Greasley and District Civic Society / Kimberley Residential Assocation

Matter1: Consultation.

• The language used in the consultation process by Broxtowe Borough Council has been misleading and hard to understand by the public. • The phase Core Strategy doesn't present itself clearly to the non- expert. • The consultation form from Broxtowe Borough Council was often delivered with what is termed junk mail (supermarket leaflets), thus the take up on the consultation was naturally low, given the wording on the form (core strategy) plus content in complicated legal jargon and the way it was distributed!

• The forms themselves do not encourage a reasoned pro active response but rather a series of disjointed reactionary statements

• The Housing Background Paper 2013 is a late piece of evidence written in a convoluted style that is only partly excused by the complexity of the subject matter. The complexity is in itself the result of an attempt at precision in demographic projections which is totally inappropriate.

• We believe the plan has not been prepared in accordance with each authority’s statement of community involvement in accordance with the 2004 act.

• With regard to the sustainability appraisal, this hasn’t been carried out adequately

• We believe there is no evidence that the neighbourhood plan, which sets out a positive vision of the future of our area, and empowers local people to shape their surroundings, hasn’t took place. • Very little or no encouragement by our local council (Borough and Town Parish) allowed for public involvement to inform of the planning process or the number's involved for our area (Kimberley). The majority of the public was and still are unaware. The public have the right to participate and we believe for the vast majority, this has been denied.

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Matter2: Spatial strategy and housing policy

• We would like to make the point that no evidence has been show by Broxtowe Borough Council in way of the housing requirements for Kimberley has been calculated . We would also like to draw on the 2011 census in way of evidence to contradict the housing allocation for Kimberley by Broxtowe Borough Council.

• The Growth Point proposals were and still are subject to testing through the local plan and development control systems. They gain no credit for having been around a long time. We are a little disturbed by the fact that that the production of the ACS has been managed by a “Growth Point team” based in Nottingham City. This has to put a question mark against the objectivity of the assessment of housing needs.

• Some representations refer to more localised levels of housing need, but is there any evidence that the plan is based on incorrect definitions of the Housing Market Area (HMA)?

• Have the ACS housing figures taken full account of the fact that the East Midlands Regional Plan has been revoked. Some representors suggest that the councils have been ‘too wedded’ to its figures?

• As with Greenbelt, no comprehensive and systematic review has been undertook by Broxtowe Borough Council and the other Districts. The mergence of the ancient villages of Watnall, Nuthall, Greasley and Kimberley with Nottingham has not been understood. Kimberley itself has very little green belt left. Priority should be for Brownfield sites.

• Now since the A610, and housing developments over the last thirty years, we have seen much of this rural settlement disappear and its strong local community / identity set apart from Nottingham diminish as a result.

• On the technical issue of land availability the three authorities have failed to co operate so far as a five year supply of housing land is concerned. Since the housing requirement is calculated on a HMA basis it is clear the land availability should be assessed on the same basis. Broxtowe Borough Council sought to permit the development of Field Farm on the grounds that they would not otherwise be able to demonstrate a five year supply of housing land and would be showered with decisions granted on appeal. At no time was there any mention of the position in Nottingham City. The latest assessment for Nottingham city shows a 5.6 years supply on the ACS rate plus 5 %and this on the assumption that windfalls will yield only 25% of what they have in the past five years. If we assume the same rate of windfalls the supply becomes 6.2 years; a surplus of 1200. There is ample evidence on the ground that the recession is producing a large number of industrial, filling station and public house site. Commercial estate agents are finally waking up to the possibility of residential redevelopment outside the City Centre. The potential of the City Centre remains and is highly relevant since the need for Nottingham Trent University students is included in the housing requirement. We have set out in some detail in 2.5.1 to 2.5.11 of our main statement ways in which the assessed supply in all three Districts could be increased.

• Appendix C of the publication draft of the ACS sets out the resources in Broxtowe and the figure given for SHLAA sites in the PUA is 1328. The equivalent figure in Table 9 page 15 of the March 2012 Land Availability report is 1952, 1852 if completions are deducted. The same report usefully sets out at appendix 2 a list of

Darren Warner 15/09/2013 Page 2 other allocation options which corresponds to sites assessed in the SHLAA sheets as suitable if policy changes. The total capacity of sites meeting two or more criteria in the Tribal Report is 9843 of which 6874in the PUA. These figures exclude a site at Chetwynd Barracks with a capacity of 1517. There is a need for some justification for the preference for 660 dws at Kimberley to an equivalent capacity from this identified resources .

We also note there are some 1200 dwellings on sites that will start in the period 2013 to 2018 but will extend into the period beyond. We see this as something of a comfort zone since delivery on those sites could easily be speeded up in response to a more lively market.

• Whilst we agree that the five year supply in Broxtowe and Gedling should be assessed against the ACS it should be against a trajectory that is realistic which the current trajectory is not. A sensible view would be that there would be a build up from current levels to the ACS rate over the next five years. This gives an annual figure of 206 for Broxtowe and 269 for Gedling. The surplus in the City is equivalent to a five year supply for Broxtowe In assessing the five year supply Broxtowe took the view that they are not “ allowed” to include any sites in the five year supply that do not have planning permission. This is incorrect as was made clear in the Engine Common appeal (APP/P0119/A/12/2186546) in April 2013. It is also nonsense to build in a 20% buffer to stimulate the market and then assess delivery of large sites with planning permission on the basis the market does not pick up.

Matter:7 Infrastructure

• We believe the allocation for 650 house's for Kimberley is flawed by the incapacity for the local infrastructure to cope. • Kimberley's ancient lanes and Victorian road system built in and around the town's Hub is dwarfed by the huge numbers proposed. Kimberley's settlement is over 800 years old and in that time has accumulated a housing stock of around 2700.

• Have the Highways Agency’s concerns about impact on the strategic road network from development at Kimberley been addressed?

• When realising a 25% increase over the time period involved, this appears out of proportion in the extreme. In recent year's, Kimberley is down to one GP surgery, there is no Police station now, not to mention the impact on the schools. The capacity to cope with this proportion on scale is simply ridiculous.

Conclusions

Not legally compliant in terms of public consultation, sustainability appraisal, duty to co operate and lack of compliance with the NPPF on greenbelt and brownfield priority.

Unsound because of a failure to justify the housing requirement and for the proposed distribution between the Nottingham PUA and settlements such as Kimberley

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