Amber Valley Local Plan Report of Publicity and Consultation on the Preferred Growth Strategy This page is intentionally blank 1 Contents Page No. 1. Introduction 3 2. Public events and community involvement 4 3. Summary of comments received from the public 6 4. Summary of comments from Parish/Town Councils 12 5. Summary of comments from Borough Councillors 18 6. Summary of comments from key bodies 20 7. Summary of comments from site promoters 34 on scale of housing growth 8. Summary of comments from site promoters on the 40 preferred growth sites 9. Summary of comments on other potential strategic sites 47 2 1. Introduction The Borough Council produced the Preferred Growth Strategy as part of the preparation of the Core Strategy for Amber Valley. Derby City Council and South Derbyshire District Council also produced Core Strategies for their administrative areas on an aligned timetable. These three authorities form the Derby Housing Market Area. The Preferred Growth Strategy set out proposals for the number of new homes to be provided in the Borough up to 2028, as well as identifying the Council’s preferred locations for strategic sites to contribute to housing growth. The Preferred Growth Strategy was approved by the Council on 26 September 2012 and was published for public consultation and community involvement from 30 September to 21 December 2012. The process of consultation and community involvement included a series of public events held in key locations across the Borough to enable local people to learn more about the proposals. Specific consultation on the Preferred Growth Strategy was also undertaken with a range of statutory bodies and other individual and organisations, as well as with those who have responded to previous consultation on the emerging Core Strategy. 3 2. Public events and community involvement There were 7 public ‘drop in’ consultation events held in the following areas: Thursday 18 October 2012 John Flamsteed School, Denby Friday 19 October 2012 Alfreton Community Hall, Alfreton Monday 22 October 2012 Ripley Leisure Centre, Ripley Tuesday 23 October 2012 Arkwright Suite, Lion Hotel, Belper Wednesday 24 October 2012 Community Centre, Heanor Thursday 25 October 2012 Peverel House, Codnor Friday 26 October 2012 Kilburn Village Hall, Kilburn John Flamsteed School, Denby Around 40 local residents attended this public consultation, 9 of which submitted a consultation response form at the event. Alfreton Community Hall, Alfreton Around 51 local residents attended this public consultation, 21 of which submitted a consultation response form at the event. Ripley Leisure Centre, Ripley Around 50 local residents attended this public consultation, 9 of which submitted a consultation response form at the event. Lion Hotel, Belper Around 30 local residents attended this public consultation, 6 of which submitted a consultation response form at the event. Heanor Community Centre, Heanor Around 40 local residents attended this public consultation, 16 of which submitted a consultation response form at the event. Peverel House, Codnor Around 125 local residents attended this public consultation, 39 of which submitted a consultation response form at the event. 4 Kilburn Village Hall, Kilburn Around 40 local residents attended this public consultation, 4 of which submitted a consultation response form at the event. 5 3. Summary of comments received from the public In total 796 individual representations were received on the Preferred Growth Strategy for Amber Valley. Derby City Council received a total of 164 representations and South Derbyshire District Council received a total of 297 representations on their Preferred Growth Strategies. The Scale of Housing Growth The majority of representations stated that the proposed provision of 9,000 new homes in Amber Valley between 2008 and 2028 was too high. The reasons given for this are as follows: This number of new homes is not required There are few jobs to enable people to afford to buy the houses There are many empty properties in the Borough, and these should be brought back into use first. There is a lack of infrastructure to support this amount of housing Houses that already have planning permission are not being built The Preferred Strategic Sites The main concerns raised in respect of each of the preferred strategic sites are as follows: AV2 – Outseats Farm, Alfreton Development would result in the loss of greenfield land Existing roads are already very congested The access arrangements are unsuitable Loss of wildlife Local infrastructure will not be able to deal with the extra demand Part of the site is within an outer consultation zone for hazardous substances Approximately 120 individuals commented on this site, of that around 89 objected, 22 supported and 11 stated it should be modified. 6 AV8 Alfreton Road, Codnor Green Belt land should not be developed Local infrastructure will not be able to deal with the extra demand Extra traffic will be created on already congested roads The by-pass may not be implemented There is no evidence of a need for a by-pass Development of this site would detract from the setting of Codnor Castle and the Codnor Park Conservation Area Existing footpaths and access to Codnor Castle would be adversely affected Former coalmining activities will detract from the viability of the site Overhead electricity lines cross the site Approximately 190 individuals commented on this site of that around 166 objected, 14 supported and 13 thought it should be modified. The Council also received a 1,091 signature petition in relation to this site from the ‘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. 7 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. AV13 Land North of Denby The size of the site is too large Too many houses are proposed Concerns regarding the need to remediate the tar pits Flooding issues Development on this scale will result in a major impact on local infrastructure, especially the roads Loss of countryside and wildlife Approximately 150 individuals commented on this site of that around 82 objected, 38 supported and 16 thought it should be modified. Denby Footpaths Group 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. - Green Belt development. - Historic and heritage aspects. - Link to Derwent Valley Heritage Site. - Other opportunities for the land. 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 to readers of the Preferred Growth Strategy. The land stands out in the tables as an obvious development site as 23% of the need can be met by 900 houses being built on land incorrectly classified. Whilst other development is mainly on Greenfield, readers will be swayed by the table and figures presented as Brownfield development would be a preferential choice. This is evident in the comments in “A Significant Opportunity For Development On A Strategic Scale At Denby (2012)”. This document indicates support for this area to be developed in preference to Greenfield and indicates that this support is not from Denby residents. The review of the 2008 Strategic Housing Land Availability Assessment will hopefully address this issue once published. 8 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. Green Belt Development: The northern part of the land is located in Green Belt and should therefore be precluded from development. 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.