derby) Ltd Riddings Junior School Rocbore Ltd Safety reflectives Ltd R.J. Ryder Planning Consultant and Ridgeway Nursing Home Architect Roger Tym & Partners Salcare Ridgewood Equestrian Centre Rachaels Bouquet Roger Yarwood Planning Salloway Property Consultants Ridgewood Farm Consultants Ltd Radbourne Parish Council Riding for the Disabled Rollersnakes Inline Hockey Club Salt Pot Café Radleigh Homes

Bodies invited to make representations Appendix A

Sanderson Weatherall LLP Somercotes Library South Yorkshire Passenger Shipley Hall Transport Executive Sangham Group Somercotes Medical Centre Shipley Motor Co Ltd Southern Derbyshire CCG Sarah's Foot clinic Somercotes Parish Council Shipley Parish Council Southern Staffordshire Chamber of Save The Children Fund Somercotes Parish Council Commerce and Industry Shipley Parish Plan Savills Somerlea Park Centre Space 4 Work Shirland and Higham Parish Council SB Wrought Iron Ltd Somme Road Environmental Spirita Shottle & Postern Parish Council Improvement Group Scaan Ltd Sport England SIA Abrafoam Ltd Sound Dynamics Ltd Schades Ltd Sport England - East Midlands Signet Planning Sound Products Region Schofield commercial Interiors Ltd Simpley Tiles Ltd South Derbyshire Council Spotted Cow Scorpion Exhausts Ltd SJY South Derbyshire District Council SSAFA Forces Help Scott Wilson Ltd Slacks Travel South Derbyshire Voluntary Sector SSR Planning Scotts Heavy Haulage (Ireland) Ltd Mental Health Forum Slater Electrical St James Church Codnor Scrumptious South Normanton Parish Council Slenderella Wholesale Ltd St John The Baptist C of E Church Seat Design Co Ltd South Staffordshire Water SLS Design Consultants Ltd St John's C of E Primary School Selston Parish Council South Staffordshire Water Plc. Smalley Church St Johns Primary School PTA Selway Group South Wingfield Local History Group Smalley Parish Council St Luke's Church Selwood Plant Hire Ltd South Wingfield Methodist Church Smith Cooper St Margarets Hall Alderwasley Sercel England South Wingfield Parish Council Smith Stuart Reynolds St Matthew Morley C of E Church Severn Trent Water Ltd. South Wingfield Primary School Smiths Gore Staff Connect Shepherd Hydraulics & Pneumatics South Wingfield School PTA Sndritz Sales (UK) Ltd Stanley and Stanley Common Sherwood Packaging Ltd South Wingfield Social Club Solid Fuel Association Steam-Models Shipley Cricket Club

Bodies invited to make representations Appendix A

Stedmark Tarragon Electrical Services Ltd The Derbyshire Federation for Sure Start (Ripley) Mental Health Steedman Planning & Land Taylor Wimpey UK Limited Swanshaws Ltd The Dolls House Emporium Steedman Planning, Ashby De La TC Fabrications Ripley Ltd Zouch Swanwick Baptist Church The Durham Ox Terra Nova Equipment Ltd Stent Swanwick Community Association The Ecclesbourne School Testing & Analysis Ltd Stephen Jones & Associates Swanwick Hall School The Education Welfare Service THC (Midlands) Ltd Stephen W Bateman Swanwick Methodist Church The Employment Law Director Ltd The Bear Inn & Hotel Stepping Forward Swanwick Parish Council The Finch Consultancy Ltd The Beattie Partnership Stepping Stones Swanwick Parish Council & Tansley The Guinness Trust - Midlands Area Parish Council The Black Swan Office Steve Beer Transport Ltd Swanwick Petition The Bridge Inn The Highways Agency

Steven Thaw Swanwick Pre-school The British Wind Energy Association The Imperial Decorating Co

Stonewall Swanwick Primary School The Certificate Framing Co The Jessop Medical Practice

Stop 500 Swanwick Residents Association The Christian Conference Trust The Kedleston Country House Hotel

Stormwater Proofings (UK) Ltd Swanwick School & Sports College The Church Commissioners for The Kings Head Inn England STR UK Ltd Swanwick Social Club The Lawn Tennis Association The Coal Authority Strawberry Field Allotment Swanwick Womens Institute The Marquis of Ormonde The Codnor Castle Preservation Street Lane Community Association T & M Motors Society The Mulberry Bush

Strutt and Parker T E Boddington The Cottage Private Day Nursery The National Autistic Society

Studio Emet Tapton Estates Ltd The Curzon C of E Primary School The National Forest Company

Summerfield Engineering Ltd Tarmac Ltd The Curzon C of E Primary School The National Probation Service

Sure Fire Technical Services Ltd The David Sharp Studio The National Trust Tarragon electrical Services Ltd Sure Start (Bolsover) The Park Surgery

Bodies invited to make representations Appendix A

Waystone Ltd The Phone Shop Tree Hugger & Son Tree Services Victors WBC Export Services Ltd The Planning Bureau Ltd Trent Barton Vincent & Gorbing Webcare Ltd The Planning Design Practice Triple S Fabrications Ltd Voice (East Midlands BME Forum) Weldex The Playstation Private Day Nursery Triples Fabs. Ltd Voluntary Community Mental Health Ltd Support (Red Cross) Welfare Rights Service Trusley Parish Council The Showmen's Guild of Great W A Protheroe (Belper) Wessington Parish Council Britain Turley Associates W Beach & Son West Hallam The Stroke Association Turley Associates for Western Power Waingroves Community Association Weston Underwood Parish Council The Theatres Trust Turnditch & Windley Parish Council Waingroves Community Woodland Wheeldon Brothers The Tors Community Sports Club Turnditch C of E (Aided) Primary Waingroves Drama Group White Peak Distribution The Woodland Trust & Ancient Tree School Forum White, Young and Green UIM Propertys Ltd Waingroves Primary School Thomas Williams Recreation Ground Whitehall Financial Independent Ltd UK Coal Walker Products Ltd Thomsons Whiteheads Solicitors Ltd UK Mediation Ltd Walkers Bingo Club Time Designs Wigglesworth Planning Ltd UK Tyres Direct Ltd T/A Peak Signs Walton & Co TMCS Wildlife Trust Umbrella Warwick Development (East Topaz Computer Systems Ltd Midlands) Ltd William Bailey Ltd United Castings Ltd Trade Services (Belper) Warwick IC Systems Ltd William Davis Limited University of Derby Trade Web Solutions Wass Management Ltd William Davis Ltd UPM Tillhill Trakotel Watchorn Memorial Methodist William Gilbert Endowed School UPS Church Transcare 28 Ltd Windley Village Preservation Trust Vibrock Ltd Watchorn Tennis Club Transition Belper Windley Woodland Victim Support Derbyshire (Amber Waystone Traveller Law Reform Project Valley & Erewash)

Bodies invited to make representations Appendix A

Windows 2000 Ltd Woodville Sure Start Your Move Wirksworth Town Council Woodward PDA Ltd Your Move Attenborough & Co

WJB Welding & Fabrication Ltd Word by Word Proofreading Zycomm Electronics Ltd Women's National Commission Services

Wood Lane Garage Wrights Garage

Woodbridge Junior School Wrights Good Tyres

Woodland Trust WTS Manufacturing Ltd

Woodlands Wulf Investments Ltd

Persons invited to make representations Appendix A

Mrs Enid Abbott Mrs Melissa Amey Peter Alldread Ms Jill Arrowswell Ms Beverley Abbott Ms Vanessa Ancliff Ms Amanda Allen Ms E Emma Ascott Mrs S Abel Mrs E Evonne Anderson Beth Allen Miss R C Asher Asher Mr D Abel Mr C Christopher Anderson C M Allen R Ashton Ms Katie Ablett Anderson Chris Allen Mr Andrew Ashton Ms Nichola Abrehart Mr Geoffrey Andrews Mrs C Catherine Allen J Jean Adams Mr Martin Angold Mr Simon Askew Mr & Mrs R Allsop Ms Sharon Adams Ms Louise Annable Mrs C Aspinall Mrs P Allsop J E N Adams Ms Jennifer Annable Mr A Aspinall S P Allsop Mr Steve Adams Mr Tyler Annable R Atkin M Allsop Mr & Mrs Adeach Mr Jordan Annable Miss R Rosie Atkin Mr & Mrs William & Pamela Allsop Ms J Jenny Aitken Ms Donna Annable Ms M P Mary Atkin Mr M Michael Allsop Mr Luke Aitkin Ms Chantel Annable Miss S Sarah Atkin Ms Gail Allsopp Kamel Akil Ms Codie Annable Miss Atkin Mrs M Allsopp Mr & Mrs K Aldread Mr & Mrs Anthony Mrs P Pauline Atkin Miss T Allsopp Ms Susan Aldridge Mr James Anthony Mrs Atkin J M Jessey Allwood Luke Allan-Smith H Antonova Mr William Atkin L Leslie Allwood Ms Olivia Allcock Mr & Mrs M Mark Armes Mr Atkin Mr Trevor Almey Heather Allcock Mr Neil Armstrong Mr S Scott Atkins Ms Jenny Almey Mrs Vera Alldread Mr T Tim Arnold Mr S Stuart Atkins L Alton R Alldread Ms W Winifred Arnold Mrs C Carol Atkins Ms S Sandra Alton J Alldread Mr P Peter Arnold Mr & Mrs S L & E.M.C Atkinson

Persons invited to make representations Appendix A

M A Bailey Dr Steven Atkinson J E Bannister Mr & Mrs Barratt B & M Bailey N Atkinson J W Bannister Tim / Julia Barratt / Todd Mr A Bailey D Atkinson M Banton Ms Stephanie Barrett Ms Pamela Bain B B Atkinson K M Barber Mr Ken Barrett Mr Anthony Baines Mike Atkinson John Barber Mr M Barrett C Baines Mr M Mark Attenborough Diana Barcz Mr Pearce Barrett Ms Baker Mr Peter Attenborough S E & A Barham Mr Andrew Barrett D T Baker Ms S Sara Austick Mr Barker Duncan Barron Mrs B Baker Mrs Sarah Austin Mr & Mrs Christine & Roy Barker Christopher Barry Ms Elaine Baker R W Austin R D Bartlett Miss T L Baker Mr & Mrs Barker Luke Axten A Bartlett Mr / Mrs J / W Jon / Wendy Baldwin MS Laura Barker Mr Richard Bacon D J Barton Mrs R Ball Mr P Barker Mr Lambert Bacon Mrs Betty Barton MS Lisa Ball Barker-Dix Mrs Peggy Bacon Ms Josie Bate Mr Ken Ball Mr S Steve Barlow J Bacon Miss I E M Bateman Mr Keith Ballin Mr James Barlow C Bacon Mr N P M Bateman Ms Lynne Bamford R & H Barnes Mr M Bagan Mrs Janet Bateman J & E Bamford A Barnes Mr Mike Bagan Mrs S M Bateman K Bamford Mr K Kenneth Barnsley Mr & Mrs Bagguley Mrs Eileen Bates S Band Ben & Nicola Barrass M Bailey Peter Bates Mrs Elizabeth Bankes Mr John Barratt Ms Theresa Bailey Mr Andrew Bates Mr David Banks Mrs Barratt

Persons invited to make representations Appendix A

J S Bates Richard Biggin Natasha Bednall J Bentley Batters Leanne Biggs Mr J Beeby Tony Bentnall Mr / Mrs B / J Bilbee Mr W G Bax M Beeley Gary Beresford P Baxendale Lindsay Billsborrow Mr I Ian Bell John Beresford J Beadell Tom Bingham Mrs P Bell E K Beresford M Beadell Kelly Birch Cllr G Graham Bell Kate Berkin Mr G Gerald Beake B Birch Mrs P Bell Mrs C Bestwick Beard Mrs W Birch Dr Bell Lisa Bestwick Mrs D Beard Steve Bell Michelle Bestwick-Walters Caron Beardmore Mr Ralph Birch Mary Bell Cameron Beswick Julie Beardsley Mrs J Jean Birks Ms C Caroline Bell John Beswick Steele Mr Scott Beardsley Mrs D Birks Erwin Bene Mr A Bettison Mrs H L Beardsley Mary Bishop Mr & Mrs J G Bennett Mrs L R Bettison J W Beardsley Mr & Mrs Bishop Maureen Bennett Mr / Mrs T M / D Bevan Jorge Beasley O Biss Mr M R Bennett Mr D David Bewick M Beasley Mr R J W Black Malcolm Bennett Emily Bexon Mr Alan Beastall Miss C Black Mrs S Benniston D Bexon Mrs C Beaston Mrs J Black Tim Benson Rose Bexon Corrina Beatson Robyn Blackburn Mrs P F Benson Rose Bexon Mr S Beaver Blackwell Mr/Ms D / F Dave/Fay L Laura Bexon Mr M Mike Beavis Benson/Couchman Penny Blackwell Natasha Bexton F Beckett Sheila Bentley Mrs Christine Blake

Persons invited to make representations Appendix A

Margaret Bonsall Ms B Beverley Bott Simon & Juliette Blake Bradley Ms A Alyson Bott-Stevenson Anna Bland Mr John Bonser L Bradley Peter Bowden-Smith Rosalind Bliss Mrs L J R Bonser W Bradley Mr A S AS Bowler Geoff Blissett Miss Sophia Bonser Alan Bradley C Bowler Mr George Blount Mrs Janine Bonser Karen Bradley Ian Bowler Mr Jamie Blount Mr Paul Bonser Mr M Malcolm Bradley Alan Bowley Mrs C Blount Mr Derek Bonser Nicola Bradshaw Mr & Mrs A P Bowley Blount William Bonser Helen Braithwaite Jennifer Bown Mr &Mrs Boam Nicole Bonser Mr J John Brassington F Finlay Boxall Mrs C A Boddington Mr M S Boot Brassington Boxall Boik Booth Ms J Jill Brassington Scott and Lianne Boxall Mr P Philip Boles Dylan Booth Mr P Peter Brassington Boxall Ms L Lynn Bollard Suzanne Bore Colin Brassington L Laila Boxall Sarah Bolt Mr & Mrs D J Bore Mr & Mrs P & C E Bratt Mr & Mrs S, L, F, & L Boxall K Kim Bond Mr & Mrs J C & KJ Bore Carl Brearley

Mr Ryan Bond Andy Bore Mr & Mrs N Boxall M B Brennan Zoe Boyes Mrs L Lyn Bond Jez Borysiak Keri Bretnall Mr D Bradbury Mr L Laurence Bond George Bostock Samantha Brewer David & Pauline Bradbury Mr Adam Bond Mr & Mrs Bosworth Sandra Brewster Bradbury Mr M Malcolm Bonnington C & S Bosworth Cllr Alwyn Bridge Bridget Braden R Bonsall Richard Bott Ann Bridgeford Polymnia Bradford

Persons invited to make representations Appendix A

John Bridges Judith Buckley Valerie Broom Rokia Brown Elspeth Brien J Buckley James Broome Kevin Brown Mrs M Briers Mick Buckley M W Brougham Ms S Sharon Brown Mr R Robert Briggs Jim Bull Mr David Brougham Sidney and Monique Brown R Briggs Karina Bull Katie Brougham Mrs Marilyn Brown Mrs Amie Briggs Richard / Vanessa Bull Ann Brougham Jonathan & Jemma Brown P Briggs Mrs S Sandra Bull J Brougham Mr J Jonathan Brown John Briggs Ms H Hellena Bull Olivia Broughton Mrs V Brown Julie Briggs M Bull M A Broughton S Brown Mrs P M Briggs Beryl Bullman Dennis Brown David Brown Mrs Briggs A W Bullman John Brown Mrs A Brown Robert Briggs Peter Bullock E.J. Brown Paul Brown Anna Bristow Mr I Ian Bunting Mrs A Brown Mark Britland Lee Brown Fiona Bunting Mr I Brown Diane Broadhead R G Brown T J & M Brown Steven Bunting Mrs A E Broadhead R Rachel Brown Tom & Gillian Brown Mrs H Helen Bunting Mrs J Broadhurst Mr D David Brown Laurie Brown V Burgin Mr & Mrs Brookes Mr G Graham Brown Mrs H Brown M Burgoyne Paula Brooks Brown C & S Brown / Barton Caroline Burke Clifford Brooks Mrs P Brown John Bryan Jo Burkinshaw Christine Brooks Brown C & M Buckland A Amanda Burley Mr W Brooks-Kinder Brown

Persons invited to make representations Appendix A

Paige Burley Janette Campbell Mrs Margaret Buxton J B Cartland Darren Burley Campbell Kim Buxton Alan Cartledge Nicola Burns Mrs E Campbell Buxton Mr K Cartledge Ms Sally Burns Campbell MS N Buxton S & P Cartwright Olly Burrell Campbell Neil Buxton Gaynor Cauldwell Mr A Burston Mr A Campbell Buxton T & J Tom & Janice Caulfield R Burt Ms D Donna Canlin Brian Caulton Mr Anthony Burton Mr Stanley Buxton T Cann S Sam Byard Gina Chadwick A C Burton Mrs Y Capewell Mr R Richard Byard David / Janine Chadwick Mrs Patricia Burton Mr Vincent Capewell Christine Byard Andy Chadwick Burton Mr R Roger Capewell Mrs J Janice & Emily Byron Louise Chamberlain Mr T Trevor Bush Miss Lianne Capewell Mr J R Byron M Chamberlain Mrs G Busuttil Mrs P A Capewell L.J Cade John Chamberlain Adam Busuttil Mr & Mrs C & H Carman O I Calladine C Chambers Janet Butler Stephen Carnelly Ms J Jayne Calladine G Chambers S Stuart Butler Mrs B Brenda Carpenter W C Calladine M Chambers L Butt Ms E Emma Carr M Callaghan Ross & Emma Chambers mr & Mrs C Butt Lynda Carter Michael Callahaan Mr & Mrs Chandler M Butt Denise Carter Mr P Paul Callister M Madeleine Chandler G Butterfield Carter Claire Campbell J Channell Marcella Buttery Mr P J Philip John Carter Mark Campbell Denise Chapman K Buttery Mr & Mrs K Carter

Persons invited to make representations Appendix A

C P Chapman Natalie Clarke Jane Coleman L Clark Mrs B Charles Miss Jade Clay M Coleman Mrs J Clark Miss A Chase Michelle / James Claypole / Throw Mr / Mrs D / C David / Christine Christine Clark Colledge Alison Chase H Clemens Paul T Clark David Colledge D Diane Cheetham Alyx Clark Mr & Mrs K & K Clements Becci Colledge Ms P Cheetham Linda Clark Mr Roy Clements Mr & Mrs M Mark & Maxine Colledge Trevor Childs Mrs Janett Clark C Corinne Clemson Anthony Colledge Childs Peter Clark J Jonathon Clifford David / Christine Colledge Mr G Chill Ms M Melinda Clark Mr & Mrs Clifford Mr M Mike Collier Miss Susan Chinchen Georgina Clarke Mr K Kevin Clifton Collier Richard Christian Samantha Clarke D Clowes Mrs B Brigitte Collier Mr / Ms J / D John / Diane Churchill G Clarke Ms S Coates M Collins Ms D Dawn Churchill Carol Clarke Mr A Cockayne M & C Collins Mr David Clapham Mrs N Clarke I Cocker Rachel Collins Stephen Claridge Peter Clarke C Cohen Michael Collins Helen Claridge J Janet Clarke Mr & Mrs Coker Richard Collis Mr D David Clark Ginette Clarke M Colcioual Jenny Collyer Mr N Niall Clark Pat Clarke Mr M Colclough J Colombo Rebecca Clark Mr M Matt Connell Susan Clarke M & S Colclough Alison Clark Mr A Anthony Connor Mrs Nicola / Kieran / Lauren Clarke David and Angela Cole Staphanie Clark Miss Kirsty Conquest Ms Monique Clarke Lorna Cole Joseph Clark Jonathan Cook

Persons invited to make representations Appendix A

Lindsey Cox Mr P Paul Cook J Cooper Mr C Colin Crowder Molly Cox E Cook Chris & Griff Cooper & Ererett J A Crowfoot F W Cox Tracy Cook Cope Mrs Jean Crowshaw Mrs L Coxlead Mr Brian Cummings T O Cook A P Cope Jim Crabtree Christine Cummings V & L A Cooke / Inquieti D Cope Mrs N Nicola Crabtree Lee Cummings / Wheatley Clare Cooper Mr S Steve Cope P & J Cracknell D & E Dave & Elaine Cunnah Mr P Paul Cooper Mr & Mrs H Harold Cope Phil & Jackie Cracknell Mrs Jocelyne Cunningham Mr T Tony Cooper Chris Copeland Ms K Kay Crago Mr J H John Cunningham Mr & Mrs P & L Phil & Louise Mr & Mrs Corns Cooper Craig Russell Currins Claire Cottam D Cooper Phil Cresswell Curtis Mr J John Cotton Sally Cooper Mr & Mrs S Cresswell Richard/ Erica Cuthbert/Sommer Mrs J Jean Coulson Kathleen Cooper Mr & Mrs Cresswell Mr / Mrs A Daddy Mr R Coulter L Cooper E Crews Pete Dakin S Coulter Justin Cooper Ann Crisp Linda Dakin Mr Edward Cowey Mrs S Cooper Robert Critchlow Mr N Daley Geoff Cowlishaw Mr & Mrs G Gordon Cooper Mrs Margaret Croft Mr M Michael Dalton Mr A Alan Cox Mr G Geoff Cooper P Croft Gilles Daniel Celia Cox John & Leni Cooper Crombie Mr, Mrs and Miss P Daniel Amy Cox Mr J A Cooper Ms Louise Cross Dianne & Robert Darke Mr Matthew Cox Mr D Cooper Thomas Cross Mr Dasson Mrs S Cox Miss Helen Cooper B Crossland Laura Dauson

Persons invited to make representations Appendix A

H Dawn T David Mr / Mrs J John Devonport Mr B Bob Dossetter Ms J Jill Day Christal David Karen Devonport Mrs A H Dossetter G & N Day Issy Davidson Mrs Patricia Dewis Dr Alexander Dossetter T Day Mr N Nigel Davidson Mrs M Dexter May Douglas T Day Mr P A Davies M Diamond Ian Douglas Colin Daybell Katy Davies Andy Dickenson Mr M Michael Downes Diane Daybell A Davies R Dickerson Tracey Downing Mrs Glenda Dean Davies Dickinson Dr Una Doyle William Deans Mr T Davies Mrs D G Gillian Dickinson E Draper Rebecca Deans B Dilks Mrs B Davies R Draper Gillian Deans R B Dilks Karen Davies Mr R Ross Drenic Leah Deaton Mr C Clifford Dobson Mr T Davies Mr Peter Dring Jonathon Deaville Andrew Dodman James John Davis Mrs Fern Drummond Mr Brian Deer Jan Dodsley L G & C Davis David Dryburgh Sarah Delrosso Mr P Dodson B & H Davis Mr David Dudek P Dempsey Neil Doherty Beth Louise Davis Carol Dun Anna Dempsey R W Doleman P Davis Joan Dungworth Amy Dennis Mr G Graeme Donald Sheila Davis June Dunlop Jackie Dennis Ms K Karen Donald Graham Davison E M Dunstan Mrs S Dennis Mr N Dore S O Davy G Dunstan Robert Derbyshire Mrs S Dore B Beverley Dawes J Dunstan Karen Devonport Mr J Dore

Persons invited to make representations Appendix A

M Dunstan Jaya Eley J S Eratt John Farrow Mr P Paul Durant Mrs A F Annette Eley Jamie Eratt Duro J Farrow B Elliott J Erratt Mrs P Pamela Durose Stephen Fathers Mrs Y M Elliott J S Erratt C & K Durose Mr N Neil Fearenside Mr C Elliott P Pat Ethelston Mr Trevor Durose Mr & Mrs Feeney Miss Sarah Elliott S &M Evans Liam Dwane Viviane Ferris Mr B Brian Elliott K Evans P R Dye Andrew Fiddes John & Pauline Elliott T Evans David Dykes Andrew Field Mr Roger Elliott A Evans Robert Eadsh Brian Field T Elliott Mrs S Everett C East Mrs L Field E Ellis Paul Ewings Kathy Eastwick Kevin Finn Hannah Ellis Elaine Ewings Paul Eastwood Craig Finn C Elmeel mrs P Ewins Mr R Eaton I Ian Fisher Mrs M Else Mr P J Ewins Mr & Mrs Edgar Mr & Mrs L Fitzgerald R S Ely Ms A J Eyre Mr & Mrs Edmondson Laura Flemming Mr & Mrs M & C Emery R L S Eyre S Stuart Edwards Mrs A Emmas-Williams Ian & Rachel Flemming Mr & Mrs Eyre Mrs Egner H R Emmas-Williams Kathryn Fletcher Kathy Fairweather Ian Elder Cllr C Chris Emmas-Williams B B Fletcher Ms T Tina Faloon K Eley Roland & Sheila Emmas-Williams Mr T Terry Fletcher A Farmer Sam Eley T Tracy England Janet & David Fletcher Brigid Farnan Clive Eley Mr P Paul English Mr / Mrs A / D Fletcher David Farrelly

Persons invited to make representations Appendix A

L Fletcher Ron Ford Dr & Mrs R & M Gaunt Mr Michael Frost Steven Fletcher Ford Y Gay Sarah Frost Mrs L Fletcher Forman Philip Gedard Christopher Frost R & K Fletcher & Bock Shirley Forster Sheila Geehan Mrs D Frost Mr G Gary Flinn Barry Forster Nigel Gell Miss Megan Frost A Flint Roger Foster Gell & Meanwell C Fullwood D Flint Robert Foster Tim Gent Anglea Gallacher Revd Dr A Alan Flintham Mr Steven Foster Jade Gent M & J Gallagher Floob / Swift Martin Foster Mrs S Gent Mr D G Galley Mr R Flood Ms K L Foulkes Mr R Roy Gent Miss K Kirsty Galvin Mrs R Flood R Ruth Fowler Maurice Gent Mike Ganley Mrs B Flounders Mark & Michele Fowler Mr P Peter George Sandra & Roger Garner J & R Flynn K Kyle Fowler C W George Mrs L Linda Garnett Claire Flynn P Phoebe Fowler Mrs S George Michelle Garratt R Foden M Fowlkes Thomas George Ms J Jacqui Garrett Sally Fogell Ms P Patricia Fox Mark George Jean Garrett Simon Fogell Mrs J M Fox Mrs M George Mrs S L Garton P Fontana D & B Fox Miss T George Mr B Garton Dr Mrs Q Fontana Fox K Kai George Mrs K A Katie Gartside Andy Fookes Mr N D Norman Fox Mr D George Mrs Gascoyne Mrs M Forbes-Park Francis German S Gascoyne Mrs P Ford H Freeman Graeme German

Persons invited to make representations Appendix A

Mrs Wendy Goddard Ms R Rachael Grime Paul Ghuman Louise & Andrew Gratton Mr Derek Goodall Ms A Alison Grimley Jaspel Singh Ghuman Anthony Gray Chelsey Goodall Edward Grimwood Ms P Patricia Giaquinto Helen Greasley Jean Goodall Olivia Grimwood Mrs Julia Gibb Mr & Mrs G Greaves Mr R Rex Goodall I J Grundy Mr P Paul Gibbons Pamela Greaves Colin & Emma Gooding P D Grundy Mrs E Gibbs Andrew Green Liam Goodland Gurl M Gibbs Mr & Mrs Green Mrs M G Mary Grace Goona A Guy K Gilbert Ruth Green V Goona Guy Mandy Gile Rebecca Green Kathy Gorman R Hachett Peter Gill P Green Mr Lewis Gough P Hakes D Gill Pat Green K Gould Mrs Hazel Haley J E & D Gill & Stewart Roger Greenfield J Grainger Mr R O Dick Hall Susan Gillway Karen Greenwood Angela Hall Mrs A Grainger Pete Giumall Janis Gregory Miss Deborah Hall Andrew Grainger M Glenn G Gregory Tony Hall Mr & Mrs S & JA Grainger Mr Jason Glennie Mr / Mrs L Gregory G F Hall Kerry Grainger J G Glew Mr Eric Gregory A Hall Emily Granger Adrian Gloss Aiden Grice John Hall Jennifer Grant Mr & Mrs P J L Glover Mr T Trevor Griffin Stephen Hall Jonathon and Julie Gras/Beadell Beryl & Ian Goadby Mr P Peter Grimadell Mr & Mrs P A Hall B Gration Mr Mark Goddard Mrs S Grimadell Howard Hall Tony Gration

Persons invited to make representations Appendix A

A Angela Hall Mrs R A Harnan Mr & Mrs Hartshorn Keeti Hannah Patricia Hall R A Harnan Linda Hartshorn Beryl Hannant R Hallam Ms W Wendy Harnan-Kajzer Mr G Glyn Hartshorne Mr T Hanrahan M Hallam Mr M Harrington Mr M Harvey P G & C Hanson Murray Hallam Mr J John Harrington Peter Harvey Ms L Linda Harahan Richard Hallam Harris Mr & Mrs L & S Harvey Mr D Harby H / R Hannah / Russell Hallam Carol Harris Debbie & Steve Harvey / Dawson Mr O Oliver Harding Mrs K L Kay Hallam Black Jeff Harris Gemma Haslam Ms K Katrina Harding Hallam-Gray / Gray Mr M Mark Harrison Shelly Haslam G T Hardstaff J Hamilton Dawn Harrison Mrs l Haslam J Hardstaff Mr & Mrs Hammersley Patrick Harrison R & S Haslam Mr Christopher Hardstaff Mr S Simon Hammond Mr & Mrs Harrison David Haslock David Hardwick T J Hamp W Wendy Harrison David Haswell Linda Hardy Mrs W A Hamson Tom /Gillian Harrop Ms Sarah Hatfield D Hardy Mr S Hamson Mr D L Harry Rachel Hatfield Helen Hardy Jenny, Eric & Charlotte Hancock J Hart Colin Havercroft Louise Hardy Mrs Margaret Hand Mrs V Hart Mary Hawkins David Hardy Mr T Tim Handbury Mr T Hart R Hawley Keith Hardy Handley Ms L Lorraine Hart Mrs J Hawley David Hardy Mr & Mrs Hart Mr P Peter Handley-Wright R Hawood P J Hardy Lisa Hartley Ms L Linda Handley-Wright M Hayes J Hardy Matthew Hartley D David Hann Jon Hayes

Persons invited to make representations Appendix A

L Lee Hazeldine S G Stuart Hinds Jon Hayes Mr & Mrs Hill A Amy Hazeldine D Hinds J / S Jon / Sally Hayes Mr T Tim Hill Mr L Heaton Kay Hitchcock Sue Hayes Mr P A Hill Mrs J A Heaven Mrs Y Yvonne Hithersay A Hayes Mrs Dawn Hill Henderson Mr J Jonathan Hodgkinson Hayhoe Mr Matthew Hill Mike Hendy D Hodgkinson Miss R Hayhoe ` Hill Mr P Paul Henshaw L / A Hodgkinson / Forrest Miss S Hayhoe David Hill Mr & Mrs S Henson Mr & Mrs P / M Hodson Hayhoe Mrs Dorothy Hill Pam Hesselden Mr N T Hodson Hayhoe Hill Graham Hesselden Hogben Mr Hayhoe Miss W J Hill David Hewett Mrs M Hogben Mr P Haynes Mrs Emma Hill L Hewitt M Hogg Cliff Haynes R Hill D Hewitt Wendy Hogg J Julie Hayward I Hill D H & M F Hibbert Charlotte Hogg Mr P Peter Hayward J Hill Hibbert M P Hogg H H Haywood Mr P Hilton Frazer Hicken Mrs S Hogg Andrew Haywood Ms M Margaret Hinchcliffe Mrs D Hicklin Hogg Andrea Haywood Ellie Hind Mr K Holbrook Mr Hicklin Ms Alison Haywood Kirstie Hind Ms E M Holden Mr D David Hickton Stuart Haywood J Jennifwe Hindell Mr F Holdroyd Mr & Mrs D David Higginbotham Stuart Haywood Ben Hinds Mrs A Holdroyd Mr R Roger Higgins Andrea Haywood Ann Hinds Keith Holes Mr D Derek Hill

Persons invited to make representations Appendix A

Barbara Holland Mr Frank Hunt Miss Skylen Hoolam Skylen Hoolam Miss H Hoyes Bernadette Hunt Mr J Jack Holland Pauline Hoolan Jennifer Hubbal Mr J John Hunt Mr M Michael Holland Peter & Valerie Hopkins E Emma Hubball F & B D Hunt J Holland R Hopkins Mr Mike Hubball Mr & Mrs Malcolm / Susan Hunter Stuart Holliday Tessa Hopkins B Hubbard Mr Darren Hunter Mr Geoffrey Alan Hollingsworth Mr Alan Hopkinson Mr Neil Hudson A E Hunter D J Hollingworth Chris Hopper Lyn Hudson Ms Dawn Hunter Ms A Hollis Horace Neville & Barbera Millward T / J Trevor / Jose Hudson Mr & Mrs F M Hurst Gill Holmes Anna Horadczh M Hudson-Green Husbands Mr N Neil Holmes N Hornsaw Gareth Hughes John Huskins A Agnes Holmes Julie and James Horsley Les Hughes Ms S Sue Huskins Claire Holmes Mr M Horsley Mr L Hughes Jane Hutchinson Mrs M A Margaret Holmes J Horsley Elliott Hughs Frances and Duncan Hutchinson John Holmes Mr Anthony Horton Mrs Judith Hughs D Hutchinson Mr & Mrs P Holmes Mr M Mark Howard M & E Hulse Mr Duncan Hutchinson D Dale Holmes Mr J Joseph Howard Guy Humphreys Gordon Hutchinson T Trevor Holmes M & C Howard Hunt L Huthwaite Mrs F Holmes Sue Howard Gareth Hunt Lucia Iantosca Paul Homes Ms C Catherine Howe Jonathan Hunt Mr D A Dudley Ibbett Mary Homes Peter Howe Mr M Malcolm Hunt Mrs G Ibbett Janet Honey Mr R Richard Howe Mrs G Hunt Elvin Ibbotson K Keith Hoofan Mr K Howley

Persons invited to make representations Appendix A

Mrs C Ingram Mrs Lorraine Jeffrey Mrs J Jones Johnson S Irving M Jeffries Stuart Jones Celia Johnson James Isam A Jeffries Mrs P Jones Nigel Johnson Ms H Helen Jackson Mrs L Jeffries George Jones D Johnson Mr Jackson C L Jeffries D B Jones Mrs M Johnson Mr J John Jackson Ms J A Jenkins Amanda Jones Ms C Coral Jones Vickie Jackson Mr Jenkins H Helen Jordan Tina Jones Mrs Jackson J Jenkins A Jordan Mr & Mrs S & M Jones Mr Ian & Helen Jackson Dorcas & Chris Jennings Mr David Jowett Robert & Ann Jones Mr M Jackson J Jennings Jennifer Jowett Mr M Mark Jones Susan James Mr & Mrs R M Jepson Mr & Mrs G Joynes Mr Paul Jones Sandra James Charlotte Jerram Cllr Stuart Joynes P Jones Anita James Mrs T Jewkins Judkins A Adrian & Alison Jones Mr E Edward James Mr M W Johnson M Maisie K Jeremy, Jasper & Freya James Mr Simon Jones nighton M D Johnson Mr D James Mrs R M Jones Mrs F Freda Kay Johnson Bob Janes mrs B Jones S A Keeling Miss Brenda Johnson Jaspal Singh Ghuman Mr & Mrs Jones Jand D Keeling Peter Johnson Sara / Paula Jay / Browne S Jones P Kelly R Johnson J & L Jeaves T Jones Michael Kelly K Johnson Mr I K Jeffery P Jones Anne Kennedy Mrs P Johnson A & D S Jeffery Jones Mr Gavin Kenning Geraldine Johnson

Persons invited to make representations Appendix A

R Kenning Shane King Mr J John Lander Ms L Lisa Knighton Rebecca Kenny Tom King Anne Lane Mrs B Knighton Mr F Francais Kenny Mary King P Peter Large Barbera Knoules Stephen Kent Kathleen Kinton Robert Large R Knowles Mrs K Kent Karen Kinton Peter Large A Amy Knowles Mr/Mrs/Mrs B / L / M Bob/Linda/Mary Mr & Ms S/A Stephen/Andrea Karen & Tom Kinton Large/Burt Kent/Smith Mr Ronnie & Jane Knowles A Kinton Mr S Latham C & S Kerr/Davies Thelma Knowlson Alisha Kirk Mrs A Latham Mrs J Kerry S Kowalski J E Kirk Janice Laven Mr E D Kettlewell Mr S Kruczkowski Callum Kirk R Lavender Ben Kew S Kruczkowskil Mr & Mrs B & S Kirk John Lavender Mrs A Kiel Mr Micheal Kunica Emma Kirk Karen Lawler Mrs K Kerry Kiernan B & J Kyte Brianna Kirk Mr C Lawman David Killer Mrs J Kyte Jennifer Kirk E M Lawrence Mr S Sean Kinder Sally Lally Mr Phillip Kirk P Lawrence Mrs R Kinder Sarah Laman Mr B Brian Kirkland Ms B Brenda Lawrence T Kinder Alsastair Lamb Geoffrey Kirsopp Mr David Lea Sam King A Lambert G W, D A & N L Knight Mike Leahy Alicia King Mr L G A Lambert A R Knight Mrs I Iris Leam Dane King B J Lambert Ms T Theresa Knight Mr F Lean E K King K Landeg J Jasmine Knighton Mr & Ms D / Y David & Yvette Adele King Neville & Margaret Lander Leatherland/Hunt Mr S Scott Knighton

Persons invited to make representations Appendix A

Mr Jack Lee C Lioyd D & M Ludlam Peter James Lord Linda Lee Mark Little Mrs J A Ludlam Graham Love Mr S Stephen Lee Daniel Lloyd Kiera Ludlam Carol Love Stephen Lee Mrs D Lomas Stephen Lycitt Kerry Lovell Mr P Peter Lee K & R Lomas Alwyn Lycitt N & P Norman & Pam Lovelock Mr G Gareth Lee Lomas Mr G Glynn Lydiate Gregory Lowe Simon Lee K R & R Kath Lomas Mr Anthony Lynch G Lowe Mr David Lee Mr & Mrs Paul & wendy Lomax Kathleen Lynch Sharon Lowe Mrs Pamela Lee G Long Lorraine MacAlister John Lowe Andrew Lee Martin Long Mrs A Macdonald Kim Lowe Ebony Lee S M & J Long MacDonald J W Lowett Lees Dr M Martin Longbottom Mr & Mrs G J E MacDonald Mr David Loydall Brian & Valerie Leeson L A Longbottom Ms J Janet Macdonald Mr M Martin Lucas G R Lefevre Tamia Longdon Mr & Mrs Y & P Machin Sarah Lucey Mr & Mrs M Leggett Emma Longdon Mr Bevis Mackie Mr / Mrs R / J Roy / Jane Luckett Shaun Lemmon S Longstaff Ms / Mr L / C Linda / Chris Macleod / K Ludlam Simcox C Lemmon R Longstaff Mr K Ludlam Mr A J Alan MacMaster Mr J Lemmon Mrs Dawn Lonsdale Mr C Ludlam Ms C Cynthia Maddock Mr R Raymond Lesley K Lonsdale Jock Lewis Lexi Ludlam Madge Dr Steven Lonsdale Mr Marl Lillywhite Master J W Ludlam Ms J Jane Maggs Mr N Norman Loomes Mrs G Lineker Max Ludlam Mr J John Maher Helen Lord

Persons invited to make representations Appendix A

Mahon D Maxwell Ms N Nina Marshall Mrs M McGowan P Pamela Makin Mr B Brian May Chelsea Marshall Linda McGrath Malin Mr S Simon May Richard Marshall Darren McGrath Mr & Mrs Mallett May A S Marshall Mrs A McGuinn J Manan Mr and Mrs Maycock Allen Marshall Ms D Diane McHarg S Manan Mr P Maycock Marshall H Holly McKeown Mr Sydney Manchester J H Maycock L Layla Marshall Mr Edward McLaughlin Mrs T Mann S Steven Mayes Steve Marshall-Clarke David Mc'Loughlin Mr J P Mann Aiden Mayes K & S Marson Mc'Loughlin Pippa Mansel Sharon Mayes Mr S Stuart Martin B.P,R.E & J.T McMahon Ann Mansell Gareth Mayes D & C McNaught C Martin Phillip Marcett Mr Philip Samual McAleese R J Meads Ann Martin Ms S Sarah Marchbank Karen McBride Diane Meakin Jenny Martin Mr B Markham Elaina McCabe Dr Alan Meakin Mr Glenn Martin R, D & C Marksman Lian McCabe T Meakin Gareth Martin John Marooney McCormick / Hatton Jacob Meakin Gary Martin Marriot / Wetton J McCulloch John Meakin Richard Mason H Marriott Mrs Eileen McCulloch Meakin Sylvia Mason Colin Marriott Mr & Mrs B McDonald Meakin R Massey Jon Marriott Mr Daniel Mc'Fall Mr B Meakin Mr R Richard Massey Paul Marsh Margaret McFarlane Mrs A Meakin Mr Henry Masters Mr Marshall Mr J John McGill Mr Meakin

Persons invited to make representations Appendix A

Mr M Mark Mills B Moore Mr I Ian Meakin C Mottershead Robert Mills W Moore O Oscar Meakin R & L Moulder N Mills Mr Richard Moore C Meakin Mr and Mrs Millward Mr Matthew Mozley Ben Moore Ms E Elizabeth Mears Valerie Elaine Milnes Ms N Natasha Muir Mr Dean Moran Miss Amy Measures Miles and Stephanie Milton- Barber Ms Lyndsey Mulholland C Morehen Mrs A Measures M Mindes Maureen Murfin D Morgan M Mee N A Mirfin Mr D Murfin David Morgan Ms C Christine Mee Yasmin Mitchel Peter Murfitt Mrs A Anne Morgan Nadia Meghet Alison Mitchell Molly Murfitt Sarah Morgan Mr J R John Ronald Melrose Mr Ian Mitchell J Murray Bryan Morley Ms M Mary Melton M J Mitchell Sam Mustafa Mrs Morrell Peter Mercer Chris Mitchell Weronika Myska J G Morris John Messenger Dave & Gina Mlejnecky Jula Myska Mike Morris G Godfrey Meynell Paul Mohan Natalia Myska Susan Morris M Midgley Jon Mole Helen Nahas Mr Mosley R Robert Miles I / J Ian / Jo Molyneux A Nakin Mrs S J Mosley Mr J John Milford J Monsheimer Mr C Clive Narrainen Mr I R Ian Mosley Mr S Miller K P Monsheimer A M & C Naylor Mrs H A Moss K & L Miller Mr M Montague B & L Lynne Naylor Moss Mrs A Miller Mrs J Moody J Naylor R Moss Millership Chloe & Brendan Moore Cody Needham John Mottat

Persons invited to make representations Appendix A

Kahla Needham R Noble Mr David Ottewell Gill O'Hagan A Ashley Needham Charlotte Noke S R & D R Owen Oldknow Master B Needham Ronald Noon Mrs Victoria Oxley Mr & Mrs T Olney A D & M A Neville H Hazel Noon Pace Mr J John O'Melia Tony / Margaret Neville Ms Ida Noon L Pacey S O'Neil Newbold / Parker D David Noon Richard Pacey Steve O'Neill Mr John Newton J Noon G V Gail Packard Debbie O'Neill Mr D Newton J Noon N Packham Mr R Robert Oniel Newton Mr & Mrs Norchedge Bob and Ann Paget M Newton Orme A Anouska Norman B B Painter John Newton C T Orridge W North John Painter Simon Newton Craig Orson J North Mr P Palfreyman Hollie Newton G A C Orton Jean North Giles Paling D C Newton B & O Osborne Phillip O Brien Valerie Palmer Mrs J C Newton Colin Osborne Claire O’Connell Alison Palmer Mr R Roger Newton J W Osborne G Palmer Chris Oakley Mrs S A Shirley Newton J W Osbourne Scott / Michael Palmer / Wood Mr James O'Brian Newton A Oscroft Ms C Catherine Palombo Philip O'Brien Mrs M L Nicholls Mr Keith Otterwell A & J Parker Mr / Mrs B / C Ben / Claire O'Connell Ms A Annie Nichols Mrs Sharon Otterwell W & G Parker Mr Chris O'Connor H Nichols Mr Karl Ottewell J M Parker B Oderm Annie Nichols Mr J Ottewell Elisabeth Parker Tracey O'Donnell

Persons invited to make representations Appendix A

Vince Parker Roy & Pauline Parnell L Payne John Perks Mr C Christopher Parker Suzanne Parnell Darren Payne A J Perrins George Parkes Stephen & Debbie Parrans M J Payne T & M Perry J & S Parkin David & Elaine Parrish Mr G Geo Petts J Parkin Geoff Payne Mrs Sarah Parrott Mrs V M Phelps S Parkin Mr M Matt Peacock Parry Phillips S Parkin G Peacock Emma Parry Mr R Phillips Q G Parkin Mr Leigh Parry Ms J Jayne Pearce Dean Phillips C M Parkin Graham Partridge Mr Jim Pears D Dean Phillips Hazel Parkin Mr R Parwell John Pearson E Phillips Mrs J Parkin Ms J Jean Pass Dave Peck R Phillips-Forsyth Ms L Louise Parkin Jean and John Pass Victoria Peel H Phipps Kat Parkin Uri Patel Graeme Grahame Pegg V Pickard T Parkin Andrew Patterson Ann Pegg Susan Picker Mrs P Parkin Mr A Andrew Patterson III D A Derek Pegg Mrs J P Pickering Ms L Louise Parkin Amy Paulson M Maria Peggs Mrs M Monica Pickering T Parkin Mrs Susan Paxton K Katie Peggs T & D M Pierce Charlie Parkin Mr Bob Paxton Pepper Mr R Richard Pike Claire Parkin Mr J John Payne Joe Pepper L Linda Pilkington David Parkin J Payne Peter Pepper Mr & Mrs John Pilkington Pat Parkin Mr Colin Payne Kimberely Percivel D Pinion Chris Parkin Maureen Payne Norman S Perkins

Persons invited to make representations Appendix A

Michael & Kay Pirnie C Priestley E Purley Darren Potter Ellen Pitt Mr & Mrs A & D Priestley Mrs A Alison Purser John & Brenda Potts Grace Pitt Jody Prince Mrs Tina Pursglove John Potts Plant J A Prince Mr & Mrs L & J Leslie & June J Pounder Pursglove Rex Ploughman Mrs K karolyn Prince Wendy Pountain Mr Dominic Purvis Mr R Plowman Eric Pritchett David Pountain N Proctor Dr R Rosemary Pykett Mrs J E Plowright Sarah Powell Mr D David Proctor mr & Mrs E Pynegar J Plowright A D Powell L Protheroe Mrs J Quarmby Luke Plowright Power / Bell Shelley Prow Rev Robert Quarton Mrs E Plumb Bob Poxon Dr K Kate & Terry Pudney & Conn T Quinn Mrs C Pollicott Raymond, Lesley, Richard Poyner Mr & Mrs Pulford Mrs J Radford Richard Pollicott Stefan Pozylo Mr T D Pulford Sandra Rainsford Sarah Pollicott Jayne Preece Gillian Pullan Danny Rainsford Rachel Pollicott Ms G Gemma Pollock Mike Press Pullan Margaret Ralph

Joan Ponney Katie Press Mr T Thomas Pullen K M Ramsay

Keith Ponney Katie Press Brenda Punter Daman Ranby

M Poole P Preston David Punter Laura-Jane Ranby

Sandra Poplar Gerald Price Purcell K & S Ratcliffe

Julie Portedus Doug Price Terry Purcell Mr and Mrs M & R Ratcliffe Dawn & Scott Ratcliffe R Porter Joyce Price C Purdey Mr A Aubrey Ratcliffe Mr / Mrs D / L David / Linda Mr R J Price Mrs Heather Purdy Postlethwaite Lynne Rathbone

Persons invited to make representations Appendix A

Richards Mr N Riley Rathbone Robinson Mrs Jean Richards Mr and Mrs Riley V Virat Raut I Robinson Paul Richards Katherie Robb Mary Ann Ravnkilde Leslie Robinson Mr David M Richards Mrs L Roberston Mr & Mrs Rawson Mr / Mrs W / I Robinson Mr S P Richards Kathryn Roberts A Rawson Rebecca Rochford Mr Ken Richards P R Roberts T Rawson Adrian Rochford Mrs J H Richards Janet Robertson J Rayson J Rockley Mr and Mrs N Richards Peter/Katie Robertson/Borsley Dr M Malcolm Read Mr & Mrs K Rode K Richardson Mr Malcolm Robins Brian Reaney J Rodgers J / S Jo / Steve Richardson Mrs D Robinson Kelly Redfern N Rodgers Mr & Mrs A J Richardson Ian Robinson Avis Redfern Craig Rodgers J Richardson Wayne Robinson Mr & Mrs T & E Redshaw Mrs L Riches Philip Roe Alex Robinson Mr R W Reed Mr / Mrs P / E Peter / Elaine Riches Andrew Roe Mr W Robinson Sarah Reeves M Riches Steve Roebuck Peter Robinson Jane Reid Mr & Mrs A Richford Mr Stephen Rogers Helen Robinson Mr and Mrs Revill Ashley Riley J Rogers Esther Robinson Lisa Revill G & S Riley Mr Kevin Rogers Jill Robinson Mr R Reynalds Alan Riley Sophia Romanos D Daniel Robinson Tom and Victoria Rhodes S Riley Boris Romanos Robinson Ms E Elizabeth Rice Mike & June Riley A G Romanos Robinson A Rich Mr John Riley Jono Romanos Donna Robinson

Persons invited to make representations Appendix A

P P Romanos Ron Rowsell Richard Salt Ms J Jacqui Scott Christine Rooth Nick Rowton J Salt Mrs A Scrivens Mr C Cliff Roper Ms J Jane Rowton Laura Salt Miss Karen Scrivens Mr Philip Rose Mr D David Ruck Mr K Sampson Mr G E Scrivens Geoffery Rotherham L H Russell Samson F & P Seals Geoffery Rotherham A A Russell Mr & Mrs A J & D Sandell Mr Adam Searson Amye Rothwell RT Rutherford Sanders Mr & Mrs Searson Mrs Andrea Rothwell Mavis Ryalls D Sanders Fox Jody Seaton Mr James Rothwell Anthony Ryalls Mrs E Sanders Fox Ant Seaton A Rothwell Mrs S Ryalls J Sanderson Mr & Mrs Selby Mr J John Roulston Ryder Mr & Mrs K & P Sansam Alan Selby S A Anne Round Mr S Scott Ryder Jon Sargisson J M R Selby Glyn Round Kay Rye Chris Sargisson Selby K Rowbotham Ms C Catherine Rylance Mary Saunders Mr & Mrs D David Selvey S Rowe Mrs Smantha Sabel Norman Saunders Roy Severn Rowe D Sage David Saxby Brenda Severn Teresa Rowe G Saheed I Saxton B Severn Rowe Stuart Saint Philip & Samantha Saxton Ms B Becky Rowell B Brenda Severn Brogan / James Salmon Oliver Schafer Chris Rowland M Severn Mr R A Salmon Sam Scott Cheryl Rowland Severn Mrs Susan Salt C & T Scott P J Rowley S Severn Ian Salt Craig Scott

Persons invited to make representations Appendix A

E Severn Michael Shaw Herbert & Brenda Shipley T H Simpson S Severn Shane Shaw Mr W Shipley Mr Simpson T Severn Mr M Matthew Shaw M Margaret Shipp Mr P Paul Severn June Sims L Lucy Shaw Nichola Shore Janet Severn Mr G Geoff Sims Mrs D & T J Shaw Ian Short L Severn Connor Sinclair Mr K Shaw Susan Siddal R Roy Severn John Sinclair Shaw Megan Siddans Kathy Shand Ms A Alexandra Sinfield Mr J J Shawing Alan Siddon Mrs K Sharman Mr J Joshua Sinfield Mr Russell Sheffield Mr John Sidsaff Mrs D Sharman S Sisson Sheldon Mrs L Sidsaff Beverley Sisson Miss D Sharman Mr Andrew Sheldon Sidsaff Mr P Sisson Mr T K Sharman R Shelley Rose Simmons Mrs Tracy Skelton Nicola Sharp Mr C Shelton Steve Simms Skelton Pauline Sharp Gemma Shelton Freddie Simon K Skelton David Sharp S Shelton Charlie Simon S L Skelton Jamie Sharp L Shelton Graham Simons C Craig Skelton Ms S Diane Sharpe Glynn Shepherd Ms Mary Simpson S Stephen Skelton David Shaw Mr and Mrs S W Shieldon Christine Simpson I Skelton Bronia Shaw Maggie Shields P Simpson Mrs L Skevington Richard Shaw Alan Shiels K Keith Simpson Joanne and Keith Skevington Lisa Shaw Mr T Terry Shiels Mr A H Simpson Lynn Skinner Mr S Steve Shaw Mr B Shilling S Simpson Robert Skinner

Persons invited to make representations Appendix A

Mrs L A Smith D Debbie Smith Ms L Smithirst Gill Slack Jamie Smith David Smith Ellen Smith-Marooney Mrs G M Gillian Slack Christine Smith Mrs J M June Smith Julie Smithson Julie Slack Gladys Smith Mrs J Jane Smith Sean Smyth Steve Slack Mr & Mrs Peter Smith Mr & Mrs I & T Ian Smith Ms M Smythe Mr E Slater A E Smith Smith Mr P Snape Slater Mr James Smith J Smith Soar Ms S Sharon Slater Lynne Smith Edna Smith J & H Soar D Slater Richard Smith Ben Smith David and Sharon Soar Mr I Ian Sleeman Mr Michael Smith Mrs J Joan Smith Lesley Soar Smadley Graham Smith Miss L K Smith Erica Sommer Smalley Angela Smith P & G Smith R E Southworth Mr C T Colin T Smallwood D Smith J & I Smith A Sparham Mrs Klara Smedley Mrs B A Smith David Smith P & A Sparham Mary Smedley Tracey Smith Cllr P Paul Smith Ms K Karen Sparkes Claire Smedley D R Smith Martin And Annette Smith Michael Spence S Smedley M & K Smith A Smith Joe Spence Miss Susan Smedley Mr T Troy Smith Linda & Dennis Smith Martin Spence J Smile Mr K Keith Smith Mrs Carol Smitham Ann Spence George & Joyce Smith Smith Mr Darren Smitham Robert Spence Smith Mr P Smith Mr David Smitham Joe Spence Andrew Smith Richard and Angela Smith M G Smithhson Jinny Spence

Persons invited to make representations Appendix A

A Stevenson H Stone-Payne Alison Spencer Mr Mathew Stapley J Stevenson Mr & Mrs Storer K & S Sue Spencer Donald Statham Julie Stevenson Storer Kevin R Spencer S & D Statham Miss V J Stevenson Mr &Mrs Storey J Spencer Stephanie Statham Mr K Stevenson Ina & Terry Stradins / Hirst Mr P J Spencer Peter Staton Richard Stewert H Strafford Jesse Spencer P A Steed D & T Daniel & Tia Stirland C Strange M & J Spencer & Bonsall S Steele P A Stirland Stratulis Deborah Spendlove Jonathan Steele Georgia Stirland Mr & Mrs R Spink S L Street P Steeples Stirland Philip & Lorraine Spowage Ms E Edwina Strike Nigel Stephens Vanessa Stirland D Srlvely Lauryn Stuart N Stephenson M Stocks Mr R Staley S Stubbs Stephanie Stephenson Mr & Mrs Stollyfield Mrs J Staley J Stubbs P Stephenson Stone Geraldine Stamp Mr C Clive Sturgess T Stephenson Mrs R Stone Mr Alan Stanbrook Stuzaker Dom Sterland Ellen Stone A & L Suddes D Stanchard-Roberts Mrs J Stevens David Stone J D Sumpter Louise Standing Josephine Stevens Mr and Mrs Stone Mr P Peter Sumpton Lynda Staniforth C Stevenson J Stone Mr M Sutcliffe Mr Peter Stanton Mr & Mrs J Stevenson D Stone Chris Sutton Mr J S John Stanway Mr P Paul Stevenson Mrs R Stone Allan Sutton P Stapleford M Stevenson Stone R Swain Philip Stapleton

Persons invited to make representations Appendix A

G F Swain Lesley Taylor A Thomas Paul & Linda Thorp Swango K & J Taylor Mr L Thomas Thorpe Mr P Peter Sweeting Simon Taylor Mr A Andrew Thomas Cllr Valerie Thorpe Miss Ashleigh Swift Mr Stephen Ralph Taylor Marcus & Tracey Thomas P Thorpe Mrs G Swift Mr S Stuart Taylor Mr & Mrs R Thompson Coral Thorpe P Pam Swift Amanda Taylor Richard Thompson J.A Thorpe G & R Swindell Taylor Eileen Thompson Mr T S Terrence Samual Thorpe P Sykes Mr & Mrs N Taylor Robin Thompson Mr Richard Thorpe Symons Jill Taylor Emma Thompson C Thorpe I Symons Taylor A Thompson Mr & Mrs G Throw D Symons Taylor Mr Russell Thompson M W Thums M Tadman David Taylor Mrs Sheila Thompson Johnathon Tillion N Tanley Stephen Taylor K Thompson R Timms Sandra Tapper Taylor Linda Thompson Ms W Wanda Tobolkiewicz Ms Margaret Tarlton Elisa Taylor-Smith E Thompson Mr J Toft Margaret Ann Tarlton Taylor-Wilde Douglas Thomson Ms J June Tomlinson Miss Julia Tarlton Mr Martin Taylor-Wilde Miss G Thorley P G Tomlinson G Tatham Rachel Tennick R Thornhill Mrs Gaye Tomlinson Robert Tatler Mrs S Thomas Lola Thornhill Mr Mark Tomlinson Marion Taulbut M Thomas Rob Thornhill Cllr M Martin Tomlinson Mr & Mrs Taylor Mr W D David Thomas Christine Thornhill Mr P Paul Tomlinson Richard & Jan Taylor A Thomas C Thornton

Persons invited to make representations Appendix A

Mr Ken Tomlinson N Trussell J & E Vardy Mr J John Walker Lorriane Tomlinson Timura Trussell Mr W Varley Mr / Mrs C / A Chris / Ann Walker Mr M Melvin Tomlinson Mr Martin Trussell Mrs E Varley Ms L Laura Walker R J Tomlinson Mr Jake Trussell Rita Varnam Mr C Chris Walker Miss S Sherrie Tomlinson Nicola Tuck Rev Keith Vernon Mr George Thomas Jeffery Walker Sharon Tomney Ken Tucker D J Village Phil Walker Glen Tomney Mr & Mrs J R Tunstall A Village Joanna Wall James Tomney A Annie Turnbull Mrs Village Mr A Andrew Wall Joshua Toms Mrs Lisa Turner Mr & Mrs D David Village Mrs Helen Wall M Tomsett A W Turner Ronald & Wendy Wagg Mr I Wall Mr / Mrs M / P Maurice & Pat Tooze Julian Turner Richard Wain Mrs Barbara Waller Stephen Toplis Turner Amanda Wain Mr Alexander Waller Victoria Topping Donna Turner Ms J Judith Walker Mr & Mrs Townsend John Wallis G Turner S Walker Tony Travis R & A Walter Annette Turner Mr P L Walker A C Travis Mr & Mrs Walters Mr R Richard Turner Beverley Walker Gwen Tresidder Mr & Mrs J Walters Mr & Mrs Lisa / Daniel Turton L Walker Valerie Trevan John Walters Mr M Malcolm Turvey Mrs A M Walker Sara Troman N Walters Joanna Utting Walker C Walters Dudley Troth Julie Vallance J A Walker Elaine Walters D & J Trueman Ian Vallans Mrs B Walker M Warburton Mr J Truman Katerina Van Rensberg Mrs D Dorothy Walker Jenny Ward

Persons invited to make representations Appendix A

Denise Waters Mrs Maria Weston David Ward Julie Webster Chris Waters Mr Steven Weston Mrs J Ward Ms S Sue Webster Mr D G Watkins Mrs M Margaret Weston Chris Ward M Webster Jenny Weston P Watson Ann Ward H Webster C West-Oram Mrs S Watson M J June Ward Emma Webster Mrs M Westwood A Watson C Ward George Wedd Brian & Wendy Wetmore G Watson K J Ward Mike Weightman Mr & Mrs A Whawell R & J Watson Mrs P Ward Helen Weir Doreen & Des Wheatley Mr & Mrs Watson Neil Ward Darren Weir Mr Nathan Wheatley K M Watson K Wardle Mr Adrian Welch Mr S Stuart Wheatley Mr Robert Watson J Wardle Brian Weldin Carol Wheatley B M Watson Mr Wareham S M Wells M & E Wheatley R A Watson Mrs A Wareham Mr & Mrs Andy & Susan Wells Wheeler R Watson Edmund Warriner Mrs Jane Wells Gerry Charles Whelon L Watson M Warrington Mr Christopher Wells Jenny Whitaker I Watson M Matt Waterfall Nicholas Wes Peter & Dorothy Whitaker Paul Watson D W Waterfall J Weston White Susan Watson Mr / Mrs C H / P Waterfall G Weston Mrs P White John Weaver Mark Waterfall T Weston S Sophie White Weaving Jane & Graham Waterfall & Davies Mr Andrew Weston E & A White Mr A Alan Web Mrs Y Yvonne Waters Sarah Weston M & R White Alan Webb

Persons invited to make representations Appendix A

Jonny White Mr J Wickstead Wilson Mrs J M Jennifer M Wood White Mrs S Wickstead Wilson Mr A Alexander Wood Mr & Mrs D R White M & N Wigens Mr M Wilson C J Wood Martin White Peter Wigglesworth Miss N Nicola Wilson M Wood White Mrs D Wigley Mr John Wiltshire Jim Woodburn Lisa White Mrs D Wigley M & J Wiltshire Mr E Woode Mr G Graham White R Wigley Mr H Winfield G N Garrick Woodruff John White Janet Wignall Mrs Judith Wing Wendy Woodward Paul Whitebrook Ms D Donna Wilber M Wingfield A Woodward Master L Whitehead Caitlin Wildsmith Celia Winkworth Woodward Judith Whitehead P Wilkinson C K Winson Dawn Woolis S Whitehead Willers Winson B & J Woollacott Miss C Whitehead E Willgoose Beverley Withers Mr & Mrs A J Woolley Keiran Whitehead E Willgoose J / V Wood Mr Stuart Woolley Joyce Whiting Elizabeth Williams Matt & Maria Wood Isobel Tamar Woolley Samantha Whittaker Harvey Williams M & J Wood Jethro Woolley M Whittaker Daniel Williams Samantha Wood Michael Whittall Mrs J Judith Woolley Mrs J L Williams Julie Wood A Amanda Whitworth Mr & Mrs B & G Bob & Gina Woolley Ms J L Josephine Williams Mrs M Maria Wood Mrs C Chris Whysall J & J E Woolley Mark Williams Chris Wood Marie & Keith Whysall Mrs Kerry Worley Mr R S Williams Rob Wood Mr K Wibberley D Worley Ian Willis S Wood

Persons invited to make representations Appendix A

K Worley Tom Wyke Miss A Ania Worthington J & I Yarnell Mr / Mrs D & V Worthington / Mills Margaret Yates Ms J Julie Wozniczka Philip & Sheila Yendle Wragg R Young K Wray Mr A S Young Vanda Wright S Young M Wright Mr P Zimmerman Mr C Colin Wright

Mr Paul Wright

Adam Wright

A & J Wright

Arthur Wright

C Wright

Mr Pete Wright

Mr Thomas Wright

Fay Wright

Mrs Leanne Wright

Mr George Wright

Ms J Jenny Wyatt

R T Wycherley

Julie Wyer

The Local Plan Part 1: Core Strategy

Accompanying Information for the

Regulation 22 Statement of Consultation

December 2013

This page is intentionally blank Consultation and Publicity During the Preparation of the Core Strategy (Part 1 of the Local Plan) 2008-2013

The Borough Council has undertaken all previous consultation under the new legislation and regulations, some of which is no longer in line with the current Statement of Community Involvement (SCI) which was produced in 2006. This is to be updated to reflect the new regulations as soon as possible.

In preparing the Core Strategy, since 2008 the Borough Council has engaged with the public and other stakeholders using a wide variety of methods. These have included:

• Publishing news releases and putting notices in papers • Making information easily available on the Council’s web site and providing online consultation forms • Using Facebook and Twitter to provide information • Making documents and consultation response forms available in all local libraries and cash offices • Holding drop in events/workshops in a wide variety of locations, some with the assistance of Planning Aid • Keeping an up to date database containing all stakeholders including hard to reach groups and details of all members of the public and who have previously made comments on policy documents • Distributing leaflets and flyers to parents via school children, Parish/Town Councils at local events and sending these out with other information the Council is sending out regarding other matters • Producing articles for Amber Voice, a newsletter produced by the Council • Producing articles for Amber Valley Business News • Organising with colleagues at Derby and South Derbyshire a variety of HMA Workshops to debate specific issues • Ongoing liaison with other teams in the Council, including teams in adjoining local authorities and Derbyshire County Council • Fortnightly meetings of the Derby HMA Co-ordination Group • Meetings of the Derby HMA Board, which consists of senior officers of each of the Derby HMA authorities and cabinet members from those authorities • Interviews on Radio Derby • Interviews on Amber Voice radio station • Giving presentations at public meetings arranged by Parish/Town Councils • Attending Parish Council meetings to explain the process and encourage their involvement in the process • Attending quarterly meetings of Derbyshire Planning Policy Officers Group (DPPOG) • Posters in all prominent locations, including doctors surgeries, dentists, supermarkets, Borough/Parish/Town Councils notice boards • Giving presentations to organisations – eg Belper Civic Forum, WI, pensioners groups • Giving presentations in local schools • Organising meetings of the Borough Council’s Local Plan Member/Officer Working Group • Organising meetings between the Council’s Member/Officer Working Group and other local residents groups • Arranging meetings to discuss cross boundary issues with adjoining authorities, in accordance with the Duty to Co-operate

More specifically, the Borough Council published and undertook consultation on the following documents:

Issues and Ideas (2008)

This document, which was published for consultation for 12 weeks between 8 September and 30 November 2008, identified a range of issues and sought comments on the matters that should be addressed by appropriate policies in the plan for the Borough. Stakeholders were provided with a leaflet which contained a form to complete covering a wide variety of topics.

Events that took place included:

• Belper Community Forum, The Whitemoor Centre 7/10/08 • Heanor Community Forum, Community Centre, Wilmot Street 9/10/08 • Ripley Community Forum, Moss Cottage 13/10/08 • Meeting with Holbrook Parish Council 22/10/08 • Meeting with Heanor Inter Agency Group 29/10/08 • Alfreton Community Forum, Genesis Centre, King Street 30/10/08 • Meeting with Kirk Langley Parish Council 3/11/08 • Planning Aid event, Red Lion PH, Ripley 12/11/08 • Planning Aid event, St Joseph’s Community Hall, Ripley 13/11/08 • Western Parishes Community Forum, St Paul’s Church Hall, Quarndon 19/11/08 • Belper Civic Forum workshop 26/11/08

Issues and Options (2010)

This document, which was published for consultation for 19 weeks between 15 January and 28 May 2010, set out a range of policy options for delivering housing to meet the requirements of the East Midlands Regional Plan, meeting employment needs and a range of other issues.

This consultation included drop in events being held at the following locations:

Date/Time Location 3.00pm - 7.00pm Monday 1 March Alfreton Christian Centre, Hall Street 2010

3.00pm - 7.00pm Tuesday 2 March Ripley Leisure Centre 2010

3.00pm - 7.00pm Thursday 4 March The Community Centre, Wilmot Street, 2010 Heanor

3.00pm - 7.00pm Friday 5 March 2010 Belper Football Club

2.00pm - 6.45pm Tuesday 20 April Mackworth Library (Derby HMA event) 2010

2.00pm - 6.45pm Tuesday 27 April Mickleover Library (Derby HMA event) 2010

Other events included:

• 6.00pm 21 January 2010 - Meeting with Mackworth Estate Community Association at the Diocesan Centre, Mackworth (with Derby City) • 7.30pm 9 February 2010 - Meeting with Alfreton Town Council at Alfreton House • 7.30pm 24 February 2010 - Meeting with Belper Civic Forum at Strutt School, Belper • 6.00pm – 8.00pm 3 March 2010 - Public event at Mickleover Primary School (Derby HMA event) • 7.30pm 8 March 2010 - Public meeting at Peverel House, Mill Lane, Codnor • 6.30pm 11 March 2010 - Public meeting at Village Hall, Mackworth Village • 6.30pm 25 March 2010 - Public meeting at Leeke Memorial Hall, Kirk Langley • 1.30pm – 4.30pm 13 April 2010 Sustainable Urban Extensions and Strategic Sites Stakeholder Workshop, The Voicebox, Derby (Derby HMA event)

Have Your Say (2011)

This consultation took place for 12 weeks between 1 February 2011 and 3 May 2011, followed the Government's announcement that Regional Plans were to be formally revoked. In response to this decision, the local planning authorities in the Derby Housing Market Area resolved to undertake further consultation on a wider range of policy options.

This consultation included drop in events being held at the following locations:

Date/Time Location 2.00pm – 7.00pm Tuesday 1 The Green Room, Shipley Park Visitors February 2011 Centre, Shipley

2.00pm – 7.00pm Thursday 3 Feb Alfreton Christian Centre, Hall Street, 2011 Alfreton

2.00pm – 7.00pm Wednesday 9 Feb Weston Centre, Tamworth Centre, Duffield 2011

2.00pm – 7.00pm Thursday 10 Feb The Community Room, The Bridge Centre, 2011 Langley Mill

2.00pm – 7.00pm Tuesday 15 Main Hall, Somercotes Parish Hall, February 2011 Nottingham Road, Somercotes 2.00pm – 7.00pm Thursday 17 Arkwright Room, Lion Hotel, Belper February 2011

2.00pm – 7.00pm Tuesday 22 Glebe Field Centre, Glebe Field Close, February 2011 Crich

2.00pm – 7.00pm Thursday 24 Peveril House, Mill Lane, Codnor February 2011

2.00pm – 7.00pm Tuesday 1 March South Wingfield Social Club, 43 High Road 2011

2.00pm – 7.00pm Thursday 3 March Community Centre, Wilmot Street, Heanor 2011

2.00pm – 7.00pm Monday 7 March Ripley Leisure Centre, Derby Road, Ripley 2011

2.00pm – 7.00pm Friday 11 March Village Hall, Church Street, Kilburn 2011 2.00pm – 7.00pm Tuesday 15 March Leeke Memorial Hall, Church Lane, Kirk 2011 Langley

2.00pm – 7.00pm Thursday 17 Ironville Church Hall, Casson Street March 2011

2.00pm – 7.00pm Thursday 24 Sawmills Village Hall, Ripley Road March 2011

2.00pm – 7.00pm Friday 25 March The Old School House, 22 The Green, 2011 Swanwick

Other events included:

• Meeting with pupils from Aldercar Community Language College 16/2/11

Options for Housing Growth (2011)

This document, which was published for consultation for 12 weeks between 11 July and 30 September 2011, sought views on a range of options for the overall scale of new housing development in Amber Valley and where this new housing should be located, including 16 potential locations for strategic housing sites.

This consultation included drop in events being held at the following locations:

Date/Time Location 3.00pm – 7.00pm Monday 11 July Ripley Leisure Centre, Derby Road, Ripley 2011

3.00pm – 7.00pm Tuesday 12 Leeke Memorial Hall, Church Lane, Kirk July 2011 Langley

3.00pm – 7.00pm Wednesday 13 The Community Room, The Bridge Street July 2011 Centre, Langley Mill

3.00pm – 7.00pm Thursday 14 Peverel House, Mill Lane, Codnor July 2011

3.00pm – 7.00pm Friday 15 July The Old School, 22 The Green, Swanwick 2011

3.00pm – 7.00pm Monday 18 July Village Hall, Church Street, Kilburn 2011

3.00pm – 7.00pm Tuesday 19 Somercotes Parish Hall, Nottingham Road, July 2011 Somercotes 3.00pm – 7.00pm Wednesday 20 Weston Centre, Tamworth Street, Duffield July 2011

3.00pm – 7.00pm Thursday 21 The Community Centre, Wilmot Street, Heanor July 2011

3.00pm – 7.00pm Friday 22 July The Arkwright Suite, Lion Hotel, Belper 2011

3.00pm – 7.00pm Monday 25 July Alfreton Christian Centre, Hall Street, Alfreton 2011

Other events included:

• Distributing leaflets at Marehay Show, Ripley 3/9/11 • Distributing leaflets at Alfreton Party in the Park 4/9/11 • Public meeting arranged by Swanwick Parish Council 25/8/11 • Interview on Radio Derby 30/8/11

An Opportunity For Development On A Strategic Scale At Denby (2012)

This document, which was published for consultation for six weeks between 10 February and 23 March 2012, followed a response to the ‘Options for Housing Growth’ consultation in respect of the option of a new settlement, which suggested that land at Cinderhill, Denby could have the potential for a mixed use development on a strategic scale.

This consultation included drop in events being held at the following locations:

Date/Time Location 4.00pm - 8.00pm Tuesday 21 February John Flamsteed School, Denby 2012

3.00pm – 7.00pm Thursday 23 February Lion Hotel, Belper 2012

3.00pm - 7.00pm Friday 24 February 2012 Ripley Leisure Centre, Derby Road, Ripley

4.00pm - 7.00pm Monday 27 February Village Hall, Church Street, Kilburn 2012

Other events included:

• Meeting with Kilburn Parish Council 6/2/12 • Discussion with Labour and Conservative groups 22/3/12

Preferred Growth Strategy (2012)

This document, which was published for consultation for 12 weeks between 1 October and 21 December 2012, sought views on the Council’s preferred strategic growth sites for new development, following previous consultations on the options for growth.

This consultation included drop in events being held at the following locations:

Date/Time Location 4.00pm – 7.00pm Thursday John Flamsteed School, Derby Road, 18 October 2012 Denby

3.00pm – 7.00pm Friday 19 October Alfreton Community Hall, 3 Mansfield 2012 Road, Alfreton

3.00pm – 7.00pm Monday 22 October Ripley Leisure Centre, Derby Road, Ripley 2012

3.00pm – 7.00pm Tuesday 23 October Arkwright Suite, Lion Hotel, Bridge Street, 2012 Belper

3.00pm – 7.00pm Wednesday Community Centre, Wilmot Street, Heanor 24 October 2012

3.00pm – 7.00pm Thursday 25 Peverel House, Mill Lane, Codnor October 2012

3.00pm – 7.00pm Friday 26 October Kilburn Village Hall, Church Street, Kilburn 2012

Other events included:

• Derby HMA Stakeholders Workshop 17/10/12

Local Plan Part 1 – The Draft Core Strategy (2013)

This document, which together with an accompanying Sustainability Appraisal and a draft Infrastructure Delivery Plan were published for consultation for 8 weeks between 28 June and 23 August 2013 sought views on these emerging documents, following previous consultation on the Preferred Growth Strategy.

The production of the Core Strategy took into account all of the responses received in relation to these previous consultations, and a more thorough summary of the key issues raised through responses to these consultations is available on the Council’s web site.

This consultation included drop in events being held at the following locations:

Date/Time Location 3pm – 7pm Friday 12 July 2013 Meeting Room, Ripley Leisure Centre, Derby Road, Ripley 3pm – 7pm Monday 15 July 2013 Alfreton Christian Centre, Hall Street, Alfreton 3pm – 7pm Wednesday 17 July 2013 No. 28 Market Place (Former Salvation Army Hall), Market Place, Belper 3pm – 7pm Thursday 18 July 2013 Wilmot Street Centre, Wilmot Street, Heanor

Local Plan Part 1 – Pre Submission Core Strategy (2013)

This revised document, which together with an amended Sustainability Appraisal were published for consultation for six weeks between 18 October and 29 November 2013.

This document was a modified version of the Draft Core Strategy, taking account of comments received as a result of the consultation. The Sustainability Appraisal was also amended in response to comments received.

This consultation included drop in events being held at the following locations:

Date/Time Location 3pm – 7pm Wednesday 6 November Wilmot Street Centre, Wilmot Street, 2013 Heanor 3pm – 7pm Thursday 7 November Alfreton Christian Centre, Hall Street, 2013 Alfreton 3pm – 7pm Friday 8 November 2013 Meeting Room, Ripley Leisure Centre, Derby Road, Ripley 3pm – 7pm Tuesday 12 November No. 28 Market Place (Former Salvation 2013 Army Hall), Market Place, Belper

Formal notices were also placed in the following local newspapers:

Derby Telegraph 18 October 2013 Derbyshire Times 24 October 2013 Ripley & Heanor News 24 October 2013 Belper News 30 October 2013