The Local Plan Part 1: Core Strategy Regulation 22 Statement of Consultation December 2013 This page is intentionally blank 2 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 3 This page is intentionally blank 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. 2 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. 3 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. 4 • 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. 5 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.