Janice Byron ID 77

Q1. Duty to Co-operate (DTC)

The AVBC Local Plan relates mainly to development within an area of c. 3 mile radius of Ripley. The nearest points at which development will stand in relation to administrative boundaries are Alfreton, (North East Derbyshire and Bolsover) and Heanor (Broxtowe and Erewash). Apart from Alfreton, no development is in close proximity. It would therefore be instructive to learn what sort of engagement with other local authorities is required.

2. Policy SS1 At a time of economic uncertainty, with no evidence of job creation in Amber Valley, it surely makes sense to opt for a more conservative approach to the assessment of housing requirements. Q3.1 Apportionment of the SHMA-assessed needs throughout the Derby HMA It would useful to learn the mean of justification for 9,000 houses in Amber Valley (+a 20% buffer against under-delivery). This is relatively small, already heavily developed area of the borough. There are no large-scale projects for job creation in Amber Valley. There is no rail link with Derby apart from Ambergate and Belper where no development is proposed. There are only road links. Surely the environs of Derby offer a more appropriate location for large-scale housing development, closer to job opportunities.

Q4.1 Distribution of housing growth throughout the District Development is heavily concentrated around Ripley, Codnor, Waingroves, Heanor and Alfreton in an area with a radius of c. 3 miles. These are far reaching implications for the road system, for medical services and schools provision.

5. The 5-year land supply Q5.1 There is a 5 year land supply. Q5.2 The 20% buffer for persistent under-delivery is not warranted. Responsibility must rest squarely with developers. Planning ministers have indicated awareness of problems associated with land-banking by developers. Local authorities cannot compel developers to develop. Land-banking will only be exacerbated by the compulsion to allocate additional sites as a buffer. More houses will not be built. Moreover, land which is designed for housing and then not developed tends to become degraded over time. Land is thus ecologically damaged, becomes a visible blight and represents a loss of amenity and usefulness to a community.

Q6.3 AVBC has failed to provide assistance for the creation of Neighbourhood Plans.

7. Policy SS2 7.1,2,3 If there is to be a Green Belt review in order to release new sites for employment, it is surely more logical and potentially less wasteful to consider housing and employment needs simultaneously. Brownfield sites, thus released could be re-used for housing and incursions into the Green Belt would be minimised. Thus the 2-stage Local Plan does not provide a robust process to meet the approach to the Green Belt review as set out in paragraph 83 of the NPPF.

8. Policies SS4 and SS5 8.1 The production of a Masterplan for either Alfreton or Belper cannot be regarded as more than an ultimate objective. It falls short of meaningful policy.

9. Policy SS8 Strategic objectives which meet the needs and concerns of local people must be set out.

10. Policy SS9 As above (9)

11. Policy SS12 11.1 This policy appears to be consistent with paragraphs 28 and 55 of the NPPF. It includes both safeguards for the countryside and objectives designed to meet rural needs.

13. Policies H3/ H4 – Affordable Housing Q13.1 The requirement for 30% affordable housing is consistently waived as developers claim this percentage is unaffordable.

15. Policy E2 Q15.1 These are high-sounding objectives, not necessarily realised.

16 Policy E3 Q16.1 Archaeological issues constitute a significant omission and must be included in this policy. This policy states that important areas which make up the distinctive character of the borough will be protected from unsympathetic development. How effective can this policy be? The enclosure and settlement patterns of the Duffield Frith are apparently worth protecting. On the other hand, Codnor Common, with a history extending to the Norman Conquest and beyond, as evidenced by the ridge and furrow system of its fields, is considered ripe for development.

18. Policy E6 Why do such high-sounding objectives inevitably translate into net losses for nature? Ecological values are secondary when planning applications are determined. Greater protection for wildlife is vital.

19. Policy SG1 (Outseats Farm, Alfreton) Outline planning permission for the site was granted ahead of its inclusion in the Local Plan. There is indeed a developer but many questions remain concerning the viability of this site; e.g. Alfreton Town Council’s traffic survey indicated significant problems. The adjacent Bolsover site must also be considered.

20. Policies SG2 (Alfreton Road, Codnor) and SG7 (Nottingham Road, Ripley) 20.1 The Ripley Neighbourhood Plan includes sites which are not in the Green Belt which would supply housing needs as forecast. The Ripley-Codnor Link Road would then follow a route which would be less environmentally damaging than that proposed by AVBC (i.e. one not linked to the above housing development). 20.2 There is conflicting evidence available concerning the need for the link road and the purposes it would serve. The road will also facilitate an out of town supermarket which is neither desired nor needed; it would undermine much needed town centre regeneration. 20.5 The Ripley-Codnor relief road has been under discussion for many, many years. Given that sources of funding remain uncertain, timely delivery seems unlikely. 20.7 Exceptional circumstances for omitting these sites from the Green Belt have not been demonstrated.

21. Policy SG3 (Derby) Remediation of a contaminated site is highly desirable.

22. Policy SG4 (Newlands/Taylor Lane, Heanor) Core strategy sites without pre-development viability testing. There is strong local evidence of the site’s value in terms of wildlife, particularly birds.

23. Policy SG5 (Radbourne Lane, Mackworth) Another site where planning permission was granted before pre-development testing. Adjacent to the site of Kedleston Hall, this development site must not be allowed to mar the setting of this historic building, park and garden.

24. Policy SG6 (Coppice Farm, Ripley) Yet another site where planning permission has preceded viability testing. The known likelihood of flooding in this area is exacerbated by sewage contamination emanating from an out of date sewerage system. Older combined flow sewers and surface water sewers operate at full capacity in this area.

The eastern part of Amber Valley will bear the brunt of housing development required by the Derby Housing market. Traffic congestion, increased pressures on schools and medical services, dangers to wildlife: these are the challenges associated with housing development on a large scale within a relatively small area. There will be an irreversible loss of precious green spaces.