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Erewash Core Strategy Review

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Erewash Core Strategy Review RECORD OF EXECUTIVE DECISION – LEADER OF THE CABINET Title of matter: Erewash Core Strategy Review – Draft Options For Growth Decision maker: Cllr Chris Emmas-Williams, Leader of the Cabinet (elected on May 2019 by the Council) Power(s) giving authority to make an executive decision: Sections 9E(2) of the Local Government Act 2000 and under all other powers. a) Decision: a.1 That the following representations be made by the Borough Council in response to the consultation by Erewash Borough Council on the Erewash Core Strategy Review - Draft Options For Growth. Amber Valley Borough Council (AVBC) has been consulted on the above document, which sets out the strategic growth options for housing development in Erewash up to at least 2037 and the preferred option for Erewash Borough Council (EBC). EBC has established, through the application of the Government’s standard methodology to calculate a minimum annual housing need figure, that they will need to plan for the delivery of 393 additional dwellings per year in the Erewash Core Strategy Review, for the period up to at least 2037 i.e. a total of 6,680 for the period 2020 to 2037. This reflects the anticipated date of adoption of the Review in 2022 and the Government’s policy requiring local planning authorities to plan for at least 15 years from the date of adoption. EBC also need to identify sufficient sites capable of delivering housing to provide a minimum of 5 years supply against the housing requirement. As EBC has not met the Government’s Housing Delivery Test, the minimum 5 year supply figure will include the 393 dwellings per year established through the standard methodology, plus a 20% margin (79 dwellings per year) giving a total of 2,360 dwellings. AVBC has considered the Draft Options For Growth document, in terms of its wider implications for joint working on strategic planning matters across the Derby Housing Market Area (HMA) and the Greater Nottingham Housing Market Area (HMA) (which includes Erewash Borough), as well as the potential impact on Amber Valley of any specific proposals in the document. Template 31 May 2019/CP Comments on the potential implications for joint working in relation to plan-making within the Derby HMA and the Greater Nottingham HMA In preparing plan documents, local planning authorities need to ensure that policies and proposals are soundly based on robust evidence and that cooperative working has taken place with adjoining planning authorities and other delivery partners on strategic cross-boundary planning issues. In this respect, there are a number of serious concerns with the approach that has been taken by EBC in preparing and consulting on the Draft Options For Growth document. The Draft Options for Growth document only includes proposals for housing development and does not appear to take into account the relationship between new housing development and economic growth The range of potential sites and preferred sites for housing development appears to be based on a limited range of evidence – in particular it is unclear whether any up to date evidence in respect of employment need, landscape sensitivity or flood risk, has been undertaken or commissioned to inform the process In relation to those options where it is proposed to delete land from the Green Belt boundary and allocate sites for housing growth, there is no evidence that a comprehensive review of the Green Belt within Erewash has been undertaken or commissioned, against the five purposes of Green Belt as set out in paragraph 134 of the NPPF and consequently no assessment of how each of the potential site options perform against these Green Belt purposes. In terms of Green Belt, Erewash Borough is situated within the Nottingham-Derby Green Belt. The Green Belt covers all of the local authority areas in both the Derby HMA and Greater Nottingham HMA. In this context, it is of particular concern that the Draft Options For Growth document does not appear to have been informed by either a Borough-wide or wider strategic Green Belt Review, especially as the document is proposing the allocation of four large areas of land currently located within the Green Belt. Two of those areas of Green Belt, at Acorn Way on the edge of Derby and on land to the north of Cotmanhay raise significant implications for the wider areas of Green Belt within which they are located, as set out in more detail below. Template 31 May 2019/CP Two strategic Green Belt Reviews have previously been undertaken covering Erewash Borough, namely: • the Nottingham-Derby Green Belt Review (NDGBR), which was undertaken jointly by Derbyshire County Council and Nottingham County Council in 2006/07 on behalf of the (then) East Midlands Regional Assembly (EMRA) to inform the preparation of the East Midlands Regional Plan (EMRP) • the Derby Principal Urban Area Green Belt Review (DPUAGBR), which was undertaken jointly by Derbyshire County Council, Amber Valley Borough Council, Derby City Council, Erewash Borough Council and South Derbyshire District Council in 2012 to inform the preparation of each local planning authority’s Core Strategy or Local Plan. In this context, it is disappointing that the Draft Options For Growth document has not referenced the conclusions of each of these Reviews, in respect of the assessment of their potential impacts on the Green Belt. Furthermore, it is also of concern that no meaningful assessment has been carried out in the Draft Options For Growth document, or in the supporting Sustainability Appraisal, of the impacts of the proposed allocations on the five Green Belt purposes set out in paragraph 134 of the NPPF. It should be noted that the NDGBR assessed a range of broad areas against the five main Green Belt purposes. Three broad areas were defined that covered Erewash Borough, namely:- • Area 1: Nottingham to Long Eaton and Ilkeston • Area 2: Derby to Long Eaton • Area 3: Derby to Ilkeston. In terms of their assessment against the five Green Belt purposes, these three broad areas were all assessed as being of ‘high’ importance in meeting the five Green Belt purposes. The overall conclusions of the NDBGR (paragraph 95) indicated that the area between Nottingham and Derby and the areas immediately to the north were strategically the most important areas of Green Belt. The DPUAGBR assessed a range of broad areas of Green Belt on the edge of the urban area of Derby, against the five Green Belt purposes. Two broad areas covered part of Erewash Borough, namely:- • Area C: Derby North East • Area D: Derby East. The conclusions in respect of both of these broad areas was that they both performed well against the Green Belt purposes. In particular, both areas were assessed as performing a particularly important role in preventing the coalescence of the urban areas of Derby and Nottingham and the settlements in Erewash Borough in between. Template 31 May 2019/CP Both of the strategic Green Belt Reviews referred to above highlight the strategic importance of the whole of the Green Belt covering Erewash Borough and consequently, the importance of the need for a Green Belt Review (either Borough- wide, or Derby HMA/Greater Nottingham HMA-wide) to be undertaken to inform any consideration by Erewash Borough Council of the potential release of significant areas of the Green Belt for housing development. In particular, a Strategic Green Belt Review may have been likely to identify other alternative less sensitive areas of the Green Belt in the Borough that may be suitable for potential release for housing development than those which have been put forward in the Draft Options For Growth document. At the very least, such a Review would have provided an important assessment of how the sites that have been put forward for allocation compared to other alternative sites in meeting the five Green Belt purposes. Green Belt and the need for Green Belt review will be a key strategic issue for the local authorities in both the Derby and Greater Nottingham HMAs to consider in taking forward the reviews of their respective Core Strategies/Local Plans and will be a key cross boundary ‘duty to cooperate’ matter that will require extensive discussion between all the authorities in both HMAs in due course. The Draft Options For Growth document and its proposals for significant Green Belt release is therefore considered to be premature, pending wider strategic discussions on this matter. Overall, AVBC considers that the lack of prior and constructive engagement between Erewash Borough Council and the neighbouring upper and lower tier authorities within the Derby and Greater Nottingham HMAs could not only undermine the ‘soundness’ of the Erewash Core Strategy Review, but also have a similar impact on the preparation of the ongoing reviews of Core Strategies/Local Plans in both HMAs. As highlighted above, one of the preferred site options for housing growth relates to land at Acorn Way immediately to the east of the existing built up area of Derby, the edge of which corresponds to the boundary between Derby City and Erewash Borough. The Derby HMA authorities (Amber Valley, Derby and South Derbyshire) have recognised the limited capacity for development within Derby City to meet housing needs arising within the city boundary and both Amber Valley and South Derbyshire have previously agreed to make a contribution towards Derby’s unmet need that cannot be provided within the city. Housing development has taken place and is taking place and/or planned in the form of urban extensions to the Derby urban area, within Amber Valley and South Derbyshire. By virtue of its location, this development can be regarded as contributing to the unmet need for Derby.
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