Local Plan Part 1 Pre-Submission Core Strategy Regulation 19

Transcription

Local Plan Part 1
Pre-Submission Core Strategy
Regulation 19 Statement of Consultation
and Publicity
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Contents
Page No.
1.
2.
3.
4.
5.
6.
Introduction
Public events and community involvement
Summary of comments from the public
Summary of comments from Parish/Town Councils
Summary of comments from Borough/County Councillors/MP
Summary of comments from neighbouring local authorities and
Derbyshire County Council
7. Summary of comments from national bodies
8. Summary of comments from local groups
9. Summary of comments from developers/landowners/consultants
Appendix A – Persons and bodies invited to make representations under
regulation 18
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101
130
151
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1.
Introduction
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:
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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.
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.
This statement has been prepared in accordance with Regulation 17 and 19 of the Town and
Country Planning (Local Planning) (England) Regulations 2012, which requires a statement
setting out:
(i) which bodies and persons were invited to make representations under Regulation 18;
(ii) how these bodies and persons were invited to make representations;
(iii) a summary of the main issues raised by those representations; and
(iv) how those main issues have been addressed in the DPD
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.
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2.
Public events and community involvement
As part of the consultation process on the Draft Core Strategy the Community Planning
Team held 4 public ‘drop in’ consultations events in the following areas:
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Friday 12 July 2013
Monday 15 July 2013
Wednesday 17 July 2013
Thursday 18 July 2013
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Ripley Leisure Centre, Ripley
Alfreton Christian Centre, Alfreton
28 Market Place, Belper
Wilmot Street Centre, Heanor
Previous consultation exercises undertaken were as follows:
Issues and Ideas (2008)
This document, which was published for consultation between September and November
2008, identified a range of issues and sought comments on the matters that should be
addressed by appropriate policies in the Core Strategy.
Issues and Options (2010)
This document, which was published for consultation between January and May 2010, set
out a range of policy options for delivering housing, meeting employment needs, as well as a
range of other issues.
Have Your Say (2011)
This document was published for consultation from February to May 2011. Following the
Government's announcement that Regional Plans were to be revoked, it was decided to
undertake further consultation on a wider range of policy options.
Options for Housing Growth (2011)
This document, which was published for consultation from July to September 2011, sought
views on a range of options for the overall scale of new housing development in Amber
Valley and where this new housing should be located, including 16 potential locations for
strategic housing sites.
Development On A Strategic Scale At Denby (2012)
This consultation took place from February to April 2012, following a response to the
‘Options for Housing Growth’ consultation in respect of the option of a new settlement. It
suggested that land at Cinderhill, Denby could have the potential for development on a
strategic scale.
Preferred Growth Strategy (2012)
This document was published for consultation from October to December 2012. It sought
views on the Council’s preferred strategic growth sites for new development, following
previous consultations on the options for growth.
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3.
Summary of comments from the public
Comments on the Spatial Portrait
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Green Belt should be retained at all costs
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The majority of the Borough is rural and open. There is nothing that reflects this in
the Spatial Portrait.
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Needs to describe the landscape and the contrast between the east, west and south
west of the Borough.
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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.
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Would be helpful to include a map of the Borough.
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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.
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Needs to include vibrancy and sustainability – some parts of Amber Valley are very
vibrant and desirable.
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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.
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Undervalues the very special landscape in the Ecclesbourne Valley in the west of the
Borough.
Response
The Spatial Portrait has been amended to reflect these suggestions.
Comments on the Spatial Vision of Amber Valley
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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.
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Not concentrating growth on the four market towns.
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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.
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Nothing about landscape – what about Areas of Multiple Environmental Sensitivity
(AMES)?
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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.
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No development should proceed until existing sites, e.g. the Denby commercial site,
have been developed and occupied.
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Vision/strategy is meaningless as the housing led plan is based on sites put forward
by developers (as confirmed by CLLR Bowley at an ‘Ave you say’ meeting in January
2013) and which has stifled any serious debate about the locations of future
developments.
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No mention of protecting and enhancing the countryside and natural landscape.
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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.
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Comments on the Strategic Objectives
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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.
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Not growing Belper you are creating out of town development problems in Codnor.
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These seem good.
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Support strategic objectives 7 & 8
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Laudable objectives apart from item 10 – improvements to the transport system are
welcome but the A610 link road is a contentious matter.
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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.
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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.
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Objective 7 -& 8 supported but not enough about the countryside. Saved policy EN1
should become part of the objectives matrix.
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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.
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Comments on the Spatial Strategy
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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.
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The need to protect the Green Belt is highlighted but nothing about the countryside.
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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.
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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.
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The requirements of the Derby Housing Market do not necessarily coincide with the
needs of Amber Valley. The need for a spatial strategy that accommodates 9,400
houses is open to question. There are un built sites here, indicative of lack of
demand and also developer disinclination. A potential land banking situation instead.
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The ‘presumption in favour’ of the NPPF does not reflect local needs.
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Protecting the Green Belt – sizeable amounts are earmarked for housing
development, road building and employment – where is the Green Belt review in
relation to these demands?
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Support para 6.1 & 6.2 – priority of protecting the Green Belt and maximising
development of brownfield land before greenfield.
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The developments within 1 mile of Codnor equate to an increase in population of
5,000 people which effectively doubles the population of the village destroying its
identity as a village. The strategy will create an uninterrupted housing area from
Hammersmith in the north to Crosshill in the south, effectively making a Greater
Ripley conurbation.
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The Core strategy is unsound because alternatives to sites proposed in the Green
Belt have been dismissed without convincing reasons. No strategic review of the
Green Belt appears to have been carried out.
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Reasoning to support policies SG2 and SG7 is back to front – justification of
development proposals in order to deliver new road infrastructure.
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No evidence to back up claims that new A610 will alleviate traffic congestion. There
are contradictions in the Transport Assessments in the accompanying IDP which do
not support the need for the new road.
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I support AVBC in protecting Green Belt land. In most cases development to 2028
can be achieved without encroaching onto Green Belt land.
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I support AVBC in maximising the use of brownfield land prior to greenfield
development. A target figure for brownfield development would be beneficial to the
public, officers and the Council. ABVC needs to ensure brownfield land comes
forward ahead of greenfield. Set targets will ensure opportunities are not lost
because developers will always favour greenfield sites.
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It is disappointing that AVBC does not place more emphasis on the re-use of empty
properties, especially those above businesses. These are the most visible properties
in a town centre and have a huge impact on ambiance. ABVC should look favourably
on change of use applications to support a reduction in numbers of houses becoming
derelict. AVBC should promote the change of use of space above shops to
residential to support sustainable living.
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I support (para 6.5) that the Site Allocations and Development Management Policies
document will ensure that brownfield land is considered first and that the Green Belt
is protected from development.
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Now that the EMRP has been revoked, it would be a good opportunity to review the
dispersion of houses across Amber Valley and ensure that young people are not
priced out of their communities.
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I do not see a specific policy document that addresses creating economic and
employment opportunities.
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Para 6.9: I suggest you clearly define in the Local Plan Part 2 the re-allocation of
poor quality industrial and employment sites for housing and re-adjust your housing
requirements numbers. Part 2 could also provide a framework for monitoring the
shifting economic situation and the changing land requirements of modern
businesses, which are less than that for the historical manufacturing industry.
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Concerned that development will take place on greenfield/Green Belt sites in
preference to brownfield sites. The site at Denby which is close to Derby and has
good transportation links could accommodate much of the housing requirement for
the Borough. The Planning Minister suggested the redevelopment of the former
Butterley Works at a recent visit to the Borough. A FOI request to AVBC revealed
that 80% of necessary growth could be accommodated on brownfield sites.
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Unbalanced distribution of strategic sites resulting in coalescence of existing
settlements, unsustainable demands on existing facilities and services and an
inability to meet the greater housing demand in the west of the Borough.
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Includes protecting the Green Belt, but nothing about the countryside.
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Support 6.3 re-using empty properties. Conditions on holiday let properties should be
removed so they can become homes.
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Unbalanced spatial distribution of strategic growth sites Borough wide, focusing over
90% of the proposed development on a 3.5 mile radius of Ripley and Codnor. The
ability of local facilities and services to grow at an adequate pace to account for the
scale of development has not been taken into account. The scale of development
within a 1 mile radius of Ripley and Codnor equates to 1,714 houses and an increase
in the population from 5,000-7,000.
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Ripley, Codnor and Waingroves will become merged settlements and suburbs of
Ripley, contrary to the NPPF.
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Codnor will be completely enclosed by new development and no recreational space
will be available to a village which has always afforded a rural setting with links to
Codnor Castle. The current green space around Ripley and Codnor will be reduced
by 87%.
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The Draft Core Strategy fails acknowledge that the national rail network stations are
in Langley Mill, Alfreton and Belper, but Codnor and Ripley which have no station
will take the majority of the housing.
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Green Belt is addressed but no protection is offered to the countryside.
Response
The Spatial Strategy has been amended to reflect some of these suggestions. However,
some comments relate to matters that are too specific to be included in the Spatial Strategy
or are just general comments.
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Comments on Policy SS1: Housing Land Requirements and Distribution
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How can this bias plan have got this far, surely there should be a better split right
across the Borough rather than just concentrate on the Eastern side of the A38.
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The plan has identified a more than adequate amount of new houses
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No additional information is provided in this current strategy that would indicate
neither evidence based, objectively assessed need, nor that would justify this
forecast. On this basis alone, the need for key strategic sites to be identified is not
proven.
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Belper villages – Policy SS1 recognises the need to maintain the rural character and
individual settlement identities of the villages. Over the past 30 years, Belper has
expanded to pull in many of its surrounding villages (Broadholme, Milford, and
Openwoodgate) and would urge that those which remain separate from the town by
green spaces are kept so, namely Bargate, Blackbrook, Farnah Green, Heage and
Holbrook.
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The wording in relation to villages is not clear, suggest deletion of “the settlements
of”, purely to simplify the language used. In addition add “A limited amount of small
scale growth will be considered in villages in accessible and sustainable locations,
specifically to meet the needs of the local community”.
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The proportion of affordable housing required was substantially reduced – why?
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The large scale of proposed development is disproportionate to the needs which can
be met by currently ailing town centres.
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Don’t understand why the majority of proposed sites are in the east, especially
around Codnor. Schools and medical services would struggle to cope with the
numbers of people.
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Reasoning behind justifying allocations SG2 and SG7 are flawed – NPPF requires
LPAs to identify land for housing based on an objective assessment of local housing
need, an assessment of the capacity of local infrastructure, key environmental
constraints, and whether sites can be accessed by non-transport modes. AVBC has
assumed the desirability of the Codnor Bypass and is retrofitting site allocations to
generate resources to funds it.
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ABVC need to show it has the assessments and Sustainability Appraisal in place for
this scale of development before any more planning permissions are granted on
strategic sites.
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What impact will development of this size have on mental health and deprivation?
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The plan treats all the Borough as being part of the Derby HMA but in reality only the
southern area functions in this way. The number of houses required is based on this
assumption and has led to a figure which is unrealistic. The focus of new housing
growth on Alfreton, Ripley and Heanor is excessive and represents a level of growth
never seen in these areas which is unsustainable given the decline in the base
industries of the area.
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Distinction has to be made on what Government is trying to achieve, building houses
so that more people can find their way onto the property ladder, especially first-time
buyers or helping kickstart the building/construction industry to achieve more
economic growth for the country as part of the recovery process.
Response
It is considered that this policy will meet the full, objectively assessed needs for housing in
the Borough as required by paragraph 47 of the NPPF. It is based on work carried out by
consultants who are specialists in assessing housing need who produced a Housing
Requirements Study for authorities in the Derby Housing Market Area in 2012 and updated
the housing projections when they were commissioned a Strategic Housing Market
Assessment (SHMA) in 2013. This included a response to representations that were
received on the Council’s Preferred Growth Strategy which was the subject of public
consultation in 2012.
The policy, has, however been amended to make it clearer where housing growth is
proposed. Some of these statements are just general comments.
Comments on Policy SS2: Business and Industrial Land Requirements
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Well-designed policies for economic growth are welcomed.
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Cannot understand why there is not a prestigious business site within Amber Valley
especially as it covers such a long period.
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No mention of the land and properties owned by Tesco which they no longer intent to
develop – this is a large brownfield site with good access to the town and its public
transport networks. This site could potentially fulfil all of the building needs proposed
within Belper, but has not been identified as an opportunity in the strategy.
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Due to the changing nature of business it is believed that the sites identified as
Business & Industrial Land need to be monitored throughout the duration of the Local
Plan, as defined intervals in time, as there may still be an over allocation of land for
this purpose.
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Were appropriate AVBC should allow re-cycling of employment land as older style
businesses (with a need for large sites) are replaced by technology & knowledge
based businesses, requiring less employment land compared with traditional
manufacturing businesses. This would support the changing face of our economy
and improve dated brownfield sites by transferring them to housing land. An example
where land could be recycled for housing be Smiths Flour Mills in Langley Mill.
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Address improvements which could be made to existing sites rather than using
Green Belt for employment.
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De-allocation of existing sites will create large brownfield sites- these are not readily
utilised at present.
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New businesses have to be attracted to Heanor if a large site is to be developed at
Newlands/Taylor Lane.
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The site at Lily Street Farm, Derby Road, Swanwick could come forward as part of
the preparation of the Site Allocation and Development Management Policies
document (Part 2 of the new Local Plan). It is worth pointing out that the reason for
not taking this site forward as a Strategic Preferred Growth site for housing was, it
was not well related to Alfreton and Swanwick and its development would urbanise
an area which currently provides a rural open break between Swanwick and Alfreton.
Response
The policy has been amended to emphasise that the Council will review existing business
and industrial land allocations and the consideration of potential new allocations in the Site
Allocations and Development Management Policies DPD and to ensure that sufficient high
quality sites are included in the overall provision. Some of these suggestions are too specific
for a strategic policy or are just general comments.
Comments on Policy SS3: The Role of Settlements
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Settlements should be kept separate at all costs which plan does not reflect.
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Regarding retail – concerns over the vagueness of the term ‘larger –format units’ these units need to be in keeping with the heritage of Belper.
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Although one aim of the Core Strategy is to ‘extend and improve the quality of the
retail offer and provide a wider retail offer to ensure that spending takes place within
the Borough’ it needs to be clear that this will enhance, not conflict with the current
retail on offer.
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Settlements need to develop to survive. Pubs, shops and local facilities even in the
smallest communities need to be supported.
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The Borough settlements are set within a rural landscape so there should be
reference to the potential impact of new development on the urban/real interface.
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New development can be used to improve the rural urban interface by high quality
design in line with the local landscape character and incorporate landscape
mitigation such as appropriate planting, boundary construction, building materials,
design and colour.
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Need policy wording that positively deals with the potential impact of new
development on the urban/rural interface.
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Issue of town centre regeneration must be addressed in order to maintain settlement
distinctiveness and economic vitality.
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It will not be possible to promote and improve town centres if two major sites some
way away from existing town centres are allocated to housing and associated retail
development with a road designed to channel traffic away from existing town centres.
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Support independent retail sector by not inviting large format units.
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Policy needs to address rural amenities – village pub and shop.
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Small settlements with threatened facilities need support as well.
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The proposal to focus local development in the District Centre of Langley Mill and the
local centres of Duffield, Codnor, Leabrooks, Swanwick and Somercotes will have to
be dealt with very sympathetically, especially in respect of the neighbouring villages
of Leabrooks, Swanwick and Somercotes, as too much development will lead to
unnecessary and unwanted urbanization of these individual communities.
Response
These are just general comments or relate to matters not relevant to a policy on the role of
settlements. It is considered that no amendments to this policy are required.
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Comments on Policy SS4: Town Centre Regeneration in Alfreton
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Do need a masterplan for Alfreton, all towns need your help
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Alfreton has high social needs; the town will be augmented by 500+ houses under
current proposals. A lesser scale of development would facilitate an appropriate
approach to regeneration.
Response
The policy does state that the Council will consider the need for a Masterplan to be
produced. The other comment relates to a matter that not relevant to this policy. It is
considered that no amendments to this policy are required.
Comments on Policy SS5: Town Centre Regeneration in Belper
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You write ‘The strategy for regeneration in Belper….’ We argue that ‘regeneration’ is
not the right word and should only be used in the context of the Meadows/Derwent
Street site. Otherwise, we suggest ‘enhancement’.
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‘Larger-format units’ – needs to be defined clearly. Can there be a size limit on any
larger-format multi-national and maximum of units within one development area?
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Agree with ‘it is vital that this does not involve development that would detract from
the character of this historic market town……’ etc, but concerned how this can be
prevented if there are no specific guidelines in the local plan regarding the scale and
extend of larger-format national multiple retailers.
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Support independent retailers to keep town centre vibrant.
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A good summary
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Would appear to be a direct contradiction in stating that Belper needs more larger
national retailers, but that the independent sector is a key asset. The large number of
independents and low number of national retailers is a key part of the individual
identity of the town, which should be maintained.
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Agree totally with a Masterplan especially if this could involve the community.
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Need adequate parking for coaches and a tourist office nearby.
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There needs to be policy wording in SS5 and/or SS8 that deals with the potential
impact of regeneration/development on the wider area. A Design Brief should be
required and it must consider the impact of the development on the wider area
including landscape character, visual and environmental sensitivity.
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New development can be used to improve the rural urban interface by high quality
design in line with the local landscape character and incorporate landscape
mitigation such as appropriate planting, boundary construction, building materials,
design and colour.
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Belper is more prosperous and does not face development on the scale found in the
east of the Borough.
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Support this positive policy.
Response
The policy does state that the Council will consider the need for a Masterplan to be produced
and refers to development in the town centre looking to improve parking for coaches.
However, it has been amended to refer to supporting independent retailers. However, no
other changes are considered necessary, as the other suggestions refer to matters too
detailed for a strategic policy or they are just general comments.
Comments on Policy SS6: Town Centre Regeneration in Heanor
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These plans have been around for some time but very little seems to get delivered.
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Fully support regeneration of Heanor town centre.
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The more people who live in our town centres (i.e. above shops) & close to the town
centres (ex-relief road land and associated car park (ex. Somerfield supermarket)
can only help to support the shops and traders; as such AVBC needs to ensure its
policies support the creation of housing in our town centres.
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New businesses have to be attracted to the area to provide job opportunities.
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Need 1 hour free parking on the Market Place.
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Support the regeneration of Heanor Town Centre. The more people who live in and
near our town centres the better to support the shops and traders. AVBC needs to
ensure there are policies to support the creation of housing in town centres which
includes the ex-relief road allocation and Somerfield Supermarket car park.
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I am concerned that Heanor is a dormitory town and people spend their leisure time
away from Heanor. This is because Heanor has limited job opportunities, leisure and
shopping facilities to attract people. As such the amount of housing proposed on the
edge of Heanor should be reduced if possible.
•
Heanor suffers from low retail due to the proximity of the large retail park with free
parking.
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I suggest that the Council support regeneration prioritising development in and
around the Market Place. I have previously made suggestions on how regeneration
should be approached in the town, involving constructing the relief road on the back
of a relocated supermarket on this land with an interface with the town centre on the
site of the former Somerfield. This land could accommodate the petrol station that
requires relocation for the current major supermarket operator to release consent for
their extension. Relocation would place the main retail anchor in the heart of the town
and enable to existing supermarket site to be released for development.
Fundamentally I do not consider that the council has a strong enough strategic
approach to the regeneration of the town centre, that is failing due to the placement
of two large supermarkets either side of Heanor Hill.
Response
The general policy for development in town centres (SS8) makes reference to supporting the
provision of new housing, if it can demonstrated that it will not impact on the vitality and
viability of the town centre. It also refers to supporting the use of upper floors for residential
use. However, no other changes are considered necessary, as the other suggestions refer to
an inner relief road which was previously proposed by Derbyshire County Council which is
no longer to be provided and matters too detailed for a strategic policy or they are just
general comments.
Comments on Policy SS7: Town Centre Regeneration in Ripley
•
Ripley has been waiting for investment for some time. It has seen a decline as it
appears that the Borough Council has concentrated on Belper alone. A new out of
town supermarket is not what the Town or public want. The Ripley masterplan has
been a joke, with no timescales ever been given reasons why it has not been
delivered.
•
Regeneration of Ripley town centre would not be helped by the building of an out-oftown supermarket.
•
Not taking into account all relevant independent advice given and that the viability
and vitality of Ripley town centre will be put at great risk if the proposals for an out of
town supermarket is approved, as the NPPF requires you to protect and enhance
existing town centres.
•
It is important to attract development into the town centre and to protect what we
already have as required in the NPPF and not to promote development on the
outskirts of Ripley as with the Morrison’s proposal.
•
2 hours free parking is necessary to encourage shoppers into the town.
•
If you allow the development of Morrison’s it will seriously affect the vitality and
viability of the centre resulting in the closure of the Co-Op and several other stores.
15
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Development that takes footfall to the market place is good. Support policy.
Response
No changes are considered necessary, as some comments refer to a proposal on the edge
of the town and other comments refer to the adequacy of the Ripley Masterplan.
Comments on Policy SS8: Development in Town Centres
•
There is a need for some stimulation to attract people back to the towns surely free
parking would be an attraction.
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Agree with the policy
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Can it be specific when a retail impact assessment is ‘appropriate’?
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A Design brief should be required and it must consider the impact of the development
on the wider area including landscape character, visual and environmental sensitivity.
•
Residential development in town centres should only be considered when
commercial alternatives have been exhausted.
Response
The general policy for development in town centres (SS8) makes reference to supporting the
provision of new housing, but only if it can demonstrated that it will not impact on the vitality
and viability of the town centre. However, this policy has been amended to be more specific
about when an impact assessment will be required. Car parking charges are not a planning
issue and a development brief in the form of a Supplementary Planning Document has
already been adopted for land between the A6 and the River Derwent in Belper.
Comments on Policy SS9: Primary Shopping Frontages
•
Ripley Primary Shopping Frontage as indicated does not correspond with that on the
ground. Grosvenor Road, Church Street and the High Street need to be included.
Response
Restricting non retail town centre uses on these streets would have a negative impact on the
vitality and viability of the town centre.
16
Comments on Policy SS10: Green Belt
•
Fully support AVBC in protecting Green Belt land from inappropriate development
and that the boundaries shall only be changed under exceptional circumstances.
•
Maintenance of the Green Belt is a fundamental importance of protection of the
countryside.
•
Part b) Not convinced it should include sports facilities
•
Point e) limited infilling in villages, and limited affordable housing for local community
needs. This should be qualified, by adding, ‘Where the local community has identified
that need and has agreed by consultation that it is necessary’.
•
Point f) seems extraneous, it is actually talking about brownfield sites, and as far as I
am aware the fact they are ‘brownfield’ ipso facto means they can’t be green belt.
•
Point J) should be qualified ‘engineering operations’ could be used to cover all
manner of other developments that don’t fall within any other category.
•
Part I & j) these can have a very significant detrimental effect so there should be
wording about restraints.
•
Over the past 30 years, Belper has expanded to pull in many of its surrounding
villages (Broadholme, Milford, and Openwoodgate) and would urge that those which
remain separate from the town by green spaces are kept so, namely Bargate,
Blackbrook, Farnah Green, Heage and Holbrook.
•
Green Belts check the unrestricted sprawl of large built-up areas and assist in
safeguarding the countryside from encroachment.
•
This policy also requires additional wording to accommodate the needs of villages
washed over by Green Belt, such as Holbrook. The final paragraph of SS10 also
needs adjusting to accommodate such local village growth.
•
The first section of this is basically a summary of points from the NPPF.
•
The first sentence of SS10 should state, ‘Within the designated Green Belt, planning
permission will only be granted where exceptional circumstances can be
demonstrated, and where the development falls in one or more of the appropriate
categories listed below’.
•
Poor farmland should be considered before good – e.g. poor quality land that has
been outcropped and not drained properly.
17
•
Too much emphasis on Green Belt. If the site is ideal apart from Green Belt issues,
why not use it? Green Belt land not fit for farming is a constant headache plagued by
motorbikes, dog walkers and vandals.
•
A policy of little substance given the excessive erosion of the Green Belt in Ripley
and Codnor.
•
Weak policy – purports to protect the Green Belt, but indicates circumstances where
some may be lost as with the new link road.
•
Policy SS10 has far too many reasons for granting appropriate development and
because of this weakens the protection Green Belt land is afforded.
Response
Some of the wording of this policy cannot be changed, as this would not be in accordance
with the NPPF. It is not agreed that the policy should allow more development in villages
washed over by the Green Belt.
The policy has been changed to state that:
‘Within the designated Green Belt, planning permission will only be granted where
exceptional circumstances can be demonstrated, and where the development falls in one or
more of the categories for appropriate development, as follows’
Comments on Policy SS11: Amendments to the Green Belt
•
There should be a strategic review of the Green Belt across neighbouring LPA areas
under the Duty to Co-operate to see if a more sustainable approach of
accommodating future growth exists. This was proposed by the EMRP (which is still
a material consideration).
•
There should be no changes to the Green Belt until all brownfield sites have been
developed.
•
The arguments used to justify the amendments are totally flawed with no recognition
of the objections shown by the independent survey carried out by the Ripley &
Heanor News and other petitions and letters totally objecting to the desecration of our
Green Belt
•
There is no justifiable reason to change the Green Belt boundary at this time around
Heanor as there is sufficient and more appropriate development land available within
the town boundary which will support and encourage economic growth.
•
In principle against identifying green belt land
18
•
Strongly object to the amendment – Development of another large supermarket that
the town doesn’t need is leading the need to push for housing and the road line to be
moved to the north into open countryside and the green belt. It will be visually
intrusive, spoiling the landscape of the area and the openness of the countryside.
•
No Green Belt review is indicated for Amber Valley.
•
The integrity of the Green Belt must be maintained, housing developments designed
to fund a contentious road – also proposed for the Green Belt – not acceptable.
•
Green Belt boundaries should not be altered only in exceptional circumstances, and
in my opinion Amber Valley have not demonstrated that exceptional circumstances
apply in these cases to warrant moving the green belt boundary.
•
The suggested amendments to the green belt as indicated are not justifiable in
accordance with paragraph 85 of the NPP; this is clearly shown in figure 11.
•
‘The A610 link road and a former railway line will provide a clear defensible boundary
for the Green Belt, in accordance with paragraph 85 of the NPPF’. This is a
misinterpretation of the NPPF. The proposed altered boundary of the green belt to
the east of Codnor has not been defined by ‘using physical features that are readily
recognisable and likely to be permanent’, it has in fact assumed an artificial boundary
first, the proposed link road, the defined that as the boundary; there are clearly no
‘physical features that are readily recognisable’ where this boundary is proposed
now.
•
Paragraph 3 says ‘Paragraph 90 of the NPPF refers to local transport infrastructure
as a form of development that is not inappropriate in the Green Belt, provided it
preserves the openness of the Green Belt’. This may well be the case but had the
link road not been deliberately routed to include within it the redesigned areas of
housing and commercial development, but as it does it certainly doesn’t protect the
openness of the green belt; as such your next paragraph and bullet points therefore
do not apply.
•
There is no need for the land to be redesigned, the housing need in this part of
Amber Valley has been exaggerated out of all proportion. The need for a link road to
say the least is spurious, being supported mainly by those who seek to gain from its
construction.
•
Old open-cast barren farmland should be considered as recommended by the
Government.
•
No change to boundaries without consulting the owners/public.
•
Insufficient attention has been given to the identification of brownfield sites as
alternative areas of housing, including underused and semi-derelict industrial estates.
19
•
The creation of the ‘relief road’ is being used as justification for building houses on
Green Belt land east of Alfreton Road when in truth it is only there to serve those
houses and will not act as a proper bypass for Codnor.
•
The link road is not a priority, therefore not a good reason to allow the release of the
Green Belt to the east of Codnor.
•
AVBC has not demonstrated that exceptional circumstances exist to allow alteration
of the Green Belt boundaries for sites SG2 and SG7. A long standing commitment to
deliver the A610 Codnor Bypass does not constitute ‘exceptional circumstances.’
•
No evidence AVBC has carried out a strategic review of the Green Belt using a
methodology for prioritising different parts of the Green Belt in terms of the degree to
which they fulfil the 5 purposes of the Green Belt.
•
Most are not necessary. The genuine housing need provision can be met without
taking further Green Belt land.
•
Is the new link road and housing really necessary? Amounts to urban sprawl.
•
Even a reduction of 0.5% in the Green Belt is too much as this important protected
land will not be replaced.
Response
A key component of the Spatial Strategy is the protection of the Green Belt. However, it is
proposed to delete land from the Green Belt at Ripley and Codnor, in conjunction with
proposals for mixed use development and the provision of a new A610 link road between
Ripley and Woodlinkin. There is a longstanding commitment by both the Borough and
Derbyshire County Council to securing the completion of a new A610 link road between
Ripley and Woodlinkin. The provision of this new link road will not only relieve traffic
congestion on the current A610 route, but will also improve the east-west link between the
A6/A38 and the M1 through the Borough, enabling the provision of new housing
development and the development of high quality employment land, which will help to
improve the local economy. Unlike other potential strategic sites in the Green Belt that were
not previously selected as preferred sites, the allocation of these sites would also not lead to
any coalescence of settlements, as there are no nearby settlements.
It is not considered that a review of the Green Belt boundaries is required, as the Spatial
Strategy is to only allocate land in the Green Belt for development where exceptional
circumstances can be demonstrated. Although a Green Belt Review was carried out by the
Derby HMA authorities for those areas adjacent to the built up area of Derby, it is not
considered necessary to carry out such a review as such for the rest of the Borough. When a
comprehensive review of all potential strategic sites took place, those that were located in
the Green Belt where no exceptional circumstances could be demonstrated were not
selected as preferred sites, as they would involve a significant reduction in the distance from
nearby settlements and the new boundaries created would not be permanent in the long
term and capable of enduring beyond the plan period.
20
It is accepted that the proposed amendments to the Green Belt boundaries do not have clear
defensible boundaries at present, but these amendments will not be made unless the new
alignment of the A610 is implemented that will provide such a boundary. The NPPF does not
require such boundaries to be natural. However, the background text referring to local
transport infrastructure as a form of development that is not inappropriate in the Green Belt
has been take out of the background text to this policy.
There are no proposed changes to the Green Belt at Heanor.
Comments on Policy SS12: Countryside
•
We need to retain as much countryside as possible for the use of everyone
•
•
There is no mention of the policy of allowing houses of “exceptional design quality” to
be built in the countryside. Is this policy still in effect?
•
It is essential that any new buildings in the more rural areas of Amber Valley are
adjacent to existing buildings and in similar style and scale.
•
A definition of what is meant by ‘essential in conjunction with the requirements of
agriculture’ and ‘is necessary within the countryside’ would be helpful.
•
Careful control needs to be exercised over development proposals outside the built
framework of settlements, which will maintain the openness of the countryside, whilst
recognising the need to accommodate development which is necessary to sustain
the rural economy, or which is otherwise essential within a countryside location.
•
The NPPF reinforces the need to retain the saved EN11 Agricultural Development
policy in this section of the plan. Need to include – any proposed buildings in the
countryside are located within or adjacent to existing buildings to minimise visual
impact. – Support this policy but need to include an additional point to ‘retain the
openness of the countryside and minimise the impact of visual amenity’.
•
Concerns about the method of monitoring as this monitoring tool is extremely
negative and the damage will have been done which cannot the be rectified.
•
Should be a relevant SPD with criteria against which to check/assess the
appropriateness of an application to the policy before an application is approved and
it may then also be used for monitoring.
•
It is all very well to quote the NPPF in regards to the countryside but this core
strategy does little if nothing to promote and enhancement of it whatsoever, in fact in
this section it seeks to reinforce the council’s ability to grant planning within the
countryside.
21
•
Generally support but could policy EN11 of the Local Plan be incorporated into
SS12?
•
Definition of the words ‘essential’ and ‘necessary’ would be useful.
•
(a) even if development is essential a balance has to be struck to maintain the
attractiveness of the countryside and other interests e.g. for tourism, bio-diversity,
and environmental concerns. (b) No development is absolutely necessary. This must
be a balance between gains for an individual and a loss for the whole community.
•
Under the previous Local Plan this policy was EN1 and as this policy was used in
conjunction with EN5, which protected Open Land between Alfreton, Somercotes and
Swanwick and because EN5 was not a standalone policy, this weakened the
protection
afforded
to
this
Open
Land
over
many
years.
SERIOUS consideration now needs to be given to a policy in the Local Plan (Part 2)
regarding the protection of the field to the north and to the field to the south of the
proposed Crematorium/Burial Ground, to prevent expansion, which will inevitably
come in the future and prevent any other development coming forward in the future.
This standalone policy needs to be unambiguous and categorical in its nature.
Response
The NPPF refers to special circumstances for development in the countryside, but it is not
considered necessary to refer to this in this policy. The policy has been amended by adding:
“All forms of development in the countryside will be required to be of an appropriate scale or
character and to not have a significant adverse impact on the character of the locality and is,
where possible, located within or adjacent to existing buildings to retain the openness of the
countryside and minimise visual impact.
Development will also be required to comply with the criteria set out in policies E2, E3, E4
and where applicable, E5”
Comments on Policy SS13: Presumption in Favour of Sustainable Development
•
You have not shown a convincing argument of sustainability for the majority of sites
selected for growth.
•
‘Where there are no policies relevant to the application’ seems to be a green light in
favour of development. This paragraph needs to be much tighter.
•
Request that AVBC ensure that it includes sufficient clauses within this section and
policy to ensure that compliance with all the requirements of the Local Plan are
mandatory, prior to allowing development to proceed per this clause and policy.
•
Plan should meet objectively assessed needs; these should be published and up to
date.
22
•
The section is totally meaningless, objectives are laudable but languages translate
into often unhappy development.
•
‘Sustainable development’ challenges definition, not readily corresponding to reality.
•
I suggest the following is added to Line 1 of para 1: “When considering…..
….National Planning Policy Framework, provided the application is in accordance
with the policies of this Local Plan.”
•
Fine in principle but you need to develop a more robust test of sustainability than has
been demonstrated in your reports to the Planning Board in the last 3 years.
•
Concerned at “where there are no policies relevant to the application or relevant
policies are out of date at the time of decision making”. Surely until the emerging plan
is adopted the existing Local Plan policies will apply.
•
The community affected by any development must not be disadvantaged in order to
secure the gain for an individual/development company.
Response
This policy wording has been suggested by the Planning Inspectorate and should not
therefore be changed. However, the words “provided the application is in accordance with
the policies of this Local Plan” have been added to the policy as suggested.
Comments on Policy SG1: Outseats Farm, Alfreton
•
A £15,000 traffic survey proved this site to be unsustainable.
•
The combined impact of the development of this site and the site at Eachwells Lane
will create severe traffic congestion
•
Is on a scale disproportionate to the existing settlement – local housing needs are not
on this scale and local need for social or ‘affordable’ housing seems unlikely to be
met by developers.
•
Inevitable that it will place heavy demands on already overstretched community
services.
•
Potential problems of traffic congestion need to be addressed.
•
Local public open space will be significantly reduced.
23
•
Is a gross of over exaggeration of housing needs in Amber Valley particularly in the
areas around Alfreton, Ripley, Codnor, Heanor and Denby – these areas are being
unfairly burdened with the proposed housing development.
• This area of development should not be included in the Core Strategy.
Response
This site now has outline planning permission. However, the policy has been amended by
adding criteria to address the concerns that have been raised.
Comments on Policy SG2: Alfreton Road, Codnor
•
Codnor is not a market town.
•
Belper is a more suitable location
•
Flooding problems would be created
•
Development would result in neat sewage entering the local water course
•
The argument is flawed and the infrastructure will not support this level of housing.
•
Codnor needs a by-pass not a link road, so reference to the A610 needs to state this.
•
Use of Green Belt not acceptable.
•
Community identity is likely to be submerged by the weight of proposed housing
developments in Codnor.
•
The proposed development relates to the provision of a major road rather than
meeting housing needs.
•
Main justification for using this site appears to be that the development of the site for
housing would deliver the A610 link road is not acceptable and is considered a low
priority in the Derbyshire Local Transport Plan.
•
Green Belt is supposed to be protected by the NPPF and confirmed by the Planning
Minister Nick Bowles so why is this site still being considered.
•
•
This area of proposed re-designation of green belt is only possible because of the
misinterpretation in the strategy of the intentions in the NPPF.
24
•
The development will separate Codnor from its castle.
•
The land has historical significance as it is part of the once larger Codnor Common
owned by the illegitimate son of William the Conqueror and should not be covered by
a housing estate.
•
Old mine workings may lead to subsidence problems.
•
How will the spring, the source of the watercourse be accommodated?
•
This site may be able to contribute to the delivery of a new A610 link road, but there
are far too many houses in a small area.
•
The huge influx of people due to the new housing development would only add to the
problem of traffic congestion as there would be more cars in use. Public transport
links are poor so new residents would be heavily reliant on cars.
•
The building of 600 houses on Green Belt land will merge communities and is
contrary to NPPF policy.
Completely out of scale with the existing area.
•
•
The inclusion of this site is a political aspiration. All the sites selected are in the
Labour controlled wards.
•
An exit poll of attendees at the consultation of the Draft Core Strategy in Codnor in
October 2012 showed 87% against the development of this site. 91% of
representations to the Draft Core Strategy in December 2012 were against
development of this site. A petition of 1,091 signatures opposing development of this
site was presented to AVBC by STOP 500 Residents Group.
•
Failure to acknowledge well used public ROW across SG2.
•
There will not be the demand for this scale of new housing as there are not enough
people who want to live in the Ripley/Codnor/Waingroves area.
•
The residents are extremely proud of their doomsday village heritage and identity.
The Green Belt land to the east of the village forms part of the Codnor Castle ancient
deer park.
Response
The reasons for amending the Green Belt in this location have already been explained in the
response to the comments on policy SS11. However, this policy has been amended by
25
Comments on Policy SG3: Land North of Denby
•
This is possibly the most contaminated plot in the UK
•
The run-off from this site will end up in the Bottle Brook which will in turn flood Kilburn
and Denby
•
As a site identified to provide a significant amount of housing - roughly in favour.
•
Remediation of contaminated land is to be welcomes as is the provision of
employment land, schools and community facilities.
•
No reference made to nature conservation and this could be included.
•
Uneasy about the impact on Belper
•
Understand that the latest proposal to alleviate Lower Kilburn traffic increase from
development is to replace the toll bar lights with an island instead. If so this new
traffic island will need part time traffic lights at peak times. Not sure that traffic lights
will be required off the A38 at Coxbench, as they will just back-up the traffic
dangerously onto the dual-carriageway.
•
Brickyard Lane should not be used as a secondary link road to Rawson
Green/Northfield and Belper Road A609.
•
Protection should be made to ensure flooding does not happen.
•
No Green belt land should be used.
•
Should exclude land to the north of the bridle way leading from the occupation bridge
across the A38 (including the bridle way itself).
•
Need to ensure there is good frequent public transport between this site once
developed and Belper to avoid necessity to use of car. (There is good connection
between Ripley and Derby).
•
Too large a development without A38 link road.
•
26
•
•
Supportive of housing development, particularly the Phase 1 application for
approximately 120-170 dwellings. However, the scale of the site is excessive and I
am concerned about the impact on landscape and wildlife in the nearby woods and
nature reserve. Need assurances on how these will be protected from impact.
Concerned that Denby, Marehay, Kilburn and Belper will merge.
•
Proposed changes to roads must not be detrimental to historic and village character.
•
Concerned that new shopping will threaten existing businesses that are already
struggling.
•
Consider a larger play area and public open space.
•
Past agreement between AVBC and local residents on remediation of the tar pits and
the use of the A38 to serve the development (not the B6179 and A609) must not be
reneged on.
•
Severe mining subsidence in the area must be taken into account.
•
Need Green Infrastructure to retain identity of semi-rural area.
•
No development should commence until the new A38 link road is in place.
•
Development traffic must not use Brickyard Lane so as to avoid contamination from
tar pit waste on lorry wheels.
•
New health facilities required for the development.
•
Impact on police, fire, ambulance, clergy and education services must be mitigated.
•
Capping the tar pits will not work and 20 years later the new residents will have died
from cancer.
•
Good to use brownfield land and remediate the tar pits, but the proposal is for too
many homes.
•
AVBC should consider allocating a larger number of houses here in order to protect
the Green Belt at sites SG2 and SG7. This would be the most sustainable place in
which to alter the Green Belt boundary to meet housing requirements.
Response
The allocation does not involve ant land within the Green Belt.
The policy has been amended by adding criteria to address the concerns that have been
raised.
27
Comments on Policy SG4: Newlands/Taylors Lane
•
Happy that some of the housing will be on a former brownfield site.
•
Newlands – Great care should be taken to protect the land and wildlife adjoining
Bailey Brook and retain the green space and various habitats in the area (north and
south of the brook)
•
Taylor Lane – appears to have potential for development and even better if money
could be made available to improve the recreational area around Loscoe dam.
•
Housing allocation in the Heanor area is considered to be very high and suggest it is
reduced if possible and the area has limited facilities.
•
Will lead to the merging of settlements in Heanor, Loscoe and Langley Mill. Taylor
Lane should be employment land.
•
It is not made clear whether the sites are Greenfield or Green Belt.
•
Development which supports regeneration of Heanor town centre would be positive.
•
•
Good land should not be used if there is an alternative.
•
Already an over-developed area which will cause traffic congestion.
•
How can this site have the potential to provide employment and services when there
are all the empty shops in Heanor?
•
In a floodplain with serious traffic congestion issues.
•
The site is in close vicinity to Codnor and Waingroves and new residents will
undoubtedly use the current road system through Waingroves and Codnor to obtain
access to Ripley, Derby the Peak District and the M1.
Response
The policy has been amended by adding criteria to address the concerns that have been
raised.
28
Comments on Policy SG5: Radbourne Lane, Mackworth
•
The proximity of the site at Radbourne Lane, Mackworth, to Derby is a positive factor.
The adoption of a huge tract of countryside is a negative one.
Response
The site now has full planning permission. However, the policy has been amended by adding
criteria to address the concerns that have been raised.
Comments on Policy SG6: Coppice Farm, Ripley
•
This is important agricultural land
•
Waingroves village will be destroyed
•
Development will involve excessive traffic movements on to roads that are already
congested
•
Run off from the site will create flooding problems
•
Neat sewage already runs into Bottle Book and the problem will be made worse by
the development of this site
•
Again green open space site is being developed prior to brownfield sites being used.
•
The infrastructure does not support this development
•
It is regrettable that productive farm land is designated for building and employment.
•
Development will complete the built-up area of Waingroves and lead to the merging
of communities.
•
There should be more provision for affordable housing on this scheme, in the region
of 20-30% below this figure is unacceptable.
•
•
Area has a long time history of being used by local people for recreation and I heard
that all the local community are against so this proposal seems to particularly fly in
the face of the NPPF.
•
Loss of agricultural land at Coppice Farm is unacceptable.
29
•
Steam Mill Lane already suffers with congestion.
•
There will be problems with surface water run-off for new residents at the bottom of
the hill. Run-off already creates flooding. Proposed SUDS by Peveril Homes will
simply flood all over the public walkways.
•
Access road into the proposed development is regularly gridlocked and near to the
local primary school.
•
Object to this site being included in the Core Strategy. Planning permission for 98
homes granted on appeal has been obtained for a site on the Codnor/Waingroves
boundary. This site is accessed from Waingroves Road which is already gridlocked
with traffic before any new build commences. A further 79 homes on that site are
awaiting a second planning application appeal (Codnor/Waingroves site).
•
This is an appropriate area on which to provide housing as it would genuinely fit into
the surrounding development and would include an element of previously developed
land. As with all the other housing developments in the area it should be serviced by
the prior development of an improved highway system and not built before.
•
Response
The site now has outline planning permission. However, the policy has been amended by
Comments on Policy SG7: Nottingham Road, Ripley
•
Not required especially the new supermarket as the AVBC and other surveys on
retail have demonstrated.
•
New supermarket will kill Ripley and don’t need a new one –see retail study.
•
It is a nice way to see Ripley for the first time.
•
No compelling reason for building in the Green Belt.
•
Green Belt is supposed to be protected by the NPPF and confirmed by the Planning
Minister Nick Bowles so why is this site still being considered.
•
Main justification for using this site appears to be that the development of the site for
housing and a supermarket would deliver the A610 link road is not acceptable and is
considered a low priority in the Derbyshire Local Transport Plan.
30
•
Application in for proposed Morrison’s and has been subject to very strong objections
and is clear that this proposal is in clear breach of AVBC’s own policy as well as the
Local Plan and the NPPF.
•
No mention of your own Retail Study commissioned by yourselves which clearly
states that no further supermarkets are required in Amber Valley, let alone Ripley.
Furthermore, the Ripley Masterplan prepared by AVBC with external advisors also
states, that they too clearly reject any out of town development.
•
•
The play area is a good idea.
•
Morrison’s is not a good idea. There have been two independent surveys saying this
supermarket is not needed within 100 yards of another supermarket. It will take jobs
away from the town centre and Sainsbury’s.
•
May be able to contribute to the delivery of the A610 link road.
•
Retail studies concerning the need for a Morrison’s supermarket opposite the existing
Sainsbury’s are contradictory; the study commissioned by AVBC in 2011 suggested
there was no requirement for such a store. There is fear that the store will remove
business from the town and threaten the existence of the town’s anchor trader, the
Co-op.
•
Retail need has not been demonstrated and an assessment of the impact of the new
supermarket on the vitality of Ripley town centre has not been carried out, as the
NPPF requires.
•
There are 9 supermarkets within a 5 mile radius of Ripley and this does not include
mini-markets. The building of out of town shopping centres is contrary to present
government policy.
•
Object to this site being included in the Core Strategy.
•
Out of scale, but the northern side of the road would be a logical location for some
development.
•
Ripley and Heanor News conducted an online poll which showed 77% did not want
the supermarket development. A petition was presented to AVBC by the ex-Mayor of
Ripley with 2,600 signatures against building the supermarket.
31
•
The retail study carried out by Tym and Partner in 2011 revealed there is no need for
a new supermarket in the Borough until 2028 and then the store would most likely
serve Alfreton.
•
•
The plans being described by AVBC as the new sports-hub masterplan are not those
submitted for determination by the Planning Board.
•
AVBC prepared a Ripley Masterplan that rejects out-of-town-centre development.
The basis and outcomes of the applicant’s Retail Study have been challenged by the
town’s anchor trader, the Co-op, which could not absorb an estimated 17.5% loss of
revenue.
Response
The reasons for amending the Green Belt in this location have already been explained in the
response to the comments on policy SS11. However, this policy has been amended by
Comments on Policy H1: Housing Type, Mix and Choice
•
Need more affordable/social housing
•
Specific note should be made about not allowing the ‘larger’ 3 storey housing near
existing houses. Has happened too much in recent years were large houses have
been built inappropriately close to existing dwellings.
•
Should be a ‘buffer’ of green space between new housing & existing housing.
•
Housing provision which reflects demographic change is to be welcomed.
•
A good mix of tenure and house types.
Response
No changes to the policy are necessary in response to these comments.
Comments on Policy H2: Housing for Elderly or Disabled People
•
More emphasis should be placed upon the provision of this type of housing
32
•
Housing for elderly and disabled people is also timely but marooning these residents
in very large housing developments with few shops and an infrequent bus service is
likely to lead to social isolation. There must be awareness of people’s needs.
•
This type of housing should be a priority.
Response
No changes to the policy are necessary in response to these comments.
Comments on Policy H3: Affordable Housing
•
Need more affordable/social housing
•
A greater proportion of affordable housing should be included in each site
•
Despite the Derby HMA SHMA identifying a need for 61% of new housing to be
affordable AVBC states ‘a more realistic 30% be an expected provision’. The reasons
for this are not adequately explained.
•
Affordable housing should remain ‘as long as a need exits’. How is this going to be
monitored/assessed?
•
Developers now state that they are unable to provide the percentage of affordable
housing previously suggested. Legal precedents indicate that local authorities must
accept this – in any case, housing developments in Amber Valley must not become a
dumping ground for socially problematic people.
•
Young people should be able to get on to the property ladder.
•
Bending to the pressure of the development industry if 30% is realistic but 61% is
needed.
Response
This policy reflects the existing policy in the Local Plan. The development industry alone can
never meet the full needs for affordable housing and a balance has to be struck between
ensuring that as much affordable housing as possible is secured but at the same time not
having a target which is too onerous and would mean that housing developers will look
elsewhere to provide market and affordable housing. Experience has shown that requiring
more than 30% affordable housing would usually render schemes unviable and/or mean that
other requirements such as developer contributions to improving educational facilities could
not be obtained.
33
Comments on Policy H4: Viability of Proposed Housing Sites
•
Houses that have already been approved are not being built and appears that
developers are just saving up land for more profit.
•
This Core Strategy Plan is looking to 2028, some provision must be made for an
improvement in the economic situation over that period and expect developers to
provide low cost housing.
•
If the economic situation has not improved by 2028 there will be a huge need for low
cost housing.
•
Developers might be reluctant to build in a difficult economic climate. Equally,
Council taxpayers must not be expected to shoulder additional financial burdens for
development which many view as unnecessary or undesirable, particularly when they
are struggling to cope with their own financial difficulties.
•
Long overdue. This test has not been applied sufficiently to many of the current sites
with extant permissions.
Response
It is not considered that these comments require any changes to the policy.
Comments on Policy R1: Reducing the Use of Non Renewable Energy Resources
•
With reference to the ‘costly amendments’ to the Building Regulations ‘to achieve
zero carbon development’ can it be specified which of these amendments are
expensive and which can be incorporated at little cost? Also important to consider
cost to community (both financial and environmental) if regulations are compromised
to safeguard developers’ profits.
•
Climate change does not wait for economic recovery (and allegedly the country is
already on the road to recovery). And what if the economy does not recover? Do we
continue to compromise? There is also a danger that developers will rush in their
planning applications before the deadlines of 2016 and 2019. There also needs to be
consideration of the long term cost to the community and the environment.
•
The exceptions to achieving Good standards are too vague.
•
•
Disagree with c) and f) delaying until 2016.
•
H) - is vague. If surrounding environment is already dense, does that mean that new
development is to be equally dense or less dense (to balance out)?
34
•
I) - Please add making use of solar panels if appropriate
•
J) - Also consider need to ensure ventilation during heat waves/sunny conditions (so
avoiding need for air conditioning/fans).
•
The paragraph beginning ‘if it is considered that meeting criteria a) c) or f) ….. render
a scheme unviable ….’ Please define ‘unviable’ – is this related to cost or feasibility
with present technology?
•
Amber Valley needs to campaign to increase recycling and composting rates and
make people aware of programmes in place.
•
This should read ‘In considering development proposals, the Borough Council will
require that Development and the Design of, has regards to: e) re-using previously
developed land and existing buildings within settlements in preference to developing
greenfield sites’.
•
Support this policy.
Response
It is not considered that any of these comments require any amendments to be made to the
policy.
Comments on Policy R2: Renewable Energy Installations
•
Wind power – concerned that Local Plan is over – zealous in its quoting of ministerial
announcements. 1) The government will change between now and 2028. 2)
Windpower technology will improve. 3) Climate Change marches on and will be
accelerated further by backing off from viable renewable energy sources. 4) There
needs to be room for manoeuvre in the Local Plan to respond to changing
environment/climate in a proactive way.
•
How can you argue that ‘environmental protections’ override the need for renewable
energy, insofar that use of non-renewables will damage the environment in the long
term.
•
What are the guidelines on numbers of wind turbines? Noise etc? This is very vague
(needs cross-referencing)
•
See wind farms as a way forward
•
The visual impact of wind turbines and large scale panel installations in particular can
cause large detrimental impact.
35
•
D) Significant is very vague & given the presumption in favour of ‘sustainable’
development is not likely to have much weight, therefore this in particular could be
strengthened.
•
Think there needs to be a section on Non-Renewable Energy (fossil fuel) and a
Policy R3 giving planning guidelines/restrictions.
•
How do you define ‘significant detrimental impact on local landscape’?
•
Under point h) ‘deemed to be acceptable’ - this policy wording must ensure that the
land will return to original land use and condition, or better and not lower of standard
of land than was there originally.
•
Renewable energy in development: in Amber Valley sources of renewable energy
must be carefully sited. The eastern half of the Borough is to be increasingly built up
if the proposed housing developments are carried out. Wind farms are not only
visually and noisy, they are inefficient; Solar Panels are also visually intrusive.
Biomass which relies on tree growth is dependent on slower replenishment of fuel
than the rate of utilisation. Nevertheless, energy efficiency throughout the Borough is
to be welcomed.
•
Support this but would add – All schemes , whether within agreed areas or
elsewhere, should be judges on their own merits using established objective criteria
to assess impact, e.g. existing regulations, industry standards and best practice.
•
h) Should be changed to more appropriate wording to ensure the site would be
returned to its original state or better.
•
Valuable landscapes outside the WHS need equal consideration.
Response
The criteria and requirements of this policy and the background text have been amended to
address these concerns.
Comments on Policy E1: Managing Flood Risk
•
Houses should not be built on flood plains.
•
Could specific points be made e.g. encourage ‘green roofs’, planting of native
trees/bushes within a development to reduce runoff / flood risk.
•
This policy is endorsed – Amber Valley must take into account concerns raised in
relation to potential flooding in the area between Marehay and Kilburn where much
housing development is projected. The Environment Agency has previously raised
such concerns.
36
Response
The policy has been amended to refer to the potential of ‘green roofs’ and the planting of
native trees/bushes within a development to reduce runoff/flood risk.
Comments on Policy E2: Quality and Design of Development
•
Could ‘adequate’ be a more realistic, central bin bank for multiple households?
Support this policy but need to ensure it can be delivered.
•
a, b and c are of major importance but objective standards need defining.
•
Question how robust the policies would be in guarding against poor standard
developments e.g. Asda, Langley Mill/ Tesco, Heanor/Malik Way, Heanor. If a
supermarket wanted to build in Langley Mill again, would the Council consider that a
standard ASDA would meet design policy aspirations? The policy should make
reference to and encourage the use of standard floorplates and patterns where they
suit the characteristics of the site and where the external form and appearance can
be tailored to suit the characteristics of the site and/or the wider locality.
Supermarkets will respond to this positively but only where there are clear policies
promoting such an approach. Based on the draft E2 policy, I would understand that
such a scheme would not accord with the aspirations of this design policy – however
I cannot see how this policy would guard against this type of development that fails
to:
-
define
spaces
(instead
being
set
back
behind
a
car
park).
- offer direct, convenient and attractive pedestrian connectivity (try walking from
ASDA entrance to the Bus stop heading to Heanor via the most direct route, rather
than the indirect route and the problems here will become clear).
- offer a sense of character or at least give a hint that it is located in Amber Valley.
The scale of such buildings does not lend themselves to vernacular styles and
materials and therefore the reference to local styles and materials within the policy
would not necessarily achieve a good design solution when faced with a supermarket
proposal at some point in the future.
•
There is a subtle but important distinction between high quality and good design. An
example of policy wording could be “As a minimum the Council requires all
developments to meet a good standard of design, with high quality design promoted
particularly in strategic and/or prominent sites and locations.” This would then be
consistent with the NPPF that requires ‘good design.
37
•
Reference is made to Homes for Life in the background notes. I believe this should
refer to Buildings for Life. I would suggest that with respect to the reference to
Building for Life, a direct policy commitment is made to the effect of, "the council will
expect residential developments to achieve 12 green indicators against Building for
Life. Schemes that secure one or more red indicators will not be supported. The
council strongly encourages applicants to use Building for Life as a basis for Preapplication discussions and as a method of structuring dialogue with the local
community and other stakeholders".
•
Policy E2(d) should include space for adequate waste storage.
•
Sufficient parking provision must be sensitively integrated.
•
Policy E2(h) does not appear to have any relevance to urban design practice with
respect to the reference made to CCTV. Best practice would suggest that CCTV is
unnecessary if places benefit from, for example, clearly defined public and private
spaces, well lit and well-surveilled public, private and semi-private spaces, the
formation or completion of perimeter blocks. The reference to CCTV has no
relevance to quality design.
•
There is a lack of emphasis on key principles of urban design in the policy, such as:
- well-defined and well-managed public spaces;
- spatial definition. i.e. the spatial enclosure of spaces to create well-defined streets
and spaces.
- connectivity, prioritising the need for direct, safe and attractive pedestrian and
cycling routes (to encourage reduced use of cars, particularly for shorter journeys).
- a local or otherwise distinctive sense of character.
•
Support this policy but need to ensure it is delivered.
•
A) – concerned with the word ‘scale’ (needs better definition here and elsewhere in
the Local Plan, as developer could justify building something as high and broad as
East Mill, on grounds that is the same scale).
•
B) – This may need improvements in public transport (routes, times and frequency) –
so could perhaps mention.
•
C) – ‘Landscaping’ could be defied more clearly – e.g. using native species, to
enhance biodiversity, reduce flood risk.
•
D) – Agree, again specify what is meant by ‘adequate’ here (safe play areas for
children?) Sitting areas? Communal gardens? ) Is there a policy defining area of
amenity space per number of houses? (Over and above parking space).
38
•
F) – What if local surroundings are awful (e.g. concrete slabs and corrugated iron
roofs or nearby industrial sites)? Need wording to prevent justification of more of the
same ugliness.
•
G) – Agree, will these protected open land areas in Part 2 of the Local Plan?
•
I) – Please leave out phrase ‘where appropriate’ as this doesn’t mean anything in this
context (public transport, even when quite good, can always be improved further).
•
J) – need to encourage free parking ( for 2 hours?) within town centres and
reasonably priced day parking to encourage tourists (especially Belper!) and park
and rise season tickets to encourage commuters to use trains/buses.
•
N) How? Have a park and ride system?
•
O) – Could mention water conservation schemes, installation of water butts,
encouraging obtaining energy from communal anaerobic digesters (which safeguards
land resource).
•
The last paragraph of this policy is vague and ambiguous - is it encouraging high
density in a high density area? (or the opposite) think there should be some idea of
need for balance in the paragraph.
•
Really needs to be enforced and not become just a ‘wish list’
•
Seems good but (m) is not applicable in the countryside and ( r ) surely a better way
of dealing with waste collection and recycling rather than providing everybody with
lots of bins. Multiple bins outside every property are ugly and intrusive and large
lorries in narrow lanes equally unsustainable.
•
Para 5 needs to be split into two paragraphs and reworded so the statement about its
positive contribution etc relates to all the aspects mentioned above not just wildlife
sites or species. Also there is a need to recognise the ‘sensitivity’ of a landscape as
well as its features and conservation interests.
•
The natural environment is vitally important: trees, woodlands, wildlife and green
spaces. Unfortunately the provision is often marginalised in relation to housing
developments. Managed open space cannot be equated with a vital open landscape.
•
The provision of footpaths and cycle lanes is welcomed.
•
Trees and woodland should be protected (and please make sure that developers
don’t accidentally fell protected trees on site).
39
•
Support this policy and in particular point a) – that development proposals are in
scale and character with their surroundings. The monitoring for this should be
prospective and not retrospective.
Response
The policy and the background text have been amended to address these concerns and to
take on board the suggestions made.
Comments on Policy E3: Historic Environment
•
Need to protect all our ancient monuments and deer parks, especially Codnor Castle
•
•
The electrification of the railway is likely to become an issue – the Policy needs to
ensure that the heritage of Belper is preserved.
•
‘Where there is evidence of deliberate neglect or of damage to a Heritage Asset…….’
– Agree but what about sites left derelict by the owners, what are the powers to
restore historic buildings on these sites?
•
Include Areas of Multiple Environmental Sensitivity (AMES)
•
This is poorly written – would be better if the text was changed to fit in with the
distinct areas of the Borough that reflect the differences in the coalfield to the east,
the Peak Fringe and Lower Derwent to the west and the Needwood and South
Derbyshire Claylands to the south west.
•
Why not create a special category for the care or protection if non-designated locally
important heritage assets?
•
Encouraged to see that at last, some cognisance has been given to different
characteristics of the west of the Borough. However this awareness does not seem to
be reflected in the ensuing Policy E3 which seems to focus purely on the built
heritage. Would like to see an addition to the policy to reflect the need to ‘continue to
conserve the local distinctiveness through…… ensuring that new development
respects the character of the locality’.
•
Support this policy – local list of non-designated heritage assets is an excellent
concept.
•
Historic environment includes landscape e.g. Ecclesbourne Valley as well as the
WHS.
40
Response
Comments on Policy E4: Landscape Character
•
Possibility to be strengthened, one of the Borough’s assets is it’s landscape
character.
•
Support this policy
•
There should be a map showing the National Character Areas and their subdivision
into Landscape character types.
•
The monitoring tool is extremely negative as the damage will have been done and
cannot be rectified. It isn’t fit for purpose.
•
‘Development proposals that will have an unacceptable impact on landscape
character, visual amenity and sensitivity will not be permitted’ what will the criteria be
for unacceptable impact?
•
There is little evidence that the Core Strategy is protecting local landscapes in the
eats of the Borough from unsympathetic development.
•
A supplementary planning document should be created to reflect Local
Neighbourhood Plans where they have been adopted would be a way forward.
•
The plan needs to fully recognise that many areas may not be of such quality to merit
national designation but their importance is very high to the local community due to
the cumulative denegration of the area by historic developments.
•
A map would be useful. Last sentence of first paragraph could read “Development
proposals that will have an unacceptable impact on landscape character, visual
amenity and sensitivity, including (or especially) in the Special Landscape Area, will
not be permitted.”
•
Monitoring tool “Development approved that detracts from the character of the
landscape’’ seems to suggest “shutting the stable door after the horse has bolted.”
•
Private gain should not be allowed to override historic character of the landscape.
Need to include old policy EN11 with regard to development within or alongside
existing historic sites.
41
Response
take on board the suggestions made. A link has been provided in the background text for
those who wish to view the Landscape Character Areas.
Comments on Policy E5: Special Landscape Area
•
Special areas of landscape significance were removed before which was a mistake
as it gave that land no protection.
•
Support this policy
•
Special Landscape Area designation has helped to preserve and enhance the very
rural (western) side of Amber Valley making it a more attractive area not only for the
residents by also an increasing number of visitors and is absolutely essential it is
retained.
•
This policy has achieved a great deal over the last 25 years but the evidence does
not seem to be cited that would support it.
•
In terms of the monitoring – who will decide this and what criteria will it be based?
This monitoring tool is extremely negative as the damage will have been done which
cannot be rectified.
•
The western part of Amber Valley is protected.
•
Hope that if in some time in the future the Government ceases to support the local
designations, Amber Valley will retain protection of this area.
•
A supplementary planning document should be created to reflect Local
Neighbourhood Plans where they have been adopted would be a way forward.
•
With special reference to Vision for Idridgehay, Alton and Ashleyhay it is essential
that this category is retained, with adequate safeguards to prevent inappropriate
development.
•
Could the words “including agricultural proposals” be added to this policy, as per the
background notes?
•
Support this policy, but lack of evidence is a worry. The La must have more than a
map to support this policy e.g. what damage has occurred in the areas just outside
the SLA?
•
Evidence for this policy needs to include evidence from the current landscape
character assessments.
42
Response
The policy has been amended to include agricultural development as an example of a
development proposal.
Comments on Policy E6: Biodiversity
•
Should be reworded “all new development should” & remove “seek to”.
•
If developments are to fully compensate for any loss of biodiversity then this needs to
be really spelled out.
•
Could you also add to the bullet list: ‘existing corridors that allow movement of wildlife
between sites’?
•
Agree with the idea of restoration and re-creation of habitats rather than just
mitigation.
•
Add Regionally Important Geological Sites and the SSSI at Mount Pleasant,
Idridgehay & Alton.
•
Practical measures to support biodiversity are welcomed – large buildings sites will of
course eliminate wildlife habitats. There is no convincing evidence that wildlife
corridors work.
•
Paragraph 12.6 Biodiversity - ‘Other areas of land are also important in providing
corridors of movement for wildlife between different habitats’ – This is a really
important point.
•
Support this policy. Pleased to see the Ecclesbourne Valley Restoration project as
key evidence.
Response
Comments on where you think a ‘Local Green Space’ should be allocated
•
Between settlements to protect each village or town with its own identity
•
Should be something in each of the areas for housing development.
•
Land to the north and south of Bailey Brook on the Newlands site.
43
•
Belper has expanded to pull in many of its surrounding villages (Broadholme, Milford,
and Openwoodgate) and would urge that those which remain separate from the town
by green spaces are kept so, namely Bargate, Blackbrook, Farnah Green, Heage
and Holbrook to retain the character of Belper and its surrounding villages.
•
There is no policy here but the final paragraph suggests something might be
forthcoming in the Site Allocations document. Surely there ought to be a short policy
statement here to cover that.
•
The designation of local green space should apply to a tract of land within or close to
a community and which has been or is well used by the community and is valued for
whatever reason. This is not big enough to support 500 houses. Ideally, it would also
act as a buffer zone between communities, e.g. between Swanwick and Alfreton.
•
Residents in Alfreton and Waingroves had all the areas they identified passed for
development.
•
Near any new estate. Young people say they have nowhere to go.
•
The remaining area at Codnor Common is long overdue for protection by this or
another designation. This would reflect the majority view of local residents and meet
their aspirations, but the delay in doing so in this Plan is leaving it vulnerable to
development which would destroy its value to the area. It needs to be done now.
•
This needs a policy statement and then Neighbourhood Plans could address this
issue.
•
A new Policy to protect the remaining two fields, one to the north and one to the
south of the proposed new Crematorium and Burial Ground on Derby Road,
Swanwick
needs
to
be
established
under
Local
Green
Space.
This could also be put into the Neighbourhood Plan, currently being produced for
Swanwick.
Response
These suggestions will be considered when the Site Allocations and Development
Management Policies DPD (part 2 of the Local Plan) is produced.
Comments on Policy IN1: Transport
•
AVBC’s commitment to the A610 Bypass pre-empts transport assessments for the
development for 600 and 560 dwellings respectively at Alfreton Road, Codnor and
Nottingham Road, Ripley as per the requirement of Policy IN1 (c).
44
•
Policies SG2 and SG7 directly conflict with Policy IN1 (e) which prioritises
sustainable transport modes, because a new road to serve a substantial housing
development will encourage more rather than less car use.
•
Proposals for the A610 relief road do not allow debate on the need for the road or
the most appropriate line of it. Consultants at exhibitions have only been willing and
able to answer technical questions.
•
Point C) – Is a lower limit allowable or could a lower limit be recommended, such as
10?
•
Point D) – Could encourage the creation of safe routes using bridleways and disused
transport routes.
•
Point I) – Not all homes are usable for extensive work from home (kids, no spare
room etc). So also encourage internet business centres and/or community rooms
within each town where people can use internet/communication systems for work
purposes to reduce need to travel to cities on daily basis.
•
There is no viable funding information available
•
Amber Valleys continued commitment to the A610 link road mentioned throughout
the plan pre-empts that transport assessments for the development for 600 dwellings
at Codnor and 560 dwellings at Ripley have been taken into account.
•
The amount of proposed development plus the proposed supermarket will cause
‘severe’ traffic congestion on the A610 as all the local traffic from Ripley, Codnor,
Waingroves, Loscoe, Heanor, Langley Mill and Ilkeston etc will carry on using the
A610 as the proposed link road will be of no use to them.
Response
A planning application for the new A610 link road has been submitted which includes
supporting evidence including a Transport Assessment that is currently being assessed. The
policy has been amended to address other concerns that have been expressed.
Comments on Policy IN2: Green Infrastructure, Parks and Open Space
•
Our parks must be enhanced especially the toilet facilities which are a disgrace.
•
No mention made throughout the strategy of the intention to improve facilities and
access for cyclists and walkers in Amber Valley.
•
Need to retain and improve facilities for horse riders
•
Our parks must be enhanced especially the toilet facilities which are a disgrace
45
•
No mention made throughout the strategy of the intention to improve facilities and
access for cyclists and walkers in Amber Valley.
•
Need to retain and improve facilities for horse riders
•
Also needs to give specific examples e.g. encouraging communal gardens and
allotments, enabling environmental educations in it’s a) to h) list.
•
Town centre shopping should be promoted over out of town facilities. Frequent and
reliable bus services must be in place to combat car dependency. The provision of
cycle lanes or footpaths would also be helpful. High speed broadband is desirable
but not necessarily available in Amber Valley.
•
Section is full of jargon that is meaningless – clarification is necessary.
Response
The policy and the background text have been amended to address these concerns and
take on board the suggestions that have been made.
Comments on Policy IN3: Community, Leisure and Health Facilities
•
Very good
•
There is a need for a community centre for young people to meet up and where
different activities and courses could be run cheaply.
Response
These comments do not require any changes to the policy.
Comments on Policy IN4: Strategic Transport Infrastructure Priorities
•
The roads cannot cope with the traffic that we have now and the proposals of 2,500
houses within a 3 mile radius of Codnor will make it even worse.
•
The commitment of DCC and AVBC has always been to a Codnor by-pass to
complete the section of the A610 from Eastwood to its junction with the A38. This is
not met by the support of a link road; the proposals need to upgrade the new section
of road to the same standard as the Ripley and Langley Mill by-passes.
•
The car will still remain the main method of transport; no amount of bus routes/cycle
ways will change that. Look at provision of better roads etc.
•
A610 impinges on ‘heritage assets’ and HER at Codnor Park and Butterley Park
46
•
The building of the A610 link road between Ripley and Codnor is an issue which
divides Amber Valley residents. It is moreover proposed for the Green Belt and its
funding is partially dependent on the building of an out of town supermarket – this is
unacceptable.
•
Traffic will move from the 60mph Ripley by-pass to a 30mph road with at least seven
exits before joining the 60mph Langley Mill by-pass. There is a grave danger that
traffic for Heanor will use the first part of the relief road and then Alfreton Road which
is unsuited for heavy traffic. As far as I’m aware there has been no transport study
examining the effects of building a ‘relief road’ of this nature rather than a full 60mph
by-pass to match those at either end of the road. In addition the ‘relief road’ will
effectively restrict access from Codnor to the land to the east, including Codnor
Castle. Unconvincing efforts have been made by the consultants employed by the
AVBC to promote the scheme to suggest ways of crossing the road, but in effect little
short of a pedestrian bridge will make it crossable. Four public footpaths cross the
route of the relief road although plans produced by the consultants have repeatedly
failed to show them.
•
In addition to building on green land currently available to the inhabitants of Codnor,
the proposals restrict their access to that land that is left.
•
Traffic congestion occurs at only peak times on the A610 around Codnor, but not
every day. This indicates that the problem is not the volume of traffic but obstructions
in Codnor which affect traffic flow. If cars were prevented from parking on the main
road at peak times, traffic would flow freely, even if a queue builds up to turn right
onto Alfreton Road. The link road would only shift bottlenecks.
•
AVBC has not carried out an up to date transport assessment for the proposed new
road.
•
There is ample evidence that bypasses usually create more traffic within a few years
of opening, e.g. the Newbury Bypass.
•
The so-called bypass is only a relief road for the proposed housing and has no
support from residents. No traffic survey has been carried out to suggest there is any
need for the road.
•
As the road will include two roundabouts traffic congestion will merely increase due
to an increase of 200% in the local population.
•
Any transport modelling study will no doubt be a retrofitting exercise.
47
Response
A planning application for the new A610 link road has been submitted which includes
supporting evidence including a Transport Assessment that is currently being assessed. The
policy and the background text have been amended to address the other concerns that have
been expressed.
Comments on Policy IN5: Infrastructure Delivery
•
Not a total picture of how the infrastructure will be delivered
•
Full information relating to costs must be provided for Amber Valley residents. There
must be transparency over financial arrangements.
•
90% of the proposed building is in the third of the Borough east of the A38 and there
are no plans to deliver the appropriate infrastructure to support the inhabitants of
these houses.
Response
The Infrastructure Delivery Plan has been updated to provide additional information on what
infrastructure will need to be provided to serve development and what the estimated cost of
this infrastructure will be.
Comments on Policy IN6: Developers Contributions
•
Not always to the benefit of the community who has the development
•
Developers should pay, rather than residents. Any development should not impact on
the existing community of Amber Valley.
•
Developers should contribute, especially on large sites. But on really small sites this
may make the project economically unviable.
Response
These comments do not require any changes to be made to the policy.
Any further comments you wish to make on the content of the plan
•
The five year supply has been incorrectly calculated.
•
Our traditional, proud and separate communities will be merged into one very
unpleasant and enormous conurbation, reducing desperately needed green space,
utilising Green Belt land rather than brownfield, and without consideration of limited
infrastructure or the quality of life of current and future residents
48
•
Transport and water infrastructure cannot cope. Water sewerage and drainage
capacity is over burdened already.
•
The highway infrastructure will not be able to accommodate the traffic being
generated. There are no figures showing the accumulation of traffic from all of the
proposed developments.
•
The majority of the sites are on Green Belt or greenfield land, contrary to the NPPF
•
Between 1,000 and 2,000 homes are standing empty
•
The preferred sites are all, with the exception of the Mackworth development, within
a 3.5 radius of the most impoverished part of the Borough.
•
Critical of the process, calculations, viability and sustainability of such large-scale
building proposals into the east side of the Borough where green space is at a
premium and where there are no plan on how to create jobs for the new residents.
•
The total process appears to be totally bias with no development in Swanwick, Belper
or Duffield.
•
Pleased that the other areas which were identified as possible housing development
sites have been excluded.
•
No Green Belt land should be used to build on.
•
To support town centre vitality, I would favour a policy that promotes housing
provision close to the town centre, including conversions of properties to housing.
•
Concerned that the final draft should contain a statement to prevent overdevelopment in the Borough.
•
Pleased to note that the strategy makes a commitment to ‘Areas and buildings of
architectural or historic interest and their settings, will be preserved and enhanced
and protected from unsympathetic development’
•
It is far too long and complicated for the majority of the population to be able to
comment on in a useful and meaningful way.
49
•
Section 6.9 – Economic Growth. The word ‘regeneration’ needs to be qualified.
Elsewhere Belper is described as having vitality, above average employment etc.
Suggest ‘regeneration and/or enhancement’ of the four market towns. Agree that we
need to ensure local people benefit from growth and supporting community based
projects, but also suggest the Local Plan specifies the type of business to be
especially encouraged (i.e. businesses which offer good quality, secure employment
opportunities for training, businesses that are sustainable and beneficial to the
community and environment, and whose profits will go back into the community).
•
A map of the whole Borough somewhere in the Core Strategy is a serious omission.
•
The NPPF makes reference to light pollution, Para25 : By encouraging good design,
planning policies and decision should limit the impact of light pollution from artificial
light on local amenity, intrinsically dark landscapes and nature conservation – What
about the south west and west of the Borough that has relatively dark skies due to
the lack of settlement and street lighting. This should be protected.
•
The NPPF makes reference to tranquillity, Para123: Planning Policies and decisions
should aim to: Identify and protect areas of tranquillity which have remained relatively
undisturbed by noise and are prized for their recreational and amenity value for this
reason. – The Borough plan mentions tranquillity in relation to Green Space, the
consideration and protection of tranquillity should be included in a separate policy
relating to development in the countryside.
•
There is a gulf between the stated objectives and the likely outcomes, between the
vision and the reality. The NPPF is fundamentally flawed and is no basis for
community development. The scale of proposed development is too large to allow
assimilation within Amber Valley.
•
Considering that such a large proportion of the Borough of Amber Valley is rural
countryside it is of concern that, in a document of 102 pages, only 242 words are
devoted to the Countryside
•
The Core Strategy is unsound because the development strategy proposed is not
justified and is not effective. This is because: 1. Alternative options to sites proposed in the Green Belt have been dismissed
without convincing reasons.
2. No strategic review or viability study of the Green Belt appears to have been
carried out
3. The reasons intended to support policies SG2 and SG7 is not acceptable in trying
to justify development proposals on specific sites in seeking to deliver a
commitment to a new road is against the wishes of the local residents.
4. The Council claims that the new road will alleviate the existing road traffic
congestion is not backed up by any evidence.
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• Strong objections have been submitted to AVBC for SG7 in the form of petitions or
the on-line poll carried out by the local newspaper which was strongly against this
proposed development, so therefore the Draft Core Strategy is not providing a fair
reflection of the local resident’s views in respect of their wishes.
• Amber Valley needs to re-think the proposed development strategy for Ripley and
Codnor as the Core Strategy is not deliverable.
• This Draft Core Strategy is only too willing to quote great chunks of the NPPF when it
suits the council’s agenda, in particular when it wishes to emphasise ‘presumption in
favour of sustainable development’.
•
Support for the re-designation of employment land that has not come forward, to be
re-designated for housing land.
•
Support for deletion of Hardy Barn, Heanor Site (AV15) – poor employment location
as satellite conurbation of Heanor does not form an employment ‘hotspot’ in Amber
Valley.
•
No plans to create jobs for all the new residents from the six large developments
•
Concerns about air quality from proposed growth.
•
Water infrastructure will not cope with the growth – residents already have raw
sewage in watercourses.
•
Already flooding problems – surface water flooding at Steam Mill Lane and Codnor
Market Place during last bad storm.
•
Proposed link road will not be able to cope with extra traffic generated in the Steam
Mill Road area.
•
All strategic sites, except Mackworth, are in the poorest parts of the Borough least
able to sustain jobs, transport or homes. Western half of the Borough has more land
available with better transport links to Derby where job prospects are better, but
growth is shoved to the east.
•
Majority of sites are on greenfield when NPPF states brownfield sites should be
prioritised. What about Butterley Engineering, Stevensons Dyers, Hanson Brick and
American Adventure?
•
Concerned about impact on schools – schools in Ripley, Codnor and Waingroves are
near capacity, but AVBC have stated that the additional demand for school places
can be accommodated without the need for any new schools.
•
Concerned about loss of agricultural land.
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•
Codnor, Waingroves, Ripley and Woodlinkin will be merged together in an urban
sprawl.
•
Belper is untouched by strategic sites when future generations might welcome a
small amount of development.
•
Empty homes need to be occupied before new development – e.g. Farm View.
•
The strategic sites are too large. Fewer large sites and more smaller ones would be
more appropriate.
•
Large schools/hospitals etc. are not always a good idea.
•
Many of the sites have too many constraints which may make them an unviable
proposition for developers; flooding, Green Belt, traffic congestion,
ownership/boundary problems, access, wildlife issues, overhead lines.
•
The views of local people have not been sufficiently taken into consideration. The
consultations that have been conducted by AVBC, its consultants and the Parish
Council have consistently shown 90% of respondents opposing the proposals.
•
The lynchpin of the AV7 and AV8 developments is the ‘relief road’ and the lynchpin of
that is the new supermarket, and the sale of land for it which we are (sometimes) told
will fund the road. Here AVBC has sold its own land for development and given
planning permission for it. It has tried to avoid conflicts of interest by employing an
officer from Bolsover, Kevin Hopkinson, as manager of the Ripley Gateway
Development, and by employing consultants DLP Design Ltd to run some
consultations.
•
If any strategic sites were not adopted within the Local Plan, please confirm that the
re-allocation would be in the order of preference as per the SA analysis: firstly rereview the ‘Good’ performing sites to try to overcome the issues/challenges; secondly
re-review the sites with ‘Moderate’ performance. In addition if the strategic site/s in
Heanor is/are not adopted I would suggest a re-allocation of employment land should
be considered to form a further strategic site, possibly adjacent to Adale Road and
Heanor Gate Industrial Estate.
•
The protection of tranquillity in Ashleyhay and Idridgehay should be included in the
local plan. In fact, planners should aim to reduce noise and advance peaceful living
in all parts of the Borough.
•
The Plan does not take account of an appropriate level of protection of the
countryside and important open areas.
52
•
The Duty to Co-operate should be used such that neighbouring Councils help meet
some of Amber Valley’s need in more sustainable locations.
•
There are no policies specifically relating to agriculture and forestry.
•
No policies relate to dark skies and light pollution (NPPF para. 125)
•
•
No policies regarding tranquillity and noise pollution (NPPF para 123)
The Draft Core Strategy does not define the ‘improved facilities and services’ which
development proposals at SG2 and SG7 are.
•
The promotion and determination by AVBC of sites SG2 and SG7 shows a clear
conflict of interest.
•
Complete lack of evidence to support a rigorous assessment of the use of brownfield
sites in preference to greenfield and particularly Green Belt sites.
•
It is very difficult to respond to this questionnaire. The overall plan is weighted
towards the urban areas of AVBC, although these take up less of the area. Nothing is
mentioned that will encourage tourism in the area. More tourists in AV will take
pressure off the more ‘honey pot’ areas in the Peak District.
•
The weight of public opposition against the proposed housing, road and supermarket
associated SG2, SG6 and SG7 is immense.
Response
The relevant policies and background text have been amended, where it was considered
that the concerns are valid and should be addressed. A key diagram showing the whole of
the Borough has been added to the document.
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4.
Comments from Parish/Town Councils
Comments on the Spatial Portrait
Horsley Parish Council: The proposal for focused development in local centres is
supported.
Comments on the Spatial Vision
Horsley Parish Council: The PC is totally supportive of the proposals to protect the Green
Belt.
Horsley Parish Council: The PC supports the proposals but are wary of the proposals to
develop ‘rural villages’. Providing that this policy is measured against ‘economic, social and
environmental conditions in the area’ rather than allowing opportunist gain, the PC is
supportive.
Response
These comments do not require any changes to be made to the Spatial Portrait, the Spatial
Vision or the Spatial Strategy.
Ripley Town Council: there are major contradictions re sustainability of developments, with
sites dependent on the car. No relationship of housing developments to employment.
Response
These comments are not accepted. No changes have been made to the Spatial Strategy in
respect of these comments.
Ripley Town Council: Empty properties are 2% of the housing stock in AVBC area but are
not counted in the number of housing units that need to be supplied. This is perverse.
The proposals do not recognise that we need housing in rural areas too, especially
affordable housing.
SHLAA sites heavily biased to big sites of 500 plus units; if smaller ones were considered
too then coalescence could be prevented.
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Response
The Core Strategy already explains why although the Council is committed to bringing empty
properties back into use, they cannot make a significant contribution to meeting future
housing needs.
Smaller sites in the SHLAA will be considered for allocation when the Site Allocation and
Development Management Policies DPD is produced, which will form part 2 of the Local
Plan. These will include sites in the villages and sites in rural areas that could provide
affordable housing.
There seems to be a misunderstanding of what the SHLAA is. The SHLAA is a collection of
numerous sites that might have the potential for development, and most of these sites are
not capable of accommodating 500 dwellings.
Horsley Parish Council: Concerns would be if this development took place in rural villages
– in the PC area the development of the industrial estate at Lady Lea Rd, Horsley
Woodhouse.
Response
This is a matter for when the Site Allocation and Development Management Policies DPD is
produced, which will form part 2 of the Local Plan. However, it is unlikely that any business
and industrial allocations will be made in the rural areas unless there is a clear local need.
Horsley Parish Council: Developments of the Towns detailed is supported. However new
forms of retailing is required to bring vibrant trading back to these towns.
Response
No change to policy required.
Ripley Town Council: The market towns strategy is deeply flawed. There is a bias towards
Belper getting all the attention; there is not an even-handed approach (if one takes tourism
or heritage for example).
Response
This view is not accepted. No change to the policy is required.
55
Belper Town Council : Belper residents have been consistent in opposing another
supermarket chain i.e. Asda or Tesco. Any planning application for a large national
supermarket chain should be discouraged as it will damage the trade for some of the small
established independent stores in the town centre.
Response
This comment does not require any amendment to the policy.
Horsley Parish Council: It is essential that town centres retain a varied retail offer - not
championed by charity stores. The Council should work with Landlords to ensure sensible,
practical rents apply.
Response
Horsley Parish Council: The Council should not allow housing development purportedly to
support agriculture unless absolutely necessary. The determination of landowners in
Smalley Mill Rd, Horsley is indicative of the attempts to evade the Green Belt and build
houses or convert barns for household use. Concerns over allowing developments in
gardens. Any development in a garden in Church St. Horsley would almost certainly see a
domino effect in applications from other owners. These developments would destroy the
balance of village life.
Response
Belper Town Council: This Local Plan needs to ensure that no Green Belt land is lost
where it will result in communities being joined together.
Response
This comment does not require any amendment to the policy. There are no allocations
proposed on Green Belt land at Belper.
Ripley Town Council: There is no consideration of the wider strategic view for the Green
Belt. There is no link with neighbouring authorities so a co-ordinated planned use is denied.
Proposals encourage coalescence of communities.
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Response
This view is not accepted and the areas proposed to be deleted from the Green Belt will not
encourage the coalescence of communities. The reason why the Borough Council does not
consider a Formal Green Belt Review as such is necessary is explained in the Core
Strategy.
Idridgehay, Alton and Ashley Parish Council: Agree with the need to maintain extra
stringent control on development in the countryside. Save policy EN11 could also be
included here.
Response
The policy has been amended to incorporate the wording of existing Local Plan policy EN11.
Horsley Parish Council: The PC supports the proposal providing that:
•
•
Individuals are not allowed to thwart the current local plan by using gardens for
development for personal gain
That Green Belt agricultural land is not abused by allowing development by using
‘agriculture’ as the excuse to build large houses for personal gain.
Response
These comments do not require an amendment to the policy.
Alfreton Town Council: The Town Council opposed the developments at both Outseats
Farm and Eachwells Lane. A significant driver in the Planning Authority’s decision to
approve was the apparent shortage of housing provision in the Borough, the case for
housing need could have been argued more strategically had the Core Strategy been
delivered earlier.
The Town Council believes that the failure in the delivery of a timely 5 year housing supply
plan will lead to very little housing being built on ‘brownfield’ sites; essentially the question
could be asked why the planning process, particularly the NPPF and its reliance on a 5 year
housing need, leave an open door to building on greenfield sites.
57
Response
Outline planning permission has now been granted for this site and these comments do not
require an amendment to the policy in themselves. However, changes have been made to
add criteria to the policy to address concerns previously raised by the Town Council, other
bodies and members of the public.
Codnor Parish Council: Is still not convinced that the case for desecrating the green belt
and historic deer park attached to the Codnor Castle estate has been demonstrated. The
original proposed ‘by-pass’ that was being portrayed as the reason for the policy change for
this land has now become at best a ‘link road’ and now only a ‘service road’ for the potential
617 houses. This now makes the previous judgment flawed and is also contrary to the
NPPF.
The village of Codnor does not have the schools, doctors or other relevant services to
support this potential development, which would be on top of the 200 houses either
approved or being processed on the land between Codnor and Waingroves on Codnor
Common.
We also have grave concerns that only part of the ‘link road’ will actually be completed due
to the number of developers that could be involved. This would the leave Codnor with an
even more serious traffic congestion problem that it already has today.
We held our own consultation event and we also conducted an exit poll which both have
shown that over 90% of residents attending are opposed to this scheme. The independent
online survey by the Ripley and Heanor News was also strongly against the Ripley Gateway
Scheme of which the ‘link road’ is a major part.
On the basis of all our involvement and of the consultations and representations to our
Council meetings, Codnor Parish Council strongly object to this scheme and request that the
proposed SG2 – Alfreton Road, Codnor should be removed from the Amber Valley Borough
Local Plan.
Response
The policy has been amended to add criteria to address these concerns. The justification for
the new A610 link road and the amendment to the Green Belt in this location have been
covered in the Core Strategy. A planning application for the development of this site and the
new A610 link road has been submitted which includes supporting evidence that is currently
being considered.
58
Horsley parish Council: The PC supports this development. However –
1. Severn Trent should make public their proposals on how sewage will be dealt with
and whether current facilities are sufficient.
2. Now that the County Council is responsible for water dispersal, a clear understanding
of how matters will be dealt with to avoid risk of flooding at Bottle Brook and in Lower
Kilburn.
3. Confirmation that the speed reduction to 30mph in Lower Kilburn with illuminated
signs will be approved and installed.
Response
These are detailed matters to be considered when a planning application is submitted.
Denby Parish Council: As stated in all of the Parish Council’s previous consultation
responses the tar pits must be remediated before any housing development takes place and
the remediation work must be in accordance with assessments made by the relevant
environmental consultant. To this end the remediation of the tar pits should not become a
consideration once any application has been approved.
Suggest there should be on-going monitoring of the whole site for contamination which
includes both the areas known as the tar pits and the Denby Disposal Point. Monitoring
should not be excluded to these areas and samples should be taken from different locations
around the site.
Tar pits should be remediated to provide a green open space for residents of the parish.
Are empty units at the Denby Hall Business Park further along Derby Road and suggest that
this is because there is not need for the units or business cannot afford to move into the
area. Also have concerns for residents living in the development as employment premises
will undoubtedly cause noise, disruption and additional traffic. Consideration should be given
to this and any employment premises on the development should adhere to strict working
conditions during daylight hours only.
Suggest a traffic impact assessment is carried out before any development commences and
all amendment and changes to the transport infrastructure should be made before any
development takes place. The Parish Council also believe that direct access to the A38 via a
slip road on and off from Derby Road is essential to the development.
If extension is made to John Flamsteed School a drop off zone should be included within the
plans to alleviate both the current and expected increase in congestion and street parking
along Derby Road. The Parish Council consider this to be especially important as the school
is opposite the highway which will lead into the new development. Any extra provision at
John Flamsteed should include an additional provision for 6th form places.
59
The Parish Council are concerned that a primary school within the proposed development
site could be detrimental to Denby Free and Street Lane Primary Schools.
The proposed development will be, in terms of numbers of houses, the same size as Kilburn
and would mean the whole Denby Parish would become three times its current size.
Suggest a number of services and facilities that they think should be included to support the
development that should be located within walking distance to the existing settlement so
they are available to all residents of the parish.
State that the greenway should be re-instated as a high priority. Footpath 74 which links
Denby Bottles to Openwoodgate has been recognised as a site of historical interest and
should be protected and all existing footpaths which run through the proposed development
site should be protected.
It would be preferable that this land is sold as a whole and developed by one individual
developer.
Concerns over flooding as the proposed buildings and roads will reduce the grounds ability
to absorb rainfall. Flooding from the brook course along Derby Road has already significantly
increased since the development of the Denby Hall site.
Work is needed to deepen and widen the brook course along Derby Road in the form of reculverting to cope with the additional run off – these works will need to be undertook from
Street Lane to the River Derwent at Little Eaton, this is needed to avoid moving the flood
plain from Derby Road into the Kilburn area.
The delivery plan has a number of unknown costs associated with the development at
Denby namely the remediation of the tar pits, the cost of introducing sufficient electricity and
water resources to the area. These costs need to be ascertained as soon as possible so
provision can be made for any anticipated shortfall. As mentioned in Policy IN6 Developer
Contributions – any shortfall should be met by developer contributions.
If CIL is adopted by the Borough Council the charging rate needs to be sufficient to cover all
infrastructure costs and if section 106 monies are used to bridge the funding gap these
should form part of the planning obligations and be guaranteed without any option available
to the developer to relieve them of the obligation.
Response
The policy has been amended to add criteria to address these concerns. Other comments
made are detailed matters to be considered when a planning application is submitted.
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Comments on Policy SG4: Newlands/Taylor Lane, Heanor
Heanor & Loscoe Town Council
Have serious concerns over Land at Taylor Lane, Loscoe and Land at Newlands, Heanor
(AV14). Comments are as follows: •
Increased traffic will be created by both sites. Heanor’s roads operate close to
capacity already. Even if an access road to Taylor Lane was developed via Hogbarn
Lane it would not be a total solution to the problem.
•
Both parts are comparatively isolated from the centre of town.
•
Both developments are sited in the Bailey Brook Flood Plain
•
Provision of school places in the area is already close to capacity, both primary and
secondary schools would be struggling to take more pupils without significant
development.
•
Medical provision in the Heanor area is at present at capacity
•
Local employment is at a premium in this area – these new housing developments
would lead to an increase in commuter traffic.
The Parish Council are of the view that the housing component of the Amber Valley Borough
Council Preferred Growth Strategy needs urgent re-visiting.
Response
The policy has been amended to add criteria to address these concerns. Other comments
made are detailed matters to be considered when a planning application is submitted.
Ripley Town Council: The housing mix proposed appears acceptable, but enforcement of
the mix is required.
Response
This comment does not require any changes to the policy.
Ripley Town Council: Renewable energy should be encouraged better. Solar panels could
be made compulsory on new builds (especially factory units).
Response
The Borough Council cannot insist on solar panels being fitted to new buildings.
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Horsley Parish Council: Bottle Brook in Lower Kilburn is already a problem. A solution to
the current problem should be found before any future development is approved.
Response
Derbyshire County Council is responsible for managing local flood risk.
Idridgehay, Alton and Ashleyhay Parish Council: Agree with the principles and consider
a,c,e,f and g should be given priority especially in the Special Landscape Area.
Response
It is not agreed that priority should be given to the Special Landscape Area, or that these
criteria should be given greater priority over the other criteria.
Horsley Parish Council: Horsley village contains a ‘garage’ used in the 18th century for
coaching purposes. The building is 150 cubic metres in size and is in the Conservation Area.
This garage, formerly part of Coach and Horses PH, Should be preserved and added to the
proposed ‘list’
Response
Belper Town Council: Belper Town Council members are concerned about the number of
properties within the World Heritage Site and Conservation Areas that have been modified
within the last two years with incorrect materials i.e. roof tiles have not been adhered to.
Planning enforcement allowed the modifications to remain instead of insisting that the
materials are changed to the appropriate materials that the World Heritage Site and
Conservation insist.
Response
62
Idridgehay, Alton and Ashleyhay Parish Council: Essential policy that needs to be
retained but monitoring has to be at the planning stage. Planners need to be proactive and
implement policies before development takes place. Retrospective action against
inappropriate development in the rural environment is unacceptable – the damage is done
and can be irreparable.
Response
Idridgehay, Alton and Ashleyhay Parish Council: Essential policy that needs to be
retained but monitoring has to be at the planning stage. Planners need to be proactive and
implement policies before development takes place. Retrospective action against
inappropriate development in the rural environment is unacceptable – the damage is done
and can be irreparable
Response
Ripley Town Council: Parks and greens should be properly protected not built on.
Response
Codnor Parish Council: There is still not been an all-embracing transport study undertaken
to evaluate what the impact of an additional 2,500 houses within a three-mile radius of
Codnor will have on the road system. The sites that make up this total are SG2 – Alfreton
Road Codnor, SG4 – Newlands/Taylor Lane Heanor, SG6 – Coppice Farm and SG7 –
Nottingham Road Ripley plus the 200 between Codnor and Waingroves on Codnor
Common.
Response
The justification for the new A610 link road is included in the Core Strategy. A planning
application has been received for the new road and the development of the sites at Alfreton
Road, Codnor and Nottingham Road, Ripley. This is accompanied by a Transport
Assessment which is now being considered.
63
Ripley Town Council: Strongly oppose re-routing of current A610 route.
Response
The justification for the new A610 link road is included in the Core Strategy. A planning
application has been received for the new road and the development of the sites at Alfreton
Road, Codnor and Nottingham Road, Ripley. This is accompanied by a Transport
Assessment which is now being considered.
Ripley Town Council: S106 and CIL funding needs active reference to Derbyshire County
Council infrastructure.
Response
This comment requires no amendments to be made to the policy.
Alfreton Town Council:
The Town Council is concerned that housing growth in Alfreton will have an alarming impact
on the Town and in particular its transport infrastructure. The HMA seems to isolate some
areas from consideration whilst focusing on towns like Alfreton.
The HMA seems to have glaring gaps in its strategy, particularly the level of identification
and subsequent caution on the environmental impact those developments will have.
The Core Strategy is, in a sense already delivered in Alfreton, given the approval for 500
dwellings at Outseats Farm (it has struck residents of Alfreton that is was something of a
waste of time to persist with the Core Strategy consultation exercise in Alfreton when
effectively it’s a ‘done deal’) The Town Council feels that Outseats Farm and more recently
Eachwells Lane have been approved, together with all the other approvals already on the
books, Alfreton ought to be indemnified from any future approvals of that scale.
The Town Council is also concerned that the Core Strategy, as it stands, does not identify
and reserve sites – notionally those where the build plan is less than 500 dwellings. In the
Town Council’ view such sites should be identified when and if larger approvals fail to
complete. Sites in the west of the Borough should be considered to meet that need. The
Town Council has consistently taken the view that the Core Strategy should reflect a housing
growth in the west of the Borough; the Core Strategy as it stands is skewed towards
development in the already congested eastern areas.
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Response
The reasons why the strategic sites proposed for allocation have been preferred over other
potential strategic sites is already explained in the Core Strategy and other accompanying
documents.
Ripley Town Council: Economic Impact Assessments appear to be lacking – mixed
messages are being sent.
Response
No action is required in response to this comment.
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5.
Comments from Borough/County Councillors/MP
Comments on the Spatial Vision for Amber Valley
Nigel Mills MP: While I would agree with the majority of the vision set out I consider that
there are some additions required, namely that:
• The protection from unsustainable development is only set out for villages – this
should be extended to towns, districts and local centres;
• There should be an explicit vision of all areas of the Borough having access to high
quality communications infrastructure fit for the 21st century.
• The statement that growth will be concentrated at the four market towns strikes me
as inconsistent with the proposed plan – both in terms of the lack of development
proposed for Belper and the fact that a significant proportion is allocated to the
Codnor area and the land north of Denby.
• A specific commitment to protecting the Green Belt should be added – presumably
this protection will be greater than that promised for ‘important green open spaces.’
Response
The Spatial Vision has been amended to take on board these comments.
Comments on the Strategic Objectives and state what (if any) changes you consider
necessary
Cllr Emmas-Williams: The proposed plan has directed all the potential housing proposals
to the East of the A38 with the maximum use of Greenbelt and green open spaces. This is
totally against the spirit of the NPPF and the numerous consultation exercises, surveys and
petitions which have all shown significant percentages who have visited and voted against
these developments.
Response
These are general comments about the Spatial Strategy.
Nigel Mills MP: I am surprised there is no strategic objective to protect the Green Belt. I am
concerned at the statement ‘whilst maximising opportunities for renewable energy
generation and utilisation’ in objective 1 – this risks being inconsistent with policy R2 which
clearly sets out criteria where such development would be inappropriate. Given the recent
rejection of the solar farms applications I would suggest this wording should be amended. I
am not sure why there is a need to mention any specific local communities in objective 4 –
surely the aspiration to meet the needs of ‘all local communities’ is sufficient. It is also not
clear how providing ‘decent, affordable and well-designed dwellings’ could meet the needs of
travelling communities.
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Response
The Strategic Objectives have been amended to take account of these comments. It is not
considered that a specific objective to protect the Green Belt is necessary, as this is national
policy and the Council’s commitment to protecting the Green Belt unless there are
exceptional circumstances is an important part of the Spatial Vision and the Spatial Strategy.
Comments on the Spatial Strategy and state what (if any) changes you consider
necessary
County Cllr Cox: The development of brownfield sites should be actively encouraged in the
more urban areas.
County Cllr Williams: I support the strategies of maximising the use of brownfield land and
re-using empty properties. However, whilst there is an identified list of strategic growth sites,
a similar analysis of ‘brownfield’ sites has not been attempted. There is no identification and
analysis of potential brownfield sites.
Nigel Mills MP: As set out in my comments in the previous consultation, I consider that the
level of housing considered to be required over the period to 2028 is excessive and the
chosen sites may not be appropriate for the following reasons:
• The overall number of houses proposed for the Derby Housing Market Area (HMA) is
excessive compared to expected levels of growth, past performance and proposals
for neighbouring areas;
• The number of houses proposed for Amber Valley especially appears to be
excessive compared to expected growth levels and as 27% of the proposed total for
the HMA higher than indicated in 3 of the 4 options considered in the original
assessment;
• The preferred strategic sites exclude several brownfield sites in Amber Valley where
significant numbers of houses could be constructed – and indeed where developers
have proposals to do so;
• The preferred sites still include the loss of Green Belt which should be a last resort;
• The preferred strategic sites seem to be disproportionately in the east of the Borough
despite other areas of the Borough having easier access to Derby.
I would urge the Council to reconsider whether this level of housing growth is necessary,
desirable or achievable. I remain concerned that use of brownfield land has not been
maximised despite the claims on para 6.2 of the Spatial Strategy.
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Response
There are no available sites of a strategic scale that are brownfield in the Borough that could
be used for housing, although parts of the sites proposed for allocation north of Denby and
at Taylor Lane, Loscoe are brownfield. When the Site Allocations and Development
Management Policies DPD is produced (which will form part 2 of the Local Plan), brownfield
sites will take priority when deciding which sites to allocate. The level of housing growth
proposed does meet the objectively assessed need for housing in the Borough.
Cllr Emmas-Williams: The proposed plan has directed all the potential housing proposals
to the East of the A38 with the maximum use of Greenbelt and green open spaces. This is
totally against the spirit of the NPPF and the numerous consultation exercises, surveys and
petitions which have all shown significant percentages who have visited and voted against
these developments.
Response
This is a general comment about the Spatial Strategy.
Cllr P Jones: The strategic site identified within the document set out below appear to show
a bias towards developments to the east of the A38 and away from Belper.
Figures for developments and planning proposals since 2008 appears to substantiate this of
the wards to the east of the A38 there is a commitment to build 1,334 houses yet the
remaining wards only have 858 . There is a obsession to preserve Belper and its immediate
environs to the detriment of the other parts of the Borough.
There is an expectation that the new residents will have to travel to work this does not
support any aspect of having a green travel plan or reducing vehicle use. This seems in
contradiction to IN1 transport section e) which states that the Council is '..seeking to ensure
that development is located where the need to travel can be minimised and sustainable
transport modes can be maximised and section f) goes on about ' minimising emissions for
transport by reducing the need to travel..'
There seems a total lack of recognition of the need to affordable housing for rural
communities.
Response
These are general comments about the Spatial Strategy. The need for affordable housing in
rural areas will be considered when the Site Allocations and Development Management
Policies DPD is produced (which will form part 2 of the Local Plan). In the meantime, saved
Local Plan policy H11 will continue to be used to provide affordable housing in rural areas.
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County Cllr S Freeborn: The Plan does not recognise that we need housing in rural areas
too, especially affordable housing.
Response
The need for affordable housing in rural areas will be considered when the Site Allocations
and Development Management Policies DPD is produced (which will form part 2 of the Local
Plan). In the meantime, saved Local Plan policy H11 will continue to be used to provide
affordable housing in rural areas.
Nigel Mills MP: The proposal is that 27% of the housing growth should be constructed in
Amber Valley – a higher proportion than options 1,2 and 4 of the original consultation (15%,
23% and 24% respectively). Given that there has been far more demand in South
Derbyshire in recent years and that the City represents the preferred area for growth given
the availability of infrastructure and work opportunities, it is surprising that so high a
proportion has been agreed for Amber Valley.
While I appreciate the issues with the World Heritage Site and the very rural nature of some
of the western parts of the Borough, the preferred sites do seem to be disproportionately
allocated to the east of the Borough. Given the ease of access to Derby for the southern and
western parts of the Borough, it would seem sensible to reconsider whether any suitable
options for housing developments are available in that area.
Response
This is a general comment about the Spatial Strategy. The amount of housing growth
proposed does meet the objectively assessed need for housing in the Borough.
Cllr Emmas-Williams: A lot of the old industrial sites are now looking tired but unless the
Borough can attract new industry and businesses then the SA study is completely worthless.
There should be at least one major business/industrial site within the Borough should the
right developer approach the authority.
Cllr P Jones: The strategy fails to identify any significant site which can be developed for
'high tec' industry . I would suggest that the infrastructure at Lilly Street Farm provides a
such a site which would bring in high quality employees and boost the local economy
significantly This omission is a significant weakness in the strategy which should be about
the economic drivers which will allow our communities to develop and flourish.
County Cllr S Freeborn: There is a lack of strategic thinking on employment sites.
County Cllr Cox: There seems to be lack of consideration regarding employment
opportunities in relation to housing, leading to more dependency on the car.
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Response
These issues will be addressed when the Site Allocations and Development Management
Policies DPD is produced (which will form part 2 of the Local Plan).
Cllr Paul Smith: Considers that further efforts should be made to bring back into use the
empty office and industrial units that are currently developed and have existing service/utility
provision and proven access capability. Before any further land is allocated for industry, an
empty warehouse/factory strategy should be developed.
Poor quality industrial land allocations should be removed from the strategy and land that
was previously included, such as Birchwood Lane, Somercotes, should definitely be
removed, as the develop is requesting, because the site is no longer required and should be
re-designated as a Green Belt buffer zone from the existing Cotes Park Industrial Estate.
Response
These issues will be addressed when the Site Allocations and Development Management
Policies DPD is produced (which will form part 2 of the Local Plan).
Cllr Emmas-Williams: Settlements should be protected as they all have their own identities
which need to be preserved. If residents wanted to live in towns they would buy their house
there hence some people prefer the 'village' life and do not want to be swallowed up by a
town.
Response
This is a general comment that does not require any changes to the policy.
Cllr Emmas-Williams: 'Free parking' would possibly be a way of attracting shoppers and
helping to re-generate the Market Place
Response
Car parking charges are not a planning policy issue.
Cllr Emmas-Williams: If the Morrison’s store is built out of the town then more shops will
close in the Town. The market is hardly supported by residents and there are very little of the
big name shops left in Ripley. Charity shops, food outlets and chemists are all that is left.
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Response
Cllr Emmas-Williams: Bring in 'Free Car Parking' to try and attract the shoppers back it
certainly seemed to work when the Co-Op dropped their prices for some months.
Response
Car parking charges are not a planning policy issue.
County Cllr S Freeborn: The market towns’ strategy is flawed. There is bias towards Belper
getting all the attention; there is not even-handed approach (tourism or heritage, for
example). So called Masterplans are set in isolation to wider strategic issues. The Plan
acknowledges but ignores the evidence of Retail Impact Assessment regarding proposals for
an out-of-town supermarket at Ripley.
Response
It is not accepted that the strategy is flawed, or that there is a bias towards Belper. The
current proposal for a supermarket is not a matter for the Core Strategy.
Cllr Emmas-Williams: If you look at what the planning documents say that only
development in the green belt can be given in extreme circumstances. This is not evident in
the Core Strategy. It is not justified and alternative to green belt sites have been dismissed
without convincing reasons.
County Cllr S Freeborn: There is no consideration of a wider strategic view. There has
been no link with neighbouring authorities so a co-ordinated planned use is denied. The
proposals encourage coalescence of communities.
County Cllr Williams: The National Planning Policy Framework (NPPF) emphasises the
importance of continuing to protect Green Belt from inappropriate development and that
established Green Belt boundaries should only be altered in exceptional circumstances.
Except for the purpose of the proposed A610 Ripley – Codnor link road, I do not agree with
the proposals to delete Green belt land at Ripley and Codnor. ‘Exceptional circumstances’
have not been demonstrated.
This follows logically from the choice of the strategic growth sites SG2 at Alfreton Road,
Codnor, SG6 Coppice Farm, Ripley and SG7 Nottingham Road, Ripley.
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It is accepted that Coppice Farm has outline planning permission but the choice of all three
as strategic growth sites – without considering brownfield sites, empty properties and
currently existing planning permissions which have not yet been implemented – will lead
precisely to problems which the introduction of the Green Belt in the 1930’s and 1940’s was
intended to avoid.
The Draft Core Strategy in Policy SS10 rightly highlights the ‘longstanding commitment by
both the Borough Council and Derbyshire County Council to securing the completion of a
new A610 Link Road between Ripley and Codnor’ and mentions its advantage of relieving
congestion on the current A610 route.
However, an A610 ‘bypass’ has needed to be constructed for the past 30 to 40 years,
irrespective of whether any additional housing and business and/or retail park developments
are built as part of the strategic growth sites SG2, SG6 and SG7.
Local authorities need to adhere to the originally designed route of the A610 bypass, without
changing its route to accommodate deletions of the Green Belt.
Response
It is considered that exceptional circumstances have been demonstrated in respect of the
proposals for the new A610 link road and the proposed allocation of the strategic sites at
Alfreton Road, Codnor and Nottingham Road, Ripley. The new route for the A610 has been
designed in consultation with the Highway Authority and the original route still involves
development in the Green Belt.
Cllr Emmas-Williams: AS I have mentioned above(Q16) certainly SG2 and SG7 should be
replaced with other sites out of the earlier proposed list of sites. It would appear that the
assessments have taken place after the selection and are now shown to justify why they
have been selected not as part of a proper comparison exercise
County Cllr S Freeborn: Strong objection to the moving of the Green Belt ‘boundary’ to the
north of Ripley and the ensuing proposals to build 1,100 plus houses to the north of
Nottingham Road, Ripley and to the east of Codnor.
County Cllr Cox: I have major concerns regarding proposals to develop Green belt sites,
particularly the Alfreton Road/Nottingham Road, Codnor area. I do not support the re-routing
of the A610 if it is dependent on the loss of the Green Belt.
County Cllr Cox: I do not agree with the proposals to delete Green belt land at Ripley and
Codnor
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Response
Cllr Emmas-Williams: Green open space and countryside should be protected against
development especially sites with heritage buildings on them. These should only be even
considered when all the 'brownfield sites' and current approved un built properties have been
exhausted.
Response
Cllr Emmas-Williams: Sustainable development is a judgemental assessment which I do
not believe has been evaluated correctly. Because a potential development is near to a
current settlement does not mean that the new residents will fit into the current way of life. It
does not take full account of the lack of current requirements for schools, doctors, police and
dentists or the road infrastructure.
Response
Cllr Emmas-Williams: This policy should be removed as the selection criteria is flawed. The
number of houses would not keep Codnor sustainable as the school is at capacity, there is
no resident doctor or dentist and the police are at full stretch. The potential increase would
increase the size of the village by a third. The original by-pass is now no more than a service
road and there is no guarantee that the road will be built which could leave Codnor with a
worse traffic congestion should only the first part of the road being built. The NPPF states
that Green belt should only be built on if there are exceptional circumstances ,the now
proposed 'link road' is no longer an exceptional circumstance. This green belt is also part of
the Codnor Castle estate which includes part of the ancient deer park. There are numerous
public 'rights of way' footpaths which would be cut off if the green belt is desecrated by this
potential development.
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County Cllr Williams: The development of sites SG2, SG6 and SG7 collectively contradict
Policy SS12: Countryside, and should not be permitted because:
•
•
•
•
•
They are collectively of excessive scale;
Two or the three are in the Green Belt and one is farmland, outside the built
framework of settlements;
They are not essential in conjunction with the requirements of agriculture, rather SG6
is built on former pastureland;
Any of the three could be reasonably be located within an existing settlement by use
of brownfield sites, re-using existing empty properties and ensuring existing planning
permissions are used;
The developments may incur further government expenditure on health facilities –
GP surgeries, hospitals and dentists; public open space and outdoor sports facilities;
community facilities for all age groups – leisure centres, community centres and
libraries; preserving and enhancing historic buildings – e.g. Codnor Castle,
conservation areas and the historic environment.
None of this is likely extra expenditure is mentioned or costed in the Draft Core Strategy.
Policy SG2 – with 600 dwellings planned for Alfreton Road, Codnor by deleting the Green
Belt - in particular, will contradict policy SS3 for Codnor to continue to act as a local centre.
Codnor will no longer be considered as a ‘local centre’ as it will be another small town,
having undergone a big increase in size, if these policies are implemented.
Nigel Mills MP: There is significant concern that the proposed A38-M1 Link-Road/Bypass
may not be delivered
Response
Cllr Emmas-Williams: For this development to succeed the tar pits need to be totally
removed prior to any approval.
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Nigel Mills MP: A similar issue with phasing of development arises with the proposed
development on the land north of Denby. Again the original justification for allowing a
reduction in the Green Belt at this site was the remediation of the tar pits, and so no
development should be allowed on any part of this site without there being a clear and
binding scheme in place to deliver this remediation. Given the fractured ownership and the
potential for a planning application for a small part of this site to come forward in the near
future, the Council needs to be very clear how this phasing could be achieved and ensure
that the proposed policy is sufficiently robust. I am concerned at the viability of this without
there being a clear cost estimate for the decontamination available and would urge the
Council to ensure this is obtained before Policy SG3 is adopted.
Housing development of this scale will clearly have a substantial impact on the existing
community and will require extensive community facilities to be incorporated. While these
are referred to in SG3(e), it would be helpful if more extensive comment could be made here
on what will be required.
Similarly on SG3(c) the 1,800 houses plus employment land will lead to a significant
increase in traffic flows. While the Infrastructure Plan includes some road improvement
details, I am not convinced that these will be sufficient and would urge the Council to
reconsider the viability of a new access onto the A38.
For SG3(d) this area is served by various primary schools currently (including in Denby,
Street Lane and Kilburn). There may be need for investment in these schools also arising
from this development and therefore it may be appropriate to amend the wording in policy
SG3(d) to reflect that such investment may be required in addition to a new Primary School.
Response
The criteria in this policy have been amended to address these concerns. The Highways
Agency have confirmed that they have no objection to the improvements proposed to access
the site and the improvements to highway infrastructure surrounding the site proposed,
without the need for a new junction on to the A38. However, they will require further
information when the planning application is submitted.
Cllr Emmas-Williams: Some of this development is on reclaimed land and with the correct
infrastructure this would be acceptable.
Response
This is a comment supporting the policy.
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Cllr Emmas-Williams: This site has already been approved. Correct usage of the 106
monies is vital to help with all the extra residents this will bring. The proposed road
improvements associated with this approval will do very little to improve the current situation,
without the increase in vehicular movements.
•
•
•
•
•
Two are in the Green Belt and one is farmland, outside the built framework of
settlements;
Response
These are general comments regarding the proposed strategic allocations in this area. The
criteria for each of these sites have been amended to address some of these concerns.
Cllr Emmas-Williams: Despite the Borough Councils own independent retail study that they
commissioned, petitions, independent on line surveys and results from all the consultation
exercises which clearly demonstrate that the out of town supermarket is not required they
still plough on with trying to ignore the wishes of the local people and residents.
Response
The current proposal for a supermarket is not a matter for the Core Strategy.
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•
•
•
•
•
Two or the three are in the Green Belt and one is farmland, outside the built
framework of settlements;
Response
These are general comments regarding the proposed strategic allocations in this area. The
criteria for each of these sites have been amended to address some of these concerns.
County Cllr S Freeborn: The housing mix proposed appears to be okay, but enforcement of
the mix is required.
Response
Cllr Emmas-Williams: More ground floor accommodation should be perused to meet the
perceived increase in elderly and disabled people.
Cllr P Jones: Lifetime Homes - The proposals within the plan to build lifelong housing is to
be welcomed.
Response
These comments do not require any amendment to the policy.
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Cllr Emmas-Williams: To meet the required of amount of social/affordable housing required
in the Borough the current target of 30% will not even meet the requirement. The reduction
agreed on the Coppice site should not be permitted.
Cllr P Jones: Within the strategy H1 the Council's own plan recognises that all new
developments will have to have as a minimum 61% affordable housing up to 2038 to meet
demand. However, there is nothing within the strategy to support this aspiration
Response
This policy reflects the existing policy in the Local Plan. The development industry alone can
never meet the full needs for affordable housing and a balance has to be struck between
ensuring that as much affordable housing as possible is secured but at the same time not
having a target which is too onerous and would mean that housing developers will look
elsewhere to provide market and affordable housing. Experience has shown that requiring
more than 30% affordable housing would usually render schemes unviable and/or mean that
other requirements such as developer contributions to improving educational facilities could
not be obtained.
County Cllr Cox: There is emphasis on developing in already congested areas when rural
areas are in need of affordable housing to maintain communities and road and other
transport links are better in the west of the Borough.
Response
This is a general comment on the Spatial Strategy that does not require any changes to the
policy.
Cllr Emmas-Williams: This has to a major concern as at the moment already approved
housing schemes are not being built with considerable 'land banking' taking place.
County Cllr Cox: Housing proposals appear not to take into account need and
infrastructure.
Response
These are general comments that do not require any changes to the policy.
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County Cllr S Freeborn: Renewable energy should be encouraged in the Plan more
explicitly. For example, solar panels should be made compulsory on new buildings
(especially factory units).
Response
The Borough Council cannot insist that solar panels are fitted to new buildings.
Cllr Emmas-Williams: This is a major concern right across the whole of the Borough as
demonstrated in the Draft Infrastructure Delivery Plan (pages 10 to 13) with very little
confirmed initiatives to alleviate these problems.
Response
This is a general comment that requires no changes to the policy.
Cllr Emmas-Williams: As I have stated earlier due care has not been taken with regards to
Codnor Castle and its Deer Park. This is the only recognised mediaeval castle in the area
and if the developments go ahead will be severed from the village that it is senominous with.
Response
The criteria in the policy for the proposed strategic site at Alfreton Road, Codnor (SG2) have
been changed to address these concerns.
Cllr Emmas-Williams: Special Landscape Area where removed at previous plans which
has led to some of the current problems that we have had to endure.
Response
This comment relates to Areas of Local Landscape Significance defined in the previous
Local Plan 1994, not the Special Landscape Area.
Cllr Emmas-Williams: Why not just protect 'Green Belt' sites and look to the other sites to
supply the housing stock that it is alleged to be required. There may be opportunities to
'swop' some small parts of green belt with green open spaces on a limited bias.
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County Cllr S Freeborn: Parks and greens should be properly protected not built on.
Response
These comments do not suggest any areas that could be allocated as Local Green Spaces.
Cllr P Jones: Alternative forms of transport - There appears to be no recognition within the
strategy to links with potential extending the Tram system from Nottinghamshire into
Derbyshire. If it is to be visionary document that surely this aspect of alternative, greener
transportation needs to be recognised along with the potential for alternative employment
such as transport in the Langley mill area with the marina development.
Response
This scheme has not yet been agreed, and is unlikely to be implemented during the plan
period.
County Cllr Marshall-Clarke: There is no provision in the document that addresses the
environmental impact of pollution created by the proposed sites. In particular, the impact
additional traffic will have on the health of residents already residing in the target
development areas. The Area Profile for Alfreton, Somercotes shows the life expectancy of
male residents is the lowest in the Borough.
I fail to understand how a partial development of a Ripley-Codnor bypass would provide any
benefit on highways grounds. We should be making it clear that we would need a completed
bypass to come forward fully funded before we would consider approval of developments in
that area.
We have previously supported developments from a highways perspective that have
subsequently failed to deliver the outcomes we desire. The Core Strategy needs to focus
much more on integrated transport issues. More weight needs to be given to walking, cycling
and public transport infrastructure. A glaring problem with this Core Strategy is the access
issues to train services for disabled users and cyclists on the Erewash Valley line.
Developing sites in these areas should be declined until a properly thought out infrastructure
plan is in place together with the appropriate funding to implement the plan.
This Core Strategy fails to look at areas that would have least impact on the existing
infrastructure. There is better developed infrastructure in the west of the area with good
access to rail services. This should be a priority area as it would relieve pressure on the
highways network.
The highways network of the A52 and A515 are better placed to absorb the additional impact
of increased traffic that the already congested areas identified in the Core Strategy.
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Response
The criteria in the policy addresses some of these concerns. Other concerns have been
addressed elsewhere in the Core Strategy. The Highways Agency have concerns with any
further development off the A52.
Cllr Emmas-Williams: We have to protect and increase the parks, open space and sports
grounds to meet the increase in requirements for recreation and carry on the legacy from the
success of the 2012 Olympics.
Cllr Emmas-Williams: We have to protect and increase the parks, open space and sports
grounds to meet the increase in requirements for recreation and carry on the legacy from the
success of the 2012 Olympics.
Response
These comments require no amendments to these policies.
Cllr Emmas-Williams: Without a complete total area travel/traffic study being completed
then sites cannot be properly evaluated. Belper has suffered over many years as each
planning application were decide on each merit which gave an overall unacceptable situation
in Belper. This cannot be allowed to take place in the Borough again.
County Cllr S Freeborn: Strong objection to the proposed alteration to the long agreed line
of the Ripley-Woodlinkin A610 by-pass.
Response
The new alignment for the A610 link road has been designed in consultation with the
Highway Authority and the previously agreed line which would still involve development in
the Green Belt was never the subject of any detailed investigation. A planning application
has been received for the new A610 link road and the development of the strategic sites at
Nottingham Road, Ripley and Alfreton Road, Codnor. This is accompanied by a Transport
Assessment which is being considered.
Cllr Emmas-Williams: If this infrastructure is demonstrated then total guarantees on
delivery needs to be enshrined in planning law.
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County Cllr S Freeborn: The policies and background text relating to Section 106
Agreements and CIL needs active reference to the County Council’s infrastructure
requirements.
County Cllr Williams: However, an A610 ‘bypass’ has needed to be constructed for the
past 30 to 40 years, irrespective of whether any additional housing and business and/or
retail park developments are built as part of the strategic growth sites SG2, SG6 and SG7
Response
These comments require no amendments to the policy.
County Cllr Williams: Local authorities need to adhere to the originally designed route of
the A610 bypass, without changing its route to accommodate deletions of the Green Belt.
Response
The new alignment for the A610 link road has been designed in consultation with the
Highway Authority and the previously agreed alignment which would still involve
development in the Green Belt was never the subject of any detailed investigation.
Cllr Emmas-Williams: Developers contributions should be ring fenced for the areas that will
suffer from the development. All local members should be included in discussions from the
earliest opportunity.
County Cllr S Freeborn: The policies and background text relating to Section 106
Agreements and CIL needs active reference to the County Council’s infrastructure
requirements.
Response
These comments require no amendments to the policy.
Cllr Emmas-Williams: Many of the possible arguments put forward on SG2 & SG7 have
been demonstrated to have been flawed and puts the Core Strategy reasoning at risk. No
strategic reviews have been demonstrated for the Transport requirements, Green Belt and
Sustainability assessment.
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Cllr P Jones: Comments specific to Heanor - According to statistic from Derbyshire County
Council the Heanor area has already demonstrated significant growth since 2001 l
Greater Heanor 9.1%
Heanor Central 7.9%
against an average of 5.45% so it seems logical that any future growth should be in those
areas which have failed to grow over this time scale rather than putting extra burdens on an
already creaking infrastructure.
The identified sites within Heanor do not take cognizance of other potential developments
within the neighbourhood and whilst this is understandable it fails to recognise the impact of
other potential developments. If the plans for Falls Road, Heanor and the former American
Adventure site were approved the additional housing for the Heanor area would then be
1,072, It seems a major flaw within the strategy to recognise the potential that the Heanor
area could have twice the development that the Council has identified within these strategic
sites. The impact on the local highways and transport are covered in my earlier comments.
County Cllr S Freeborn: Economic Impact Assessments appear to be lacking resulting in
mixed messages being sent.
The use of Community Infrastructure Levy (CIL) in unclear. The use of brownfield sites is
largely discounted without considering use of CIL to provide a cost balance between green
and brown field sites.
Empty properties area 2% of the housing stock in the AVBC area but are not counted in the
number of housing units that need to be supplied.
The sites proposed for allocation in the Core Strategy are heavily biased to big sites of 500
plus units. It should include smaller sites which could help to stop coalescence etc.
There are big contradictions regarding sites dependent on the car. There is no relationship
between housing developments and employment.
There is no mention of the Ripley Neighbourhood Plan, which is being developed and
proposes to provide the new housing required in Ripley without going north of Nottingham
Road.
Response
Most of these comments have already been responded to elsewhere in this document. The
current proposals for Shipley Lakeside and Fall Road Heanor are still being determined and
will be taken account of when calculating the need for housing if they are approved. There is
no need to refer to Neighbourhood Plans in the Core Strategy.
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County Cllr Williams: In Appendix B: Proposed Scale and Location of Housing Growth in
Amber Valley, the overall requirement of homes from 1/4/08 to 31/3/28 is 9,400. There are
also ‘just over 1,000 homes that have been empty for 6 months or more which are 2% of the
housing stock in Amber Valley’. Nevertheless, empty properties are not included in Appendix
B in the number of housing units that need to be supplied. This would seem to represent a
significant under-counting of houses which can be supplied without resort to new-build.
Response
The Core Strategy already explains why although the Council is committed to bringing empty
properties back into use, they cannot make a significant contribution to meeting future
housing needs.
County Cllr Williams: The Draft Core Strategy is not balanced when it broadly ignores the
fact that the Ripley area has had an industrial history and heritage of its won since the 18th
Century, stretching from Ambergate/Bullbridge/Sawmills, along the Cromford Canal to Ripley
and the former Butterley Works. There has also been a history of industrial unrest with the
Pentrich uprising in 1817 and of course, in the 20th century Barnes Wallis was resident in
Ripley. None of this history is even referred to in the Draft Core Strategy, although the
Cromford Canal merits a mention.
Response
The rich history of coal mining in the eastern part of the Borough and the Cromford Canal
are mentioned in the background text to the historic environment policy.
County Councillor P Jones:
The disproportionate identification of strategic housing sites to the east of the A38 will have
significant infrastructure problems for highways and the education authority within these
communities and I would question if they have been evaluated to an acceptable and logical
basis for inclusion.
There is no identified strategic site for industrial development yet the site at Lily street Farm
in Swanwick is the best connected site within the entire Borough for development of High
technology businesses.
The inclusion of homes for lives is a welcome development and fits in well with DCC’s
accommodation strategy for Adult care
There is no recognition of the development of a tram system within the Eastwood area which
has the potential to develop towards Ripley through Heanor and Langley Mill.
Response
Responses to these comments are covered elsewhere in this document.
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6.
Comments from neighbouring Local Authorities and Derbyshire County Council
Erewash Borough Council: Notes and supports Amber Valley’s preferred spatial strategy
which sets out the location and scale of development needed to meet long-term growth
requirements. Focusing new development particularly in Amber Valley’s four market towns of
Alfreton, Belper, Heanor and Ripley is considered sustainable due to the presence of a
range of existing physical and social infrastructure which can help the Borough to absorb the
impacts of growth.
The strategy also largely maintains the openness of the Nottingham-Derby Green Belt.
Erewash Borough Council strongly welcomes the planned retention of the Green Belt
between the towns of Heanor and Ilkeston (as situated inside the Borough of Amber Valley)
to ensure their continued separation in line with the purposes set out within the National
Planning Policy Framework at paragraph 80.
Response
These comments are in support of the Spatial Strategy
Ashfield District Council: Notes and supports Amber Valley’s preferred spatial strategy
which sets out the location and scale of development needed to meet the long term growth
requirements of the Borough. The focusing of new development within the four market towns
of Alfreton, Belper, Heanor and Ripley is considered sustainable due to the presence of a
range of existing physical and social infrastructure.
Response
These comments are in support of the Spatial Strategy
Broxtowe Borough Council: Broxtowe Borough Council generally supports the housing
figure within the context of the Derby HMA evidence set out, in that it provides for your
objective assessment of Derby HMA housing need. It supports your intention to meet in full
your housing need within the Borough.
Response
These comments are in support of the policy.
Erewash Borough Council: Amber Valley’s housing provision of a minimum of 9,400 new
homes by 2028 is noted by Erewash Borough Council. This represents slightly less than a
third of the overall Derby Housing Market Area (HMA) requirement of a minimum of 35,350
homes across the same period. Work that has been undertaken through the Council’s
Housing Requirements Study (seen at Appendix A) has objectively assessed what the
housing needs for both Amber Valley and the wider Derby HMA are. It is understood that
Derby City Council and South Derbyshire District Council both continue to prepare separate,
but nevertheless aligned documents which plan or their own objectively assessed housing
needs.
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If through these documents, the remaining minimum provision of 25,950 homes is
adequately planning for then the housing need for the Derby HMA will have been met in full.
This should ensure that there will be no consequential additional demand for housing in
neighbouring Housing Market Areas, including the Nottingham Core Housing Market Area
(which includes Erewash Borough) and therefore this approach is supported.
Response
Derbyshire County Council:
The comprehensive range of robust evidence and the extensive level of collaborative
working between the four Derby HMA councils are considered to justify AVBC’s proposed
housing target of 9,400 dwellings. The broad scale of proposed housing development is,
therefore, considered appropriate and meets the requirements of Paragraph 47 of the NPPF,
which requires local planning authorities (LPA’s) to objectively assess their housing needs
and to meet those needs in full. In addition, much of Amber Valley Borough is covered by
Green Belt, therefore, it is likely that a higher housing target would impact much more
significantly on the Green Belt.
The broad distribution of housing growth is supported in principle, which seeks to focus the
majority of growth in and surrounding the Borough’s four main towns with the remainder
being accommodated on the strategic sites and within the district and local centres. This is
considered to provide for a sustainable pattern of development as required by the NPPF. It is
a continuation of the broad spatial strategy for growth in Amber Valley Borough set out in the
former East Midlands Regional Plan (EMRP).
However, it is considered premature for the County Council to comment further on the
acceptability of the Strategic Growth Sites until theses on going modelling works,
discussions and planning application consultations have been concluded.
Response
Ashfield District Council: The housing provision of a minimum of 9,400 new homes within
Amber Valley by 2028 is noted. This represents slightly less than a third of the overall Derby
Housing Market Area (HMA) requirement for a minimum of 35,350 homes across the same
period. It is understood that Derby City Council and South Derbyshire District Council both
continue to prepare separate aligned documents which plan for their own objectively
assessed housing needs. If through these documents, the remaining minimum provision of
25,950 homes is planned for, this should ensure there will be no consequential additional
demand for housing in neighbouring Housing Market Areas, including the Nottingham Core
Housing Market Area, which Ashfield District Council is included and therefore this approach
is supported.
Response
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Derbyshire County Council: The approach to economic growth in the Borough is
supported in principle. This seeks to focus economic growth and regeneration in the four
market towns of Alfreton, Belper, Heanor and Ripley; help businesses in the Borough to
grow and develop, ensuring local people benefit from growth; and draw funding into the
Borough to support community based projects. This is consistent with the aims of national
policy in the NPPF.
The LPDCS proposes to allocate approximately 75ha of business and industrial land and
was informed by the Derby HMA Employment Land Review (ELR) 2008 and the ELR update
in 2013. The ELR and ELR Update concluded that, although the Borough has a sufficient
quantity of existing and proposed employment land, many of the sites are of poor quality.
Consideration, therefore, should be given to de-allocating some of the poorer quality sites.
The LPDCS Part 1 proposes to allocate better quality employment land to attract new
businesses to the Borough and the opportunity to consider the de-allocation of poorer quality
employment sites will be addressed in the Site Allocations and Development Management
Policies DPD (part 2 of the Local Plan). This broad approach to the provision of new
employment land and de-allocation of poorer quality employment land is supported. In
accordance with Councillor Smith’s concerns, it is also recommended that Policy SS2:
Business and Industrial Land Requirements incorporates an appropriate policy criterion
which seeks to bring existing empty office and industrial units back into beneficial
employment use.
Response
These comments are in support of the policy. The policy has been amended to address
Councillor Smith’s concerns, by adding that the Borough Council will also actively encourage
the re-use of vacant business and industrial units.
Derbyshire County Council: The policy approach in policies SS3 to SS8 for the
regeneration of, and development within, the four main town centres and Langley Mill District
Centre is broadly supported.
The policy approach to Langley Mill District Centre is particularly supported as this defines a
new boundary for the District Centre, which was not defined in the adopted Amber Valley
Local Plan (AVLP).
Response
Derbyshire County Council: Similarly, the policy approach to Heanor Town Centre is
particularly supported which recognises that the town centre has a poorer level of vitality and
viability and needs to be improved. The exclusion of Tesco foodstore from the town centre
boundary is supported.
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Response
Derbyshire County Council: The main concern with the policy approach is in Policy SS8:
Development in Town Centres. Whilst the policy appropriately seeks to direct new retails,
leisure and other town centre related development to the Borough’s four main town centres
to sustain and enhance their vitality and viability, the policy does not adequately include the
principles of the sequential test for edge-of-centre and out-of-centre retail developments.
This is a key requirement of the NPPF. The policy should include additional criteria,
therefore, to assess edge-of centre and out-of-centre retail developments and include the
need to assess the availability of sites within town centres; the potential impact on the vitality
and viability of town centres; and the accessibility of the proposed development to the town
centre. It is suggested that Paragraph 4 of Policy SS8 should be amended to read as
follows:
‘Where appropriate, planning applications for developments outside town centres will need
to be supported by a retail impact assessment and/or a transport assessment’.
Response
The policy has been amended as suggested.
Erewash Borough Council: Strongly welcomes the planned retention of the Green Belt
between the towns of Heanor and Ilkeston (as situated the Borough of Amber Valley) to
ensure their continued separation in line with the purposes set out within the National
Planning Policy Framework at Paragraph 80.
Response
Derbyshire County Council: The general approach to Green Belt policy is supported in
principle, which sets out AVBC’s commitment to protect the Green Belt unless exceptional
circumstances can be demonstrated. This continues the approach to Green Belt policy set
out in the former EMRP, which recognised that, to accommodate future growth, some
development was likely to be necessary in the less sensitive areas of Green Belt around the
main towns. Policy SS10 in the LPDCS is a detailed policy to assess development in the
Green Belt, which is consistent with the NPPF.
The only locations where the Green Belt is proposed to be amended is in Ripley and
Codnor, in association with the development o the Strategic Growth Sites and proposals for
the A610 Link Road between Ripley and Codnor. In light of the transport modelling works,
the need for future evidence and on-going discussions between County Council and AVBC
officers about the Strategic Growth Sites and A610 Link Road, it is considered premature to
comment further on these matters in respect of their potential impact on the Green Belt.
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Response
These comments are in support of the policy in principle.
Derby and Derbyshire Development Control Archaeologist: Archaeological potential
within the site relates primarily to its proximity to Carnfield Hall, a known medieval site.
Geophysical and trial trenching evaluation was carried out pre-application on the northern
part of the site only, and yielded no significant archaeological results. It was recommended
therefore that archaeological evaluation of the southern part of the site could take place
post-consent, as part of a conditioned scheme.
Response
Outline planning permission has now been granted for this site, which includes conditions
relating to the need for an archaeological evaluation post-consent.
Derbyshire County Council: This site has an existing outline planning permission for 500
dwellings and a Section 106 Agreement in place.
AVBC’s Draft IDP highlights expansion of local primary schools (Copthorne Infant and Leys
Junior Schools) to serve Outseats Farm and accords this a medium priority. Policy SG1 and
the IDP should reiterate these critical (high priority) infrastructure requirements, even though
a Section 106 Agreement is in place. This would be helpful should planning permission
expire or the developer seeks a revised Section 106 Agreement at the reserved matters
stage.
Response
The policy has been amended to refer to the need for a financial contribution to be provided
towards the expansion of the Copthorne Infant and Leys Junior Schools.
Derby and Derbyshire Development Control Archaeologist: There are numerous records
for opencast coal extraction covering parts of the site (Derbyshire County Council dataset),
and this is likely to severely limit archaeological potential in the areas affected.
Archaeological potential on the site arises primarily from its proximity to the historic core of
Codnor, and the potential of medieval/post-medieval archaeology on those parts of the site
closest to the settlement, and also from a general potential for hitherto undiscovered
archaeology on large greenfield sites.
The northern part of the site contains a small remnant (four fields) of fossilised ancient strips,
and this area is therefore of enhanced historic landscape value, as well as being classified
as of Secondary Sensitivity in the Areas of Multiple Environmental Sensitivity (AMES)
defined by Derbyshire County Council – these constraints weigh against designation of the
site for development.
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Response
Criteria have been added to the policy to address these concerns.
Derbyshire County Council: It is proposed that 600 dwellings would be provided on this
site. The IDP states that Mill Hill School could accommodate some secondary pupils
associated with this development and the Aldercar Community Language College has some
limited capacity and could be expanded. The IDP states that primary pupils could be
accommodated through existing surplus capacity or the extension of existing primary
schools, with funding secured via a Section 106 Agreement.
Originally, the proposal for this site was to develop 500 dwellings. At that scale, the normal
area school may have been able to accommodate the development through expansion
(funded via Section 106 Agreement with the developer). The LPDCS is now proposing 600
dwellings. The County Council is of the view that it may be difficult to accommodate that
scale of development through expansion of the existing school. However, officers in the
County Council’s Property Services Department are currently looking at the site and
examining the feasibility of expanding the school. In the meantime, it is imperative that the
LPDCS continues to identify the site as a notified site as it is the statutory playing field for the
existing school.
The roll-out of high speed broadband is a key Government priority and is a strategic priority
project in the DIP. It should, therefore, be accorded high priority in the Borough Council’s
IDP and Policy SG2 of the LPDCS should require the design of any development proposals
to facilitate the on-site provision of high speed broadband connectivity.
DCC has identified the area east of Codnor as being of Secondary Sensitivity in terms of
Historic and Visual Sensitivity.
Impact on the landscape, landscape character and environmental sensitivity, and the
need for appropriate mitigation of such impacts, will be an important consideration in
assessing the development potential of the site and should be given a high priority in the
assessment process.
The DIP states that Loscoe Household Waste Recycling Centre (LHWRC) is over capacity.
This is acknowledged in the IDP. However, the LPDCS does not set out how this critical
infrastructure issue will be addressed and this puts the deliverability of the Core Strategy into
doubt. Policy SG3 of the LPDCS should state that development of this strategic site should
contribute towards the provision of additional household waste recycling through expansion
of LHWRC via a financial contribution secured through either a Section 106 Agreement or
CIL.
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Response
The comments regarding the position regarding the primary school and the notified site are
noted. The policy has been amended to require the design of development to facilitate the
on-site provision of high speed broadband connectivity. It is not considered appropriate for
any Section 106 Agreement to require a contribution towards the provision of additional
household waste recycling through the expansion of the Loscoe Household Waste Recycling
Centre, but consideration will be given to including it as in infrastructure project to be funded
through a Community Infrastructure Levy (CIL). Criteria has been added to the policy
requiring any development to respect the classification of this site as being of secondary
importance in DCC’s Areas of Multiple Environmental Sensitivity (AMES).
Derby and Derbyshire Development Control Archaeologist: The site contains numerous
HER records associated with historic industrial uses, in particular the site of the former
Denby Ironworks (HER 18806) with potential for associated below-ground archaeology, and
the routes of 19th century mineral tramways associated with the former mining and
ironworking interests in the area.
The site has been subject to substantial opencast coal extraction, and archaeological
potential would be limited to those areas not previously subject to extraction.
As noted in my original consultation response, the area AV13 contains numerous
undesignated heritage assets.
Areas of heritage significance should be given weight when considering allocation and the
associated policy.
Response
The policy has been amended to require appropriate design and masterplanning to protect
and enhance heritage assets, both within and adjacent to the site.
The IDP identifies the need to provide a new primary school on-site as part of the
development, and a contribution towards expanded secondary school provision, as a
medium priority. Policy SG3 of the LPDCS states that the development will need to deliver
improvements to the highway network, a new primary school on-site, an expansion to the
existing John Flamsteed Secondary School (via financial contribution secured by Section
106 Agreement), a safeguarded route for a Greenway, and protection of existing footpaths.
This is supported.
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The DIP states that LHWRC is over capacity. This is acknowledged in the IDP. However, the
LPDCS does not set out how this critical infrastructure issue will be addressed and this puts
the deliverability of the Core Strategy into doubt. Policy SG3 should state that development
of this strategic site should contribute towards the provision of additional household waste
recycling through expansion of LHWRC via a financial contribution secured through either a
Section 106 Agreement or CIL.
Response
The policy has been amended to require the design of development to facilitate the on-site
provision of high speed broadband connectivity. It is not considered appropriate for any
Section 106 Agreement to require a contribution towards the provision of additional
household waste recycling through the expansion of the Loscoe Household Waste Recycling
Centre, but consideration will be given to including it as in infrastructure project to be funded
through a Community Infrastructure Levy (CIL).
Derby and Derbyshire Development Control Archaeologist:
Newlands: There are no known archaeological or historic landscape constraints within the
site.
Taylor Lane: The eastern part of the Taylor Lane site was formerly the site of the Ormonde
Colliery (Derbyshire Historic Environment Record 20513).
Response
These comments do not require any changes to the policy.
The IDP states that Aldercar Community Language College has limited capacity and could
be expanded and that Heanor Gate Science College, which is an academy, is at capacity,
and would be difficult to expand. The IDP also states that local primary schools are at
capacity and that this is a constraint that will require further liaison with the Local Education
Authority.
Development at this site may require education contributions towards both primary and
secondary provision, but not for the whole scale of housing proposed.
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The DIP states that LHWRC is over capacity. This is acknowledged in the IDP. However, the
LPDCS does not set out how this critical infrastructure issue will be addressed and this puts
the deliverability of the Core Strategy into doubt. Policy SG4 should state that development
of this strategic site should contribute towards the provision of additional household waste
recycling through expansion of LHWRC via a financial contribution secured through either a
Section 106 Agreement or CIL.
Response
The policy has been amended to require a financial contribution towards primary and
secondary school provision in the locality. It has also been amended to require the design of
development to facilitate the on-site provision of high speed broadband connectivity. It is not
considered appropriate for any Section 106 Agreement to require a contribution towards the
provision of additional household waste recycling through the expansion of the Loscoe
Household Waste Recycling Centre, but consideration will be given to including it as in
infrastructure project to be funded through a Community Infrastructure Levy (CIL).
Derby and Derbyshire Development Control Archaeologist: The site was subject to
archaeological evaluation at the pre-application stage and no remains of archaeological
significance were identified. No archaeological work is therefore required at the post-consent
stage.
Derbyshire County Council: This site has planning permission for 530 dwellings and a
Section 106 Agreement in place. This policy is supported.
Response
These comments support the policy.
Derby and Derbyshire Development Control Archaeologist: The site has been subject to
archaeological desk-based assessment and geophysical survey at the pre-application stage.
Derbyshire County Council: AVBC has resolved to grant outline planning permission for
360 dwellings on the site. This policy is supported.
DCC has identified an area including this site as being of Secondary Sensitivity in terms
of Historic and Visual Sensitivity.
This area is identified as being in the ‘Derbyshire Coalfield National Character Area’, and
part of the finer landscape subdivision ‘Coalfield Village Farmlands’ landscape character
type where the settlement pattern is characterised by small villages expanded by red
brick former mining terraces and ribbon development.
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Impact on the landscape, landscape character and environmental sensitivity, and the
need for appropriate mitigation of such impacts, will be an important consideration in
assessing the development potential of the site and should be given a high priority in the
assessment process.
Response
Criteria has been added to the policy requiring any development to be designed to respect
the classification of this site as being of secondary importance in DCC’s Areas of Multiple
Environmental Sensitivity (AMES).
Derby and Derbyshire Development Control Archaeologist: The majority of the site has
been subject to opencast coal extraction and therefore retains no archaeological potential
over much of its area. The eastern boundary of the site is formed by the former course of a
19th century mineral tramway (HER 24708) associated with the Butterley Works site and
retaining evidence for former cuttings along the route. Development in this location may
therefore provide opportunities for conservation and enhancement of this route as part of the
Green Infrastructure associated with the site, and any application for the relevant areas
should contain a brief heritage appraisal in relation to the surviving fabric of the historic
tramway and any proposed enhancement/management.
Response
The policy has been amended to require that development is of an appropriate design that
protects and enhances heritage assets and their settings.
The LPDCS states that the site needs to help deliver the A610 Link Road, additional open
space, and enhancements to existing footpaths.
The IDP states that Mill Hill secondary school could accommodate some pupils and that
primary school pupils could be accommodated through existing capacity and expansion to
existing schools, via Section 106 Agreement, if necessary. This is consistent with advice
provided to AVBC previously by the County Council’s Children and Younger Adults
Department (CAYA). The County Council’s Property Services Department is undertaking a
feasibility study to look at the potential to expand the existing school.
Policy SG7 should refer to the opportunity for enhancing existing footpaths in order to
provide connections to and enhance the Derbyshire Greenway Network.
Response
The policy has been amended to refer to the opportunity for enhancing existing footpaths in
order to provide connections to and enhance the Derbyshire Greenway Network.
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Derbyshire County Council: The LPDCS requires development of 0.5ha or 15 dwellings or
more to provide 30% affordable housing, in line with evidence in the Derby HMA SHMA. It
must be acknowledged that affordable housing provision has a very significant impact on the
viability of development. Requiring this level of affordable housing could impact significantly
on the level of funding available for infrastructure.
Response
These comments are noted.
Policy H4 provides AVBC with the ability to assess applications on a case by case basis and
to consider waiving any requirements for developer contributions in order to ensure schemes
remain viable. However, it is not clear how the critical infrastructure required to support
development will be delivered in areas of poor viability where exceptions are made under
this policy.
Policy H4 should set out other potential sources of funding (potentially borrowing, Regional
Growth Fund, capital programmes, CIL, etc) that can be used to fund infrastructure in areas
of poor viability where developer contribution requirements under Section 106 Agreements
are waivered. This will help to ensure the Core Strategy is flexible and deliverable.
Response
The policy has been amended to require that the Council will expect all other potential
sources of funding to make a scheme policy compliant to have been investigated.
Derbyshire County Council: This policy allows for, amongst other things, developments to
be designed to be adaptable and accessible and to adapt to changing lifestyle needs. The
policy also requires the provision of space for increased recycling receptacles and access for
refuse collection as part of the design of development. This is supported.
The roll-out of high speed broadband is a key Government priority and is a high strategic
priority project in the DIP. It should therefore be accorded high priority in the Borough
Council’s IDP and Policy E2 of the LPDCS should require the design of development
proposals to facilitate the on-site provision of high speed broadband connectivity.
Response
The policy has been amended to require the design of development to facilitate the on-site
provision of high speed broadband connectivity.
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Derbyshire County Council: Whilst Policy E3: Historic Environment sets out AVBC’s
commitment to support the Outstanding Universal Value, integrity, authenticity and
significance of the Derwent Valley Mills World Heritage Site (DVMWHS) and its setting, it is
recommended that:
•
•
•
There is a separate criteria based policy for the DVMWHS and its buffer zone.
The policy should require development proposals to demonstrate how they would
contribute towards the achievement of the management objectives outlined in
DVMWHS Management Plan and enhance the WHS.
The policy should encourage the interpretation and promotion of the significance of
the WHS and its assets.
It is considered important that a consistent policy approach is taken to the DVMWHS by
AVBC and the City Council in their Local Plans.
Preservation of the route of the Cromford Canal and restoration of its features or stretches
has the potential to significantly contribute to the objectives set out in the LPDCS, for
example, by contributing to the landscape quality of Amber Valley (including the landscape
character within the Green Belt), to flood risk management and the quality and design of
development. The route of Cromford Canal is a direct link between Amber Valley and the
DVMWHS.
By protecting and enhancing the canal route there is further potential to support the
objectives to improve green infrastructure, parks and open spaces, community, leisure and
health facilities and strategic transport infrastructure projects.
In conclusion, it would be appropriate therefore if the route of the Cromford Canal was to be
specifically named in ‘the areas and buildings of architectural or historic interest… which will
be preserved and enhanced and protected from unsympathetic development’ and included
in the local list of non-designated Heritage Assets.
Response
These suggested changes have been made to the policy. The existing saved Local Plan
policy on the World Heritage (EN29) will remain and will be replaced and amended as
necessary by a policy in the Site Allocations and Development Management Policies DPD,
which will form part 2 of the new Local Plan.
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Derbyshire County Council: Extensive comments on the landscape and visual impact
issues have been provided by the County Council’s Landscape officers. The salient points of
the comments are outlined below which:
•
•
•
•
Fully support the environmental objectives, in particular, those related to
conservation and enhancement of the Borough’s landscape, ecology and the
promotion of quality design;
Express concern about inconsistencies in the identification of environmental base
data (particularly Areas of Multiple Environmental Sensitivity (AMES), which would
have been defined by Derbyshire County Council, and the omission in the Core
Strategy to explain clearly its use in the decision making process;
Suggest amendments to the policy background text to improve clarity and
consistency; and
Suggest amendments to the policy wording to improve clarity and ensure all relevant
aspects are covered.
Detailed landscape character, visual impact and environmental sensitivity comments have
been provided to AVBC on various Strategic Growth Sites and on a number of subsequent
outline applications, particularly relating to Ripley Gateway. These comments remain
outstanding and relevant.
Response
The Core Strategy policies, site assessments and the Sustainability Appraisal have been
amended where relevant to refer to Areas of Multiple Environmental Sensitivity (AMES).
Derbyshire County Council: As the Highways Authority for the area, the County Council
has concerns about the rate of progress on the development of the transportation evidence
base, in particular, the identification of transport infrastructure needed to support
development growth proposed in the Draft Core Strategy.
A significant amount of new housing development on a number of the Strategic Growth Sites
has already been consented by AVBC with minimal off-site transportation infrastructure.
These include Outseats Farm, Alfreton and Coppice Farm, Ripley. Planning Permission has
been granted for 530 dwellings on land at Radbourne Lane, Mackworth. This does, however,
include provision of off-site infrastructure and a Travel Plan.
Land is identified to the north of Denby as a Strategic Growth Site for around 1,800
dwellings. Whilst some traffic impact assessment work has been provided by an interested
party promoting the site, this only sets out to establish that a new grade separated junction
onto the A38 is not required.
However, it does not consider either the impact of existing consented development in the
area or the cumulative impact of other development that may emerge from the Core
Strategy.
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Land is identified at Newlands and Taylors Lane, Heanor, as a Strategic Growth Site for
around 500 dwellings. Again, little transport evidence has been provided apart from the
submission of some traffic impact assessment work by an interested party promoting the
sites.
Key evidence is discussed on page 58 of the LPDCS, which refers both to the Derby HMA
Transport Modelling that is taking place and a Derby HMA Transport Position Statement.
However, at the time of writing, both transportation papers are concerned solely with the
principal urban areas of Derby and say very little about the impacts of potential development
over the wider highway and transport network(s) beyond Derby. The Transport Position
Statement does not mention about Amber Valley.
It is considered that AVBC’s Core Strategy would be greatly strengthened by a more
comprehensive approach to transportation assessment and analysis to enhance the
evidence base for land allocation and it is recommended that this is prepared in advance of
the EIP.
Response
There are a number of opportunities across the Borough to develop the Derbyshire
Greenway network, helping to improve community access for disabled people, walking,
cycling and horse riding. The County Council would like to see the Derbyshire Greenway
network explicitly referenced by this policy (with an accompanying map).
Response
The policy now refers to the Derbyshire Greenway network needing to be protected and
enhanced, and a key diagram has been included in the Core Strategy which shows the
location of this network.
Derbyshire County Council: Strategic Transport Infrastructure Priorities indicates that
AVBC will support the provision of a new A610 Link Road between Ripley and Codnor in
conjunction with other development proposals, which would include new housing, retails and
employment development. At the current time, however, no evidence has been provided
regarding feasibility, deliverability or impact of the scheme over the wider highway network
or indeed its environmental impact. It is anticipated, however, that by the time the Core
Strategy reaches EIP, a planning application would have been submitted for the A610 Link
Road, which should include extensive evidence relating to these issues.
Response
A planning application for this scheme has now been submitted which includes extensive
evidence relating to these issues.
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Derbyshire County Council: Policy IN5 could be significantly improved by setting out
exactly what items of infrastructure are required and seen as critical to delivery of the Local
Plan Core Strategy and clearly stating how that infrastructure will be funded and delivered.
Response
The infrastructure Delivery Plan will set out what items of infrastructure are required and
seen as critical to the delivery of the Local Plan Core Strategy. As this policy already states
that infrastructure delivery will take place through the Infrastructure Delivery Plan, it is
considered that no change to the policy is required.
Derbyshire County Council: Policy IN6 could be improved significantly by identifying the
key items of infrastructure that are critical to delivery of the LPDCS, what the funding gap is,
and exactly what sources of funding will be sought to help bridge the gap. Clarity on AVBC’s
position in introducing a CIL would be helpful.
Response
The infrastructure Delivery Plan will set out what items of infrastructure are required and
seen as critical to the delivery of the Local Plan Core Strategy. As this policy already states
that infrastructure delivery will take place through the Infrastructure Delivery Plan, it is
considered that no change to the policy is required. The Borough Council have now resolved
to start the process of implementing a CIL.
Any further comments you wish to make on the content of the Plan?
Greater Nottingham Growth Point on behalf of Broxtowe Borough Council, Erewash
Borough Council, Gedling Borough Council, Nottingham City Council and Rushcliffe
Borough Council: It is noted that the Core Strategy refers to a housing provision for the
Derby Housing Market Area of 35,350 homes between 2008 and 2028, of which 9,400 are
provided for in Amber Valley. As this is based on an objective assessment of housing need,
if both Derby City Council and South Derbyshire District Council plan for the remaining
housing provision, the Core Strategies will accord with the National Planning Policy
Framework requirement that local plans should meet objectively assessed needs. This
should ensure that there will be no consequential additional demand for housing in
neighbouring Housing Market Areas, including Nottingham Core Housing Market Area. This
approach is supported.
I note references in the appendices to the level of growth in the Nottingham Housing Market
Area, which appears to be taken from the Broxtowe, Gedling and Nottingham City Aligned
Core Strategies, and therefore missed housing provision in Rushcliffe and Erewash
Borough’s Core Strategies (assuming Rushcliffe make the proposed modifications agreed at
their cabinet). For the avoidance of doubt, the Nottingham Core Housing Market Area
housing provision is 49,950 new homes between 2011 and 2028.
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Response
This reference has been deleted.
Broxtowe Borough Council: In the “Scale of Housing” section of Appendix A, it is stated
that; “By way of comparison, this exceeds the increase in the housing stock being proposed
in the Greater Nottingham aligned Core Strategies.”
If this statement is to be retained, it should be made clear that the Aligned Core Strategies of
Broxtowe, Gedling and Nottingham City cover only part of the Greater Nottingham HMA and
that the figure for the whole of the Nottingham HMA includes figures in the Rushcliffe and
Erewash Core Strategies, which, in combination with the Aligned Core Strategies, amount to
provision for 49,950 new homes.
Response
This reference has been deleted.
Derbyshire County Council Officer’s: Overall, the LPDCS is broadly supported, although
there are various outstanding issues that require further cooperative working between the
County Council and AVBC, particularly relating to transport, education provision and other
infrastructure requirements. Detailed comments on a number of issues, particularly town
centres, heritage and strategic infrastructure planning and service delivery (particularly
relating to the seven Strategic Growth Sites) are included.
Response
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7.
Comments from national bodies
Comments on the Spatial Portrait of Amber Valley
English Heritage: We welcome reference to historic environment attributes within the
spatial portrait including the Derwent Valley Mills World Heritage Site (DVMWHS).
National Trust: Whilst quite brief the Spatial Portrait in most respects adequately
summarises the key economic, social and environmental features of the Borough – the
exception is the lack of any particular reference to its nature conservation resources which
are also a valued feature, a small addition to the text would be appropriate. Apart from the
exception noted above there is a reasonable balance within the Spatial Portrait; any other
significant additional changes are likely to lead to requests to add more detail to the other
areas.
Response
The text has been amended to refer to the high quality of flora and fauna in the Borough.
Comments on the Spatial Vision of Amber Valley
English Heritage: We welcome reference to historic environment attributes within the
vision.
National Trust: Generally the proposed Spatial Vision is supported, with the section on the
Historic Environment being suitably worded and supported accordingly. However, it is
considered that the part relating to nature conservation is unambitious, especially so in the
context of relatively poor levels of bio-diversity and the ambitions of strategies such as the
bio-diversity action plan. It is therefore requested that the following addition is made:
“All important green open spaces and areas of nature conservation interest in the Borough,
including the Derwent Valley corridor, will be protected and enhanced wherever practical.” It
is considered that such wording would also be consistent with the approach then taken in
Strategic Objective 8.
Response
The text has been amended as requested.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: More
thought needs to be given to the vision for Belper, ideally through a Neighbourhood Plan.
Although tourism can contribute to the diversity and vibrancy of the town, its economy should
not become reliant on tourism. Remaining manufacturing industries should be protected, and
links with the creative industries promoted, e.g. design, fashion, film etc.
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Response
A Neighbourhood Plan for the Parish of Belper is a matter for Belper Town Council to
consider.
Sport England: Welcome the commitment to protecting important green open spaces,
though clarity required about what constitutes ‘important green open spaces’.
Also support the last element of the vision concerning the delivery of high standards and
ease of accessibility in respect of all open space, parks, recreational areas, leisure facilities
and community facilities (which is taken to include indoor and outdoor sports facilities), and
their acknowledged contribution to the network of green infrastructure.
Response
This support is noted. It is not considered necessary to explain what constitutes important
green open spaces, as examples are provided in the vision.
Natural England:
Natural England generally supports the vision particularly the paragraph that relates to the
protection of nature conservation interests, green spaces and the Derwent Valley corridor.
We also welcome the reference to the green infrastructure network.
Response
This support is noted.
The Woodland Trust: It is disappointing that the paragraph in the vision on greenspace is
the last one. Also, it talks about parks and recreational areas but does not make any mention
of natural greenspace or trees and woods.
The Forestry Commission's "Case for Trees" in 2010 said the following:
"there is a growing realisation among academics about the important role trees play in our
urban as well as the rural environment. It has long been accepted and confirmed by
numerous studies that trees absorb pollutants in our cities with measurable benefits to
people’s health – such as reducing asthma levels. Yet trees also deliver a whole host of
other extraordinary economic, environmental and social benefits"
Response
The paragraph on green open space is no longer the last one. The vision has been
amended to refer to access to natural greenspace and woodland.
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National Trust: This is a good, well-worded, set of Strategic Objectives that the National
Trust is pleased to support.
Response
Environment Agency: The EA agrees with proposed Strategic Objectives 1,8 and 13.
Response
Sport England: Support objective 6 that aims to improve health and well-being but consider
that express reference should be made to sport as one of the activities specified within the
objective.
Welcome objective 9 relating to the ensuring availability of easily accessible space and
facilities, but consider that sports facilities should additionally be expressly referenced.
Response
These objectives have been amended as suggested.
Natural England: We support objective 6 which encourages the health and well-being of
local people but we would also suggest that it should note the importance of access to the
natural environment as a leisure and cultural activity. We also support objectives 7 and 8
which cover our interests in landscape and biodiversity. Whilst we welcome objective 9 we
would like to see green infrastructure specifically mentioned within the wording.
Response
These objectives have been amended as suggested.
English Heritage: We welcome the inclusion of a strategic objective relating to the
protection and enhancement of heritage assets (SO7).
Response
The Woodland Trust: Welcome in particular Objective 8 on nature conservation and in
particular the emphasis on reversing fragmentation and improving connectivity. For the
reasons outlined in the previous section, we would like to see this expanded to include a
reference to trees and woodland.
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Response
This objective has been amended to refer to woodland.
National Trust: The approach adopted is appropriate to the circumstances of Amber Valley
and is supported. Arguably the terminology in Section 6.4 could be more positively worded –
indeed the title could equally be “Safeguarding Key Amber Valley Assets.” This is especially
true in terms of the heritage resources (referred to in the NPPF as heritage assets)…so the
sentence part way through this paragraph could be amended so as to more appropriately
read: “Other important constraints assets are associated…”
Whilst a case might be advanced that turning this section around to refer to assets is not as
appropriate in the context of flood risk, the case can in fact be made that the areas that are
at risk of flooding are actually assets as these are the floodplain areas that temporarily
accommodate excess run off and thereby protect built up areas away from flooding impacts;
i.e. they are a flood prevention asset that benefits adjoin land and property. (NB there
appears to be a small typographical error at the start of this Section (page 12): “The principal
focus for new development across the Borough will be that of urban concentration…”)
Response
The title of section 6.4 has been changed to “Safeguarding Key Amber Valley Assets” as
suggested. The suggested changes to the text in this section has also been amended as
suggested and the typographical error has been corrected.
Environment Agency: The EA agrees with the focus on maximising the use of brownfield
land, which provides an opportunity to remediate and clean-up sites contaminated by a
legacy of industrial uses.
Response
English Heritage: We note the proposed levels of growth and its distribution to be mainly in
the market towns of Alfreton, Belper, Heanor and Ripley. We particularly support the
reference to the need for development to respect areas of the Borough that are sensitive in
terms of landscape and heritage assets and their settings. We feel that this reference here is
essential given the heritage assets (including the World Heritage Site).
Response
104
National Trust: The Policy as worded is supported. The specific references to respecting
landscape and heritage are important and appropriate having regard to the particular
circumstances that apply in Amber Valley.
Response
National Trust: The sequential approach as set out in this Policy is supported, as is the
hierarchy of settlements which clearly reflect their respective roles. The cross-reference in
the individual centre policies SS4 to SS7 to Policy E3 is important and appropriate.
Response
English Heritage: We welcome reference within this policy to policy E3 (The Historic
Environment) and reference to assets within the supporting text.
Response
English Heritage: We welcome the references made within the supporting text to the
historic environment attributes within Belper, which falls within the World Heritage Site. We
consider, however, that the policy requires amending in order to ensure its effectiveness and
compliance with the NPPF.
Specifically, we consider that reference should be made within the policy itself to the
protection of the Outstanding Universal Value of the World Heritage Site. We suggest the
following amendment:
“Planning permission will be granted for development and uses in Belper town centre that
will improve its attraction for tourists as well as maintaining and improving its historic
character, appearance, and the Outstanding Universal Value as a World Heritage Site”
We also consider that reference should be made within the policy to the ‘Land between the
A6 and the River Derwent SPD’ as this relates directly to the regeneration of the town centre
for this area of land.
This document should also be added into the list under ‘Delivery’ on page 27.
105
Response
The policy and background text have been amended as suggested.
English Heritage: We welcome reference to policy E3 within the policy text.
Response
English Heritage: We welcome reference to protection of character and appearance of this
area as a traditional market town, as well as reference to policy E3 within the policy text.
Response
English Heritage: We note the contents of this policy. We are not sure how this policy
relates to Policy SS3 and the Retail Study (2011) which cites the need for comparison retail.
We are also unsure why only policy SS7 (Town Centre Regeneration in Ripley) is referenced
here – other policies SS3-SS6 are also relevant. Again we consider reference to the SPD for
Belper is essential here.
Response
National Trust: No objection to the approach set out here but would query two matters.
Firstly, the Policy appears to relate to individual plans for each of the main centres, so
presumably the first sentence of Policy SS8 should read: “Within the Borough’s town
centres, as shown on the following maps, planning permission for…”
Secondly, in the final paragraph the cross reference appears to be to the wrong policy
number; i.e. should read: “…the criteria in policy SS79 (Primary Shopping Frontages) will
also need to be satisfied”.
Response
The policy and background text have been corrected as suggested.
106
English Heritage: We welcome reference within criterion c) in relation to the protection of
heritage assets.
Response
Derbyshire Wildlife Trust: We support this policy on Green Belt.
Response
Sport England: Broadly support paragraph b), but consider that it should be revised to state
‘appropriate’ rather than ‘essential’ facilities for outdoor sport and outdoor recreation….,
thereby making it consistent with paragraph 89 of the NPPF.
Response
Natural England:
Although we recognise that the green belt designation is not made for the purpose of natural
environment protection as such, we nevertheless suggest that there is potential for it to
deliver more positive benefits for the natural environment and people’s enjoyment of it and to
play a role in climate change adaptation. We would therefore suggest that this policy should
encourage the taking of any opportunities to link the green belt into green infrastructure and
ecological networks both within the urban areas and with the open countryside, and should
state that wherever possible the land should be used for positive purposes. This would be
consistent with the advice in paragraph 81 of the National Planning Policy Framework
(NPPF).
Response
National Trust: The National Trust has no specific comments to make upon these detailed
proposals. However, more generally it is noted that there is an intention to remove land from
the Green Belt and potentially at a later date the case might be made to review other land
outside the current Green Belt limits to see if changes or new/improved information or
understanding would warrant any additions to the current extent of Green Belt.
107
Response
This comment is noted.
Derbyshire Wildlife Trust: The proposed changes to the Green Belt will result in additional
areas of countryside being exposed to future development. We consider that there could be
greater impacts on wildlife associated with land east of Codnor that the land at the north and
east of Ripley. However, we are not aware of any detailed ecological surveys of these two
areas. Our own data suggests that brown hares could be displaced and a range of common
woodland, hedgerow, garden and arable bird species could be affected.
Response
Criteria have been added to the policies SG2, SG7 and IN4 to address these concerns.
National Trust: The approach set out in Policy SS12 is agreed and supported. However, the
Policy does indicate that exceptionally development will take place in the countryside; but
unlike other Policies it contains no stipulations or guidance on the form or appearance of
such development. It is suggested that cross-references to other policies, such as E2, E3
and E4 would be appropriate, or alternatively the inclusion of a list of detailed criteria that
any development would need to comply with.
Response
The policy has been amended to cross reference these policies as suggested.
English Heritage: We consider that this policy, as present, is unsound in relation to the
allocation of this site. Whilst we note that outline consent has been granted, no further policy
guidance is given for which any future reserved matters consent should take into account.
As stated in our representation in December 2012, development at this site is likely to impact
on the setting of the grade II* listed Carnfield Hall and the setting of Carnfield Hall
Conservation Area. We consider that criteria for this policy should be included. This should
make reference to the need to protect the setting of heritage assets through appropriate
design and masterplanning.
Supporting text to the policy should also be developed and reference should be made to
these issues.
Response
The policy and supporting text have been amended to address these issues.
108
Sport England: Evidence based approach should be adopted to determine form of open
space drawing on Playing Pitch Strategy. The Infrastructure Delivery Plan should be updated
as necessary.
Response
The Infrastructure Delivery Plan has been amended in accordance with this suggestion.
English Heritage: We provided comments with regard to this site and the proposed road in
our last consultation response, dated 19th December 2012 in terms of impacts of the
proposed allocation and road upon the setting of heritage assets associated with Codnor
Castle, including listed buildings, a conservation area and scheduled monument. The
remains of the Castle are on the 2013 ‘Heritage at Risk Register.’ In addition the grade II
listed Castle Farmhouse is also on the buildings at risk register by Derbyshire County
Council.
We are therefore concerned that the policy makes no reference to the need to protect the
setting of these assets and consider that without such a reference, the policy will be unsound
as it is not justified in excluding this, it will be ineffective in the protection of historic
environment considerations and not be in accordance with relevant historic environment
paragraphs of the NPPF.
We consider that a further criterion is required in order to make this sound.
these issues.
Response
The policy and supporting text have been amended to address these issues.
Derbyshire Wildlife Trust: Are concerned about the potentially adverse impacts on
biodiversity and countryside locally. We would strongly urge a more detailed ecological
appraisal of this area to provide greater clarity on potential impacts and help inform any
decision on the number and scale of house buildings here.
Response
The policy has been amended to address these issues. Any planning application will be
required to be accompanied by a detailed ecological appraisal of this area.
109
Sport England: Evidence based approach should be adopted to determine form of open
space drawing on Playing Pitch Strategy. The Infrastructure Delivery Plan should be updated
as necessary.
Response
Natural England: We note that the Sustainability Report (18.6.7) considers that the
development of this site will have a significant impact on the character of the built and
natural environment, and from our desk-based study we agree with this assessment as
regards the natural environment. We therefore suggest that wording of this policy needs to
be strengthened to ensure that settlement design protects and where possible enhances
landscape character, habitat creation and connectivity and green infrastructure.
We acknowledge that the policy has identified the need for public open space and the
protection and enhancement of footpaths. We would also expect to see, within the policy, a
requirement for these to be linked to green infrastructure, to habitat provision, and explicit
links to policies E4 on landscape and E6 on biodiversity.
Response
The policy has been amended in accordance with these suggestions.
English Heritage: We provided detailed comments in respect of this site allocation in our
letter dated 19th March 2012. At this time, we identified impacts upon the setting of the
grade II* listed Park Hall and grade II listed Gate Piers and Garden Walls. We also identified
potential impacts on the World Heritage Site, as, although outside of this designation and
buffer zone, views into this area are enjoyed from Park Hall due to its elevated position. Also
of historic interest is the former industrial nature of the site, associated with the former
Denby Colliery and a Brick and Tile Works.
setting of these assets and consider that without such a reference, the policy will be unsound
as it is not justified in excluding this, it will be ineffective in the protection of historic
environment considerations and not be in accordance with relevant historic environment
paragraphs of the NPPF.
these issues.
110
Response
The policy and supporting text have been amended in accordance with these suggestions. It
is not considered, however, that explicit reference needs to be made to the setting of the
World Heritage Site, as those parts of the site that may be visible from the World Heritage
site will remain undeveloped to protect the setting of Park Hall.
The Highways Agency: The majority of proposed housing sites on their own will have fairly
limited impacts on the A38. The exception to this is the proposed strategic growth site to the
north of Denby for some 1,800 dwellings. The Agency notes that Policy SG3 indicates that
this development will involve ‘major improvements to the surrounding road infrastructure’
(SG3c). The Agency has previously engaged with the Council and the promoters of the
Denby site, but the nature of measures required to enable the site to satisfactorily access the
A38 have not yet been determined.
The Agency would like Policy SG3 (C) to be amended to specifically refer to the need for
appropriate A38 improvements to mitigate the impact of the Denby site as follows:
c) Major improvements to the surrounding road infrastructure, including either a significant
upgrade to the A38 Coxbench junction or provision of a new A38 junction to serve the site.
Response
The policy has been amended in accordance with these suggestions.
Derbyshire Wildlife Trust: Part of the site is of exceptional wildlife value (designated as a
Local Wildlife Site and supports European and UK protected species) and there may be
conflict between the protection of wildlife and remediation followed by subsequent
development. This policy also needs to satisfy policy E6.
Response
The policy has been amended to refer to the need for development to be designed to protect
wildlife and habitat connectivity, and enhance biodiversity. The need to also comply with
policy E6 has also been added.
Environment Agency: The EA agrees with the requirement to remediate and clean-up this
site, which has been affected by historic land contamination.
Response
Severn Trent Water: We promoted a new sewer capacity project in January 2013 to start to
look in more detail at what sewer capacity improvements would be required to accommodate
the strategic development allocation at Cinderhill.
111
The timescales for this project will be dependent on when the developer is due to connect
and phasing but at present improvements are planned for completion in 2017/18. This can
however be brought forward if development phasing warrants capacity improvements to be
provided earlier. At present we do not envisage any capacity issues which would delay
development on the Cinderhill site but it would be useful if you could provide an indication on
phasing if possible.
With regard to developer contributions, all off-site capacity improvements to the existing
sewerage system will be wholly paid for by Severn Trent. The developer will be responsible
for paying for all on-site new sewers within the development plus the cost of connection to
the existing sewers. They will also be responsible for paying a connection charge per
property, which is a standard charge for all new development connections.
Response
Natural England: We are concerned about the policy for development proposed for this
allocation because the site incorporates a large part of a 14.6ha wildlife site, the Cinderhill
Tar Pits and Morrells Brook Local Site (Habitat Mosaic). This is linked to the Morrells Wood
Local Wildlife site and ancient semi natural woodland. These local sites are connected, and
therefore make an important contribution to the wider ecological network, the protection and
enhancement of which is a specific aim of the National Planning Policy Framework (NPPF).
We would like to see the policy for development on this site itself incorporate stronger
protections for wildlife and habitat connectivity, and require developers to look for
opportunities to enhance biodiversity, particularly in view of resilience to climate change.
Response
The policy has been amended to refer to the need for development to be designed to protect
wildlife and habitat connectivity, and enhance biodiversity. The need to also comply with
policy E6 has also been added.
Natural England: We note that the description of this site mentions there is a nature
conservation site which is part of the Bailey Brook Marsh Local Wildlife Site. We would
suggest that this advice is strengthened to include the requirement for the protection and
enhancement of this nature conservation site.
Response
The policy has been amended to refer to the need for development to be designed to retain
and enhance areas of nature conservation interest, including the adjoining Bailey Brook
Marsh Local Wildlife Site.
112
Derbyshire Wildlife Trust: This policy also needs to satisfy policy E6.
Response
The policy now refers to the need for development to also satisfy policy E6.
English Heritage: We consider that this policy, as present, is unsound in relation to the
allocation of this site. Whilst we note that outline consent has been granted, no further policy
guidance is given for which any future reserved matters consent should take into account.
This allocation sits away from designated heritage assets. In order to reduce impact on their
setting, however, we still consider that criteria are required in order to ensure that setting of
heritage assets is protected here.
Response
The policy has been amended by adding criteria that requires appropriate design and
masterplanning to protect the setting of heritage assets.
National Trust: It is considered essential that any policy reference to this site, or
alternatively any reference in the supporting text in the DPD, makes specific mention of
development needing to be in accordance with the adopted SPD for this site.
Response
The policy has been amended to require development to comply with the SPD for this site.
English Heritage: As per our other comments for sites, whilst we note that outline
permission is likely to be granted here, policy criteria are required in order to guide any
reserved matters consent.
Response
The policy has been amended to require development to be of an appropriate design to
protect the setting of heritage assets.
English Heritage: We have previously made comment that this site may impact on the area
in terms of its industrial interest and in relation to Butterley Park. A grade II listed milepost
also lies adjacent to the site.
113
setting of these assets and consider that without such a reference, the policy will be
unsound.
Response
The policy has been amended to require development to be of an appropriate design to
protect the setting of heritage assets.
Derbyshire Wildlife Trust: Are concerned about the potentially adverse impacts on
biodiversity and countryside locally. We believe that, should this proposal be taken forward,
the policy should ensure that land is retained and enhanced for biodiversity especially along
the former railway line and in relation to hydrology and drainage which could affect the Carr
Wood LNR downstream.
Response
The policy has been amended to require development to retain and enhance land for
biodiversity and drainage, especially along the former railway line and in relation to
hydrology and drainage, having regard to any impact on the Carr Wood Local Nature
Reserve.
Sport England: Need to ensure existing playing fields are protected in line with NPPF
paragraph 74 and Sport England’s Playing Fields Policy. Evidence based approach should
be adopted to determine form of open space drawing on the Playing Pitch Strategy. The
Infrastructure Delivery Plan should be updated to reflect the above as necessary.
Response
Natural England: The development of this site will have a significant impact on the
character of the built and natural environment and impact on the resilience of wildlife to
climate change, Natural England believes that the policy for this development should be
strengthened. Our comments on SG2, Codnor, apply equally here, and we would like to see
the same requirements for enhancement of landscape character, habitat creation and
connectivity, and maximising of green infrastructure benefits within this site. As with SG2, we
would suggest that it is essential that the design of any proposed development is carefully
landscaped, particularly at the edges, so that it is compatible with the surrounding
countryside and that green infrastructure is incorporated at the early stages of the
masterplan process. All opportunities should be taken to enhance the quality of the green
infrastructure and wildlife habitat, possibly linking to Butterley Park Wood Local Wildlife Site,
and increase the recreational connections into the surrounding countryside.
114
We acknowledge that the policy has identified the need for public open space and the
protection and enhancement of footpaths but we would like the requirement for these to be
linked to green infrastructure.
Response
The policy has been amended to require development to retain and enhance land for
biodiversity and drainage, especially along the former railway line and in relation to
hydrology and drainage, having regard to any impact on the Carr Wood Local Nature
Reserve. It has also been amended to require development to enhance landscape
character, habitat creation and connectivity and green infrastructure through appropriate
design and masterplanning, and maximising of green infrastructure benefits within the site.
Comments on Policy H1: Housing Types, Mix and Choice
English Heritage: We note the contents of this policy. We consider that cross reference
should be made within this to policy E2, regarding design and quality to ensure that types
and mix, also reflects the character of the local area.
National Trust: a cross-reference to Policy E2 would be appropriate, but otherwise no
comments to make.
Response
The policy has been amended to refer to the need for development to also comply with the
criteria in policy E2.
National Trust: Not convinced about either the overall approach or the detailed wording
proposed for Policy R2. As it stands the Policy is intended to cover all forms of renewable
energy (solar, hydro etc, not solely wind) and at all scales (i.e. including micro-renewables).
In this context some of the criteria in the Policy appear to be lacking; in particular criterion d)
appears to be directly related to wind turbine developments, but not to address specific
geology/hydrology/flood issues that could arise from hydro developments, or glare
associated with solar arrays.
It appears to the Trust that this needs to be addressed by: a) a more general Policy
approach that is backed up by detailed guidance in a separate document [Development
Management DPD or Renewables SPD]; or b) the introduction of separate Policies for
commercial scale renewables and micro-renewables – with the former sub-divided to give
technology-specific criteria for wind, biomass, hydro, solar etc.
Response
The policy has been amended to address these concerns.
115
Environment Agency: The EA supports the content of this Policy on reducing the use of
non-renewable energy resources, particularly in terms of water efficiency; reducing waste;
promoting sustainable forms of drainage; and improving and protecting surface and ground
waters.
Response
The support for this policy is noted.
English Heritage: We note and welcome reference to World Heritage Site and protection of
Outstanding Universal Value in criterion a. We are however concerned in relation to the
latter part of this which states ‘in the case of adverse effect, there is no alternative solution
and there are imperative reasons of overriding public interest’ Paragraph 132 states that
substantial harm to World Heritage Sites should be wholly exceptional. Paragraph 133 sets
out the tests against which this is assessed. This sentence within the policy does not accord
with these paragraphs in relation to the harm being wholly exceptional. We consider that this
sentence should be deleted.
We note reference to heritage assets in criterion b, however we are concerned in relation to
the proposed wording. Specifically we are unsure to what ‘objectives of designation will not
be compromised’ means. Significance of heritage assets and their setting should be
assessed when considering impacts of proposals. The NPPF is clear in paragraph 132 that
great weight should be given to the asset’s conservation and that substantial harm to
significance should be exceptional or wholly exceptional. The wording of this criterion does
not reflect this and therefore is not compliant with the NPPF. We suggest that this is
amended to state:
b) the significance of heritage assets, including their setting, is not harmed.
Response
This policy has been changed as suggested.
The Woodland Trust: Welcome the reference to woodfuel on page 70 as a source of
renewable energy and we recognise the need to ensure that this is obtained from
sustainably managed sources.
Would like to see more use of wood as a fuel providing that harvesting is carried out
sensitively and respects the biodiversity, scale and cultural importance of the site especially
ancient woods.
Response
The support for this reference is noted.
116
Natural England: Natural England generally supports this policy and welcomes the
protection that it gives to the World Heritage Site, SSSIs and local landscape character.
Response
Environment Agency: The EA agrees with the content of this policy on managing flood risk.
We would just highlight that SuDS now stands for Sustainable Drainage Systems. The
acronym used to be SUDS – Sustainable Urban Drainage Systems but research shows that
the methods are equally applicable to rural settings hence changing to SuDS.
Response
The policy and the supporting text have been amended as suggested.
The Woodland Trust: Would like to see the policy and text on managing flood risk include
some recognition of the role which trees and woods can play in this if planted in appropriate
locations.
The creation of short rotation coppice woodland can lead to a reduction in major and local
flood events.
Response
Crime Prevention Design Advisor for Derbyshire Constabulary:
The text of this policy makes a substantial reference to the provision of or contributions
towards CCTV security systems, which I think is possibly historical, with the policy first
coming into use at the time of the Governments CCTV challenge scheme where town centre
systems were required to be match funded by locally sourced finance.
I wonder whether this lengthy reference is still relevant, and may in fact be
counterproductive, in that Policy E2 is looking for better design quality, but the CCTV
references are leaning to a more engineered solution to designing out crime.
We would rather see more emphasis to design solutions within E2(H) referencing for
example part 1 of the ACPO Secured by Design scheme and Community Safety SPD.
117
Response
English Heritage: We welcome reference to heritage assets within the supporting text to
this policy, however we are concerned that there is no further reference to these within the
policy wording itself. Given the levels of growth proposed and the number and types of
designated heritage assets, we consider that lack of such reference is unjustified here. We
consider that a further criterion relating to the protection of heritage assets should be made
here.
Response
The Highways Agency: The Agency supports Policy E2, particularly E2 (b), (i) and (m).
Response
Sport England: Support paragraph l) that seeks to ensure that there is capacity and
availability of infrastructure to serve any new development that is in accordance with the
objectives of Policies IN5 and IN6 and would not result in the loss of existing facilities,
services or amenities unless provision is made for equivalent or improved provision.
Welcome supporting comments accompanying this policy that recognise the important
contribution and functions of open spaces. Also endorse recognition that new development
can make a positive contribution to the level of open spaces and the connecting links
between open spaces.
Support going beyond a ‘standards based’ approach to the provision of open space and
exploring opportunities for additional provision where appropriate and making provision for
future maintenance. Welcome the requirement to secure off-site open space provision where
on-site shown not to be appropriate.
Support evidence based approach e.g. Facilities Planning Modelling Assessment and
Playing Pitch Strategy.
Response
118
The Coal Authority:
Given the presence of surface coal resources across the entire eastern half of the Borough,
The Coal Authority is pleased to note that criterion (o) of Policy E2 seeks to safeguard
mineral resources, to avoid their unnecessary sterilisation by other forms of development.
Given the extensive legacy of past coal mining activity within the Borough, which can result
in issues of unstable land, The Coal Authority is pleased to note that criterion (p) of Policy E2
requires development proposals to have regard to site characteristics such as land stability.
It is therefore important that the policy in the Amber Valley Local Plan acknowledges this
locally distinctive issue. Criterion (p) of Policy E2 provides an appropriate local policy hook
to support the above risk-based approach to ensuring that coal mining legacy issues are,
where necessary, addressed.
Response
Natural England: Natural England generally supports this policy however we would suggest
that the wording should be strengthened in (c) where it says that development should “have
regard to distinctive landscape features and nature conservation Interests” it should say
“should protect and enhance the“, which would reflect the wording in paragraph 109 of the
NPPF.
We also suggest that this policy should make reference to policy IN2 on Green
Infrastructure, parks and open space as GI should be integral to the design and quality of
development and needs to be considered at the earliest stages of a proposal.
Response
English Heritage: We greatly welcome and support a specific policy on the historic
environment, which helps towards the requirements of the NPPF to set out a positive
strategy for the conservation and enjoyment of the historic environment (Paragraph 126) as
well as having a strategic policy on this topic (Paragraph 156).
We consider, however, that there is scope for improvement to this policy and its supporting
text in order to fully comply with NPPF paragraph 126 regarding a positive strategy.
Firstly, whilst the supporting text gives a basic overview of the areas historic environment
character, no reference is given to scheduled monuments or registered Historic Parks and
Gardens. Whilst we also welcome recognition of non-designated heritage assets, there is
little description regarding historic landscape character, rural heritage and industrial heritage.
119
Better demonstration of the plan area’s historic environment, is needed here in order to
make the document sound.
With regard to the policy wording, we welcome the first paragraph which deals with the
Derwent Valley Mills World Heritage Site. We note, however, that reference to this here,
means that Policy EN29 in the existing Local Plan is not to be taken forward (as stated within
the appendix). We do not agree that this reference here as a strategic policy, provides
adequate policy protection in development management terms and we would expect the
existing Local Plan policy to be saved, as well as further detailed policy guidance to be
provided for this area in the forthcoming DPD.
In terms of other heritage assets, we welcome reference to these here. In terms of the
‘strategy’ we welcome reference to the production of a local list, requirement to designate
conservation areas and use of Article 4 Directions. However, we also consider that in order
to fully comply with paragraph 126 of the NPPF, reference should also be made to other
tools such as:
•
•
•
•
The production of and use of Conservation Area Appraisals and associated
management plans.
Use of the adopted SPD’s.
Encouraging the repair and reuse of heritage assets ‘at risk’
Undertaking appropriate statutory intervention (for example enforcement action),
where necessary.
Response
The policy has been amended as suggested and the existing Local Plan policy has been
saved and will be amended as necessary when the Site Allocations and Development
Management Policies DPD is produced.
The Woodland Trust: Welcome the inclusion of Historic Parks and Gardens in policy E3.
This could be expanded to include reference to ancient and veteran trees.
Response
English Heritage: Within the supporting text, we note reference to the World Heritage Site
in the forth paragraph, however we feel that this reference should be improved. Part of the
identified Outstanding Universal Vale of the Derwent Valley Mills is its landscape setting and
the juxtaposition between the industrial nature of the mills and resultant settlements against
the rural landscape backdrop. We consider that reference here should be made more
positive in this respect as it is a large factor of the historic landscape character in this area
today.
120
We also consider that reference to other historic landscape character is required, both in the
policy and the supporting text. We welcome reference to the AMES study, which does take
into account historic landscape character.
Response
The policy and supporting text have been amended as suggested.
The Woodland Trust: Welcome the reference on page 84 to the importance of woodland as
a key element of landscape character.
Response
National Trust: National Trust supports Policy E4. It notes that several references are made
in the supporting text to the history of the landscape, but that there is no explicit reference to
Historic Landscape Character in the Policy itself – such an addition would be appropriate.
Response
Natural England: Natural England strongly supports this policy and is pleased to note that
the Derbyshire Landscape Character Assessment and the National Character Areas have
been referenced in the explanatory text.
Response
Natural England: We generally support the approach that this policy takes.
Response
English Heritage: We welcome reference to the protection of ancient woodlands and
veteran trees within this policy.
Response
121
The Woodland Trust: Welcome your wording in policy E6 which gives strong protection to
ancient woodland and ancient/veteran trees.
However, would like to see a stronger assertion of the need for all new development to
include areas of natural greenspace including trees and woods as part of green
infrastructure.
Ideally we would like to see the council use a standard for provision of natural greenspace
and woodland, for example the Woodland Trust's Access to Woodland Standard and/or the
Natural England Access to Natural Greenspace Standard.
Response
Derbyshire Wildlife Trust: 12.6 Biodiversity – We recommend that the term Sites of
Importance for Nature Conservation is deleted from paragraph 3 p88 under the above
heading as the terms Local Wildlife Site and Local Geological Site are now used in
Derbyshire.
With reference to the policy we recommend the terms Local Sites to include Local Wildlife
Sites and Local Geological Sites. We recommend the wording is amended slightly to say
“…damage must be kept to a minimum and any adverse effects fully mitigated against or
compensated for …”.
We would suggest that the condition of Local Wildlife Sites could be used as a monitoring
indicator.
Response
Environment Agency: The EA agrees with the content of this policy on biodiversity but asks
that reference is made to the Humber River Basin Management Plan (RBMP) in the
justification text. The RBMP implements the Water Framework Directive requirement for river
basin planning and sets out the pressures on the water environment, including the impact of
land use changes. Local authorities are charged with having regard to the RBMP in
exercising their functions.
Response
Reference to this Plan will be made in the background text to this policy before the Core
Strategy is submitted.
122
Natural England: Natural England generally supports this policy and considers that it
provides a strong strategic framework for the protection and enhancement of biodiversity
and geodiversity. We would however suggest that it could be further strengthened by the
addition of the following points:
In the first sentence of the policy wording we would suggest that it should state that it seeks
to achieve net gains for nature to better reflect the advice in paragraphs 9 and 109 of the
NPPF.
Reference should be made to the protection of biodiversity at a landscape scale and the
importance of ecosystem services. This would better reflect the advice contained in the
NPPF.
We note in the last sentence of the fourth paragraph in the explanatory text that English
Nature is mentioned. Please could you update this to say Natural England.
We would also suggest that this policy should include safeguards for the long term capability
of Best and Most Versatile agricultural Land (BMV - Grades 1, 2 and 3a in the Agricultural
Land Classification) and make clear that areas of lower quality agricultural land should be
used for development in preference to the BMV land. The plan should recognise that
development (soil sealing) has an irreversible adverse (cumulative) impact on the finite
national and local stock of BMV land. Avoiding loss of BMV land is the priority as mitigation
is rarely possible. Retaining BMV land enhances future options for sustainable food
production and helps secure other important ecosystem services.
Response
Natural England: Natural England supports this paragraph that encourages Local Green
Space designation. We believe that everyone should have access to good quality natural
greenspace near to where they live. We particularly consider that there should be increased
opportunities for natural and semi-natural greenspace. The provision of accessible seminatural greenspace within green infrastructure in and around urban areas significantly
contributes to creating places where people want to live and work. Its provision is therefore
vital to sustainable development and communities.
Response
123
The Highways Agency: The Agency broadly supports this policy. However, the Agency
considered that the policy should refer to the key transport infrastructure projects required to
support the totality of growth proposed in the Borough. This should include reference to a
significant upgrade to the A38 Coxbench junction or provision of a new A38 junction to serve
the site at Denby. Alternatively, such as statement should be included in Policy IN4:
Strategic Transport Infrastructure Priorities.
Response
Policy SG3 has been amended as suggested.
English Heritage: We welcome reference to the protection and enhancement of heritage
assets within this policy. Green infrastructure, parks and open space can include heritage
assets (such as parks, cemeteries, etc) or contribute to the setting of heritage assets. With
regard to the policy stating that exceptions may be made if the park or open space is
“underused or undervalued” it is important to recognise the potential historic qualities of
specific parks or open spaces, which may be underused or undervalued but still merit
retention due to their historic significance.
Response
This reference has been removed from the policy.
National Trust: The Policy is welcomed and supported as a key element in the Borough’s
approach to achieving sustainable development.
Response
Sport England: Welcome the recognition of playing fields as a key component of Green
Infrastructure, and the social, economic and environmental benefits of green infrastructure
within the supporting text.
Support a strategic approach being taken to the delivery, protection and enhancement of
Green Infrastructure and would emphasise the importance of preparing and drawing upon a
robust and up to date evidence base to inform this strategic approach, including the cited
sources.
124
The requirements within Policy IN2 are welcomed with regard to the protection and
enhancement of Green Infrastructure assets (which would include sports facilities),
presumption against schemes that would have an adverse impact on green infrastructure,
and the requirement for development to enhance Green Infrastructure (on-site or off-site).
Have concerns about the wording or paragraph b) in terms of weighing up the need for the
development against the harm caused. This would not be consistent with paragraph 74 of
the NPPF and should be replaced with clear criteria that would accord with paragraph 74.
Broadly endorse the principle of prioritising new / enhanced infrastructure in areas of growth
i.e. new residential development, although would emphasise the need to draw on
appropriate evidence such as the Playing Pitch Strategy to inform decisions on the spatial
distribution of provision.
Also support ‘physical activity and well-being opportunities for local residents’ such as
formal sports provision being included as one of the key aims of Green Infrastructure,
although have some reservation about requiring multi-functional benefits being required in all
cases where green infrastructure is provided because although this will usually be
appropriate there may be circumstances where this would not represent the optimum
solution.
Have concerns about exceptions being made to the above if a park or open space is shown
to be underused or undervalued. Whilst the policy requires alternative scheme designs to be
considered before mitigation, and requires the reasons for parks and open spaces being
undervalued to be explored and where possible addressed prior to alternative schemes
being permitted, it still provides the scope for open space, including sports facilities, to be
lost to development without a case being made as required by NPPF paragraph 74. Instead
of having an exception based on a notional idea of a space being underused or
undervalued, it is recommended that clear criteria consistent with NPPF paragraph 74 are
included within the policy, and that it is made expressly clear that sports provision/playing
fields are covered by the policy protection.
Response
The policy has been amended to address the concerns expressed.
Natural England: Natural England strongly supports this policy and considers that it
provides a strong framework to deliver the protection and enhancement of green
infrastructure throughout the Borough. We would suggest that it would be useful if the Core
Strategy included a concept plan of the Green Infrastructure Network to illustrate the
linkages between the larger areas of accessible public and other open space and area of
biodiversity value across the Borough.
Natural England would welcome recognition of the need for partnership working to deliver
green infrastructure. Delivering GI will require local communities, organisations, landowners
and developers to work towards agreed aims.
125
Response
The policy has been amended as suggested, and a key diagram has been included in the
Core Strategy highlighting footpath/cycle routes.
The Theatre’s Trust: While Policy IN3 will protect existing community, leisure and health
facilities, there is an inconsistency with SO9 as the word ‘cultural’ is not included either in the
title or in the policy text. For continuity and consistency we suggest the word ‘cultural’ is
included in the title as the word ’health’ does not appear in either SO 6 or 9.
The function of community facilities is to provide services and access to venues for the
health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of
the community. We therefore strongly suggest for clarity and so that guidelines are clear and
consistent, that a description of the term ’community facilities’ be added to section 13.3
which would obviate the need to provide exclusive examples - community facilities provide
for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural
needs of the community.
Response
The title and content of the policy have been amended as suggested.
Sport England: Support protection of existing facilities (that would include sports facilities),
although would recommend tighter wording of first paragraph to make clear how need would
be assessed and what would be a 'suitable' alternative (this would need to be something
equivalent and or better in terms of both quality and quantity, and also in terms of
accessibility, in line with NPPF paragraph 74).
Also welcome positive approach to new facilities in the second paragraph, but would
recommend adding clear criterion in relation to the strategic / local need for the facilities as
informed by Infrastructure Delivery Plan and robust evidence base, rather than using the
term ‘where appropriate’.
Support going beyond the current SPD and ‘standards based approach’ using up to date
evidence e.g. Facilities Planning Modelling Assessment, Playing Pitch Strategy.
Response
126
Derbyshire Campaign to Protect Rural England: Amber Valley’s commitment to the A610
Bypass, reiterated throughout the Core Strategy, pre-empts transport assessments for the
development for 600 and 560 dwellings respectively at Alfreton Road, Codnor, and
Nottingham Road, Ripley. The process is back to front. Policies SG2 and SG7 directly
conflict with Policy IN1 e) because providing a new road to serve substantial housing
development will encourage more rather than less car use.
Amber Valley claim that the A610 Bypass will relive road traffic congestion by proving a new
road link between the A6/A38 and the M1. This would be a first – a new link road which is
hardly used by road traffic and therefore does not generate additional road traffic and
congestion. There is ample evidence now that bypasses at most displace traffic and usually
create more, and within a few years of opening. The Newbury Bypass is a case in point –
traffic levels were back to before the Bypass within 5 years of opening. In fact, the extract in
the Infrastructure Delivery Plan from such transport assessments as have been carried out
expresses concern about the “severe” congestion expected to be generated by the A610
Bypass.
The Core Strategy is vague on sources of funding. While it is appreciated that detailed
negotiation may need to be conducted once the Core Strategy has been agreed, the funding
strategy is so vague at this stage that it constitutes real risks not only to delivery of the Core
Strategy as Amber Valley envisage it but also potentially to services provided by Amber
Valley. The Infrastructure Delivery Plan lists the costs of the Bypass as “unknown” and
sources of funding as developer contributions and a range of others.
Without clarity about either total cost or sources of funding, there is a real risk that Amber
Valley (or potentially Derbyshire County Council) will have to underwrite finance – with the
negative implications this is likely to have on other services the Local Authorities would
otherwise be able to provide.
Response
A transport assessment has been submitted as part of the background evidence for a
planning application that has now been submitted for this scheme which is being considered.
The Infrastructure Delivery Plan refers to existing and potential future congestion, but not
congestion being created by the proposed A610 link road between Ripley and Woodlinkin.
One of the main reasons for implementing this scheme is to reduce congestion. A funding
package for the scheme is being finalised.
English Heritage: We note the policy in relation to the A610 link road between Ripley and
Codnor. The significance and setting of a large number of heritage assets may be affected
by the bypass. We consider that criteria should be cited within this policy in order to provide
guidance on issues which will need to be considered. We consider that the road will need to
take into account impacts upon heritage assets and their setting here and reference should
be made to this, within this policy.
127
Response
The policy has been amended, as suggested.
Derbyshire Wildlife Trust: We note that the proposed route of the A610 link road passes
through part of a Local Wildlife Site. This has not been identified by the Sustainability
Appraisal. Any adverse impacts on this site should initially be avoided or minimised, but
where impacts remain there will need to be adequate mitigation and/or compensation. At this
stage we are not aware of any ecological studies looking at potential impacts along the
entire route and clearly these impacts need to be better understood.
Response
The policy has been amended, as suggested.
English Heritage: We note the infrastructure proposals within the Infrastructure Delivery
Plan – consideration should also be given to the protection and enhancement of heritage
assets under this.
The Highways Agency: The Agency supports this policy, which sets out the Council’s
approach to ensuring a coordinated approach to delivery appropriate infrastructure in a
timely manner.
National Trust: Infrastructure delivery should specifically include, in the Policy or more
overtly in the supporting text, key environmental resources – especially bio-diversity and
heritage resources.
Sport England: Support evidence based approach to infrastructure delivery. The Draft
Infrastructure Delivery Plan will need to be updated based on up to date and emerging
evidence including Playing Pitch Strategy and Facilities Planning Modelling Assessment. Up
to date evidence and assessment of needs and opportunities, including those for sport need
to feed into the Infrastructure Delivery Plan in the form of firm proposals, in accordance with
NPPF paragraph 73. This may also require allocation of specific sites in order secure the
delivery of the infrastructure where it is needed.
Response
These comments are noted and the policy, background text and the Infrastructure Delivery
Plan have been amended, as suggested.
128
English Heritage: Consideration should also be given to the protection and enhancement of
heritage assets through such means – particularly where new development has an impact
on historic environment considerations.
Response
Policy 1N5 has been amended to refer to developers contributions being required to protect
and enhance heritage assets, where relevant.
The Woodland Trust: Would like to see a portion of developer funding used for green
infrastructure, including woodland creation.
Derbyshire Wildlife Trust: We support this policy.
Response
National Trust: Potential developer contributions should specifically include, in the policy or
more overtly in the supporting text, key environmental resources – especially biodiversity
and heritage resources.
Response
Policy 1N5 has been amended to refer to biodiversity and heritage resources.
Sport England: Welcome a policy requiring developer contributions as set out. A broader
evidence base providing greater detail beyond that within the Infrastructure Delivery Plan
should be cited and used to underpin this including Playing Pitch Strategy and Facilities
Planning Modelling Assessment.
Response
129
8.
Comments from local groups
Swanwick Residents Association: Question how many former industrial sites have been
redeveloped for housing. Trust the balance to be struck between encouraging new
development and protecting the environment will be strictly and strongly adhered to.
Response
Belper Civic Forum: Belper Civic Forum believes that the final sentence of this section
needs strengthening. The previous page talks of the need to support vibrancy of the local
towns and their distinctiveness, and this paragraph ends on 'as many sectors of the local
population as possible will have access to local facilities without having to use the car'.
In that case, the Council's Vision should also make explicit reference to ensuring
developments such as housing and industry, as well as leisure, are based around minimising
car journeys and supporting local economies, rather than providing high speed routes to
large cities. This needs to be in complete conformity with Policy IN1.
Response
The Spatial Vision has been amended as suggested.
Swanwick Residents Association: Opening paragraph is too optimistic and needs to be
tempered. The emphasis is being on more use of public transport, cycling routes and
walking, but we do not see this happening in any great measure. Apart from the proposed
A610 link road we see no plans to improve/change the current road networks in and around
the market towns.
Response
It is considered that these aspirations should not be tempered.
Belper Civic Forum: Objective 11 needs strengthening to read, in addition, 'There will be a
strong presumption against developments which run counter to this.'
Response
It is not considered necessary to amend this objective.
130
Swanwick Residents Association: Objectives 10 and 11 only refers to the A610 link road
in terms of providing supporting improvements to the local transport network.
Response
Derbyshire and Peak District Campaign for Better Transport: The thirteen strategic
objectives listed on page 7 of the Draft Core Strategy are all very general with the exception
of number 10, which states “To provide and support improvements to the local transport
network, including a new A610 link road between Ripley and Codnor”. We do not think that
a specific project can be a strategic objective.
Returning to the Core Strategy’s strategic objectives, we consider that number 10 is, as
written, incompatible with objectives 11 and 12: “To provide infrastructure that creates
opportunities for non-motorised transport, increase public transport accessibility and
mitigates against the creation of severe traffic congestion.” and “To aim to ensure that local
services, facilities and employment opportunities in the Borough are accessible by as many
sectors of the population as possible”.
Response
It is considered that the implementation of the A610 link road is a strategic objective and it is
not incompatible with the other objectives.
Belper Civic Forum: The Civic Forum is interested that the Council is committing to a
'Garden City' approach to larger village type built-up development, and would like to see a
reference in paragraph 6.6 to 'ensuring that housing developers respect the character of the
local landscape, where possible preserving existing natural features and ensuring lower
density development, providing generous green open space in any developments of over 25
houses'.
Response
These matters are covered elsewhere in the Core Strategy and it is unclear why these
requirements should only apply to developments of over 25 houses.
Transition Belper:
In the context of Belper, this suggests new housing could be extensive and take place
anywhere. In reality, this is not what is meant (see Appendix B and elsewhere in the Local
Plan). Since this is important preamble for Policy SS1, We would like more care with the
wording to avoid ambiguity/confusion.
131
Response
It is not considered that any changes are required to the background text.
Belper Civic Forum: No sites have been identified in the plan. The Civic Forum would like
to see specific reference to encouragement of use of sites in Belper like the Bullsmoor and
ER1C mixed-use site.
Response
The Core Strategy has only identified sites at a strategic scale. These sites will be
considered for allocation when the Site Allocations and Development Management Policies
DPD is produced.
Transition Belper:
In this section it mentions de-allocating existing allocations and replacing with new
allocations of higher quality. What is meant by higher quality?
Response
Sites that have good access to the strategic road network.
Derbyshire and Peak District Campaign for Better Transport: We do not believe that any
land identified for employment development can be classified as a sustainable location if it
requires a new road through the Green Belt.
Response
The justification for the proposed new A610 link road is not just to provide good quality
employment land.
Transition Belper:
The word “appropriate” is too vague and open to many interpretations.
Regarding retail – we are concerned by the vagueness of the term “larger-format units”.
These units need to be in keeping with the heritage of Belper and the fact that Belper is
successful because of its many outstanding independent shops. Is it possible to limit the
scale of these units e.g. per sq. metre and height within the local plan.
132
Although one aim of the Core Strategy is to “extend and improve the quality of the retail offer
and provide a wider retail offer to ensure that spending takes place within the Borough” it
needs to be clear in Policy SS3 that this will enhance, not conflict with the current retail on
offer.
Response
It is not considered that aims of policy SS3 will conflict with the current retail offer.
Belper Civic Forum: Change wording of 6.11 Belper, last sentence to read ‘To continue its
economic success, the Council will commission a Masterplan to ensure a co-ordinated
approach’. Reword Policy SS5 so that 'To continue its economic success, the Council will
consider if a Masterplan needs to be produced' to read 'To continue its economic success,
the council will commission a Masterplan'.
Response
The Council has not yet decided if a Masterplan should be produced for Belper.
Transition Belper:
We believe the council should proceed with the commissioning of a Masterplan for Belper.
One critical aspect of any Belper economic development is the A6/Bridge Street problem
running through the centre of the town and needs to be addressed.
Response
The Council has not yet decided if a Masterplan should be produced for Belper.
Heanor Regeneration Board
The Board are glad that a policy giving weight to the Heanor Masterplan was being put in.
Response
133
Heanor Regeneration Board
Feel that the proposed town centre boundary should be extended to cover the whole of the
college site. It is an important development site within Heanor and the development on that
site should be town centre orientated. By putting it in the town the plan would be
encouraging town centre uses on the site.
Response
It is not considered that changing to town centre boundary to include the college site is
necessary.
Heanor Regeneration Board:
The Board felt that Ray Street should also be included in the Primary Shopping Frontage
policy. This is because Ray Street has a lot of A1 uses that should be protected. This would
then concentrate no A1 uses around Red Lion Square which would support the aims of the
masterplan.
Response
This change would discourage non retail uses from becoming established in the town centre.
Transition Belper:
The drawing shows extension on western side of Strutt Street, not eastern side. Is the text
incorrect?.
Response
The text has been corrected.
Belper Civic Forum: The Civic Forum would like to see the replacement of any Green Belt
land lost to development, and is pleased that the Council is recognising the importance of
'using natural features such as streams and other barriers’.
Response
134
Stop 500: Site SG2 is in the Green Belt and enjoys very significant protection from
inappropriate development, as re-established in National Planning Policy Framework
(NPPF). Paragraph 84 does not present a carte-blanche for removing green belt designation
to conveniently afford housing land provision.
In this overall strategic context and function of Green Belts, paragraph 87 of NPPF reiterates
the well-established policy priority for inappropriate development to be permitted in the green
belt only where there are very special circumstances. Moreover, should the release of green
belt land be demonstrated as being essential to accommodate necessary growth across the
Borough, the location and extent of such release(s) should be informed by transparent and
systematic study of the functionality, amenity, heritage and environmental (landscape,
biodiversity, ecosystems services) value of all existing Green Belt area, and not be solely
pre-determined by the desire to expedite other council objectives where this is ‘convenient’
for the Council. As part of Local Plan evidence base, comprehensive and focused Green
Belt Reviews (such as West Lancashire Council’s) have been carried out by many LPAs
across the UK in considering the need for Green Belt releases or alteration. These then can
be used to properly inform policy decisions, be open to public scrutiny and aid transparency.
No such study appears to have been undertaken in identifying SG2 as a valid Green Belt
release. This significant element of the plan’s spatial strategy is therefore not supported by
robust evidence, and therefore likely to be found unsound at Examination.
Stop 500 considers that the justification for a relief road is being pursued, despite inadequate
evidence of need or proportionality to perceived congestion problems, primarily so that a
release of green belt can be justified and in doing so secure contributions which will fund a
significant cost of the proposed road and help meet housing targets.
To the council this may appear to be a win-win situation, but it is essentially flawed and must
be rejected as an unsustainable form of development, as well as wholly against community
opinion.
Even if need were established in part for congestion relief measures, the provision of such
significant and expensive infrastructure would appear unreasoned and disproportionate to
the degree of any problems arising from such congestion. Examination of alternative, more
proportionate and significantly cheaper traffic management options do not appear to have
been afforded proper consideration.
Signage strategies, public transport enhancement, and localised highway improvements to
the existing line of the A610 appear not to have been considered or investigated, and
instead the most expensive and environmentally damaging option appears to have been
prioritised from the outset.
The council’s flimsy justification for inappropriate development in the green belt is further
undermined when consideration is given to the promotion that the by-pass would then
present a valuable ‘defensible’ boundary to the Green Belt. It may present an obvious
boundary should it be delivered, but on its own does not help justify development in the
green belt and removal of the land from it as proposed by SS11. The presenting of a new
defensible boundary as a benefit is misleading and disingenuous.
135
The Council has operated Green Belt policy using the existing boundary defined by
properties along the Alfreton and Nottingham Roads for many years, without it seems undue
difficulty, as is the case for the great majority of the Green Belt boundary across Amber
Valley. The creation of a new easily defined boundary is not required for existing and future
Green Belt policy to be properly applied and therefore no public benefit should be afforded to
the achievement of such through delivery of the road.
The Derby Housing Market Area study recognised that there is an over-supply of
employment Land in Amber Valley, suggesting further allocations are of very limited value
and should not be used as justification for environmentally constrained sites, such as those
within the Green Belt.
Derbyshire and Peak District Campaign for Better Transport: We find it hard to see how
an “east-west link between the A6/A38 and the M1” can count as local transport
infrastructure. The road is already a “Primary Route”. If it is designed to enable new
housing development, then it will not preserve the openness of the Green Belt. The main
purpose of a Green Belt is to limit development within it. Despite the scheme being a “longstanding commitment”, the Council has not suggested a need to modify the Green Belt
boundary in the past.
Response
There is a longstanding commitment by both the Borough and Derbyshire County Council to
securing the completion of a new A610 link road between Ripley and Woodlinkin. The
provision of this new link road will not only relieve traffic congestion on the current A610
route, but will also improve the east-west link between the A6/A38 and the M1 through the
Borough, enabling the provision of new housing development and the development of high
quality employment land, which will help to improve the local economy. The Council does
consider that this represents exceptional circumstances for development in the Green Belt.
Transition Belper: Compensation for loss of green space must be within the immediate
community.
Response
136
Stop 500: Stop 500 considers the identification of this site to be based primarily on the
council’s opportunistic approach to securing the road proposals through releasing a
significant tract of green belt to development. In addition, Stop 500 considers that past
engagement in the process has not been afforded due weight and suggests disregard of
very considerable public opposition to the proposals at Alfreton Road. Such intransigence by
the council in light of such community concern suggests that political support for the relief
road and an engineered opportunity for development to deliver that road has resulted in a
situation where there is real danger the preferred plan will support the proposals at Codnor
as a fait accompli.
Stop 500 objects in the strongest possible terms to the inclusion within the draft plan of the
strategic housing allocation for 600 dwellings across land east of Alfreton Road, Codnor,
presently within the Derby and Nottingham Green Belt. In doing so, Stop 500 specifically
objects to policies SG2, SS11 and IN4.
Whilst SG2 refers to housing development only, other elements of the draft plan, notably in
supporting text to SS11 and IN4 suggests that the site would deliver housing and ‘high
quality employment land’, and in doing so immediately presents inconsistency and lack of
clarity in the draft plan.
The site is identified at SG2 as a strategic site for the delivery of around 600 houses. This
area of countryside frames the eastern fringe of Codnor (defined by properties along Alfreton
Road and along Nottingham Road (A610) and presents a clear and established delineation
between the settlement and the open countryside across the site and beyond. The site is an
extensive area overlying an attractive shallow valley of small fields and pasture with an open
watercourse, mature hedgerows with hedgerow trees which form a strong landscape pattern
and ecological network which adds to landscape and biodiversity value. The site is crisscrossed by at least 5 public rights of way and as such presents accessible, attractive and
well used amenity value to the community, especially in relation to accessing Codnor Castle.
It forms a significant element of the wider setting of Codnor Castle, a Scheduled Monument
and Grade II Listed Building.
All such environmental, heritage and amenity qualities suggest the area is of considerable
overall value and sensitivity in its own right, even before green belt status and functionality is
considered. It is particularly significant to note the glaring inconsistency within the draft plan
between the mostly commendable suite of draft environmental, green infrastructure and
heritage specific policies, such as E3, E4, E6 and IN2, and the inevitable consequences of
delivering the by-pass and developing SG2 which will decimate those established valued
characteristics and functions. It would seem that the council will seek to promote responsible
environmental stewardship and protection, but only where it suits it to do so.
The scale of development expected within the site – having regard to the road’s delivery,
suggests this will render the housing development unviable without significant reduction in
overall developer contribution.
137
The very real and predictable outcome in this regard is that planning permission for the
development of SG2 and IN4 would be granted but that developer contribution will not be
secured to the degree anticipated by the council in the draft plan. Consequently housing
delivery will be stalled unless the council relaxes negotiated sums, or pressure mounts on
the council for the development of SG2 to go ahead without the by-pass.
Stop 500 therefore believes that there is a very real likelihood that the combined proposals
are not deliverable within the plan period, and therefore would fail to be found sound at
Examination. For this reason alone, the combined policies SG2, SS11 and IN4 should be
deleted from the draft plan.
Response
It is considered that the development of this site will assist in delivering this scheme, but
criteria have been added to the policy for this site to address the concerns expressed. It
should also be noted that a planning application has been received for the development of
this site, together with the new A610 link road and the development of the site at Nottingham
Road, Ripley. The development of this site will not take place unless the whole of the new
A610 link road is implemented, as required by the policy for this site. The application is
accompanied by a number of accompanying documents which include a transport
assessment and a variety of other documents that consider the other impacts that the
development of the new link road and this site would have.
Belper Civic Forum: The Civic Forum would like to see the Council reduce the overall
number of homes suggested for this site to 900, whilst retaining the boundaries suggested.
This should be in keeping with our response to questions 6 and 36, requiring developers to
demonstrate how they respect the landscape with less intensive development and provision/
retention of green open space.
Response
Development at this scale would not enable the site to be as self sustaining as possible.
Transition Belper: Need to ensure there is good frequent public transport between this site
and Belper to avoid necessity to use the car.
138
Response
Denby Footpaths Group: Denby Footpaths Group has read the consultation document
Local Plan Part 1 The Draft Core Strategy produced by Amber Valley Borough Council. Our
response to the consultation refers to Policy SG3, Land North of Denby as follows:
Policy SG3 (f) states ‘safeguarding of the disused transport route within the site as a
potential public transport corridor or a multi-user route for pedestrians and cyclists’. Denby
Footpaths Group are against the route being used as a public transport corridor. This route
forms a key section of the Ripley to Little Eaton multi-user route already under development
and any other use of this section of the route would compromise the overall scheme.
The inclusion of SG3(g) ‘protection and enhancement of existing footpaths within the site’ is
welcomed by the policy. Policy E2(g) refers to ‘opportunities for walking, cycling… can be
maximised’ and this statement is also encouraging.
However, although Policy E2 is referenced as a condition in SG3, this does not adequately
cover the importance of safeguarding the heritage and historically important aspects of this
area. Policy E3 Historic Environment goes some way to addressing this and should be
included in SG3.
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
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.
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.
Historic and Heritage aspects
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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. The routes
are still evident today and their preservation is paramount. A key document written by
Trevor Griffin (February 2012) has been received by Amber Valley Borough Council. It
covers most comprehensively the history and development of the railways. “The railway
is an important relic of a Derbyshire based industry that contributed to the worldwide
development of railways as a major form of transport”.
Bassett Pit worked from 1817 to 1866
Slater’s Brick and Tile Works operated from 1874 to 1977
Denby Iron Works from 1860 to 1929
Park Hall, a grade II listed building dating back to 1702
In 1901, Tarmac was ‘invented’ changing road building around the world.
Denby Footpaths Group is working on a scheme to have this heritage recognised with
installation of relevant signage boards and the possibility of a partial reconstruction of a
railway section.
Link to Derwent Valley Mills World Heritage Site:
The area identified for development falls on the border of the Derwent Valley Mills World
Heritage Site Buffer Zone. The development of the Belper and Morley Park railway was
critical to the success of the Derwent Valley Mills during their development. The route of
this railway links the two sites physically along with the network of ancient rights of way
running through the area.
Other opportunities for the land:
There is vast potential for this site to attract tourists into Amber Valley due to the key
heritage and historic aspects identified already in this response. The development of Denby
Pottery will bring in tourism and this site is easily accessible from the Pottery making a ‘day
out’ in Amber Valley. Similarly, development of the Ripley to Long Eaton Greenway will
bring in visitors as the route passes through the development site. Future development of
greenways in the area as identified in the East Midlands Greenway Strategy (DCC) will link
the area into Shipley Park and the Nutbrook Trail.
This area already meets the need for open space and could be further enhanced by
developing the open spaces for recreation (nature trails, trim tracks and cycle paths for
example). Preserving historic hedgerows and protecting the biodiversity of the area would
further improve this much used public open space.
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Leisure needs are met by the area which provides a green open space for walkers and
riders. Denby Footpaths Group is carrying out much needed improvements to the path
network to make the area accessible and enjoyable. Derbyshire County Council has
recently assisted this work by carrying out major improvements along the key route opening
the connection once more to the Derwent Valley Heritage Site through Openwoodgate.
Denby Footpaths Group feel that Amber Valley Borough Council need to consider in much
greater depth whether this development is really in the best interests of the whole Borough
bearing in mind the negative impact it would have on the area we have outlined.
Policy E6: Biodiversity should form part of the Policy SG3. Several ancient and historically
important hedgerows exist on the development site. It is noted however, that hedgerows are
offered no protection in E6 and ask that they be included.
Response
Criteria have been added to the policy for this site to address these concerns.
Transition Belper:
Why is only half of the needed affordable housing is being proposed (30% rather than the
60% required up to 2028)?
Funds used for affordable housing could be spent off site – empty properties, cheap
properties for sale in poor condition, infill in villages etc. Retrofitting would upgrade the
energy efficiency of older stock and having development sites with a higher proportion of
market housing might have a changed economic dynamic.
Response
This reflects the existing Local Plan policy. Experience has shown that requiring developers
to provide more than 30% affordable housing would render schemes unviable and/or would
result in order contributions not being provided for infrastructure such as open space and the
expansion of schools. The Council does, when appropriate, require developers to provide a
contribution for the provision of affordable housing elsewhere in the locality.
Transition Belper:
Does this mean that there can be a compromise on the 30% affordable housing guidelines?
i.e. even less than 30%? Could the exact circumstances when this is allowed be made
clear?
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Response
Each planning application has to be considered on its own merits. If independent advice is
received that advises the Council that requiring 30% affordable housing will render a scheme
unviable, the Council has to consider if in that particular case a lower percentage of
affordable housing should be permitted.
Delaying Code 4 due to economic conditions is not acceptable; Climate Change is not
waiting for improvement in economic conditions.
The exceptions to achieving Good standards are too vague. Why should a small site
become an exception?
In particular in Belper we have the problem of the existing housing stock with solid walls,
often in WHS corridor so we will not be able to fit current external wall insulation to improve
energy efficiency performance. New properties need to be of highest standard immediately
top compensate for difficult to treat properties in Belper.
Delaying BREEAM good and very good standards until 2016 and 2019 is not acceptable, we
must act now.
Belper must be of a higher standard, therefore insist higher code immediately, possibly in
Belper only.
Delaying the ‘water efficiency component’ of level 5/6 of the Code for Sustainable Homes
until 2016 is not acceptable, we must act now.
Include consideration to ensure adequate ventilation during heatwaves/sunny conditions (so
avoiding need for air conditioning/fans)
This whole chapter falls down when viability is challenged by a developer – considering the
fairly insignificant additional costs of meeting the higher standards now it is disgraceful that a
much tougher line is not being taken immediately.
Response
It is considered that the requirements of this policy are already at the limit of what would be
viable at the present time.
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Transition Belper:
Technology is improving the design of wind turbines all the time and there are many on the
market now which are smaller in size, much less harmful to birds and much quieter. We
should not write wind power off.
Can we include in the policy the balance explaining the positive reasons for installing wind
turbines?
Should this strategic document taking us to 2028 be so specific about current government
policy that may change in a couple of years?
Are the ‘identified’ sites in Amber Valley available and promoted to potential developers,
particularly community groups or social enterprises (for the benefit of the local community)?
How can you argue that “environmental protections” override the need for renewable energy,
insofar that use of non-renewables will damage the environment in the long term.......
What about hydro and solar energy. Also, in new larger developments, anaerobic digesters
could provide some energy whilst recycling.
Can you produce Policy R3 Non-Renewable Energy (fossil fuel) - including coal, oil and gas
extraction).
Response
The policy encourages all types of renewable energy and is flexible enough to not become
outdated in future years. It is not considered that a policy on non renewable energy is
required. It has been amended to take account of some of these comments.
Transition Belper:
Do any of the policies or guidance require or encourage specific improvements such as
green roofs, or the planting of native tress/bushes within a new development.
Response
The policy has been amended to refer to development involving the use of green roofs
and/or the planting of native trees/bushes to achieve a net decrease in surface water run off.
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Transition Belper:
Concerned with word “scale” (needs better definition here and elsewhere in Local Plan, as
developer could justify building something as high and broad as East Mill, on grounds that is
the same scale).
This policy may require improvements in public transport (routes, times and frequency) – so
could perhaps mention “encouraging” this.
Landscaping could be defined more clearly e.g. using native species, to enhance
biodiversity, reduce flood risk.
With regard to the reference to the use of materials that reflect the identity of the local
surroundings, what if local surroundings are awful (e.g. concrete slabs and corrugated iron
roofs of nearby industrial sites)? Need wording to prevent justification of more of the same
ugliness. Could use words/phrases such as “appropriate” and/or “locally sourced” and/or
“traditional” and/or “good quality” materials.
Crime prevention and community security are not about CCTV only – providing better
community cohesion through communal buildings & space which will increase a sense of
ownership & community spirit.
Leave out phrase “where appropriate”. in the phrase “secure, where appropriate, improved
accessibility to the town centre by improvements to the public transport facilities”
Could free parking (for 2 hours?) within town centres (AVBC car parks) and reasonably
priced day parking to encourage tourists (especially Belper) and park and ride season tickets
to encourage commuters to use trains/buses. Paid for by edge of town supermarkets.
Could the Ripley branch of the Midland Railway be re-opened, or park and ride facilities be
provided.
Should the policy refer to the installation of solar panels at the time of building the
properties?
What about other providing other communal facilities such as water collection butts,
composting, anaerobic digesters, renewable energy installations and food growing areas.
The reference to density is a vague statement. How about small local shops provided on the
larger sites to eliminate the need to drive a distance for small provisions? A nursery/child
care service also? A supervised community room for young people to gather in, rather than
hanging around the shops? This would increase safety and employment opportunity. Also
could 1 plot be left empty & made into allotments? Preferably next to the young people’s
community room so as to integrate ages & interests.
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Is it encouraging high density in a high density area? (Or the opposite). We think there
should be some idea of need for balance in this paragraph.
Response
The policy has been amended to take account of some of these comments. However, some
of these issues such as parking charges are not matters for the Core Strategy.
Transition Belper:
Specific mention should be made about the Climate Change adaption required around the
World Heritage Mills adjacent to the Rivers, liable to be impacted by flooding.
Response
This is not an issue for a policy on the historic environment.
Belper Civic Forum: The Civic Forum would like to see encouragement given to less
intensive development of sites by housing, and evidence that developers have provided
generous green space in keeping with the ‘Garden City’ principles where possible.
Response
Transition Belper:
Should this also say rivers to include fish passages?
We very much agree with idea of restoration and re-creation of habitats (rather than just
mitigation).
Developments should have a mandatory 50%-75% green space to ensure and maintain bio
diversity. Green Roofs can be used to achieve this for larger developments.
Response
The policy has been amended to refer to fish passes. A mandatory amount of Green Space
at this level would involve an inefficient use of land and would not be in accordance with
government policy.
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Transition Belper:
Is it feasible through the Local Plan or through the neighbourhood plan to designate part of
the Meadows area as Local Green Space for provision of sports facilities and community
gardening projects accessible to all members of the community?
Response
This will be considered when the Site Allocations and Development Management Policies
DPD is produced.
Belper Civic Forum: There should be a direct reference to Policy IN1 in the Spatial Vision
for the Borough.
Response
It is not appropriate to include references to policies in the Spatial Vision.
Transition Belper:
Is a lower limit possible for when a Transport Statement or a Transport Assessment will be
required?
Encouragement should be given to reinstating school buses, especially for secondary
schools, which would reduce school-run traffic congestion and pollution etc.
Utilise community transport to link main transport corridors as per Notts CC Titan Project
Work with community transport partners to deliver more frequent flexible services.
Enterprise, incubation or community rooms could be provided to offer a few ‘hot desks’ high
speed broadband and communication equipment in a central location, possibly utilising
brownfield site.
There is no mention of any evaluations or plans to put into use the Ripley Branch or the
Midland Railway either as a cycleway/bridlepath, or reinstatement for light or major rail use
linking key parts of Amber Valley and potentially being a significant benefit to the Cinderhill
project.
The problem of the A6 running through the centre of Belper has been ignored and must be
addressed. Should a Masterplan be developed for Belper including the problems of the A6.
Review partial one ways etc.
A Masterplan could also help find a practical solution to the coach parking problem.
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Review of Rail Transport required urgently looking at Electrification of current line through
the World Heritage corridor, including Belper, or alternatives around Belper, access to the
HS2 and re-suing closed lines such as the Ripley Leg of the Midland Railway.
Extend DVM through Derby to employment locations such as Sinfin and Burnaston
All new developments – Roads to include cycle ways, Developments to include Cycle Park
provision.
Build in a location for a Car Share Scheme in Belper.
Response
Many of these comments relate to matters that are not related to a planning policy document
or are matters that are covered elsewhere in this document.
Transition Belper:
This should include a statement about working with local organisations, community groups
and social enterprises to achieve this.
Additional provision for Doctors and NHS Dentistry (local to reduce transport) required in
Belper.
Response
It is not considered that the policy needs to be amended in response to these comments.
Stop 500: It is acknowledged that there is a protected line for a relief road within the 2006
Local Plan (Policy TP13) which is based upon a ‘longstanding commitment to securing the
completion of highway improvements along the A610 between Ripley and Langley Mill,
including a by-pass for Codnor’. However it is most telling that the significance of any
inferred (but not evidenced) suggested need, and the ability to secure the necessary
funding, have clearly not become any more pressing over the previous plan periods. The
draft plan today sets out in parts a similar vague indication of ‘desire’ for the relief road rather
than any significant evidence, convincing transport modelling or community engagement
feedback to suggest that the draft policy response is proportionate or justified. Vague plan
commitments, past infrastructure philosophies (supporting by-passes) or political preference
for a relief road at Codnor cannot be maintained over such a significant passage of time
without robust evidence and review, yet the best the draft plan can suggest at this stage
(following significant earlier ‘informal’ consultations proposing the road and site) is reference
to a ‘long-standing commitment’. This is simply not a good enough basis on which to justify
a major infrastructure and strategic housing allocation within the green belt.
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There would appear to be a significant difference in interpretation between Amber Valley
Borough Council and Derbyshire County Council as Highways Authority in relation to the
need and priority afforded to the link road. Derbyshire’s Local Transport Plan 3 2011-2026
(LTP3) identifies a non-specific scheme at Codnor as being a ‘long-term project’ with
‘potential for appraisal in association with land use plans’. It does not identify the scheme as
being sponsored by the Highways Authority.
This very limited status within LTP3 clearly does not afford any significant priority to the
scheme, does not recognise congestion along the A610 as a particularly pressing matter and
further demonstrates that the case for the road remains a product of long-term plan inertia
rather than evidenced need. Clearly the priority afforded the road proposals does not begin
to justify a significant funding priority for the Highways Authority. The presence of the
proposals would appear to be included within LTP on the grounds that the Borough Council
is so strongly promoting the scheme, and not that the Highways Authority recognised need
or priority.
The Inspector’s report to the 2006 Local Plan recommended that the road alignment be
removed from the emerging plan and specifically referred to the Council’s ‘wishful, if not
entirely unrealistic desire given the plan period to secure the provision of a Codnor bypass’.
The evidence-base referred to within the plan for policies SG2 and IN4 notes that traffic
modelling is currently ‘underway’. How then can such a significant and hugely emotive
proposal be brought forward to this stage of the plan (and indeed have been so prominent in
preceding documents) when the council has no independently verified evidence that the
road is categorically essential to the sustainable development of the Borough? This clearly
must demonstrate how the political priorities of the Council are serving to take priority over
transparent, inclusive and sustainable land use planning within this part of the Borough.
LTP3 itself emphasises how transport planning now prioritises shifts away from road building
to sustainable transport solutions and modal choice. Notwithstanding the probable
significantly detrimental effect a by-pass would have on day-to-day trade within Codnor’s
existing retail and services sector, the proposal would increase the convenience of car
based movements for retail, employment and leisure activities, flying in the face of
sustainable development principles and a sustainable spatial planning approach.
The justification of the infrastructure provision, i.e. ‘long-standing commitment’ is promoted
contrary to local opinion on the degree of severity of congestion at peak times. Evidence
from many other studies suggests that by-passes of smaller settlements are likely to have
negative implications on the village’s economic well-being. This would surely apply to
Codnor’s local commerce and services community.
Response
When the last Local Plan was produced, there was no funding identified for the new A610
link road and it is referred to as a scheme with potential for appraisal in association with land
use plans in the Local Transport Plan.
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A planning application has now been submitted for this scheme which is accompanied by a
number of accompanying documents which include a transport assessment and a variety of
other documents that consider the other impacts that the development of the new link road
and this site would have.
Belper Civic Forum: There should be a presumption towards developer contributions
benefitting and being retained for infrastructure improvements close to the site where the
Section 106 levy is applied.
Response
Section 106 agreements cannot require contributions towards infrastructure that is not
related to the site.
Stop 500: Stop 500 is immediately concerned that the council is seeking to artificially and
deliberately circumvent part of the purpose of this consultation, under Regulation 18 Town
and Country Planning (Local Planning) (England) Regulations 2012. In short paragraphs
(1) and (2) of the Regulation require plan making authorities to invite (amongst others) local
residents to make representations about what a local plan ‘ought to contain’.
Very importantly, paragraph 3 of Regulation 18 states…
‘(3) In preparing the local plan, the local planning authority must take into account any
representations made to them in response to invitations under paragraph (1)’.
In this context it is of very considerable concern to Stop 500 that the invitation to comment
upon the draft plan presented on the Council’s website is caveated by the statement ‘Please note that if you have already commented on the principle of developing the
proposed strategic housing sites it is not necessary to repeat these comments, as they
have already been recorded and taken into consideration.’ (our emphasis).
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Not only does this potentially fall foul of the legal requirements of Regulation 18, it clearly
reinforces the view that the decision to take forward the strategic sites set out in the draft
plan has been decided, that the very many and well considered objections prepared to
previous non-statutory consultation have been dismissed, and that no opportunity to
reconsider in light of future evidence will be taken! It is difficult to see how else can this
statement be interpreted? It effectively says do not comment upon the strategic sites
selection…. you may have objected but we want to avoid the inconvenience and discomfort
of having to consider this any further. Unfortunately for the council, this is not an approach
which carries any weight. It is Stop 500’s right to maintain, enlarge upon and underline its
strong objection to the proposals east of Codnor in this and future plan iterations and stages.
It will do so, and this representation maps out our key and wholly valid concerns.
Response
The Borough Council is fully committed to full engagement with the public and other
stakeholders when producing its plans, in accordance with the relevant regulations. The
comment in respect of not repeating comments was only intended to advise stakeholders
that the Council are aware of the issues previously raised in respect of the principle of
developing the proposed strategic sites and they do not need to repeat them, as the
comments previously made will be forwarded to the Secretary of State when the Core
Strategy is submitted prior to the public examination taking place. The focus of this
consultation was on the proposed policies to be included in the Core Strategy.
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9.
Comments from developers/landowners/consultants
Savills: The Spatial Vision and Spatial Strategy do not appear to accord. The Vision states
that the concentration of new development will be at Alfreton, Belper, Heanor and Ripley,
however the Strategy states that development will also take place on the edge of Derby, a
mixed use site north of Denby and other locations that will accommodate the bulk of the
housing need. It appears that an attempt is being made to retrospectively justify site
selection to the Spatial Vision.
Response
The Spatial Vision and Spatial Strategy have been amended to make it clearer where it is
proposed that development will take place.
Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Generally supported
except worth adding to the second paragraph: ‘The creation of a new housing led
development at Land North of Denby will be very well advanced, making a significant
contribution to meeting the Borough’s housing needs.’
Response
The Spatial Vision has been amended to add similar wording to that which has been
suggested.
Gladman Developments:
The Draft Core Strategy states that “Villages and rural areas in the Borough will be protected
from unsustainable development.” This statement is misleading, as it suggests that by their
nature villages are unsustainable. To the contrary directing growth to sustainable villages
within the Borough will be necessary and should be welcomed. This will help to sustain and
enhance the existing facilities and services and provide housing for local needs within these
villages. Gladman therefore recommend that this sentence should be deleted from the Core
Strategy.
Response
This statement was not meant to imply that villages are unsustainable. The Spatial Vision
has been amended to make it clearer that the intention is that all areas of the Borough will
be enhanced and protected from unsustainable and unsympathetic development.
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Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Unclear
how prioritisation of the A610 scheme is evidence based or consistent with other sustainable
development objectives.
Response
Responses to similar comments about this scheme can be found elsewhere in this
document. A planning application has now been submitted for this scheme, which is
accompanied by supporting evidence documents.
Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Support Objective 4
in relation to the Council enabling sufficient housing to be provided and the cross-reference
to SG3.
Strategic Objective 1 appears unduly onerous and is inconsistent with policy R1,that refers
to carbon reduction (and NPPF approach at para.11.1). Wording of S.O.1 to be amended
accordingly.
Response
The words “where appropriate” have been added to this objective.
Marrons: We note and support Objective 1 and the need to achieve sustainable
development and Objective 3 to promote the growth and viability of the market towns,
including Belper.
In respect of Objective 11, we support the need to create opportunities for non-motorised
transport and to increase public transport accessibility. In the light of the Strategic Objectives
of the Draft Core Strategy, it is difficult to see how reliance on a single greenfield housing
allocation in open countryside on land north of Denby (SG3) can be considered to meet
these three objectives – how it is sustainable, how it promotes the vitality and viability of
Belper and how it can possibly create an opportunity for non-motorised transport.
We therefore propose an alternative pattern of development which allocates additional sites
closer to Belper, able to take advantage of the existing infrastructure of the town in a more
sustainable manner.
Response
These comments do not require any amendments to the Strategic Objectives.
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Fisher German on behalf of the Trustees of Locko Estate: The identification of land to
the north of Denby as a principal focus for development is specifically supported.
Response
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm:
Penultimate paragraph of 6.6 suggests that strategy is driven by procedural convenience
rather than the conclusions of an evidence based enquiry into the optimum pattern of
development.
Response
This paragraph has been deleted.
Savills: The acknowledgement that other towns including Somercotes can play in the
delivery of housing to meet locally assessed housing needs is welcomed and supported.
6.1: The text reads in such a way that it is acceptable to simply release land from the Green
belt in order to accommodate development proposals. There is no specific justification
provided as to why sites at Ripley and Codnor represent exceptional circumstances. If the
release of land for development is required to provide or fund the A610 link road, that should
be clearly stated.
6.5 & 6.7: The Core Strategy continues to provide no definition of what a Strategic Site is,
nor justification of why only sites that meet the unspecified criteria are identified.
6.6: Section 6.6 identifies an advantage of Strategic Sites being the potential for earlier
housing delivery without having to wait for a separate Site Allocations Document. This is an
inaccurate statement, as the only reason non-strategic sites (whatever they are) are not
being allocated now is because the Council is choosing not to.
Response
The text referred to in paragraph 6.6 has been deleted. The sites adjacent to the A610 will
not be developed unless the new A610 link road is not implemented in its entirety. The
proposals are interlinked.
Capita on behalf of Wheeldon Brothers Ltd: We broadly agree with the spatial strategy.
The revocation of the Regional Plan provides a freer hand to the HMA authorities to guide
development to the most sustainable locations and where growth will have the maximum
regeneration benefit.
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A core strategy that directs a disproportionate level of growth to Derby risks abandoning the
rest of the HMA to a fate of structural decline, where opportunities for new investment in
local services, new infrastructure and environmental improvements are missed. A core
spatial strategy which directs significant growth to both extension locations within the city
boundary and the main towns of the HMA, has the best chance of delivering growth
alongside regeneration benefits and affordable housing directly where they are most need to
local people.
The ‘Amber Valley Regeneration Strategy 2005-2015’ (Amber Valley Partnership 2005)
notes that the District’s ‘greatest challenges are found in the east of the Borough where
some industrial communities contain pockets of dereliction, deprivation and social exclusion’.
In respect of market towns, the Strategy notes that ‘most of the population of Amber Valley
live in its four market towns. These also act as service centres for the nearby rural economy’.
The strategy seeks to reposition each market town to become more competitive places that
are: better balanced local economies; better able to attract and retain spending and
investments; better able to attract and retain skilled and talented people; more distinctive
and sustainable places.
Both the strategy and the more recent Amber Valley Retail Study note that Alfreton town
centre has declining footfall and ‘has the highest (i.e. worst performing) prime commercial
yield of any of the centres in the Borough’. The recent retail study notes that ‘this suggests
the town centre is failing to attract satisfactory levels of footfall, and the vitality and viability of
the centre is likely to be compromised as a result’. Heanor is said to be ‘struggling’ and a
‘cause for concern’, while Belper ‘exhibits generally good signs of vitality and viability’ and
Ripley ‘presents a number of positive signs of vitality and viability’. The Amber Valley
Partnership and the Retail Study recognises that the key to addressing Alfreton and
Heanor’s town centre issues is investment. In the current economic climate, this will need to
be private investment through growth, directed through the Core Strategy.
The regeneration needs of Amber Valley’s main towns require investment and growth in
order to direct regenerative resources to areas of deprivation. A core strategy that does not
direct significant growth to the main towns in the District will not only be unsound, but in the
current economic climate, risks abandoning the main centres of population in Amber Valley
to a fate of structural decline, where opportunities for new investment in local services, new
infrastructure and environmental improvements are missed.
Dispersing growth among smaller settlements will not create a sustainable pattern of
development. Smaller settlements do not have the range and scale of local services and
resources necessary to sustain their communities fully. To be genuinely sustainable a
settlement must be able to educate its children to working age i.e. have a secondary school;
must provide suitable employment opportunities; and must provide a sufficient level of local
services e.g. banks, supermarkets etc, to cater for the needs of its population. While smaller
settlements may contain a few local services, they will generally require a significant
proportion of the population to travel (usually by private car) to higher order centres for
employment opportunities, secondary and further education and supermarkets.
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Response
William Davis Ltd: A further policy is required outlining the more detailed strategy on
delivering the 9,400 dwelling figure. A separate policy clearly outlining the information
identified in Appendix B is necessary. Without such a change the main text and policies of
the document do not outline the overall development strategy, including the strategic site
allocations and the fact that the residual housing target of 720 dwellings will be allocated
through a Site Allocations and Development Management Policies DPD.
William Davis Ltd object to the overall strategy for meeting the housing target identified in the
draft document. We consider the strategy to be too reliant on the significant strategic
development sites. Such an approach is likely to constrain the delivery of new housing,
particularly in the early phases of the plan period.
Response
It is not considered that these comments require any changes to be made to the Core
Strategy.
Marrons: Whilst the objective to maximise the use of brownfield land reflects a core principle
of sustainable development, which is to encourage the efficient use of land by re-using
brownfield sites, this must be seen in the context of ensuring a viable and deliverable plan
(see paragraph 173, NPPF). In identifying and allocating brownfield sites, the Local Planning
Authority will therefore need to demonstrate conclusively, as part of the evidence base for
the plan, that these sites are deliverable in the terms of the advice set out in paragraph 173
of the NPPF. We note the Council’s acknowledgement that the availability of such sites is
diminishing. Our clients therefore support the inevitable recognition that increasingly
greenfield sites will have to come forward for development over the plan period.
Response
Gladman Developments: Objections relate to the priority which is being placed on
development on previously developed land, the spatial distribution and the limited growth
that is being directed outside of the market towns and Strategic Growth Sites.
Gladman raise significant concerns with the spatial approach proposed by the Council. The
spatial strategy should be based on the findings of the evidence base and should not be a
politically driven strategy to put a disproportionate amount of housing in areas where people
do not want and will not live. If the spatial distribution does not reflect need/demand as
shown through the evidence base, then the housing will not be delivered and the plan will
not be implemented.
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Prioritising brownfield sites is contrary to the whole ethos of the Framework as it could act to
restrict otherwise suitable and sustainable development from coming forward.
The Core Strategy is placing an overreliance on the delivery of the Strategic Growth Sites. In
the event that any of these sites do not deliver to the scale and timescales proposed through
the Core Strategy this would jeopardise the delivery of the plan as a whole due to the
reliance that is placed on these strategic sites. The Council need to be able to demonstrate,
through robust evidence, that delivery of these sites are viable and consequently that these
sites are credible options to be included within the Core Strategy.
This viability evidence appears to be absent from the evidence base which is a fundamental
flaw. Gladman note that large scale housing sites such as the seven Strategic Growth Sites
will have significant lead-in times (both with regards to gaining full planning permission, but
also site preparation, provision of necessary infrastructure improvements, or remediating
contamination). This means that the delivery of housing on these sites will not happen for a
number of years, these are effectively medium to long term housing sites.
Gladman note that the Council are yet to produce a housing trajectory to support the Core
Strategy. Following discussions with Council officers it is understood that this will be
prepared in advance of the next stage of public consultation. Without the housing trajectory
which covers the whole plan period it is not possible to assess the assumptions the Council
are placing on delivery of these Strategic Growth Sites across the whole plan period and
whether or not these are realistic. Gladman therefore recommend that the Council allocate a
greater proportion of growth to be delivered outside of these Strategic Growth Sites, within
and adjacent to the sustainable settlements in the Borough, as this would have the potential
to increase housing delivery in the short to medium term (as these smaller sites are likely to
have shorter lead-in times). This could help the Council to ensure a rolling five year supply of
deliverable housing sites and work towards the Governments objectives of boosting
significantly housing delivery.
Response
These comments are noted, but it is not felt that any changes need to be made to the
contents of the Core Strategy.
Signet Planning: The draft Core Strategy indicates a small increase in housing numbers
from the Preferred Growth Strategy position of 33,700 to the current position of 35,354
across the Derby HMA. Of these 25,950 will be provided in South Derbyshire and Derby
City. It is unfortunate that these Authorities have not issued consultation documents
contemporaneously with Amber Valley so the complete‖ picture can be established.
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The level of housing provision proposed across the Derby HMA is below the RSS figure and
very significantly below the ONS (2008-based SNPP) projection. Cambridge Econometrics
(CE), custodians of the Chelmer Population and Household Model were commissioned by
Signet Planning to review the Derby Housing Market Area Population and Household
Projections Explanatory Note (July 2011). The Chelmer analysis confirmed that the SNPP
scenarios put forward by the Councils in the Explanatory Note were the best fitting - the
dwelling requirement under the 2008-based SNPP scenario over 2008-28 is 47,900. It is
important to note that Amber Valley Borough Council did not contest CE‘s analysis.
Furthermore, the Council has never formally commented on the CHELMER analysis or
presented it to their consultants for assessment.
In Amber Valley the current consultation indicates an objectively assessed need of 9,400
dwellings 2008-28 of which 4,236 are still to be allocated. 3,529 of these are identified on 5
sites with 716 to be identified in the Site Allocation DPD.
Policy SS1 states that a minimum of 9,400 houses will be required over the Plan period and
that these will be located in and surrounding the 4 market towns of Belper, Ripley, Heanor
and Alfreton. Strategic Objectives also reflect that distribution. However, the proposed
distribution does not follow the Policy (SS1) neither does it accord with Strategic Objective 2
and 3. Whilst there is a housing allocation at Cinderhill this cannot be considered as part of
the Belper sub housing market, it has its own sub market. The proposed distribution does
not take this into account.
By revising the migration assumptions, GL Hearn is questioning a methodology that the ONS
considers to be fit for purpose and makes use of the most up-to-date data that is available.
GL Hearn’s assumption that that migration will stagnate must be treated with caution. Whilst
Government policy is to reduce non-EU migrants, many of these will continue from Eastern
Europe. Furthermore, as the economy recovers further in migration will occur. The NPPF is
clear that account has to be taken of migration and suggests that it is not open to an
authority to simply make whatever assumptions it chooses. As a consequence, the Borough
Council will need to clearly demonstrate that in co-operation with other adjacent authorities
that it will accommodate unmet housing need and has taken account of migration.
The GL Hearn report also revised the CLG headship rates downwards. This undermines the
Derby HMA’s ability to provide sufficient levels of housing once the economy improves and
people have the financial security to form new households.
The draft Core Strategy also has a major part to play in developing the economic power of
the HMA. Therefore. the 2010 based assumptions should be adjusted to create a higher
growth target that is clearly needed to overcome historic shortfalls in housing provision and
improve the economic performance of the Derby HMA. The adopted approach for calculating
the proposed quantum of housing represents minimisation and containment and ignores the
potential of the HMA to attract jobs and in migration. Such a position is not tenable and the
Council’s are urged to model a Pro-Growth scenario.
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For the reasons set out above, the draft Core Strategy does not meet the tests of soundness
as set out in paragraph 182 of the NPPF. It has not been positively prepared, the strategy is
not justified, it is not effective and it is not consistent with national policy.
Response
It is considered that the work carried out by GL Hearn has produced a housing target for
Amber Valley that does meet the objectively assessed housing needs in the Borough.
Antony Aspbury Associates on behalf of Omnivale Limited: We object to the overall
level of housing provision proposed for Amber Valley for the period 2008-2028 as this level
of housing is considered to be way below the full objectively assessed needs for the
Borough and as a consequence contrary to the provisions of paragraph 47 of the NPPF. It is
our view that that this minimum threshold is inadequate and should be increased to a
minimum of 10,000 dwellings for the period and potentially 11,000 dwellings to be more
reflective of the Government’s ONS assessment of housing need.
Response
Amber Valley and the Derby HMA that does meet the full objectively assessed housing
needs in the Borough and the HMA.
Fisher German on behalf of the Trustees of Locko Estate: There should be specific
reference to Land to the north of Denby being a key growth area within Policy SS1.
Response
The policy has been amended to include specific reference to this site.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: The
policy states that strategic housing development will take place in Alfreton, Belper, Heanor
and Ripley, to support the local economies of the four towns, but no strategic growth is
assigned to Belper. Development of land to the south east of Belper could help to sustain
economic growth in the town and improve local infrastructure, including public transport links
to existing residential estates.
Response
This is a matter for consideration when the Site Allocations and Development Management
Policies DPD is produced.
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Catesby Estates Limited and Kedleston Estate: The policy sets out the minimum number
of 9,400 homes to be built in Amber Valley Borough between 2008 and 2028. We welcome
inclusion of ‘minimum’ housing numbers as this provides the necessary flexibility within the
policy to provide sustainable development to meet demonstrable housing need. However, it
is not clear from the policy whether the 9,400 dwellings is to meet the housing needs of
Amber Valley only or includes unmet housing needs from Derby; the policy omits any
reference to this important point. We consider that the 9,400 dwellings should relate to the
Borough and urban extensions to meet Derby City’s needs should be in addition to this
number. The ‘minimum’ reference provides flexibility to the policy to accommodate this,
however given its strategic importance there should be some policy steer to acknowledge
the need to meet Derby’s needs within the Borough and reference the planning mechanisms
to which these sites will be considered.
The NPPF states that the local planning authorities must “boost significantly the supply of
housing” and “use their evidence base to ensure that their local plan meets the full,
objectively assessed needs for market and affordable housing in the housing market area”
(paragraph 47). In order for the Draft Core Strategy to be found sound, the Council needs to
ensure that this policy can be robustly justified in order to demonstrate that it identifies an
objectively assessed housing need in accordance with paragraphs 47 and 159 of the NPPF.
Clarification and justification of the housing numbers will help ensure that the Council can
demonstrate this.
Response
Amber Valley that does meet the full objectively assessed housing needs in the Borough.
Home Builders Federation: Policy SS1 proposes a minimum of 9,400 dwellings primarily
distributed around the four market towns of Alfreton, Belper, Heanor and Ripley. It is not
clear from Policy SS1 whether or not the housing requirement figure of 9,400 dwellings is for
the housing needs of Amber Valley only or includes unmet housing needs from Derby. The
Council should provide greater clarity.
The Housing Requirement Study uses 2008-based ONS/DCLG statistics as its baseline
figure, fertility and death rates are as ONS based on SNPP. However household formation
(headship rates) and migration are adjusted. The adjustment of household formation rates
and migration pattern are questionable. The resultant effect is to reduce the unadjusted
figure from 47,900 dwellings to 35,354 dwellings over the period 2008-2028 for the Derby
HMA.
Appendix A also states that the Housing Requirement Study uses a vacancy rate of only
2.5% rather than the more usual vacancy rate of 3%. This variation requires explanation and
justification by the Council.
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The NPPF expects local authorities to take account of migration. It follows that an authority
would need good reasons to depart from the projected migration flows. These ought to
include an explanation of where the households affected are going to live and the results of
consultations with other authorities concerned under the Duty to Co-operate. The NPPF
requires that local plans provide for objectively assessed demand unless the adverse
impacts of doing so would significantly and demonstrably outweigh the benefits.
Amber Valley Council will need to demonstrate that whilst three of its market towns (Belper,
Heanor and Ripley) are largely surrounded and constrained by Green Belt, this has not
unduly influenced the proper assessment of housing needs.
When the “What Homes Where?” and 2011 interim household growth figures are converted
into dwellings using the NHPAU demographic method, these alternative projections would
equate to housing requirements of 11,708 and 9,577 dwellings respectively without the
addition of any constrained demand nor any unmet need from Derby, illustrating housing
requirement figures above the 9,400 dwellings proposed in the Draft Amber Valley CS.
Under Paragraph 47 of the NPPF the Council must “boost significantly the supply of
housing” and “use their evidence base to ensure that their local plan meets the full,
objectively assessed needs for market and affordable housing in the housing market area”.
The Amber Valley Draft Core Strategy is currently unsound because it fails to identify an
objectively assessed housing need as required by Paragraphs 47 and 159 of the NPPF.
Paragraph 47 of the NPPF emphasises that Local Planning Authorities should continue to
demonstrate a 5 years housing land supply, which is to be supplemented by an additional
buffer of 5% to ensure choice and competition in the land market or where there has been a
record of consistent under delivery of housing an additional buffer of 20%. Indeed Paragraph
49 of the NPPF goes on to state “relevant policies for the supply of housing should not be
considered up-to-date if the local planning authority cannot demonstrate a five-year supply of
deliverable housing sites”.
With a housing requirement of 9,400 dwellings (470 dwellings per annum) the Council will
need to identify 5 year supply of land equal to 2,350 dwellings (470 x 20). At this time there
is no evidence whether or not the Council has identified such a supply of deliverable sites
neither is there any indication of the application of a 5% or 20% buffer to this land supply.
The Council should provide further information.
In the Draft Plan there are a number of references to prioritising brown-field land, which is
contrary to the NPPF. Paragraph 17 of the NPPF encourages the re-use of brown-field land
it does not advocate a brownfield before greenfield policy. The Council should consider
deleting the following references to prioritising “The Council will ensure brown-field land is
considered first and Green Belt protected” and “6.2 Maximising use of brown-field land
priority”.
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Response
Further clarification has been provided in the Core Strategy regarding the 5 and 15 year
housing supply in the Borough. It is considered that the work carried out by GL Hearn has
produced a housing target for Amber Valley that does meet the full objectively assessed
housing needs in the Borough.
It is considered that the strategy of prioritising brownfield land, which is fully supported by
Amber Valley residents, is in accordance with the NPPF.
Capita on behalf of Wheeldon Brothers Ltd: We support the housing numbers and land
requirements set out which aim to meet objectively assessed needs. The distribution is
appropriate.
Response
William Davis Ltd: William Davis Ltd note that the Housing Target in the Draft Core
Strategy are essentially the same as the numbers Pegasus objected to previously and
consequently consider said objection to remain valid in terms of the current consultation. We
do not consider it necessary to repeat the objection made on the housing numbers to the
Growth Strategy consultation, but urge the Council to reconsider the position and review the
previous objection.
Whilst William Davis clearly identify our objection to the over reliance on large strategic sites
and the need for further information to be included in the Local Plan document, we do not
object to the urban concentration strategy identified in Policy.
We consider the policy for most of the growth in the Borough to take place in and around the
market towns is a sustainable one, with development being delivered in the most sustainable
locations within the Borough.
Response
Marrons: Para 6.7 of the Draft Core Strategy confirms that, currently, a minimum of 9.400
dwellings are proposed to be provided in Amber Valley, which represents only 26.6% of the
adopted Derby HMA figure of 35,350 dwellings over the period 2008 – 2028. The proposed
minimum provision of 39,350 is itself below the Government’s official projection of 47,900
and also less than the former East Midlands Regional Plan requirements of 36,600 for 2006
to 2026 (Appendix A confirms). Our conclusion is that the 9,400 dwelling minimum
requirement should be regarded as just that – the minimum and that the Draft Core Strategy
should provide for a higher figure of, at least, 9,900 (28% of 35,350).
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In the event that the plan is found sound and adopted on the basis that the minimum level of
provision of housing provision to be met over the plan period is 9,400 homes, then Policy
SS1 will require two further additions to the text.
a) Housing provision should be expressed as a net figure, so that any replacement homes
arising from the demolition of dwellings within the existing stock, are not then counted
towards the additional provision.
b) After paragraph two of Policy SS1 the following new paragraph should be inserted to
explain that over the plan period ultimately more than 9,400 homes could be provided, if
appropriate sites, consistent with the policies in the Core Strategy, come forward.
“Over the plan period the Council will grant planning permission for the development of new
homes on sites that are appropriate for residential development, meet the requirements of
Policy SS13 and other relevant policies in the Core Strategy. The delivery of new homes in
this way will not be constrained by reference to the minimum level of housing provision.”
Appendix B refers to a projected level of development from windfall sites, between April
2013 and March 2028, in the order of 795 dwellings. Paragraph 48 of the NPPF sets out
advice on the inclusion of windfall sites in the assessment of a five years housing land
supply. Any allowance for windfall sites should be based on compelling evidence that such
sites will continue to provide a reliable source of supply. The advice in the NPPF on Plan
Making and policies for housing, however, includes no reference to windfall allowances and,
instead, focuses on the preparation of a SHLAA to establish assumptions about delivery
from land to meet the identified needs. Recent appeal decisions, including for example,
Bugbrooke, Northamptonshire (APP/22830/A/11/2166866) indicate that the reliance on past
rates of delivery from windfall sites does not of itself amount to compelling evidence.
Furthermore, in this instance, the Council acknowledge, in the Preferred Strategy Paper, that
the forward supply of brownfield sites is diminishing.
We therefore consider that any allowance for the delivery of new homes from brownfield
windfall sites must be deleted from the estimate of the existing recorded land resource in
Amber Valley. The resulting plan will be more robust as a result of this, and, indeed, would
not preclude in any event applications coming forward for development on windfall sites.
The Council is faced with a problem of securing the delivery of new homes in the short term;
the five years of the plan period between 2013 – 2018. This is an issue which my clients
consider should be addressed in the Local Plan and through decisions taken by the Council
to approve applications for the development of appropriate sites for new housing in the short
term. To some extent, we believe this will be achieved by adopting the modification to policy
SS1, as noted earlier in this submission. It will also be remedied to a lesser extent through
the allocation in the Core Strategy of additional sites. This would encourage
landowners/developers to bring more land forward in the short term and provide a necessary
boost to the forward supply of land. We note in that regard that on two of the strategic sites
identified in the Core Strategy (Mansfield Road, Alfreton, and Rabourne Lane, Mackworth),
permissions have been granted to facilitate commencement of the developments.
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However, the shortfall in provision is so great that these sites, of themselves, will not make
any substantial “inroads” into the persistent under-provision of a five years supply of housing
land. We consider that the sites which have been identified would not deliver in total the
assessed number of new dwellings over the plan period.
Response
The policy has been amended to refer to a minimum of 9,400 homes (net) being required
from 2008 to 2028.
It is not considered necessary to add the paragraph that has been suggested, as the Council
is already granting permission for non strategic sites in sustainable locations on the edges of
settlements that are not allocated in the existing Local Plan, in accordance with the advice in
the NPPF.
The Barton Wilmore report, commissioned by Gladman Developments concludes that based
on the latest population projections and applying the 2008 based headship rates in order to
estimate household numbers, the housing requirement across the Derby HMA for the period
2008-2028 is 48,397 of which the requirement for Amber Valley is 11,391. This is
significantly higher than the emerging Local Plan requirements of 35,345 and 9,400
respectively. For Amber Valley, the requirement increases to 11,660 when account is taken
of the additional number of jobs that are projected to be created over the period 2011-2028.
Gladman raise significant concerns with the proposed Strategic Growth Sites, in particular
the land north of Denby and the sites at Ripley and Codnor which require a new link road. In
relation to these strategic sites the Council need to provide evidence of their viability to
demonstrate that they represent credible and realistic options.
In relation to these large scale sites the Council need to ensure that they are applying
realistic timescales (including lead-in times and delivery rates). The Council should allow for
a mix of sites (in terms of size) within their Core Strategy to ensure delivery of housing
numbers across the plan period.
The Council, along with the other Derby HMA authorities (Derby City and South Derbyshire),
need to reconsider the scale of housing growth required across the HMA, ensuring that this
provides an accurate assessment of the full, objectively assessed housing needs and does
not constrain housing growth through an over reliance on trend based assumptions that
have been conditioned by a period of recession and development constraint. Significant
concerns have been raised in relation to the scale of growth proposed and these would
render the plan in its current form unsound. Linked to the tests of soundness outlined in
paragraph 182 of the Framework it cannot be considered that the plan has been ‘positively
prepared’, as it is not based on a strategy which seeks to meet in full the objectively
assessed development needs including the unmet requirements from neighbouring
authorities.
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The Council claimed objectively assessed needs is based on the Derby HMA Housing
Requirements Study (September 2012) and the Derby HMA SHMA update (July 2013). The
migration and headship rates assumptions used in their trends based projections are
questionable. Trends based assumptions that have been conditioned by a period of
recession and development constraints are a wholly inappropriate basis for plan making.
They will result in a sub optimal population and household growth projection which, if it
becomes the basis for plan period housing requirements, will do great harm to prospects and
plans for economic recovery and growth.
In respect of realising economic growth aspirations, it is evident that the housing requirement
agreed by Amber Valley, Derby and South Derbyshire will not supply sufficient labour to fulfil
the ‘policy on’ objective of adding 20,000 jobs to the HMA economy over the plan period.
The requirement identified in the Barton Wilmore report will broadly match the jobs target
with labour force growth.
The implications of not planning to meet a housing requirement based on the latest
demographic projections are that economic growth within Amber Valley and across the HMA
will be constrained. This will result in failure to achieve local, HMA and LEP economic goals
and wholly contradicts the government’s growth agenda.
Furthermore, the agreed HMA housing requirement fails to address backlog affordable
housing need, which stands at 3,924 households. Moreover, it is unlikely to address current
and future housing need in full.
Taking affordable housing need into account, the housing requirement for the HMA will be
up to 3,924 greater than our objective assessment of 48,397. Accordingly the minimum
housing requirement for the HMA is between 48,397 and 52,321 and for Amber Valley is
between 11,660 and 12,574.
Despite stating within Appendix A, that an element of Derby City’s unmet need is accounted
for within the proposed 9,400 dwellings, the Draft Core Strategy provides no further details
or clarity regarding this. The Core Strategy should express clearly the overall housing
requirement, any element of this which is addressing unmet need in neighbouring authorities
and the spatial strategy for delivering the proposed scale of growth.
Response
The Strategic Housing Market Assessment (SHMA) for the Derby HMA produced in 2013
recommended the provision of a minimum of 8,326 dwellings in Amber Valley from 2008 to
2028. The figure of a minimum of 9,400 dwellings referred to in the Core Strategy is 1,074
greater than this figure, to meet the unmet housing needs of Derby and to plan for greater
economic growth than that which is currently projected to take place in the Borough during
the plan period.
164
Heaton Planning on behalf of Waystone Developments: The Government has a clear
agenda to deliver growth and significantly increase housing supply nationally. This is evident
from the NPPF, which seeks to promote sustainable development and the delivery of new
housing and a mix of housing to meet the needs of society, both present and future. Whilst
the Council is not proposing to radically lower their housing targets from that contained in the
RSS, we consider the housing targets contained in the Draft Core Strategy to be
insufficiently ambitious to ‘boost significantly the supply of housing’ (NPPF, paragraph 47).
Given the clear intent of Government and National Policy, local authorities should be seeking
to increase housing provision rather than reduce it.
Amber Valley does not have a five year housing supply. Paragraph 47 of the NPPF states
that ‘to boost significantly the supply of housing, local planning authorities should...identify a
supply of specific deliverable sites sufficient to provide five years’ worth of housing against
their housing requirements with an additional buffer of 5% to ensure choice and competition
in the market for land. Where there has been a record of persistent under delivery of
housing, local planning authorities should increase the buffer to 20%’. Due to the Council’s
lack of a five year housing supply, there is an even greater onus on the Council to identify
suitable and deliverable housing sites in their Core Strategy to make up for the housing
shortfall during the Plan period.
Given the above, we consider Policy SS1 and the Council’s proposed housing target to be
unsound. The Council should be looking to identify a supply of deliverable sites sufficient to
provide five years’ worth of housing against their housing requirements with an additional
buffer of either 5% (as a minimum) or 20% (where there is a history of persistent under
delivery of housing). Therefore, for the Plan to be sound and, given the historic low levels of
housing supply, we recommend an increase in the supply of homes to at least 11,260 (i.e.
the baseline requirement plus 20%).
Response
165
Signet Planning:
The Council has not provided a proactive and positive response in its policy framework with
regard the provision for new employment and growth in Amber Valley. Specifically the plan
does not make provision for the allocation of a strategic employment site (SES) to provide
potential for employment growth in Amber Valley in the Plan period.
In these terms the Plan fails the tests on the following basis:
•
It has not been positively prepared. The Council’s employment strategy is based on a
negative/pessimistic view of existing and projected employment needs. It ignores the
opportunities which exist in Amber Valley because of its geographical location,
juxtaposition with the A38/M1 and potential attractors to business/investors for a
SES. The non allocation of such a site represents a missed opportunity to provide for
significant future employment growth both for the existing residents of the Borough
(many of whose wards suffer from relatively high levels of deprivation) and for inward
investment.
•
The employment strategy is not justified. The employment land reviews carried out
by the Council’s consultants (BE Group & GL Hearn) acknowledge there are
significant deficiencies in the quality of the existing employment land supply –
emanating from previous allocations and unimplemented permissions. The Council’s
strategy however is for ‘more of the same’. This will not lead to a step change in the
delivery of sites for employment development that will generate employment growth
rather than periods of inactivity followed by applications for housing.
•
The plan will not be effective in delivering a positive employment strategy for Amber
Valley in line with Government policy. Furthermore it will not meet the Council’s
Strategic Objectives and specifically 2 and 12.
The lack of policy is not consistent with the National Planning Policy Framework (NPPF)
regarding the allocation of appropriate land for business and employment development and
the deliverability of sustainable growth.
Amber Valley has the potential to make the Core Strategy sound by introducing a policy
which sets out the intention to allocate a SES.
To ensure success a SES should have the following qualities:
1. A suitable size to deliver employment growth throughout the Plan period. Thus a site of at
least 30 hectares should be brought forward.
2. Be in a strategic location attractive to existing employers and inward investors and having
good accessibility to important transport routes.
3. Be located within an attractive high quality environment.
4. Have the ability to provide employment and related uses over a phased development.
5. Relate well to existing settlements/population and workforce in Amber Valley.
6. Have the ability to provide a link with the local economy through its location and type of
site potentially provided (including for local businesses expansion).
166
7. Have the ability to provide a ‘unique selling point’ in terms of either location, the provision
of support services on the site and other uses that may not be employment in nature that
would be associated with employment and growth, e.g. education, health and recreation.
The potential to accommodate a SES has not been looked at in sufficient detail by the
Council. The Council’s consultants responded to an earlier representation made by Signet
Planning regarding a potential SES.
The response to that representation identifies an opportunity for a ‘top-tier’ quality
employment site but revealed a lack of understanding of how a SES in Amber Valley would
fit alongside other SESs in other local planning authorities. In particular, the following
comments can be made:
•
Any site of a strategic nature takes a considerable period (often 18-24 months) to
obtain planning permission and bring forward for development. It need not have
(indeed typically does not have) an ‘end user’ attached to it. Examples of other
strategic sites (including in the East Midlands) demonstrates that one does not need
an initial end user at the start of an allocation process. The timescale for those end
users wanting to be accommodated on a particular site is far less than the policy and
allocation process being contemplated. They need “oven ready” sites.
•
An SES needs to provide good quality employment land throughout the Plan period.
It is therefore unrealistic to require a strategic site to have an end user attached to it.
Precedent of a number of sites elsewhere indicates that where a site is allocated and
brought forward plots are taken up in response to national and regional requirements
that change over time.
•
There seems to be an acceptance that Amber Valley would not be able to provide a
successful SES simply because there are other sites in other local authorities in the
East Midlands that have been brought forward. That is a highly negative approach. If
the other authorities in which those now successful sites had taken a similar view (i.e.
the competition was too tough) those sites would not have been brought forward and
investment would not have taken place in areas such as Nottingham City, Gedling,
Bolsover etc. Notwithstanding it is clear from the analysis in these representations
that neither of the two named “competitor” sites – Markham and Castlewood will
affect or be affected by a SES in Amber Valley. The concerns of GL Hearn have
been dealt with. There is the opportunity to raise the economic profile of Amber
Valley and generate much needed jobs in an area of high deprivation and across the
broader Borough where out-commuting is high.
•
The provision of a quality strategic employment site should take place outwith local
quantitative assessments of employment land in the Borough.
The planning arguments in favour of SESs have been set out and are considered to be
particularly strong and will address the failed tests of soundness which the Core Strategy
currently does.
167
The experience of both Knight Frank and Rigby & Co commercial agents reveals the
following:
•
Certain parts of Amber Valley possess the qualities of good accessibility,
environment and workforce availability that could enable a strategic site to develop
successfully.
•
There are a regular list of national and regional requirements from employers and
development organisations that Amber Valley currently could not provide for.
Assuming those requirements will continue into the future the provision of a strategic
employment site would allow the opportunity for investment in the Borough that has
not been able to happen before.
•
The Borough has had a large employment site potentially available in the past – at
Cinderhill. However, the high cost of bringing that site forward resulted in it never
being viable or deliverable. The policy allocation for a strategic employment site
needs to emphasise deliverability.
•
The location of part of Amber Valley is in an area where local business and economic
organisations – most recently the Local Enterprise Partnership (LEP) – have
identified as a potential area of search for significant new investment, Amber Valley
should respond to those initiatives.
Overall there is significant potential over the course of the plan period for economic
investment in Amber Valley based around strategic employment needs (which could now be
generated more quickly due to the recovery from the recession; related local economic
community and educational investment) and the attractive location of parts of Amber Valley
to meet such requirements.
There has been no analysis of these requirements or how strategic employment sites work
in the Council’s Core Strategy. This is a significant omission. A policy should therefore be
included within the Core Strategy for the Council to identify a strategic employment site as
part of the next stage of the policy evolution. Such a site should have an area of at least 30
hectares and have the qualities of accessibility, deliverability, environmental quality and
relationship to existing settlements and workforce. The lack of an end user in this regard is
an irrelevant consideration as the policy will be extant on the timeframe of the Core Strategy.
These representations identify the need for a SES and the suitability of the A38/ Alfreton
corridor as a location for a Strategic Employment Site where benefits to the Borough will be
maximised. The Council is therefore urged to reconsider its strategy in terms of employment
(which is considered to fail at least three of the test of soundness of the strategy) and include
an appropriate policy for the identification of a SES.
These representations have examined the Council’s evidence base to the Draft Core
Strategy including reports prepared by GL Hearn and the 2008 BE Employment Land
Review and consider that the Draft Core Strategy is unsound as it is not justified, positively
prepared, effective or compliant with national policy as outlined in the National Planning
Policy Framework.
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The representations raise a number of issues
1. The draft Core Strategy has not satisfactorily addressed the need to promote sustainable
economic growth in the Borough over the Plan period. It does not plan proactively to “B It
does not set out a clear vision and strategy for the area that proactively encourages
sustainable growth. Furthermore it does not respond positively to the evidence base which
indicates both a qualitative and quantitative need for employment land.
2. The Representations establish a need for a Strategic Employment Site in the Borough; it
is a misinterpretation of the market and the evidence to take the view that to develop such a
site in the Borough would affect and would be affected by the two “competitor” sites
identified by G L Hearn at Castlewood and Markham. Knight Frank has demonstrated that
would not be the case.
3. The draft Core Strategy indicates that 75 hectares of employment and business land is
required over the plan period (2008-28); this must be considered as a minimum in view of
the more rapid take up of the “competitor sites” than anticipated, the unattractiveness of
some of the “committed and allocated” sites (51 ha) within Amber Valley, the need to
address the high and increasing levels of out-commuting, the need to provide jobs and
training opportunities close to areas of deprivation where personal mobility is more restricted
and to ensure maximum financial benefit for the local economy.
4. Irrespective of the quantitative need a qualitative need has been identified by both GL
Hearn and the BE Group. To bring forward a high quality site there needs to be the right
qualities; qualities as set out in these representations that can only be met by the allocation
of a single Strategic Employment Site.
5. Taking account of the qualities for establishing a Strategic Employment Site and the
opportunities and constraints within the Borough an area of search along the A38/Alfreton
corridor has been identified. This area has the following benefits:
•
Lying outside the Green Belt
•
Lying outside the World Heritage Site
•
Being adjacent to the strategic highway network – A38 and M1
•
Being adjacent to areas of highest multiple and employment deprivation where
greatest benefits would accrue.
•
Provide a very significant economic multiplier effect on areas of highest deprivation.
•
Lying within the area of “development potential in the east of the Borough close to
the A38/Alfreton” as highlighted in para 5.26 of the GL Hearn July 2013 report
6. A Strategic Employment Site would create its own identity and the delivery of B1, B2 and
B8 uses and with the ability to accommodate ancillary uses such as education/training, hotel,
restaurant, crèche etc.
169
7. Development of a Strategic Employment Site cannot be dependent on identifying an end
user ahead of allocation and planning consent. This has been clearly demonstrated by both
Knight Frank and Rigby & Co. Local examples at Markham, Castlewood and Sherwood
Business Park have all developed successfully without any identified users. Roads and
sewers have been constructed and development has followed. The draft Core Strategy
neither reflects the process or the market when it states “insufficient interest has been
demonstrated by potential employers to require a site of this scale to be allocated”. This
demonstrates a lack of understanding of the reality of commercial investment.
In view of the above it is considered that the current draft Core Strategy is unsound as it is
not justified, effective, positively prepared or compliant with National Policy. It is considered
that an additional policy is required.
Response
Policy SS2 has been amended to state that when looking to allocate new business and
industrial sites in the Site Allocations and Development Management Policies DPD, a review
of existing business and industrial land allocations will take place, in order to ensure that a
minimum of 75 hectares (net) of business and industrial land will be provided between 2008
and 2028 for economic growth and future employment needs and to ensure that sufficient
high quality sites are included in the overall provision.
Savills: The identification of Somercotes as a local centre at which the draft policy seeks to
encourage a balanced approach to the planned level of housing and employment growth is
supported.
Response
Gladman Developments: Gladman note that the Draft Core Strategy refers to more locally
focused development occurring in Langley Mill, Duffield, Codnor, Leabrooks, Swanwick and
Somercotes and the rural villages – however the Draft Core Strategy does not provide any
further details or clarity regarding the scale of growth that should be going to these
settlements. Gladman submit that the Core Strategy needs to be more specific on the level
of growth that will be apportioned to these villages.
Gladman note that the Core Strategy evidence base does not include a settlement hierarchy
or any detailed assessment of the settlements below the four market towns of Alfreton,
Belper, Heanor and Ripley. This is a significant concern, these lower tier settlements will
need to take a degree of housing growth over the plan period.
Due to the absence of a settlement hierarchy Gladman have undertaken a brief and initial
assessment of settlements in Amber Valley. Following this initial review Gladman submit that
there are a number of settlements within Amber Valley that when assessed in relation to the
scale of services and facilities that are available are sustainable settlements and should be
subject to further consideration with regards to the scale of housing growth directed to them.
170
An example of a sustainable settlement within Amber Valley is Crich. This settlement
currently offers a primary school, food/convenience store, post office, medical centre,
pharmacy and opticians (this is not an exhaustive list). This settlement is not heavily
constrained and does not fall within the Green Belt. Gladman therefore submit that through
the Core Strategy the Council should be directing further housing growth to sustainable
settlements such as Crich. This would help meet local needs but also play an important role
helping to sustain and strengthen the existing services and facilities in these locations.
These types of settlements, for example Crich should through the Core Strategy proposals
be directed a greater degree of housing growth. This would help meet localised needs but
also play an important role helping to sustain and strengthen the existing services and
facilities in these locations.
Response
The allocation of non strategic housing sites in villages will be considered when the Site
Allocations and Development Management Policies DPD is produced.
Capita on behalf of Wheeldon Brothers Ltd: We endorse the policy as set out.
Response
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: The
strategy for regeneration in Belper should be much broader than promotion as a tourist
attraction and maintaining the market town quality. A broad range of employment
opportunities is needed, with potential for quality office development and encouragement of
creative and productive industries. A masterplan or Neighbourhood Plan is certainly required
to coordinate the complex constraints on the numerous potential redevelopment sites and
achieve the optimum distribution of retail, service sector and other employment
development, and new community facilities (sports, library, adult education etc.) which are
under consideration.
Is this the place to mention the opportunities which would arise from diverting mainline rail
services away from Belper Station (HS2 and/or a new electrified Midland Mainline) and
freeing up capacity for much more frequent local services to Chesterfield, Sheffield, Derby,
Nottingham, Leicester and Birmingham?
171
Response
The Borough Council will consider if a masterplan is required for Belper, as stated in the
policy. The comment regarding opportunities which would arise from diverting mainline rail
services away from Belper Station is noted, but the text in the document has not been
changed.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Belper
town centre boundary should include the railway station and the temporary extension to the
Field Lane car park (proposed leisure centre site, which was in residential use when Roger
Tym report was produced).
Response
The town centre boundary has been amended to include the proposed leisure centre site.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Belper:
Include both sides of Bridge Street between King Street and Derwent Street in primary
frontage. This part of the town centre has some good and lively shop-fronts, a high
pedestrian footfall due to car parking in Derwent Street, and forms the key impression of the
town to visitors passing on the A6. Consider excluding the return frontages on Campbell
Street and Green Lane.
Response
It is not considered that these changes are required.
Capita on behalf of Wheeldon Brothers Ltd: We would question whether the policy is
reflective of the realities of the high street and changing patterns of shopping and town
centre use. Primary shopping frontages should have an active mix of high street uses not
just A1 retail. The nature of retailing and shopping is also changing with increase in online
retailing. The high street must be able to adapt to these changes and to seek new active
uses. The policy risks encouraging vacancy rather than active uses.
Response
It is considered that primary shopping frontages play an important role in retaining and
enhancing the vitality and viability of the most important shopping areas in town centres.
172
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Consider
removing SHLAA site AVBC/2008/0153 (Far Laund, Belper) from Green Belt to enable
modest (non-strategic) ‘rounding off’ development in an area surrounded by existing
development on three sides and thus not of importance to the purposes of the Green Belt.
Response
The allocation of this site will be considered when the Site Allocations and Development
Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Addition of reference
to safeguarded land could be added to Policy SS11/associated plan instead of SS10.
Response
It is not considered that there is sufficient evidence to justify a need for Green Belt land to be
safeguarded.
Fairgrove Homes Limited: A considerable proportion of the Borough is designated as
Green Belt. Many smaller settlements and villages are washed over by the Green Belt in
which development will be severely constrained by Policy SS10. This seems completely
contradictory to proposals under Policies SS1 and SS3. Policy SS1 proposes that growth
outside the four market towns will take place “within the settlements of villages at the most
accessible and sustainable locations, that promote the vitality and viability of communities”
whilst Policy SS3 states “development will be encouraged to support a balanced approach to
the planned level of housing”.
Response
The policy allows limited infilling in villages.
Home Builders Federation: A large proportion of the Borough is designated Green Belt.
Many smaller settlements are washed over by the Green Belt in which development will be
severely constrained by Policy SS10 - Green Belt. This seems contradictory to proposals
under Policies SS1 and SS3. Policy SS1 proposes growth outside the four market towns
taking place “within settlements of villages at the most accessible and sustainable locations,
that promote the vitality and viability of communities” whilst Policy SS3 - The role of
settlements states “development will be encouraged to support a balanced approach to the
planned level of housing”.
Since the revoked EMRP recognised the difficulty in finding land not designated as Green
Belt to meet the objectively assessed housing needs of the Borough, it is incomprehensible
that the Council is not proposing a comprehensive review of the Green Belt as part of the
Local Plan process. Paragraph 83 of the NPPF states that “LPAs with Green Belts in their
area should establish Green Belt boundaries in their Local Plans which set the framework for
Green Belt and settlement policy”.
173
Whilst under Policy SS11 the Council is proposing to amend the Green Belt boundaries for
the strategic sites at Ripley and Codnor, it would be appropriate following a comprehensive
review of the Green Belt for the Council to consider establishing boundaries around
individual settlements within the Green Belt rather than continuing with the existing policy of
the Green Belt washing over these settlements. The washing over of settlements in the
Green Belt does not fulfil any of the five purposes of the Green Belt as defined in Paragraph
80 of the NPPF. Such a review of Green Belt boundaries would be in compliance with
Paragraph 84 of the NPPF, which promotes sustainable patterns of development by
channelling development towards towns and villages inset within the Green Belt, as well as
fulfilling the stated objectives of Policies SS1 and SS3 in the Draft Local Plan.
Response
A key component of the Spatial Strategy is the protection of the Green Belt. However, it is
proposed to delete land from the Green Belt at Ripley and Codnor, in conjunction with
proposals for mixed use development and the provision of a new A610 link road between
Ripley and Woodlinkin. There is a longstanding commitment by both the Borough and
Derbyshire County Council to securing the completion of a new A610 link road between
Ripley and Woodlinkin. The provision of this new link road will not only relieve traffic
congestion on the current A610 route, but will also improve the east-west link between the
A6/A38 and the M1 through the Borough, enabling the provision of new housing
development and the development of high quality employment land, which will help to
improve the local economy. Unlike other potential strategic sites in the Green Belt that were
not previously selected as preferred sites, the allocation of these sites would also not lead to
any coalescence of settlements, as there are no nearby settlements.
It is not considered that a review of the Green Belt boundaries is required, as the Spatial
Strategy is to only allocate land in the Green Belt for development where exceptional
circumstances can be demonstrated. Although a Green Belt Review was carried out by the
Derby HMA authorities for those areas adjacent to the built up area of Derby, it is not
considered necessary to carry out such a review as such for the rest of the Borough. When a
comprehensive review of all potential strategic sites took place, those that were located in
the Green Belt where no exceptional circumstances could be demonstrated were not
selected as preferred sites, as they would involve a significant reduction in the distance from
nearby settlements and the new boundaries created would not be permanent in the long
term and capable of enduring beyond the plan period.
Capita on behalf of Wheeldon Brothers Ltd: Policy SS10 is wholly unnecessary in the
context of the NPPF which it significantly repeats. It is not a strategic level policy. Policy
relating to the re-use of existing buildings should not go further than the NPPF guidance and
should not inhibit a pragmatic approach to sustainable re-use of existing buildings.
Response
The policy is not any more restrictive than the NPPF in respect of the re-use of existing
buildings and reflects the wording of the existing Local Plan policy.
174
John Church Planning Consultancy on behalf of David Bradbury: The policy does not
follow and is inconsistent with the wording set out succinctly in paragraphs 89 and 91 of the
NPPF and it should be simplified accordingly, unless it can be demonstrated that the
circumstances in Amber Valley justify the changes. It is not accepted that such a situation
arises.
Response
The policy has been amended to better reflect the wording in policy 89 of the NPPF.
Barton Willmore on behalf of Taylor Wimpey UK: We object to this Policy on the basis
that there appears to be no robust evidence base in the form of the Green Belt Review that
underpins the decision to release land from the Green Belt at two allocated housing sites at
land to the north and east of Ripley and land to the east of Codnor. The evidence that was
used to form this policy suggested on page 46 of the Draft Local Plan (the NPPF and the
former East Midlands Regional Plan) is not considered to be sufficient evidence. The East
Midlands Regional Plan was revoked in April 2013 and no longer forms part of the
Development Plan and as such none of the policies contained within it no longer apply.
Furthermore paragraph 80 of the NPPF clearly states that the fundamental aim of the Green
Belt policy is to prevent urban sprawl and paragraph 83 states that once established, Green
Belt boundaries should only be altered in exceptional circumstances. We therefore consider
this Plan fails the test of soundness as it is not justified based on proportionate evidence or
is it consistent with national policy.
Response
As stated elsewhere in this document, the Borough Council considers that the provision of
the long awaited A610 link road between Ripley and Woodlinkin does represent exceptional
circumstances for the land between the new road and the settlements of Ripley and Codnor
to be taken out of the Green Belt. It would not create urban sprawl, as no other settlements
exist to the east of where the new link road would be located. The new road would also
provide a new clear permanent boundary for the Green Belt. No other Green Belt sites in the
Borough can demonstrate exceptional circumstances and other sites in the SHLAA that are
not in the Green Belt are deliverable and can fulfil the full, objectively assessed housing
requirements in the Borough during the plan period. Therefore, no formal Green Belt review
as such is considered to be necessary.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Any land
removed from the Green Belt should be replaced by extending the Green Belt between
Heage and Ambergate, to prevent a net loss of Green Belt area and to prevent coalescence
of settlements.
Response
This is not considered to be necessary.
175
Savills: The justification for the A610 link road and the housing at Ripley and Codnor
appears to be circular. 6.15 states that the road will enable new housing development,
presumably in the area around Ripley. It is stated in the Strategic Sites Policies SG2 and
SG7 that the housing development must support the delivery of the link road. The release of
land for the link road and the housing appears to be a self-fulfilling prophecy. An adequate
case for neither has been made in the Core Strategy.
Response
not in the Green Belt are deliverable and in sustainable locations that can fulfil the full,
objectively assessed housing requirements in the Borough during the plan period. Therefore,
no formal Green Belt review as such is considered to be necessary.
Fairgrove Homes Limited: Since the revoked East Midlands Regional Plan recognised the
difficulty in finding land that is not designated as Green Belt to meet the objectively assessed
housing needs of the Borough, it is completely unbelievable that the Council is not proposing
a comprehensive review of the Green Belt as part of the Local Plan process. Paragraph 83
of the National Planning Policy Framework states that: “LPAs with Green Belts in their area
should establish Green Belt boundaries in their Local Plans which set the framework for
Green Belt and settlement policy.”
Whilst under Policy SS11 the Council is proposing to amend the Green Belt boundaries for
the strategic sites at Ripley and Codnor, it is therefore completely appropriate following a
comprehensive review of the Green Belt for the Council to consider establishing boundaries
around individual settlements within the Green Belt rather than continuing the policy of the
Green Belt washing over these settlements and villages. The washing over of settlements
and villages in the Green Belt does not fulfil any of the five purposes of the Green Belt as
defined in Paragraph 80 of the NPPF.
A review of Green Belt boundaries such as this would be in compliance with Paragraph 84 of
the NPPF, which promotes sustainable patterns of development by channelling development
towards towns and villages inset within the Green Belt as well as fulfilling the stated
objectives of Policies SS1 and SS3 in the Draft Local Plan.
176
Response
Oxalis Planning: We agree that relatively minor changes to the Green Belt boundary will be
identified in the Site Allocations document. However, we object to the S11 proposed
restriction which will prevent smaller housing or other development sites coming forward in
locations where positive and beneficial impacts could be demonstrated. The Core Strategy
should make explicit the opportunity at Site Allocations stage that the Green Belt will be
amended where development sites are identified and allocated.
Response
There are a number of sites in the SHLAA that are not in the Green Belt and are deliverable
and in sustainable locations that can fulfil the full, objectively assessed housing requirements
in the Borough during the plan period. Therefore, there is likely to be no need for Green Belt
land to be allocated in the Site Allocations and Development Management Policies DPD,
unless it can be demonstrated that the existing boundary has been incorrectly drawn.
Capita on behalf of Wheeldon Brothers Ltd: We endorse the amendments as necessary
to accommodate the growth needs of the Borough, recognising wider constraints. The policy
should not restrict boundary amendments in the site allocation document to ‘minor’ and
should allow a contingency and flexibility or more significant revisions if necessary.
Response
John Church Planning Consultancy on behalf of David Bradbury: Land at Kilburn Lane,
Belper to which SHLAA reference AVBC/2008/0181 applies should have been considered to
justify an amendment to the Green Belt boundary.
177
By determining that any minor changes to the boundary in the proposed Site Allocations and
Development Management Policies document will be confined to very narrow criteria, Policy
SS11 represents an insufficiently robust assessment of the advantages to be gained in this
and other highly sustainable locations by relaxing an inappropriately delineated Green Belt
that is not justified in present circumstances. This will lead to increased pressure to release
greenfield sites for development that could be more appropriately located if slightly greater
flexibility is demonstrated.
Such a situation would then be compatible with the requirements set out clearly in paragraph
83 of the NPPF.
Response
Gladman Developments: Through the Core Strategy the Council are proposing to remove
land from the Green Belt at Ripley and Codnor without undertaking a full, comprehensive
and strategic review of the Green Belt. Without this robust evidence base the Council cannot
know that these sites are the most appropriate sites to be removed when considered against
the five purposes of the Green Belt (outlined in paragraph 80 of the NPPF). The Council
need to undertake a full, comprehensive review of the Green Belt to inform the choices
made within the Core Strategy otherwise the plan will be found unsound.
Gladman note that the sites in Ripley and Codnor, which are proposed to be removed from
the Green Belt, have not been subject to a review assessing the role and purpose they play
as part of the Green Belt.
Response
178
Antony Aspbury Associates on behalf of Omnivale Limited: This policy is inconsistent
with the provisions of paragraph 28 of the NPPF in respect of supporting a prosperous rural
economy. The first bullet of paragraph 28 seeks to support the sustainable growth and
expansion of all types of business and enterprise in rural areas, both through conversion of
existing buildings and well-designed new buildings.
Policy SS12 does not determine between residential development and economic
development and indicates that new development will only be permitted if it is essential in
conjunction with the requirements for agriculture or forestry.
National Policy however has moved on and paragraph 28 specifically refers to supporting all
types of business and enterprise in rural areas. This policy is not therefore consistent with
national policy. If SS12 is intended to relate to new residential development, then the policy
wording needs to be clear in this regard.
Response
This policy is very similar to the existing Local Plan policy and it does support the
sustainable growth and expansion of all types of business and enterprise in rural areas, both
through conversion of existing buildings and well-designed new buildings. Criteria b) states
that new development will be permitted in the countryside if it is necessary and cannot be
reasonably be located within a settlement and criteria c) states that development will be
permitted if it will improve the viability, accessibility or community value of existing services
and facilities in settlements remote from service centres provided by the towns and larger
villages. It should also be noted that existing Local Plan policy ER6 (Diversification of the
rural economy) has been saved and will be amended if necessary when it is included in the
Site Allocations and Development Management Policies DPD.
Settlement boundaries should be defined so that it is clear where this policy applies.
Response
It is the intention that settlement boundaries will be defined when the Site Allocations and
Development Management Policies DPD is produced.
Savills: Whilst the intent of the policy may be justified in the context of a complete Local
Plan, it is unclear at this stage what the settlement boundaries are to which the policy will
apply. There should be consultation on the settlement boundaries together with the draft
policy in order to properly consider whether the policy is appropriate in the circumstances to
which it will be applied.
179
Response
It is the intention that settlement boundaries will be defined when the Site Allocations and
Gladman Developments: Gladman welcome the inclusion of Policy SS13, which provides
the presumption in favour of sustainable development policy as required by the Framework.
However the Council need to ensure that the other policies in the Core Strategy do not
contradict with this.
Response
Heaton Planning on behalf of Waystone Developments: Whilst we support the content
of Policy SS13, we consider the policy should be given greater prominence in the DPD and
should feature earlier in the document. The NPPF has a strong emphasis on the
presumption in favour of sustainable development and the need for Councils to proactively
engage with developers to facilitate sustainable development. At present, we consider that
this is not sufficiently reflected in the Core Strategy.
Response
It is not considered that there is a need for this policy to feature earlier in the document. All
policies have the same importance regardless of where they are placed.
Capita on behalf of Wheeldon Brothers Ltd: We fully endorse the identification of
Outseats Farm, Alfreton as a Strategic Growth Site. The site has planning permission for up
to 500 dwellings by virtue of planning permission AVA/2012/0084.
Response
180
Barton Willmore on behalf of Taylor Wimpey UK: We strongly object to this location for a
suitable location for housing growth.
Paragraph 47 of the NPPF clearly sets out the objectives to boost the supply of housing. The
NPPF states that local planning authorities should identify a supply of specific, developable
sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15. To
be considered developable, sites should be in a suitable location for housing development
and there should be a reasonable prospect that the site is available and could be viably
developed at the point envisaged.
We do not consider that the Alfreton Road, Codnor site is deliverable as all of it lies within
the Green Belt. The NPPF places great importance on protecting the Green Belt. Paragraph
84 of the NPPF emphasises that sustainable development should be directed towards urban
areas outside the Green Belt. For this reason we consider that the Local Plan is unsound as
it is not consistent with national policy. Allocating a site that is entirely in the Green Belt,
when there are other less contained sited outside of the Green Belt, such as land off
Chesterfield Road, Alfreton, is unsustainable and does not conform to the growth objectives
set out in the NPPF.
Response
The reasons for allocating this site have already been covered in this document.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Object to
this development in the Green Belt, which is poorly connected to the four towns. This site
does not form a Sustainable Urban Extension but will promote car-based commuter
development serving Greater Nottingham rather than contributing to local economic
development.
Response
The reasons for allocating this site have already been covered in this document.
Gladman raise concerns with the provision of the new A610 link road and the impact this will
have on the delivery of this site over the plan period. A new link road such as this would take
a significant time to deliver and have considerable financial implications.
The Council needs to have clarity on the funding arrangements for the new link road (and
whether this will include any Government funding), the need for an inquiry in relation to this
and any necessary CPO’s. These considerations should all be factored into the timescales
for the delivery of this Strategic Growth Site.
181
Gladman note that the Council had historic proposals for a similar link road, Ripley to Codnor
bypass; these proposals were planned and protected for over 40 years. The Council claims
that the current proposals differ from the previous ones and that they are more attainable.
However, again there is a lack of clarity regarding why these current proposals are
deliverable.
Response
The reasons for proposing the new A610 link road have already been covered in this
document. A planning application for this scheme and supporting evidence have now been
submitted and a funding package is being finalised.
Fisher German on behalf of the Trustees of Locko Estate: Policy SG3 is supported as a
strategic site that will deliver significant housing, education, community and infrastructure
development on a brownfield site. The allocation of Land to the north of Denby offers real
opportunities to consolidate the existing community; improve education facilities; provide
new shops, healthcare and other services; to improve recreation facilities; provide new
public open space and public footpaths; improve infrastructure and provide employment
development. The strategic site would also provide the opportunity to create a community
using high quality design and environmental standards delivering a mix of housing types and
tenures including family homes, elderly person’s accommodation and affordable housing.
Notwithstanding the overall support for the allocation of this strategic site at Denby, there
should be some flexibility to allow a phased development of the site particularly given the
five year housing land supply shortfall experienced by AVBC at present. The significant
shortfall in the housing land supply is increasing pressure to release sites, some of which
may not be favoured as housing allocations.
An immediate ‘Phase 1’ development could be delivered on the area between Derby Road
and the former railway line, which would bring about 130 dwellings, including affordable
homes as well as provide open space, contributions towards education, improvements to the
highway network and remediation of this area of land.
Response
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Question
whether this site is deliverable, given the failure of previous attempts (in more favourable
economic circumstances) to bring development forward on the land. Any new local centre
should not compete with surrounding town centres. Risk that local centre will draw east
Belper residents away from Belper town centre. Public transport improvements required to
connect any development to Belper town centre.
Response
182
Nathaniel Lichfield on behalf of Commercial Estates Group (CEG): Support the policy.
However, there are a couple of issues raised which we request officers revisit.
We note that the boundary of the Strategic Growth site Policy SG3 ‘Land North of Denby’
excludes the adjoining Green Belt land from the Draft Core Strategy. Officers will recall the
previous consultation document for the Preferred Growth Strategy confirmed that “…the
development of this Green Belt land would provide a further 1,200 dwellings to create a
development of 3,000 dwellings in total, but this would not be deliverable by the end of the
plan period in 2028” (Appendix A, page 26). CEG does not object to this conclusion and
timescale as a matter of principle, however, the current approach (which does not identify
the Green Belt land), fails to address the need to fix Green Belt boundaries that are capable
of enduring beyond 2028. In reviewing Local Plans the National Planning Policy Framework
(para 85) advises local planning authorities to, amongst other things and where necessary,
identify areas of ‘safeguarded land’ in order to meet longer-term development needs
stretching well beyond the plan period. In this context, and given the already identified
comprehensive sustainable development at Land North of Denby, CEG reiterates that the
adjacent Green Belt land should be identified as ‘safeguarded land’, with an individual policy
or added to SS10 or added to SS11.
Response
It is not considered necessary to identify safeguarded land at this site.
Marrons: The main strategic allocation is the land north of Denby. The site is allocated for
development in the adopted Local Plan and was recognised as a strategic site during the
preparation of the plan. However, whereas this was allocated as a mixed use development,
including 300 dwellings, in the Local Plan, the Draft Core Strategy now proposes to allocate
the site for 1,800 dwellings. Our clients support the Council’s reliance on the development of
this site.
However, they consider that the site would be unlikely to deliver 1,800 dwellings over the
plan period to 2028, for the following reasons:
•
This is a substantial strategic site with a number of different owners. Part of the site
requires remediation from contamination. These factors alone suggest that the
development and occupancy of the first dwellings, following the grant of permission,
the satisfaction of pre-development conditions, conclusion of agreements/obligations
under Section 106, and the approval of reserved matters, will not take place until
2016/17, at the earliest. This is a year later than the Council’s estimate of first
completions, as set out in Five Years Land Supply Statement; Large Housing Sites
Projection.
•
Our clients, who own a large part of this site, have still not been approached by the
Council or the proposed developer. Their collaboration is essential for a
comprehensive scheme
183
•
Under a 12 year development programme, with increasing numbers of housebuilder
participants from year one onwards, the site would yield, in our view, no more than
1,050 dwellings, with three housebuilders in place 2019/20 onwards. The projected
build rate is set out in the following table:
Table 1. Projected House building Rate – Cinderhill 2016/17 – 2027/28
2016/17
25 dwellings
2017/18
50 dwellings
2018/19
75 dwellings (2 x developers/housebuilders)
2019/20
100 dwellings (3 x developers/housebuilders)
2020/21-2027/28
100 dwellings per annum
Total: 2016/17-2027/28
1,050 dwellings
•
The need to address certain thresholds of necessary service and infrastructure
provision to be secured during the development programme in order to progress the
later phases of the scheme.
•
On the basis of a potential capacity to provide up to 1,800 homes from this site, then
we estimate some 750 dwellings will not be provided during the plan period (1,800 –
1,050 = 750). We therefore calculate that sites to accommodate an additional 1,430
dwellings need to be allocated.
Response
These concerns are noted.
Gladman Developments: Gladman note that the current proposal is a large site (85.2ha)
that is not well related to an existing sustainable settlement and is fundamentally in an
unsustainable location. Gladman raise concerns with the approach taken by the Council to
roll forward and amend this old Local Plan allocation. Old allocations such as this may not
have been delivered due to the presence of significant constraints or the requirement for
new infrastructure that makes the site unviable. This site should be assessed in detail,
particularly due to its failure to deliver previously (despite the allocation) and the Council
need to have a significant degree of certainty regarding its delivery. Through the Draft Core
Strategy significant reliance is being placed on the delivery of this Strategic Growth Site. A
‘new town’ or development of this scale will be a long time in gestation, there may well be
significant planning issues to overcome and infrastructure will need to be in place prior to the
delivery of any housing on site. The proposal of 1,800 dwellings at the land north of Denby is
not a credible option until it has been tested and demonstrated through a viability
assessment that it has a realistic prospect of being delivered.
Response
184
Antony Aspbury Associates on behalf of Omnivale Limited: We support the
identification of land at Newlands/Taylor Lane as a strategic growth site in accordance with
the development areas identified in the Draft Core Strategy. The two separate development
areas and connecting areas of Green Space comprising the Bailey Brook corridor and
adjoining open land are within one ownership and the owners are committed to bring the
sites forward for development within a comprehensive scheme.
Response
Barton Wilmore on behalf of Taylor Wimpey East Midlands: We strongly object to this
location for a suitable location for housing growth. Paragraph 47 of the NPPF clearly sets out
the objectives to boost the supply of housing. The NPPF states that local planning
authorities should identify a supply of specific, developable sites or broad locations for
growth, for years 6-10 and, where possible, for years 11-15. To be considered developable,
sites should be in a suitable location for housing development and there should be a
reasonable prospect that the site is available and could be viably developed at the point
envisaged. We do not consider that the Nottingham Road, Ripley site is deliverable as the
northern part of the site lies within the Green Belt. The NPPF places great importance on
protecting the Green Belt. Paragraph 84 of the NPPF emphasises that sustainable
development should be directed towards urban areas outside the Green Belt. Allocating a
site that is entirely in the Green Belt, when there are other less contained sited outside of the
Green Belt, such as land off Chesterfield Road, Alfreton, is unsustainable and does not
conform to the growth objectives set out in the NPPF.
Response
The reasons for allocating this site have already been covered elsewhere in this document
and in the Core Strategy.
Gladman Developments: Gladman raise concerns with the provision of the new A610 link
road and the impact this will have on the delivery of this site over the plan period. A new link
road such as this would take a significant time to deliver and have considerable financial
implications. The Council needs to have clarity on the funding arrangements for the new link
road (and whether this will include any Government funding), the need for an inquiry in
relation to this and any necessary CPO’s. These considerations should all be factored into
the timescales for the delivery of this Strategic Growth Site.
Gladman note that the Council had historic proposals for a similar link road, Ripley to Codnor
bypass; these proposals were planned and protected for over 40 years. The Council claims
that the current proposals differ from the previous ones and that they are more attainable.
However, again there is a lack of clarity regarding why these current proposals are
deliverable.
185
Response
These concerns are noted. A planning application for this site and the A610 link road has
now been submitted and a funding package is being finalised.
Antony Aspbury Associates on behalf of Omnivale Limited: We fail to see how a bold
case policy setting out such a precise and cumulative Borough wide ‘requirement’ for
property size and tenure can be effectively applied and justified in the consideration of
individual sites and significantly question the worth of such policy. The supporting paragraph
is far more justified and is the approach that developers would undertake in any event.
The policy table is again very prescriptive and confusingly introduces percentages of
affordable housing in each bedroom size category. Any Affordable housing requirements /
aspirations should be confined to the separate affordable housing policy H3 and not set out
at this detailed level of specification as there will be considerable variances of need from
location to location and site to site.
For the policy to be justified, effective and consistent with national policy, the word “require”
should be replaced by “expect” or “seek” and the supporting paragraph promoted to bold text
to form part of the formal policy H1. The table should be deleted.
Response
The policy is only intended to be Borough wide and not site specific. It is not considered
necessary to remove the table.
Savills: The policy as drafted is imprecise and unworkable. It requires applicants to have
complete knowledge of all housing developments that have and will come forward during the
plan period. A policy which applies a blanket mix to all sites is inappropriate in both market
terms and in delivering housing to meet local needs. The need for and merit of this policy
should be reconsidered.
Response
The policy is only intended to be Borough wide and not site specific.
Catesby Estates Limited and Kedleston Estate: This draft policy seeks to ensure a
specific mix of housing is provided on new developments by specifying the percentage of
types and tenure of housing required. This has been informed by the Strategic Housing
Market Assessment Update 2013 (SHMA). We welcome recognition within the background
text at page 59 that an appropriate mix will depend on viability, the local circumstances, and
information on local need in a particular part of the Borough, however it is disappointing that
this flexibility is not reflected in the actual policy wording which provides a more rigid and
onerous requirement.
186
The SHMA sets out the suggested indicative affordable and open market mix requirements
in Figures 135 and 136. However these have been applied as specific targets within Policy
H1 and if the policy is adopted, will be applicable to any planning applications made in the
Borough. This would include planning applications on sites adjacent to a neighbouring
authority boundary where they are being brought forward to address a different need. This
would be an issue given the affordable and open market mix requirements in Amber Valley
are different to Derby and South Derbyshire. This policy has been informed by the SHMA
only and we therefore consider that the policy should be re-worded to provide additional
flexibility to account for market trends.
The affordable housing mix needs to respond to the evolving requirements of Registered
Providers and allow for flexibility to assist with delivery to meet housing need and ‘chime’
with their funding constraints.
For the reasons set out above, we feel that the mix specifics should be omitted from the
policy altogether. However if the local planning authority are minded to retain these then the
policy should be re-worded to ensure that any mix specifics are noted as ‘indicative’ and a
mechanism is provided to agree a different mix with the local planning authority if it can be
justified.
Response
The policy is only intended to be Borough wide and not site specific. However, the policy has
been amended to make it clear that the table is only indicative.
Home Builders Federation: The table contained in Policy H1 – Housing Types, Mix and
Choice is too prescriptive. The table should be deleted or revised to give percentage ranges
rather than specific percentage numbers. If the Council insists upon such prescriptive
percentages perhaps incorporation as specific policy requirements for individual strategic
site allocations is more appropriate.
Response
Capita on behalf of Wheeldon Brothers Ltd: The Policy takes its lead from the SHMA
update. This might be justifiable for the delivery of affordable housing, but it is not justifiable
for market housing, which must be determined by the market.
The NPPF is clear that the mix of housing should be based on market trends as well as
demographic trends. The SHMA update also notes that its findings are based on
demographic trends only and do not take into account market information or supply side
constraints. To direct the proportionate mix of housing in this way would be disastrous for
delivery and would not meet the actual needs of the market.
187
At worst, the overall requirement and the requirement for market housing should be removed
and the split for affordable be set out as a guide.
Response
William Davis Ltd: William Davis Ltd considers the requirements established in Policy H1 to
be far too prescriptive and believe that such a policy would constrain housing delivery in the
Amber Valley. This is particularly relevant to the table included in Policy H1 which includes
detailed percentage requirements for housing in the Borough. Such a prescriptive mix policy
is not likely to be suitable on all development sites in the Borough and an element of
flexibility is needed to allow for consideration of specific site circumstances including local
character context. Flexibility is also required to allow for consideration of private market
demand. Private market demand does not directly relate to household size and household
need with smaller households not necessarily wanting to buy smaller house types. It is
essential that a more flexible approach is included within the policy, as without it there is a
real danger the size and type of housing being required by Policy H1 will not meet market
housing purchaser requirements. Paragraph 50 of the NPPF makes it clear that LPA’s
should “plan for a mix of housing based on current and future demographic trends, market
trends, and the needs of different groups in the community”.
Response
Gladman Developments: The requirement set out in Policy H1 is too prescriptive and
should be removed from the Draft Core Strategy. Gladman recommend that the Councils
approach to housing mix should be to determine this on a site by site basis, ensuring this
reflects local characteristics and evidence of local housing need. Housing type and mix
should be led by the market and need. Sites should deliver the types of units that best meet
the needs of the communities outlined in the evidence base.
Response
188
Home Builders Federation: The wording “should be” is inappropriate and it should be
amended to “encouraged”. Lifetime Homes standards is not a mandatory requirement so the
Council is imposing such a requirement as a local standard, which must be correctly viability
tested. The Council should refer to the document “The DCLG Assessing the Cost of Lifetime
Homes Standards July 2012”, which shows the average additional cost for complying with
the 12 criterion relating to internal specification is £1,525. There are also further additional
costs associated with the remaining 4 criterion for external specifications.
Response
It is not accepted that the policy needs to be amended in this way.
William Davis Ltd: Policy H2 includes the requirement for new developments to be
designed in accordance with the Lifetime Homes Design Criteria. Paragraph 173 of the
NPPF considers viability and deliverability when plan making and encourages Local
Planning Authorities (LPA’s) to avoid policy burdens that would threaten the ability of sites to
be developed viably. We consider Lifetime Homes standards to be a prime example of an
unnecessary policy burden that could constrain development. Building homes to Lifetime
Homes standards would in our opinion have significant cost implications on potential
residential schemes and should be considered in any viability analysis done on plan
requirements.
In addition to this the Government has shown no sign of supporting or encouraging Lifetime
Homes standards as a planning requirement, putting the policy at odds with national policy.
The revised ‘Code for Sustainable Homes: Technical Guidance’ (2010) indicated Lifetime
Homes Standards were not a mandatory element of the Code until level 6, targeted for 2016
and the Code itself also remains non-mandatory.
In the meantime the Government has pursued accessibility and mobility standards via
building regulations, making Lifetime Homes policy requirements effectively redundant.
Response
These concerns are noted, but the Borough Council considers it important that new
development is designed to cater for the needs of those people who are disabled and have
restricted mobility.
189
Catesby Estates Limited and Kedleston Estate: The affordable housing requirement set
out in this policy is generally acceptable in terms of the triggers and quantum at 30% of the
total number of dwellings. In respect of tenure we do not consider that a requirement for 90%
social rent with the balance (10%) being intermediate housing will provide an appropriate
mix of housing. The definitions of different types of affordable housing is made clear in
Annex 2 of the NPPF, which defines social rent, affordable rent, and intermediate housing
options. We are concerned that restricting the level of intermediate housing to just 10% (of
the 30% overall provision) with no provision of affordable rent, will result in a shortage of this
much needed provision across the Borough for the plan period. Without an appropriate mix
across the three types of affordable housing, this policy would be contrary to paragraph 50 of
the NPPF.
There is also an emerging trend for requiring a greater need of smaller affordable housing
units further into the introduction of bedroom tax, which could have implications for demand,
particularly when considering the required mix of affordable housing under draft Policy H1
requiring a degree of larger dwellings.
The recognition within the policy of the need for viability testing in certain instances is
welcomed in accordance with paragraphs 173 and 174 of the NPPF.
Response
These concerns are noted, but it is not considered necessary to amend this policy, given that
this is the existing Local Plan policy and that it refers to the need for viability testing in certain
instances.
Home Builders Federation: Policy H3 - Affordable Housing proposes 30% provision of
affordable housing on sites of more than 15 units with the preferred affordable housing
tenure split of 90% social rent and 10% intermediate housing. This overall proposed level of
affordable housing provision and affordable housing tenure split should be viability tested.
Response
instances.
William Davis Ltd: Paragraphs 173 and 174 of the NPPF clearly identify that development
identified in the plan should not be subject to policy burdens, including affordable housing,
which could threaten their ability to be developed viably. The affordable housing requirement
established in Policy H3 has not been subject to a viability assessment, with the ‘Key
Evidence’ section of text supporting the policy not including an affordable housing viability
assessment. Without this assessment the requirement cannot be proven to be viable and
policy H3 cannot be considered to be consistent with the policy of the NPPF. No evidence is
available to demonstrate that the Borough Council have done the further viability analysis of
the policy costs indicated as necessary by the Strategic Level Viability Assessment.
190
Until this is undertaken the 30% affordable housing target must be judged unsound as it has
not been adequately justified.
Response
instances.
Gladman Developments: Gladman note that the affordable housing issues in Amber Valley
remain acute. The Derby HMA SHMA (2013) identifies a substantial requirement for
affordable housing in Amber Valley and indicates that 61% of new housing provided would
need to be affordable up to 2028 to meet the needs of all households in need. The proposed
30% requirement would fall significantly short of meeting the affordable housing need.
Therefore the plan will in effect exacerbate an already large affordable housing issue. It is
unclear whether the proposed 30% affordable housing requirement is set at a viable level.
The Council do not appear to have any viability evidence, which demonstrates that this 30%
requirement is set at a realistic level.
Policy H3 states that “normally, 90% of the affordable homes should be for ‘social’ rent (or
equivalent), with the balance being ’intermediate’ affordable housing.” The mix of affordable
housing tenures should be based on an assessment of local needs. This proposed
requirement is too prescriptive. Gladman recommend that this element of the policy is
removed, and determined on a site by site basis.
Response
instances.
Antony Aspbury Associates on behalf of Omnivale Limited: We fully support the
principle of open viability assessment and recognise that in many cases the appointment of
an independent expert is important to reach a satisfactory position on the extent of S106
obligations and the parameters for any subsequent review. However, this approach is not
justified in every situation and in this context the first line of section 2) of the policy should be
modified to read:
“An independent chartered surveyor is instructed if required by the Council and /or the
developer ....”
191
Response
This policy will only be applied in those instances when a development is not policy
compliant, and it is not therefore considered necessary to amend it in this way.
William Davis Ltd: William Davis Ltd welcome Policy H4 but believe that the flexibility to
consider viability at the planning application stage does not absolve the Council from its
responsibility to consider the viability of its affordable housing target and other policy
burdens.
Response
Fisher German on behalf of the Trustees of Locko Estate: This policy is supported as it
is critical to the delivery of housing development in the strained economic climate.
Response
Savills: The principle of a policy which acknowledges the viability constraints of delivering
affordable housing and provides a mechanism for reconsideration of policy requirements for
affordable housing is supported. The policy as drafted is unclear in its application and
operation. Specifically, if the independent surveyor is appointed by the Council and
applicant, it is presumed that the costs are to be shared, but this is not stated and should be.
The use and application of the independent surveyor opinion once obtained is not stated and
should be consulted upon as it is a vital component of the operation of this policy.
Response
The policy has been amended to make it clear that the costs of employing the independent
chartered surveyor will need to be met by the developer.
Catesby Estates Limited and Kedleston Estate: The proposed mechanism set out in
within this policy is a significant requirement for any applicant to provide which takes time
and resources to carry out, notwithstanding the potential exposure of commercially sensitive
information. It should therefore be requested by the local planning authority as a last resort
and in exceptional circumstances. Indeed, paragraphs 173 and 174 of the NPPF seek to
ensure that local planning authorities viability test their Core Strategy policies so that the
majority of developments are viable in the first instance anyway. The local planning authority
should therefore ensure that all of the policies in the Draft Core Strategy have been viability
tested.
Response
192
Home Builders Federation: At this time it was not possible to find any viability assessment
reports on the Council’s website so a full analysis has not been undertaken.
However the proposed mechanism set out in Policy H4 – Viability of Proposed Housing Sites
should be a policy of last resort. The Council in compliance with Paragraphs 173 and 174 of
the NPPF whereby development should not be subject to such a scale of obligations and
policy burdens that viability is threatened should have viability tested its CS policies so that
the majority of development schemes are viable. Policy H4 should only be used in
exceptional circumstances.
Response
Gladman Developments: Gladman state that it is now necessary for the local planning
authority to ensure that the plan as a whole is viable. Paragraph 173 of the Framework
relates directly to ensuring viability and delivery. “Pursuing sustainable development requires
careful attention to viability and costs in plan-making and decision-taking. Plans should be
deliverable. Therefore, the sites and the scale of development identified in the plan should
not be subject to such a scale of obligation and policy burdens that their ability to be
developed viably is threatened” (paragraph 173). If the Council have adequately considered
viability within the preparation process and the policy requirements are realistic based on upto-date viability evidence then there should be no need for policy H4.
Response
Antony Aspbury Associates on behalf of Omnivale Limited: The policy sets out the
target requirements yet recognises that viability may be an issue constraining the full policy
compliant level of securing energy efficiency and sets out a procedure for viability
considerations to be examined and addressed.
Response
Catesby Estates Limited and Kedleston Estate: The policy should make reference to the
Government’s recent announcements on revisions to Part L of the Building Regulations. It is
inappropriate to reference meeting the Code for Sustainable Homes Level 4 by 2016. The
Draft Core Strategy will also need to remain flexible to respond to the outcome of the
Housing Standards Review in the coming months once the consultation has closed on 22nd
October 2013.
193
Response
These comments and concerns are noted.
Home Builders Federation: Paragraph 154 of the NPPF emphasises that “local plans
should be aspirational but realistic”. This is re-enforced by the document “Viability Testing
Local Plans Advice for Planning Practitioners” chaired by Sir John Harman and published in
June 2012, which states “If the assessment indicates significant risks to delivery, it may be
necessary to review the policy requirements and give priority to those that are deemed
critical to development while reducing (or even removing) any requirements that are deemed
discretionary. The planning authority may also consider whether allocating a larger quantity
of land, or a different geographical and value mix of land, may improve the viability and
deliverability of the Local Plan”. This emphasis is particularly relevant to the final paragraph
of Policy R1 - Reducing the use of non-renewable energy resources.
•
the wording “reaching higher standards of sustainability” is too vague and unspecific.
The expression has no real meaning and therefore it could be open to
misinterpretation.
•
reference to meeting Code for Sustainable Homes Level 4 for energy efficiency and
carbon emission reductions by 2016 is inappropriate the policy should refer to the
Government’s recent announcement on revisions to Part L of the Building
Regulations. This is a higher standard than the national standard, therefore the
Council should justify the reasons for imposition of such a higher local standard.
•
the water efficiency requirement for any home built after 2016 to achieve the water
efficiency component of CfSH Level 5/6. Part G of the Building Regulations April
2010 requires water usage of 125 litres per person per day. CfSH Level 5/6 requires
a maximum water consumption of 80 litres per person per day. Therefore the Council
is setting its own local standard, which should be clearly justified by evidence and
appropriately costed in viability assessments.
•
the use of Sustainable Urban Drainage systems can have substantial implications on
gross to net developable land ratios. The Harman Report emphasises “One error that
has a very large impact on the outcome of viability testing is overlooking the
distinction between the gross site area and the net developable area (the revenueearning proportion of the site that is developed with housing). The net area can
account for less than half of the site to be acquired (that is, the size of the site with
planning permission) once you take into account on-site requirements such as formal
and informal open space, sustainable urban drainage systems, community facilities
and strategic on site infrastructure etc. On larger sites, sometimes the net area can
be as little as 30%” (page 36 and Appendix B(1).
Response
194
William Davis Ltd: The current proposals included in policy R1 require climate
change and carbon emission standards that go well beyond current Government
regulations and seeks to enforce specific levels and requirements of the Code for
Sustainable Homes which the Government has not made mandatory. Whilst the
NPPF endorses the setting of local requirements they are required to be viability
tested, under the terms of paragraphs 173 and 174 (as with affordable housing
policy as described above) to ensure they will not adversely affect the delivery of
development.
Response
Antony Aspbury Associates on behalf of Omnivale Limited: This policy requires that all
development proposals meet 21 policy criteria to ensure high quality design, sustainability
and achieves an inclusive and accessible environment that respects and enhances local
distinctiveness. It is highly unlikely that all development proposals will meet all 21 policy
criteria and so this policy as worded is not positively prepared, justified or effective.
The introductory text to the policy should therefore be revised to reflect a more realistic
aspiration that most of the policy criteria should be reflected in individual scheme proposals.
The following modification to the last paragraph of the introductory paragraph is suggested
to make the policy more effective and positive:
“ Therefore all new development proposals should: ...”
This wording places expectation but not outright compulsion on developers to meet the
policy criteria and allows flexibility for applicants to justify why a specific proposal cannot
meet one or more of the 21 policy criteria. Failure to meet one or more of the criteria does
not necessarily mean that the Council’s aspirations for high quality and design are
prejudiced.
Response
195
Home Builders Federation:
•
the wording “adequate amenity space for each dwelling unit” is imprecise.
•
involving financial contributions to the operation of CCTV security systems is
inappropriate as well designed development should not require such systems.
•
designed to enable solar panels to be added to buildings without difficulty is also
imprecise. The exact requirement of the Council is not obvious, it is unclear the
interpretation given to such a policy requirement by Development Control officers
when assessing a planning application, therefore the policy requirement is
inappropriate.
The above mentioned sub clauses of Policies R1 and E2 should be deleted. If the Council
retains these policy requirements, it will need to justify with appropriate evidence the
necessity of these local standards and viability test these policy requirements in financial
assessments including the cost of mandatory national standards plus additional costs for
local standards. The Harman Report (page 26) states “The one exception to the use of
current costs and current values should be recognition of significant national regulatory
changes to be implemented, particularly during the first five years, where these will bring a
change to current costs over which the developer or local authority has little or no control. A
key example of this is the forthcoming change to Building Regulations arising from the
Government’s zero carbon agenda”. The Council should refer to the document “DCLG Cost
of Building to Code for Sustainable Homes (CfSH) Updated Cost Review 2011”. Table 2 of
this document shows that the cost of building to Code 5 represents an increase of 28-31%
on build costs dependant on the type of site and its location. As 80% of the additional costs
for the CfSH relate to energy efficiency and carbon emissions, this represents a significant
cost increase.
Response
The policy has been amended to take account of some of these comments.
William Davis Ltd: William Davis has concerns on several of the requirements established
in Policy E2. Firstly we object to point h) of the policy which requires the provision and
operation of, or financial contributions towards the provision and operation of CCTV security
systems. We do not consider that such a requirement would be necessary on well-designed
developments. We also object to point t) of the policy which requires developments to be
designed to enable solar panels to be added to buildings without difficulty. This requirement
is overly vague and imprecise and it is very unclear on how such a policy requirement would
be interpreted at a planning application stage. In addition to these specific points, it is also
important that the requirements in Policy E2 are justified by credible and robust evidence
and are suitably assessed in terms of their impact on development viability.
196
Response
The policy has been amended to take account of some of these comments.
Supporting text should include reference to the historic remnant landscape of the Duffield
Frith and its continuing impact on distinctive settlement patterns.
Response
The background text has been amended as suggested.
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Specific
reference required to interplay between natural landscape character and historic enclosure
and settlement patterns in the Duffield Frith. It would be good to see Derbyshire County
Council’s work developed into a more detailed, local SPD.
Response
The importance of the surviving historic landscape in the Borough is referred to in the
background text to the policy. The comment regarding producing a SPD is noted and will be
dependent on staff and financial resources.
Antony Aspbury Associates on behalf of Omnivale Limited: The Special Landscape
Area designation covers large parts of the rural area of Amber Valley within which
countryside polices generally control the nature and scope of new built development that can
take place. The conversion of and or modest extension to existing buildings is normally
accepted as a more appropriate/ acceptable way to secure modest development in rural
areas in particular without adverse visual and environmental impacts. This policy sets out a
negative approach to conversion/extension as a starting point and could potentially stifle
economic and sustainable initiatives in large rural parts of the Borough. This policy, by its
tone does not sit comfortably with paragraph 28 of the NPPF – Supporting a prosperous
rural economy , particularly where the paragraph seeks to support the sustainable growth
and expansion of all types of business and enterprise in rural areas, both through conversion
of existing buildings and well designed new buildings.
We consider that the emphasis of the policy needs to be changed to be more supportive of
the principle of conversion and extension to be in accordance with the NPPF , albeit it is
appropriate to require high standards of design so that proposal will not have an adverse
impact on the visual quality of the Special Landscape Area.
197
The policy should therefore be amended to read:“Development proposals including conversions of existing buildings and extensions to
existing buildings will be supported where they demonstrate high standards of design and
construction and do not have an adverse impact on the visual quality of the landscape”
Response
It is not considered that the suggested change to the wording of the policy is necessary, as it
already allows development proposals, conversions and extensions to buildings providing
they do not have an adverse impact on the visual quality of the landscape.
Concerned that an approach which states that some parts of the landscape are intrinsically
more valuable than others (without saying why) is contradictory to the Landscape Character
Approach advocated by Policy E4. Essential development in the countryside should be
informed by an interpretation and understanding of that landscape, not a merely visual
approach.
Response
Antony Aspbury Associates on behalf of Omnivale Limited: We generally support the
provisions of Policy IN 1 but are concerned in respect of criterion c) that the threshold level
of 25 homes 0.5 ha of employment land requiring the submission of a Transport Statement
or Transport Assessment to support development proposals is a very low starting point. We
are more concerned that unrealistic expectations of improvement of, or securing access to
“sustainable transport” opportunities could come out from this policy impacting upon the
viability and deliverability of development schemes . A threshold of 50 dwellings or 1.0 ha of
employment land may be more appropriate to reasonably request a Transport Statement or
Transport Assessment but if this current threshold is pursued, the wording of criteria c)
should be revised to reflect a more pragmatic approach to improving sustainable transport
accessibility. The revised policy could read:
“requiring in respect of all development proposals over 25 homes or 0.5ha of employment
land that a Transport Statement or Transport Assessment is provided to show how the
opportunities for sustainable travel have been considered and taken up where reasonably
available , depending on the nature and location of the site”
Response
The policy has been amended to state that a transport statement or a transport assessment
will be required in those instances where the highway authority consider it to be necessary.
198
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Unclear
why a road scheme is the one strategic infrastructure priority, when Policy IN1 stresses the
need to achieve a sustainable pattern of development which minimises the need to travel.
Surely the provision of new road infrastructure to deal with perceived existing problems
should be the responsibility of the highway authority and Highways Agency rather than
funded through new development in the Green Belt.
Response
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: There
should be a commitment to introducing CIL, in the interests of transparency and uncertainty.
Response
The Council has commenced work on introducing a CIL.
Catesby Estates Limited and Kedleston Estate: This policy needs clarification in respect
of the payments towards the cost of infrastructure collected through Section 106
contributions and/or the Community Infrastructure Levy to minimise the risk of double
counting.
Response
Home Builders Federation: Policy IN6 Developer Contributions refers to payments
towards the cost of infrastructure collected through S106 and/or CIL. The policy is unclear so
there is a risk of actual or perceived double dipping. The Council should provide more clarity
by reference to DCLG CIL Guidance dated 2013 Paragraphs 84-89 “The interaction between
the CIL and S106 Agreements”.
Response
199
Barton Willmore on behalf of Taylor Wimpey East Midlands: Taylor Wimpey own land
east of Chesterfield Road, Alfreton. The site is included within the Derby HMA Strategic
Housing Land Availability Assessment (SHLAA) (2008 Review), which identifies sites that
have the potential for residential development. The SHLAA concludes that land east of
Chesterfield Road, Alfreton (Site Ref: AVBC/2008/0079, land adjacent to Derby Road,
Alfreton) is potentially suitable for housing. The site extends to approximately 17.4 hectares
of greenfield land located to the north west of Alfreton. Taylor Wimpey is committed to the
delivery of this site and confirms that the site is available for development immediately. It is
in a suitable and sustainable location immediately adjacent to the northern edge of Alfreton
and within walking distance of the town centre and could be delivered within the next five
years.
Response
Stephen Heathcote on behalf of Trustees of land around Cherry House Farm: Land off
Mill Lane and Kilbourne Road, Belper (AV12): The assessment is flawed as it excludes land
at Cherry House Farm which is available for development and would enable a
comprehensive development site to be assembled. Land adjacent to Cherry House Farm is
available for development, and the owners are in discussion with the adjacent owners to the
north and south (Pottery Farm and land off Pinchoms Hill Road) with a view to entering into
a consortium agreement should the land be allocated for development. It is agreed that land
at Hill Top Farm is not suitable for development due to the adverse impact on the Derwent
Valley Mills WHS. We anticipate that the site would be developed in conjunction with the
adjacent allocated employment site at Bullsmoor, and this is included on the plan to illustrate
a mixed use development.
Most of the land proposed for development is screened from views from the WHS by the
land form. The highest parts of the site are the most remote from the WHS, where
development would be seen in the context of existing housing development and would not
impinge on views into or out of the WHS.
Inclusion of the land at Cherry Farm House enables a contiguous development area to be
proposed and a new through road to be provided. This will also provide a much needed link
to the isolated Parks Estate. The new road would fit into the existing landscape and take
account of strategic footpath links as segregated cycle/bridleways connecting with the new
road.
Response
200
Catesby Estates Limited and Kedleston Estate: Land at Kedleston Road, Quarndon,
Derby, a sustainable site that sits within Amber Valley Borough adjacent to the
administrative boundary of Derby. Amber Valley Borough council has eight neighbouring
authorities and forms part of the Derby Housing Market Area with Derby City Council and
South Derbyshire District Council. Clearly the consideration of cross boundary issues in the
Borough is important and should be reflected in the emerging Draft Core Strategy. Catesby
Estates Ltd is particularly keen to ensure that the Draft Core Strategy appropriately takes
into account the requirements of the HMA.
It is worth noting that the existing urban area of Derby City is not able to accommodate more
than 10,000 dwellings. The Draft Core Strategy needs to make clear what proportion of the
urban extensions for 7,200 dwellings will be located within Amber Valley Borough.
It also needs to clarify that these urban extensions are in addition to the 9,400 dwellings to
be provided in Amber Valley. In light of the above, it is clear that there are unresolved issues
across the HMA which need clarification within the Draft Core Strategy under the legislative
and policy requirements of the duty to co-operate.
We are concerned that there is no reference to potential broad locations for growth to meet
the needs of neighbouring authorities, an omission which we feel is significant. There are
appropriate sites on the boundary of Amber Valley and Derby City which should
accommodate housing growth. The land at Kedleston Road, Quarndon is a good example of
an unconstrained site located outside of the Green Belt with capacity to accommodate up to
300 dwellings in a sustainable and appropriate location to meet the identified housing needs
of Derby. Given the strategic importance of such sites, we consider this should be addressed
as the Draft Core Strategy progresses in order to provide the framework for the subsequent
identification of sites through the Site Allocations and Development Management Policies
document. Indeed this is common practice elsewhere in the country where broad locations
are identified for cross boundary purposes.
Response
Home Builders Federation: Duty to Co-operate: Whilst the three authorities in the Derby
HMA including Amber Valley are working on separate but aligned Core Strategies, when the
Amber Valley Core Strategy (CS) is submitted for examination, the Council will have to
demonstrate collaborative working within the wider context of its eight neighbouring
authorities and not just those authorities within its own HMA. The Council should co-operate
with all its neighbouring authorities to ensure that housing needs are addressed.
Response
A Duty to Co-operate statement has been produced explaining how the Council has
engaged with adjoining local authorities when producing the Core Strategy.
201
Marrons: Our clients’ site at Kilbourne Road, Belper would provide a sustainable urban
extension to the town. It extends to 14 ha (35 acres) and could accommodate 250 – 300
dwellings, allowing for the upper slopes of the site to remain undeveloped. The development
site lies outside the Green Belt. It is one of the few opportunities around Belper to provide a
sustainable urban extension site without recourse to Green Belt land. The NPPF advises
that once established Green Belt boundaries should only be altered in exceptional
circumstances. Therefore, in the first instance, in seeking to secure sufficient land for
housing, the Council should have recourse to sites that lie outside current Green Belt
designations, as set out in the Local Plan. Other previously identified land to the north west
of Belper, but which is outside the Green Belt, is in a Special Landscape Area, and/or falls
within the Derwent Valley Mills World Heritage Site.
Part of the evidence base for the Local Plan is the Derby HMA Strategic Site Options Study.
The study considered 25 broad locations to assess their potential for accommodating future
housing growth. Within these broad locations the study identified 61 potential strategic sites,
including the land at Kilbourne Road as part of a wider Mill Lane/Kilbourne Road site. In
commenting on Belper as a broad location for growth the study noted: “Belper could
accommodate significant new development in the form of an urban extension and offers a
wide range of services that will be able to accommodate new development. Scale and mass
of development may be constrained by the historic environment of Belper.”
Our clients consider that the development of the site we are now putting forward would be
progressed via the preparation of a development that would have regard to the World
Heritage Site buffer zone and the possible impact of the development on that area and the
Belper and Milford Conservation Area, the relationship between the development and the
Pottery Farm buildings, landscape and topography and how the new housing would be
distributed across the site in relation to those factors.
The site is deliverable and developable in the terms of the advice set out in paragraph 47 of
the NPPF. The landowners are willing to release the land for development and it is
considered that the site is in a suitable location for residential development. There are no
environmental constraints to the development of the site. There is every prospect that this
site will be available and could be viably developed during the plan period.
In addition to the above site, our clients also consider that the plan should include a further
site at Bottles Farm, Denby Bottles (3.2 ha, 7.9 acres). This is an area of white land, outside
the Green Belt adjacent to the settlement of Denby Bottles, a suburban satellite to Belper.
The Council have been previously referred to this site in our clients’ response to the Options
for Housing Growth. The settlement includes a primary school, local shops and employment
uses. This site is available for development in the short term and could therefore provide a
necessary boost or stimulus to housing provision in this part of the Borough, in line with
Government policy. It could accommodate 100 - 120 dwellings. The former Amber Valley
Borough Local Plan (November 1991) showed the site as a proposed housing allocation (H1
– 39) within the development limit of the village. The Draft Amber Valley Borough Local Plan
also showed the site allocated for housing, but it was taken out of the Plan following the
Local Plan Examination, for reasons primarily related to the reduction in housing provision.
202
Response
The allocation of these sites will be considered when the Site Allocations and Development
Heaton Planning on behalf of Waystone Developments: Whilst we do not object to any
of the individual sites allocated as part of the Strategic Growth Site Policies, we wish to
register our objection to the overall approach, including the omission of the Shipley Lakeside
site.
The Shipley Lakeside development is of strategic importance and should, therefore, be
allocated in the Local Plan Core Strategy, for the following reasons:1) Shipley Lakeside is a unique development site. This is evident from the existence of a
site-specific policy in the extant Amber Valley Local Plan and a Development Brief dealing
with its future redevelopment.
2) The proposed development would make use of a parcel of previously developed
brownfield land in the Borough, which has remained vacant and derelict for many years.
3) The development would contribute positively to housing delivery in the Borough (providing
up to 400 homes phased over a ten year period).
4) The development would contribute positively to employment provision in Amber Valley.
5) The development of the site would reduce the pressure to release Greenfield sites
elsewhere in the Borough for housing and employment growth.
The Amber Valley Local Plan (2006) contains a specific policy in respect of the future
development of the former American Adventure Theme Park site, ‘Policy EN3: Major
Developed Site in the Green Belt at the American Adventure Theme Park, Shipley’ (saved
by the Secretary of State in 2009).
In 2011, a Development Brief was prepared in respect of the site entitled ‘The Shipley
Lakeside Development Brief’ to provide a framework against which detailed development
proposals for the site will be considered. The existence of this site-specific policy and
development brief clearly demonstrates Amber Valley Borough Council’s intent for the
Shipley Lakeside site to be re-developed and brought back into beneficial use.
Given the above, we object to the omission of a specific policy in the Local Plan Core
Strategy dealing with Shipley Lakeside’s future development.
Response
This site was not previously promoted as a strategic site for inclusion in the Core Strategy. It
is the subject of a current planning application which will be determined shortly.
203
Signet Planning:
The Council is inconsistent in how it deals with green belt release. Its strategy for green belt
release is based on a need to construct a new access (A610) through the Green Belt to the
east of Ripley/Codnor. As a consequence a considerable amount of housing (1,520
dwellings including Coppice Farm which is not green belt) is proposed in this general locality.
This represents some 35% of the total of the non PUA residential allocations in the Borough.
Belper has none. This is an inconsistent position with the Spatial Vision outlined in Section 4
of the consultation which seeks to concentrate new growth in the four towns of Belper,
Ripley, Heanor and Alfreton.
Such a distribution does not reflect the stated Spatial Vision and Strategy; a strategy that
was encompassed in the now revoked Regional Spatial Strategy. If the Council is now
seeking to opening state one Spatial Vision but pursue another in the draft Core Strategy
then it needs to be very transparent and publish robust evidence to support that position.
Belper is one of the four principal towns in Amber Valley Borough. The Local Plan Part 1
Draft Core Strategy does not allocate any housing sites in or adjacent to the current urban
boundaries of the town.
It is recognised that the town is constrained by Green Belt and countryside designations but
the consultation document does not recognise the strong sub-housing market area of Belper.
At a recent planning appeal against the refusal of the Council to approve housing on a site
immediately adjacent Far Laund it was recognised that Belper was a strong sub housing
market area within Amber Valley. It is then perverse not to allocate sites where people want
to live.
In the Preferred Strategic Site Assessment within Appendix E of the consultation document it
appears that the Council is considering the proposed land at Cinderhill site (AV13) as the
site which will support Belper. However, in the townscape and integration section of the
analysis it states that the site is poorly related to services in Belper, Ripley, and Derby. This
potential site of 1,800 dwellings is located some distance from Belper and will create its own
sub housing market. There is demand to live in Belper itself and the Local Plan Part 1 Draft
Core Strategy does not address this issue.
A recent appeal at land off Mill lane, Belper was dismissed due to the potential impact on the
World Heritage Site. There are no designated housing sites to the south of Belper. To the
east the land falls away quite steeply such that development would be highly prominent. To
the west is the Derwent Valley and the main World Heritage site.
To the north is land within the Green Belt but in an area where topography lends itself to
development, it lies outside the World Heritage Area buffer zone and out of the River
Derwent Floodplain.
204
It is against this background that this representation is put forward for land off Chesterfield
Road/Far Laund as an option for growth in Belper. Concerns have previously been
expressed regarding the diminution of the gap between Belper and Heage and it is
considered that this can be addressed and the gap strengthened.
This site is to the northeast of Belper which is situated approximately 8 miles north of Derby
and 12 miles west of Nottingham. The A6 runs through the heart of the town linking Derby
and Manchester via the Peak District.
The site itself is relatively close to the A38 which provides access to the M1. The site is
within reasonable walking distance of several bus stops and the town as a whole is served
by regular bus services to surrounding towns and villages as well as longer routes to Derby
and Manchester. Regular trains between Derby and Matlock on the Derwent Valley Line stop
at Belper station centre which is 1 mile to the south west of the site.
The town benefits from a significant number of shops and services including supermarkets,
schools, leisure facilities and medical facilities. This comprehensive range of provision and
the aforementioned access to public transport presents an opportunity for additional housing
in a very sustainable location.
Overall, the settlement of Belper is considered to have a very strong housing market, it is a
place where people aspire to live and a place where people who are seeking to move
properties wish to remain in.
The site, which has the benefit of being outside of the World Heritage Site buffer zone, is
located within Green Belt. Parts of the Green Belt in this area have only average landscape
quality and at the present time there is no defensible boundary to the Green Belt between
Heage and Belper.
This site provides a very sustainable extension to Belper in view of its proximity to a full
range of facilities and has the added benefit of enabling the creation of a clear boundary to
the Green Belt on the north-eastern side of the site.
Land at Far Laund/Whitemoor is referenced as AV11 in the Draft Core Strategy. The
Environmental Considerations section demonstrates that the site is largely free of such
constraints. Green Infrastructure would be integrated into the scheme as is demonstrated
later in this representation.
The need for infrastructure is fully recognised and this is a matter for discussion with the
Council. Thus far it has not been possible to establish the precise needs and consequently
such is not shown on the illustrative scheme. The Appeal with regard land to the south
established that that site was sustainable. Furthermore public transport services could be
extended through the site
Overall the draft Core Strategy is unsound and the Council is urged to reconsider its strategy
of significant allocation east of Ripley and provide a more balanced approach that also
delivers housing in Belper. There should be a full green belt review of sites with a view to
releasing green belt land for housing in the plan period or designate it as safeguarded land
to meet the future needs of the town.
205
It is acknowledged that land at Far Laund is located within green belt but as an integral part
of the Core Strategy process the Council should review its green belt boundaries to ensure
that settlements can grow in sustainable areas. It is maintained that the site represents a
sustainable extension to Belper and that its value in green belt terms is not significant. The
Council should also give consideration to identifying safeguarded land to ensure that any
revised green belt boundaries endure well beyond the Plan Period.
The illustrative plan for Far Laund demonstrates that the identified constraints can be
overcome and that overall there is a clear benefit to allocating the site for development not
only to secure the delivery of a high quality design residential community but also to seize
the opportunity to provide a defined and defensible Green Belt boundary on this side of
Belper and allow the town to grow.
Response
The Spatial Vision and Strategy have been amended to make it clearer where new growth is
proposed. The reasons why development of land in the Green Belt at Codnor and Ripley are
considered to demonstrate exceptional circumstances have already been explained in this
document and the Core Strategy. The site at Far Laund, Belper is within the Green Belt and
it is considered that exceptional circumstances have not been demonstrated. This site is also
particularly sensitive, given its close proximity to Heage. It should also be noted that it is one
of the sites that has poor performance against the SA criteria.
Signet Planning:
In 2008 the Derby HMA authorities commissioned the BE Group to assess the supply, need
and demand for employment land and premises in the Derby HMA. There were three
elements to the study:
An assessment of the study area‘s economy that will inform the amount, location and type of
employment land and premises required to facilitate its development and growth.
A review of the current portfolio of employment land and premises.
Recommendations on the future allocation of employment land and premises to maintain the
study area‘s economic growth.
In the body of the report with regard to Amber Valley it stated:
“There is a shortage of available, immediately developable employment land in attractive
locations – much of which exists is poor quality”; and
“Amber Valley suffers from generally poor quality land resource, with few obvious
opportunities to improve (i.e. with new allocations)”.
It recognised that Amber Valley “really needs to address its land supply, to find better
allocations that are more related to key access routes. However, it is accepted that this is
difficult and reflects the nature of Amber Valley as much as anything else – dispersed
settlements and employment areas divorced from key access routes”.
206
With regard to Belper it stated:
“There is a real issue in Belper. The viability of Bullsmoor is severely questioned because its
access is poor, it is poorly located and situated and lacks prominence; while remaining sites
are also small and poor quality”
The BE report scored each of the sites in Amber Valley providing each with a total score of a
maximum of 100 and a market-led subtotal of a maximum of 50. Bullsmoor falls at the lower
end of the grading system with a score of 46 out of 100 for the total score and just 23 out of
50 for the market-led subtotal. The BE report graded Bullsmoor as low quality.
The draft Core Strategy states that the local authority considers that:
“Taking into account existing allocations, planning permissions granted and development
that has taken place since 1 April 2008, there is no quantitative need for any additional
businesses and industrial land to be identified, but there is a need to address the qualitative
issue, by considering which existing allocations to de-allocate and replace with new
allocations of a higher quality”.
The consultation document goes on to indicate that this issue will be addressed in the Site
Allocations and Development Management Policies document which will form part 2 of the
Local Plan.
The sustainability appraisal of the Amber Valley Local Plan Part 1 – The Core Strategy was
published in June 2013. In section 10 it considers the spatial approach to employment
growth and distribution. At paragraph 10.3 is refers to the preferred economic strategy for
the Core Strategy. This looks to prioritise the areas that need economic regeneration and
support existing businesses.
As with the draft Core Strategy is indicates that the issue of the quality of business and
industrial land will be addressed through the allocation of new good quality employment
sites‖ and the de-allocation of various employments sites of poor quality. The sustainability
appraisal concludes that such an approach would provide the greatest opportunity to attract
high quality investment in the Borough.
Appendix III of the Sustainability Appraisal outlines the appraisal findings. It concludes that
Option 3 (delete poor quality allocations and identify new high quality sites linked to existing
and proposed housing sites) would be the most beneficial approach. It states:
“Option 3 offers a more positive approach for redistributing some of the employment land to
more attractive locations. As such, it could have a significant positive impact on the local
economy”.
207
The BE report is clear that Bullsmoor is a low quality employment site. It is unlikely to be
attractive to inward investment and so deliver any economic benefits for the Borough if it
continues to be allocated for employment purposes. Paragraph 22 of the NPPF goes on to
state:
“Planning policies should avoid the long term protection of sites allocated for employment
use where there is no reasonable prospect of a site being used for that purpose. Land
allocations should be readily reviewed. Where there is no reasonable prospect of a site
being used for the allocated employment use, applications for alternative uses of land or
buildings should be treated on their merits having regard to market signals and the relative
need for different land uses to support sustainable local communities”.
This is very clear advice that where long term protected employment sites have not delivered
economic development and benefits in the past, they should not be retained and allocated in
that use for the future. Alternative uses should be considered and this representation
provides an opportunity to provide housing on a non-Green Belt site which is allocated for
development immediately adjacent the settlement boundary of Belper.
Land at Bullsmoor has long been allocated for employment purposes. The site has not been
delivered and advice within para 22 of the NPPF is highly material. This is particularly the
case in the light of the low BE “Total” and “Market” scores first the site and the overall lack of
need for such localised sites. Following discussions with Vaillant there is now an ability to
open up the site for housing development and provide benefits and certainly for Vaillant.
There are a number of benefits:
A. Provision of a housing site in a strong sub housing market area.
B. The delivery of much needed market and affordable housing in Belper.
C. Development outside of the Green Belt.
D. Ensure Vaillant has the ability to operate without hindrance, can improve internal
circulation and accessibility, improve parking and release land to meet operational needs.
The illustrative plan for Bullsmoor demonstrates that the identified constraints can be
overcome and that overall there is a clear benefit to allocating the site for housing
development not only to secure the delivery of a high quality design residential community
but also to seize the opportunity to provide a defined and defensible Green Belt boundary on
this side of Belper.
The Council should review its housing distribution and allocate land at Bullsmoor for
housing.
Response
Consideration of this site being allocated for housing will take place when the Site
208
Savills:
Supports the allocation of part of site AV3 - Land South of Birchwood Lane, Somercotes as a
site for approximately 250 dwellings.
Response
Freeth Cartwright:
We consider that land at Somercotes Hill, Lower Somercotes is suitable, appropriate and
available as a strategic housing allocation for consideration. The site is clearly in a
sustainable location on the edge of the existing settlement of Somercotes with good access
to local facilities and public transport. Employment opportunities also exist in the immediate
vicinity of the site which would further reduce the need to travel by unsustainable means.
The land itself is of no particular landscape or ecological merit and preliminary evaluations
suggest there are no constraints to its development in this respect. Infrastructure is generally
available in terms of drainage etc. and although there may be need to increase capacity and
to address surface water, the site is large enough either in its own right or in combination
with other land to address these issues viably.
Response
DPDS Ltd (Midlands and North): Land at Market Place, Codnor currently supports
established employment uses including offices, workshops and associated builders’ yard.
Representations are submitted with regard to the builders yard area of the site which is
currently subject to saved Local Plan policy LC9. It is understood that this site has been
subject to continued planning consent for its current use for over 20 years. Planning
permission was originally granted on a temporary basis via appeal on 21 September 1991.
This permission was renewed on 7 January 1998 (AVA/1097/0855) for 5 years and 19 May
2003 (AVA/2003/0178) for a further 5 years.
The current planning permission (AVA/2009/1110) establishes further temporary use of the
land with regard to the storage of building materials, plant and equipment and is due to
expire 31 December 2018. The reason for limiting the permanence of the use relates to the
“safeguarding” of the site for a new primary school. The policy context for this is provided
through saved Policy LC9 of the Adopted Local Plan. This states that “The Borough Council
will safeguard land, as shown on the Proposals Map, from any development that could
prejudice the provision of new schools at ………
b) Mill Lane, Codnor”.
209
It is noted that Policy LC9 of the Adopted Local Plan is intended to be saved through the
transition from Local Plan to Core Strategy with Appendix C of the Pre Submission Core
Strategy confirming that Policy LC9 is “To be considered for inclusion in the Site Allocations
and Development Management Policies DPD”.
Whilst it is recognised that this consultation does not directly relate to the Site Allocations
and Development Management Policies DPD, representations are submitted here as it is
considered that aspects of the Core Strategy which directly relate to the overall retention of
Policy LC9 cannot justify the continued “safeguarding” of my clients land.
The Core Strategy identifies a strategic growth site for around 600 dwellings on land off
Alfreton Road, Codnor to be delivered before the end of the plan period. It is noted this figure
is substantially below the normal indicative level of dwellings required to justify the building
of a new primary school (1,000 dwellings).
Given the Core Strategy proposes the allocation of no further strategic growth sites around
the town, there are prospects that the proposed retention of saved Policy LC9 in its current
form could not be considered sound as the delivery of a new school would require a much
higher level of development to be “justifiable”.
Response
Officers in the County Council’s Property Services Department are currently looking at the
Primary School site and examining the feasibility of expanding the school. In the meantime,
they have advised the Borough Council that it is imperative that the Local Plan continues to
identify the site as a notified site as it is the statutory playing field for the existing school.
Further consideration of this issue will take place when the Site Allocations and
210
Bodies invited to make representations
Appendix A
1-2 PlayDay Nursery
A-Chem Ltd
1st Alton Manor Scout Group
Acorn Training Consultants Ltd
1st Choice Dental Laboratory Ltd
ACT Services
1st Horsley & Kilburn Scout Club
Action for Children - Youth Reach (Alfreton
1st Horsley & Kilburn Scouts
Adlington Planning Team
1st Openwood Scout Group
Adrian Heapy
2nd Swanwick Scout Group
Adullam Homes Housing Association
3663
Advance Land & Planning Limited
3rd Alfreton Boys Cubs & Scouts
Advanced Lifestyle Solutions
A Hingley & Son (Timber Ltd)
African Caribbean Community Association
A Robinson & Sons (Garages) Ltd
Age Concern Derby & Derbyshire
A W Birch
Aim High
A Walters & Sons
AIMS Accountants For Business
AA Computers
AJ Fabrics & Crafts
AAA Private Hire
Alan Bentfield Ltd
Abbey Tree Care
Alan Newton Associates Ltd
Abru Ltd
Aldercar & Langley Mill Parish Council
Academy Book Services
Aldercar Community Language College
Acanthus Stoneware Ltd
Appendix A
Aldercar Infant & Nursery School
Alfreton Town Council
Aldergate Properties Ltd
All Saints Church
Alderwasley Parish Council
Alton Manor Day Nursery
Alfreton & District Funeral Services
Amber Sound FM
Alfreton & District Heritage Trust
Amber Trust
Alfreton Community Association
Amber Valley Access c/o DCIL
Alfreton Further Education Centre
Alfreton Golf Club Ltd
Amber Valley Borough Council
Alfreton Grange Arts College
Amber Valley Community Transport
Alfreton Hall
Amber Valley Consultation Panel
Alfreton Heritage Centre
Amber Valley Council for Voluntary Services (CVS)
Alfreton Leisure Centre
Amber Valley Disability Sports & Leisure Development Group
Alfreton Library
Amber Valley Engineering
Alfreton Methodist Church
Amber Valley Gymnastics Club
Alfreton Model Railway Society
Amber Valley Housing Ltd
Alfreton Nursery School
Amber Valley Methodist Church
Alfreton Park School
Amber Valley Production (South) Ltd
Alfreton Party in the Park
Amber Valley Riders
Alfreton Shop Mobility
Amber Valley Scaffolding
Appendix A
Arrow Recruitment Agency
Amber Valley SOS
Arthur Medical Centre
Amber Valley Sure Start
Artists
Amber Valley Sure Start Project
Arup
Ambergate Caravan Centre
Ashfield District Council
Ambergate Carnival
Ashfield land
Ambergate Neighbourhood Association
Ashland UK
Ambergate Primary School
Ashover Parish Council
Amberol Ltd
Ashtton Associates Ltd
Ambivet
Asian Association of Chesterfield and North East Derbyshire
Anchor Trust
Ass. Of License Multiple Retailers
Andrew Large Surveyors Ltd
Association of Indian Women
Andrew Martin Associates
Atis Real
Anthony Aspbury Associates
Atlas Building & Civil Engineering
Applied Electronics Ltd
Autism Helpline (National)
Architechtural & Building Design Servies Ltd
Axess Systems Ltd
Archway Interiors
B & B Products
Arden Court Group
B & J Carpets
Armstrong Burton Planning
B & K Structures Ltd
Appendix A
Belper & District Neighbourhood Watch
BA Recruitment Ltd
Belper Amateurs Cricket Club
BAFA (Bullbridge and Sawmills Area Civic Society)
Belper Amateurs Cricket Club
Bagshaws
Belper Army Cadets
Bailey Brook House Business Centre
Belper Bridge Club
Bailey Construction (Derby) Ltd
Belper Care & Mobility Centre
Baileys Printers
Belper Coal Supplies
Bakewell & Partners LLP, Chartered Architects & Town Planners
Belper District 50+ Forum
Balvac
Belper Drop Inn
Banks Development
Belper Golf Centre
Bankwood
Belper Historical Society
Baptists - East Midlands Regional Association
Belper Leisure Centre
Barnardo's
Belper Library
Barton Willmore
Belper Local History Group
Barton Willmore LLP
Belper Meadows Bowls Club
Barton Willmore on Behalf of Taylor Wimpey East Midlands
Belper Meadows Cricket Club
BATS
Belper Mental Health Centre
BDS Assist Ltd
Belper Minibus Association
Bellway Homes
Belper News
Appendix A
Booth & Stirland Ltd
Belper North Mill
Border Office Equipment & Stationery
Belper Poetry Group
Bow Distribution & Warehousing Ltd
Belper Pottery Bowls Club
Bowers Electricals Ltd
Belper River Gardens
Bowmer & Kirkland Ltd
Belper School
Boyer Planning(obo Bellway & Clowes)
Belper Town Council
Boyer Planning, Environmental Planning & Development Consultants
Belper Town Football Club
BPS
Belper Town Juniors
Bradfield Storage Handling Ltd
Belper Traders Association
Brailsford and Ednaston Parish Council
Belper Travel
Break Time Vending
Belper Youth and Community Centre
BREEAM Technical Consultant: Government Focus
Benzbavarian Service Centre
Brian Twigg Planning
Better Metal Store Ltd
Brian Wolsey (Planning) Ltd
Biggin by Hulland
Bridge Kitchens
Birchwood Equestrian Centre
Bridgeshire Packaging Ltd
Birchwood Lane Allotment Association
BM Contractors
Briggs Sayer & Co
Bolsover District Council
Brinard Joinery Ltd
Appendix A
Brinsley Parish Council
Butler Cook
British Chemical Distributors and Traders Association
Butterley House
British Geological Survey
C & P Structural Engineers Ltd
British Heart Foundation
C B Plant Services Ltd
British Horse Society
C Blount
British Ports Association
C W George, Painting & Decorating
British Red Cross
CAB
British Telecom
CABE
British Waterways (Central Shires Waterway)
Cadenza VM Ltd
British Waterways East Midlands
Broadbents Solicitors
Callow Parish Council
Broadholme Lane Caravan Park
Camland Developments Ltd
Brooklyn Medical Practice
Campaign for Better Transport
Broxtowe Borough Council
Campaign for the Protection of Rural England
BTH (UK) Ltd
CamTAD Campaign for Tackling Acquired Deafness
Buckingham Insurance Consultance Ltd
Canlin Castings Ltd
Bullbridge & Sawmills Civic Society
Capita Symonds
Burchell Edwards
Care For Independence
Burnsides (Marketing Aids) Ltd
Carousel Craft Group
Appendix A
Chartex Ltd
Carter Construction (Derby) LTD
Chatsworth Settlement Trustees
Cateby Estates Limited & Kedleston Estate.
Chesterfield Borough Council
Cattermole Technical Services
Chevin Fleet Solutions
CBI
Chevin House Farm Cottages
CED Ltd
Childrens Leukaemia & Cancer Support
Cedar & Co
Chiltern Mills
Cedar Doors Ltd
Chris W Roads Ltd
Celebrity Motion furniture Ltd
Christ Church Ironville
Central Driveline Services
Cinderhill OG
Central Trains Ltd
CISWO (Miners Welfare)
Centre for Ecology and Hydrology
Cito (UK) Ltd
CERDA Planning
Citroen Services
Chair of Arthur Medical Centre Patients Group
City Electrical Factors Ltd
Chapel Studio
Civil Aviation Authority
Chapman & Chubb Solicitors
Clarke International
Charapak Ltd
Clayton Engineering Co
Charnwood Management Centre Ltd
Cleaver Thompson
Chartered Surveyors
Clowes Developments (UK) Ltd
Appendix A
Co-op
Coal Merchants Federation Ltd
Co-op Supermarkets
Codnor Boys Football Club
Co-operative Retail Logistics
Codnor Community Primary School
Cope Sticks
Codnor Horticultureal Ltd
Cooper Research Technology Ltd
Codnor Parish Council
Coppice Primary School
COG - Community On-the Go
Corfield C Of E Infant School
Coldharbour Marine
Corporate College
Colin Buchanan
Council for British Archaeology
Colin Jewkes
Country Land & Business Association
Colliers CRE
Country Scales Ltd
Collis Engineering Ltd
Country Tiles (East Midlands) Ltd
Commercial Estates
Country Work Studio
Commission for Architecture and Built Environment
Cow House Dairy Ltd
Community Care Systems
Cox's of Belper
Community Transport
Cresta Gems
Concept Plastic Packaging Ltd
Crich Parish Council
Connexions Derbyshire
Crich Patient Participation Group
Contract Planning Services
Crich Tramway Village
Appendix A
Dales Housing
Criton Electrical Services
Dalesmen Male Voice Choir
Croft Infant School
Dannah Farm Country House Ltd
Cromford Parish Council
Danwood Group
Crosshill Garage
Dash Homes ltd
Crown Estate Office
Dave Clark
ct planning
Dave Knowles (Warm Air) Sales
Curiosity Interiors
David Beard Music Production
Custom Cruisers (UK) Ltd
david lock associates
Customer Plus Ltd
David Sharp Studio
CX Automotive
David Wilson/Barratt Homes North Midlands
D A Spray Ltd
DCC Corporate Property
D B Brooks Electrical Engineers Ltd
DCC Housing Strategy
D Clark
DCC Older People's Forums
D G Scott Ltd
Deaf Equality Forward
D I Blow Opticians
Deb Ltd
D J Redfern
DEB Town Planning
D S Smith
Delta Business Solutions Ltd
Dalbury Lees Parish Council
Denby Cricket Club
Appendix A
Denby Footpath Group
Derby City Council - Children and Young People
Denby Free C of E VA School
Derby City Estates
Denby Free School
Derby City Housing Strategy
Denby Institute
Derby City NHS
Derby Community & Law Centre
Denby Parish Council
Derby Diocesan Board of Finance
Dennis Mowers
Derby Hospitals NHS Foundation Trust
Department for Business, Innovation and Skills
Derby Mobility Services Ltd
Department for Children, Schools and Families
Derby Race Equality Council
Department for Culture, Media and Sport
Derby University
Department for Environment Food and Rural Affairs (DEFRA)
Derbyshire & Nottinghamshire Chamber of Commerce
Department for Innovation, University and Skills
Derbyshire & Peak District Campaign for Better Transport
Department for Transport
Department for Work and Pensions
Derbyshire Acute Hospitals NHS Trust
Department of Communities and Local Government
Derbyshire Archaeological Society
Department of Health
Derbyshire Association For The Blind
Derby & Derbyshire Constabulary
Derbyshire Association of Local Councils
Derby & South Friends of the Earth
Derbyshire Autism Support
Derby City Council
Appendix A
Derbyshire Building Society
Derbyshire Green Party
Derbyshire Business Against Crime
Derbyshire Gypsy Liaison Group
Derbyshire Campaing to Protect Rural England
Derbyshire Childrens Holiday Centre
Derbyshire Housing Aid (affiliated to Shelter)
Derbyshire Chinese Welfare Association
Derbyshire Investments Ltd
Derbyshire Coalition for Inclusive Living
Derbyshire Learning and Skills Council
Derbyshire Community Foundation
Derbyshire Lohana Community
Derbyshire Community Partnership
Derbyshire Mental Health Services NHS Trust
Derbyshire Constabulary
Derbyshire Police
Derbyshire County Council
Derbyshire Police Authority
Derbyshire County Council - Children And Young Adults
Derbyshire Positive Support
Derbyshire County PCT
Derbyshire Pre School Learning Alliance
Derbyshire County Primary Care Trust
Derbyshire Primary Care Trust
Derbyshire Dales District Council
Derbyshire Probation Service
Derbyshire Economic Partnership
Derbyshire Rural Community Council
Derbyshire Federation of W.I.s Ripley District U3A
Derbyshire Sport
Derbyshire Federation of Women's Institutes
Derbyshire Stroke Club Network
Derbyshire Fire & Rescue Service
Derbyshire Toy Library
Derbyshire Friend LGB Transgender Support Group
Derbyshire Voice
Appendix A
Derbyshire Wildlife Trust
Duffield & District Crown Green Bowls
Derbyshire Youth Forums
Duffield Community Association
Derek Latham & Co Ltd
Duffield Cricket Club
Derwent Living
Duffield Parish Council
Derwent Mills World Heritage Site Partnership
Duffield Village Forum
Derwent Theatregoers
Duncan Residential LTD
Derwent Valley Visitor Centre
DW Ball Prospect Management LTD
Dethick, Lea & Holloway Parish Council
DW Motors
Diocese of Derby Anglican Church
E & R Timber Products
Diocese of Nottingham Catholic Church
E Surv
Disability Direct
East Midlands Airport
DMS Bookkeeping Services
East Midlands Ambulance Service NHS Trust
East Midlands Councils
Dove Valley Plant Hire
East Midlands Development Agency
DPDS Consulting Group
East Midlands Electricity
DPP
East Midlands Family Placement Project
Dr Malcolm Bell Ltd
East Midlands Housing Association
Drainstore.com
East Midlands Planning Aid
DTZ
Appendix A
East Midlands Trains
EON Central Services
Eastmidlands Japanese Association
EP Industries Ltd
Eastwood Town Council
EPC-UK C/O Leith Planning Ltd
Easy Accounts Ltd
Equality and Human Rights Commission
Eaton and Hollis
Equip Outdoor Technologies Ltd
EDF
Erewash Borough Council
EGNIOL Consulting Ltd
Erewash Canal Preservation and Development Association
Ekard Ltd
Erewash Partnership Ltd
Elastogran (UK) Ltd
Eric Madeley Ltd
Elim Pentecostal
Eurocell
Ellis Fermor & Negus
Evergreen Computer Consultants Ltd
Emery Landscapes Ltd
Excelpress Ltd
England and Lyle Ltd
Exercise for Health
English Churches Housing Group
Face to Face Financial Solutions Ltd
English Heritage
Fair Play
Enigma Spa
Fairfield Sure Start
Entec (consultants for National Grid)
Fairgrove Group Ltd
Environment Agency
Fairgrove Homes Ltd
EON
Appendix A
Fairhurst
Friends of Swanwick Hall School
Federation of Small Businesses (Notts and Derby)
Friends of the Earth
Fibromyalgia Group
Fusion Online Ltd
Fields In Trust
Future Homescape Ltd
Fisher German LPP
G S Worth
Fisher German on behalf of the Trustees of the Locko Estate
Gadsby Orridge
Fishermans Rest
Gatepost Theatre Company
Fleet Arts
Gavin Kenning Engineering
Florence Nightingale Derbyshire Association
Gayton Luncheon Club
Forestry Commission
GE Equipment
FPCR Environment & Design Ltd
Gee Security Ltd
Freeth Cartwright LLP
Gem Vending
Friends of Ambergate
Genesis Business & Conference Centre
Friends of Belper Parks
Geoffrey Prince Associates Ltd
Friends of Belper River Gardens
George Shipman & Son Ltd
Friends of Cromford Canal
George Wimpey
Friends of Cromford Canal
Gerald Eve
Friends of Markeaton Brook
Girl Thing
Friends of Shipley Park
Appendix A
GL Hearn
Green Hillocks Fellowship
Gladman Developments
Griffith Laboratories
Gleeson Developments
Griffiths Superior Homes Ltd
Go Mobile Ltd
Groundwork Derby & Derbyshire
Godkin Holdings
Guildford Europe
Godwin Developments
GVA Grimley
Going Places
Goseley Dale Farm
Halifax Estate Agents
Gough Planning Services
Hall & Benson
GraceMachin Planning & Property
Hall & Partners
Graham Daws Associates
Hall Pastures Farm
Granite Connection Ltd
Hallam Land Management Ltd
Grant MSM Ltd
Hallprint
Granwax Products Ltd
halsall lloyd ltd
Graphic Results
Hamer Associates
Grays Interiors
Hanson Aggregates
Greasley Parish Council
Hanson Building Products
Green & May Ltd
Hardy Miles Titterton
Green 2k Design
Harlite Installations Ltd
Appendix A
Heanor Baptist Church
Harris Lamb
Heanor Carnival Committee
Hartshorne (East Midlands) Ltd
Heanor Gate School Project
Harvest Meadow
Heanor Gate Youth Club
Haslam Homes
Heanor Green Belt Action Group
Haworth Estates
Heanor Historical Society
Hayward Electrical & Mechanical Services Ltd
Heanor Lions Junior Football Club
Hazelwood Bowling Club
Heanor Memorial Hospital
Hazelwood Parish Council
Heanor Police Youth Project
HCA
Heanor Pre-school
HCM Electrical Ltd
Heanor Running Club
Heage Road Allotment Association
Heanor Swimming Club
Heage Village Hall
Hearing Help (AV)
Health and Safety Executive
Heaton Planning
Healthier Communities
Heaton Planning Ltd
Heanor & District Local History Society
Help the Aged
Heanor & Loscoe Town Council
Herbert Strutt Primary School
Heanor 50+ Forum
Heritage Heating (Midlands) Ltd
Heanor Antiques Centre
Hickton Construction Ltd
Appendix A
High Peak Borough Council
Horsley Woodhouse Primary School
Highedge Historical Society
Housing Corporation
Highways Agency
Howard Sharpe and Partners
Historical Model Railway Society
Hulland Ward
Hives Planning
Idridgehay Community Centre
HLE Test & Service Centre
Idridgehay, Alton and Ashleyhay Parish Council
Holbrook Miners Welfare Football Club
Impala Stone Ltd
Holbrook Parish Council
Indian Friendship Society
Holbrook Parish Plan
Indigo Planning Ltd
Holmes AntilHolme Farm Barnl
Industrial Diamond Services Ltd
Home Builders Federation Ltd
Inland Waterways Association
Home Farm
Innes-England
Home Office
Insight Town Planning
Institute of Directors
Home Start Amber Valley
International Council on Monuments & Sites UK
Homes and Communities Agency
International Shromani Akali Dal
Horsley Bowls Club
Ironville 1860
Horsley Parish Council
Ironville Parish Council
Horsley Woodhouse Parish Council
Appendix A
J & A Engineering
Jobs 2 Do
J C Balls & Sons
John A Clarke
J C Balmforth Ltd
John Carr Motorcycles Ltd
J F Neville
John Church Planning Consultancy Limited
J K S Boyles UK Ltd
John Day Decorators Ltd
J S Bloor ltd
John Dobbs Developments Ltd
J Tech Roadshow - The Party People
John Flamstead School Govonor
J W Andrews (Builders) Ltd
John Flamsteed Community School
JAG Communications
John Martin & Associates
James Beresford & Sons
John Smedley Ltd
James Engineering Construction (Alfreton)
Johnson Diversey UK
JB Planning associates
JPK Engineering Ltd
JCT 28
JS Bloor (Services)
Jem Transport
JS Environmental Ltd
Jessop Monument Trust
JT Marketing Research
JF Planning Associates
Jubilee Wedding Cars
JG Land and Estates
Judy Mallaber MP
JKW Refinishing Supplies Ltd
Just 30 Ltd
JMW Planning Ltd
Appendix A
Just Bandits Ltd
Kilburn Preservation Group
Just Jigsaws Ltd
Kinetika
JVH Planning
King Sturge LLP
K & A Cox Ltd
Kirk Hallam Building Company Ltd
Kam Servicing Network
Kirk Ireton Parish Council
KAS Designs
Kirk Langley Community Orchard
KDW Ltd
Kirk Langley Parish Council
Kedleston Park Golf Club
Kirkwells - town planning and sustainable development consultants
Keepsafe Security Services Ltd
KJD
Kelvingrove Medical Centre
Knight Frank
Kevin Palmer Media Services
KVM (UK) Ltd
Key Property Solutions Ltd
Kyleburn Historical Society
Keyclad Ltd
LA Engineering Belper Ltd
Kilburn Area Preservation Group
Lambert Smith Hampton
Kilburn Infant and Nursery School
Kilburn Nursing Care Centre
Langley Corporate Wear Ltd
Kilburn Osteopaths
Langley Mill Baptist Church
Kilburn Parish Council
Langley Mill Junior School
Kilburn Post Office
Langley Mill United Cricket Club
Appendix A
M & C Hunt
Langridge Homes Limited
M A Broughton Electrical
Leedale Ltd
M D & W Buxton Ltd
Leonard Cheshire Disability
M J Maillis UK Ltd
Leonard Miles & Son
M R Booth
Les Hutchinson Transport Ltd
M T Buxton Industrial Services Ltd
Les Riley & Sons Ltd
Mackworth Estate Community Association
Lester & Nix Ltd
Mackworth Parish Council
Life Matters
Maintenance Painting Systems Ltd
Lighthouse Charity Shop
Lightspeed Derby
Malcolm Judd and Partners
Limes Medical Centre
Malcom Scott
Little Eaton Parish Council
Manthorpe Engineering Ltd
Living Stones Sculpture Workshop
Manx Engines
Liz Portas
Maple Arenas
Loscoe C of E Primary School
Mapperley C Of E (Controlled) Primary School
Losoce Dam Project
Mapperley Parish Council
LPG Conversions
Marathon Thread (UK) Ltd
Lynx Motor Co Ltd
Marehay Bowls Club
Appendix A
Marlpool Infant School
Michael Blake - Personnel Consultant
Marrons
Michael Goodall Homes Ltd
Marshall & Till
Michael House Steiner School
Marston On Dove Estates Ltd
Martineau
Micro Connect Ltd
Massive Youth Project
Microbial Innovations Ltd
Mather Jamie
Mid Derbyshire After Care Project
Matlock Bath Parish Council
Middlebrook Transport LTD
Matthew Montague Architects
Midland Building Design Practice
Maypole Promotions
Midland Railway Trust Ltd
McDonalds (Alfreton)
Midland Structural Services
Meadow Farm Studio
Midland Tree Management
Meadowstone (Derbyshire) Ltd
Midlands Association for Amputees and Friends (MAAF)
Medequip Assistive Technology Ltd
Midlands Co-op Travel
Melfort Construction Services Ltd
Midlands Co-Operative Funeral Services
Merebrook Consulting Ltd
Midway Fencing Contractors Ltd
Merriman Plant
Milford & Makeney Community Group
Metmachex Engineering Ltd
Milford House
Metropolitan Housing Trust
Milford Pre-School
Appendix A
Morley Primary School
Mill Systems
Morris Homes East Midlands Ltd
Miller Homes Ltd
Mortgage Force
Mills Computer Products Internationsl Ltd
Mortgageline Services Ltd
Milward Construction (Belper) Ltd
Moss Office Services Ltd
Ministry of Defence
Motor Neurone Disease Association (Derbyshire)
Mitech Joinery
Mowhawk Laboratories
MMA design Ltd
MPC Services (UK) Ltd
MMD Mining Machinery Development Ltd
MT Refrigeration
Model farm
Mundy School
Mono Consultants
Nathaniel Lichfield & Partners
Montague Architects Ltd
Nathaniel Lichfield and Partners
Montague Architects Ltd
National Federation of Gypsy Liaison Groups
Monty's
Nationwide Ceramics
Moorgreen Flexible Packaging Ltd
Natural England
Moorwood Moor Angling Club
Natural England
Morecrofts Electrical
Natural England
Morgan & Co (Belper) Ltd
Natural England
Morley Parish Council
Natural England
Appendix A
Noise & Vibration Consultants Ltd
NBE Fire & Security Ltd
Norder Design Associates Ltd
NBE Fire Prevention Ltd
Norseman Holdings Ltd
Nealies
North East Derbyshire District Council
NEDCASH
Northern Counties
Neeco Engineering Ltd
Nottingham City Council
Nelson Distribution
Nottingham Community Housing Association
Nelson Distribution Ltd
Nottinghamshire County Council
Nether Heage Methodist Church
Nottinghamshire Wildlife Trust
Network Rail
Nuthall Valve Services Ltd
Network Rail property
NY Garden Services
New Bengal Balti & Tandoori Restaurant
Office of Government Commerce
New Life Church
Oldroyd Associates
New Street Accounting
Omnivale Limited C/O Antony Aspbury Associates
ng nattrass giles
Optima Financial Planning Ltd
NHS East Midlands
Opun - Regeneration East Midlands
NHS Logistics
Orange Personal Communications Services Ltd.
Nigel Davis Solicitors
Ormonde Fields Golf & Country Club
NLP Planning
Ornamental Engineering
Appendix A
Peak District National Park Authority
Our Vision, Our Future
Peak District Rural Housing Association
P & A Finishes Ltd
Peak Oil Products Ltd
P J Hamson & Co Ltd
Peak Plastics Ltd
Padley Hall
Peak Vending Systems Ltd
Page Whelan Design & Print Ltd
Peakweb Ltd
Pakistan Cultural Association
Pearsons Engineering Services Ltd
Paragon Financial Consultants
Pegasus Planning Group
Parfetts Cash & Carry
Pennine Plant & Tool Hire Ltd
Park Hall Timber Buildings
Pentalpha Exhibitions Ltd
Parker Design Associates LTD
Pentrich Parish Council
Parkinsons Disease Society
Permaroof (UK) Ltd
Parkside Surgery
Personnel Support Services (Derby) Ltd
partially deaf and partially blind
Peter Diffey Associates Ltd
Past Times
Patients Group, Arthur Medical Centre
Peter Swan Associates
PCS Edmundson Electrical Ltd
Peveril Homes
Peacock and Smith
PFD Flooring Ltd
Peacock and Smith on behalf of Wm Morrison Supermarkets Ltd
Phase Print & Design
Appendix A
Pidcock & Beastall Ltd
PW Services Loscoe Ltd
Pilkington Architecture Limited
QA Associates
Pinxton Parish Council
Quality Direct Office Supplies Ltd
Planning Design Practice Ltd
Quarndon Parish Council
Planning potential
Quiltex Ltd
Planning Potential
R D Geeson (Derby) Ltd
Plant Equipment Ltd
R.J. Ryder Planning Consultant and Architect
Planware Ltd
Rachaels Bouquet
Plastick Windows
Radbourne Parish Council
Polymerlink Ltd
Radleigh Homes
Post Office Ltd
Raglan Housing Association
Powrie-Smith Architects
Rail Freight Group
Press for Change
Ram Furniture
Pride of Place
Ramblers Association
Prime Precision
Rapleys LLP
Princess Royal Class Locomotive Trust
Reach Out, Dignity, Womens Zone
Print Scene (Print & Signs) Ltd
Red Line Cars
Promopac K Digital Studios
Redrow Homes
Prosign Print & Production
Appendix A
Resco Railways Ltd
Ripley Historic Society
Rethink (Mental Health)
Ripley Methodist Church
Richard Mullard
Ripley Music Festival
Richard Savidge
Ripley Neighbourhood Care Scheme
Richard Savidge Chartered Surveyors
Ripley Printers Ltd
Richardson Endowed Primary School
Ripley Town Council
Richford Motor Services Ltd
RMA Ltd
Riddings Junior School
Road Haulage Association Ltd
Ridgeway Nursing Home
Robert Clarke Chartered Surveyors
Ridgewood Equestrian Centre
Robinsons Solicitors
Ridgewood Farm
Rocbore Ltd
Riding for the Disabled
Roger Tym & Partners
Right 4 Staff
Roger Yarwood Planning Consultants Ltd
Ripley & District U3A
Rollersnakes Inline Hockey Club
Ripley & Heanor News
Roper Avenue Allotments
Ripley Academy of Dance & Drama
Rosehips of Duffield
Ripley Business Forum
Rotrex Winches
Ripley Greenway Play Area
Royal Mail
Ripley Heritage Trust
Appendix A
Royal Mail Group
Sarah's Foot clinic
Royal Society for the Protection of Birds
Save The Children Fund
Royal Society for the Protection of Birds
Savills
RPS Engineering Ltd
SB Wrought Iron Ltd
RPS Group
Scaan Ltd
RPS Planning and Development
Schades Ltd
RPT Engineering Ltd
Schofield commercial Interiors Ltd
RPT Rewinds
Scorpion Exhausts Ltd
Rudolf Chemicals
Scott Wilson Ltd
S & K Antcliffe
Scotts Heavy Haulage (Ireland) Ltd
S H Field Ltd
Scrumptious
Safety Deck
Seat Design Co Ltd
Safety reflectives Ltd
Selston Parish Council
Salcare
Selway Group
Salloway Property Consultants
Selwood Plant Hire Ltd
Sercel England
Salt Pot Café
Severn Trent Water Ltd.
Sanderson Weatherall LLP
Shepherd Hydraulics & Pneumatics
Sangham Group
Sherwood Packaging Ltd
Appendix A
Smith Stuart Reynolds
Shipley Cricket Club
Smiths Gore
Shipley Hall
Sndritz Sales (UK) Ltd
Shipley Motor Co Ltd
Solid Fuel Association
Shipley Parish Council
Somercotes Library
Shipley Parish Plan
Somercotes Medical Centre
Shirland and Higham Parish Council
Somercotes Parish Council
Shottle & Postern Parish Council
Somercotes Parish Council
SIA Abrafoam Ltd
Somerlea Park Centre
Signet Planning
Somme Road Environmental Improvement Group
Simpley Tiles Ltd
Sound Dynamics Ltd
SJY
Sound Products
Slacks Travel
South Derbyshire Council
Slater Electrical
South Derbyshire District Council
Slenderella Wholesale Ltd
South Derbyshire Voluntary Sector Mental Health Forum
SLS Design Consultants Ltd
South Normanton Parish Council
Smalley Church
South Staffordshire Water
Smalley Parish Council
South Staffordshire Water Plc.
Smith Cooper
South Wingfield Local History Group
Appendix A
St Johns Primary School PTA
South Wingfield Methodist Church
St Luke's Church
South Wingfield Parish Council
St Margarets Hall Alderwasley
South Wingfield Primary School
St Matthew Morley C of E Church
South Wingfield School PTA
Staff Connect
South Wingfield Social Club
Stanley and Stanley Common
South Yorkshire Passenger Transport Executive
Steam-Models
Southern Derbyshire CCG
Stedmark
Southern Staffordshire Chamber of Commerce and Industry
Steedman Planning & Land
Space 4 Work
Steedman Planning, Ashby De La Zouch
Spirita
Stent
Sport England
Stephen Jones & Associates
Sport England - East Midlands Region
Stephen W Bateman
Spotted Cow
Stepping Forward
SSAFA Forces Help
Stepping Stones
SSR Planning
Steve Beer Transport Ltd
St James Church Codnor
St John The Baptist C of E Church
Steven Thaw
St John's C of E Primary School
Stonewall
Appendix A
Stop 500
Swanwick Pre-school
Stormwater Proofings (UK) Ltd
Swanwick Primary School
STR UK Ltd
Swanwick Residents Association
Strawberry Field Allotment
Swanwick School & Sports College
Street Lane Community Association
Swanwick Social Club
Strutt and Parker
Swanwick Womens Institute
Studio Emet
T & M Motors
Summerfield Engineering Ltd
T E Boddington
Sure Fire Technical Services Ltd
Tapton Estates Ltd
Sure Start (Bolsover)
Tarmac Ltd
Sure Start (Ripley)
Swanshaws Ltd
Tarragon electrical Services Ltd
Swanwick Baptist Church
Tarragon Electrical Services Ltd
Swanwick Community Association
Taylor Wimpey UK Limited
Swanwick Hall School
TC Fabrications Ripley Ltd
Swanwick Methodist Church
Terra Nova Equipment Ltd
Swanwick Parish Council
Testing & Analysis Ltd
Swanwick Parish Council & Tansley Parish Council
THC (Midlands) Ltd
Swanwick Petition
The Bear Inn & Hotel
Appendix A
The Employment Law Director Ltd
The Beattie Partnership
The Finch Consultancy Ltd
The Black Swan
The Guinness Trust - Midlands Area Office
The Bridge Inn
The Highways Agency
The British Wind Energy Association
The Imperial Decorating Co
The Certificate Framing Co
The Jessop Medical Practice
The Christian Conference Trust
The Kedleston Country House Hotel
The Church Commissioners for England
The Kings Head Inn
The Coal Authority
The Lawn Tennis Association
The Codnor Castle Preservation Society
The Marquis of Ormonde
The Cottage Private Day Nursery
The Mulberry Bush
The Curzon C of E Primary School
The National Autistic Society
The Curzon C of E Primary School
The National Forest Company
The David Sharp Studio
The National Probation Service
The Derbyshire Federation for Mental Health
The National Trust
The Dolls House Emporium
The Park Surgery
The Durham Ox
The Phone Shop
The Ecclesbourne School
The Planning Bureau Ltd
The Education Welfare Service
The Planning Design Practice
Appendix A
Trent Barton
The Playstation Private Day Nursery Ltd
Triple S Fabrications Ltd
The Showmen's Guild of Great Britain
Triples Fabs. Ltd
The Stroke Association
Trusley Parish Council
The Theatres Trust
Turley Associates
The Tors Community Sports Club
Turley Associates for Western Power
The Woodland Trust & Ancient Tree Forum
Turnditch & Windley Parish Council
Thomas Williams Recreation Ground
Turnditch C of E (Aided) Primary School
Thomsons
UIM Propertys Ltd
Time Designs
UK Coal
TMCS
UK Mediation Ltd
Topaz Computer Systems Ltd
UK Tyres Direct Ltd T/A Peak Signs
Trade Services (Belper)
Umbrella
Trade Web Solutions
United Castings Ltd
Trakotel
University of Derby
Transcare 28 Ltd
UPM Tillhill
Transition Belper
UPS
Traveller Law Reform Project
Vibrock Ltd
Tree Hugger & Son Tree Services
Victim Support Derbyshire (Amber Valley & Erewash)
Appendix A
Victors
Waystone
Vincent & Gorbing
Waystone Ltd
Voice (East Midlands BME Forum)
WBC Export Services Ltd
Voluntary Community Mental Health Support (Red Cross)
Webcare Ltd
W A Protheroe (Belper)
Weldex
W Beach & Son
Welfare Rights Service
Waingroves Community Association
Wessington Parish Council
Waingroves Community Woodland
West Hallam
Waingroves Drama Group
Weston Underwood Parish Council
Wheeldon Brothers
Waingroves Primary School
White Peak Distribution
Walker Products Ltd
White, Young and Green
Walkers Bingo Club
Whitehall Financial Independent Ltd
Walton & Co
Whiteheads Solicitors Ltd
Warwick Development (East Midlands) Ltd
Wigglesworth Planning Ltd
Warwick IC Systems Ltd
Wildlife Trust
Wass Management Ltd
William Bailey Ltd
Watchorn Memorial Methodist Church
William Davis Limited
Watchorn Tennis Club
Appendix A
William Davis Ltd
Wulf Investments Ltd
William Gilbert Endowed School
Your Move
Windley Village Preservation Trust
Your Move Attenborough & Co
Windley Woodland
Zycomm Electronics Ltd
Windows 2000 Ltd
Wirksworth Town Council
WJB Welding & Fabrication Ltd
Women's National Commission
Wood Lane Garage
Woodbridge Junior School
Woodland Trust
Woodlands
Woodville Sure Start
Woodward PDA Ltd
Word by Word Proofreading Services
Wrights Garage
Wrights Good Tyres
WTS Manufacturing Ltd
Persons invited to make representations
Mrs Enid Abbott
Ms Amanda Allen
Appendix A
Mr C Christopher Anderson
Ms Beverley Abbott
Beth Allen
Mrs S Abel
C M Allen
Mr Geoffrey Andrews
Mr D Abel
Chris Allen
Mr Martin Angold
Mr Andrew Ashton
Anderson
Mr Simon Askew
Mrs C Aspinall
Mr A Aspinall
Ms Katie Ablett
Mrs C Catherine Allen
Ms Louise Annable
Ms Nichola Abrehart
Mr & Mrs R Allsop
Ms Jennifer Annable
J Jean Adams
Mrs P Allsop
Mr Tyler Annable
Ms Sharon Adams
S P Allsop
Mr Jordan Annable
J E N Adams
M Allsop
Ms Donna Annable
Mr Steve Adams
Mr & Mrs William & Pamela Allsop
Ms Chantel Annable
Mr & Mrs Adeach
Mr M Michael Allsop
Ms Codie Annable
Ms J Jenny Aitken
Ms Gail Allsopp
Mr & Mrs Anthony
Mr Luke Aitkin
Mrs M Allsopp
Mr James Anthony
Miss T Allsopp
H Antonova
Mr & Mrs K Aldread
J M Jessey Allwood
Mr & Mrs M Mark Armes
Ms Susan Aldridge
L Leslie Allwood
Mr Neil Armstrong
Luke Allan-Smith
Mr Trevor Almey
Mr T Tim Arnold
Ms Olivia Allcock
Ms Jenny Almey
Ms W Winifred Arnold
L Alton
Mr P Peter Arnold
Mrs Vera Alldread
Ms S Sandra Alton
Ms Jill Arrowswell
R Alldread
Mrs Melissa Amey
Ms E Emma Ascott
J Alldread
Ms Vanessa Ancliff
Miss R C Asher Asher
Peter Alldread
Mrs E Evonne Anderson
R Ashton
R Atkin
Miss R Rosie Atkin
Ms M P Mary Atkin
Miss S Sarah Atkin
Miss Atkin
Mrs P Pauline Atkin
Mrs Atkin
Mr William Atkin
Mr Atkin
Kamel Akil
Mr S Scott Atkins
Mr S Stuart Atkins
Mrs C Carol Atkins
Mr & Mrs S L & E.M.C Atkinson
Dr Steven Atkinson
Heather Allcock
N Atkinson
D Atkinson
B B Atkinson
Mike Atkinson
Mr M Mark Attenborough
Those consulted at individual properties
Appendix A
A Bartlett
Mr Peter Attenborough
Mrs B Baker
Ms S Sara Austick
Ms Elaine Baker
Mrs Sarah Austin
Miss T L Baker
R W Austin
Mr / Mrs J / W Jon / Wendy Baldwin
Luke Axten
Mrs R Ball
Mr & Mrs Barker
D J Barton
MS Laura Barker
Mrs Betty Barton
Mr P Barker
Ms Josie Bate
Barker-Dix
Mr Richard Bacon
MS Lisa Ball
Mr Lambert Bacon
Mr Ken Ball
Mrs Peggy Bacon
Mr Keith Ballin
J Bacon
Ms Lynne Bamford
C Bacon
J & E Bamford
Mr M Bagan
K Bamford
Mr Mike Bagan
S Band
Mr & Mrs Bagguley
Mrs Elizabeth Bankes
M Bailey
Mr David Banks
Miss I E M Bateman
Mr S Steve Barlow
Mr N P M Bateman
Mr James Barlow
Mrs Janet Bateman
R & H Barnes
Mrs S M Bateman
A Barnes
Mrs Eileen Bates
Mr K Kenneth Barnsley
Ben & Nicola Barrass
Mr John Barratt
Mrs Barratt
Peter Bates
Mr Andrew Bates
J S Bates
Batters
Mr & Mrs Barratt
Tim / Julia Barratt / Todd
Ms Theresa Bailey
J E Bannister
M A Bailey
J W Bannister
B & M Bailey
M Banton
Mr A Bailey
K M Barber
Ms Pamela Bain
John Barber
Mr Anthony Baines
Diana Barcz
C Baines
S E & A Barham
Ms Baker
Mr Barker
D T Baker
Mr & Mrs Christine & Roy Barker
Ms Stephanie Barrett
J Beadell
Mr Ken Barrett
M Beadell
Mr M Barrett
Mr G Gerald Beake
Mr Pearce Barrett
Mr Andrew Barrett
Beard
Mrs D Beard
Duncan Barron
Caron Beardmore
Christopher Barry
Julie Beardsley
R D Bartlett
Mr W G Bax
P Baxendale
Mr Scott Beardsley
Mrs H L Beardsley
J W Beardsley
Jorge Beasley
M Beasley
Mr Alan Beastall
Mrs C Beaston
Corrina Beatson
Maureen Bennett
Mr M R Bennett
Malcolm Bennett
Mrs S Benniston
Tim Benson
Appendix A
Emily Bexon
Mrs J Black
D Bexon
Robyn Blackburn
Rose Bexon
Blackwell
Rose Bexon
Penny Blackwell
L Laura Bexon
Mrs Christine Blake
Mrs P F Benson
Natasha Bexton
Simon & Juliette Blake
Mr/Ms D / F Dave/Fay Benson/Couchman
Richard Biggin
Anna Bland
Leanne Biggs
Rosalind Bliss
Mr S Beaver
Sheila Bentley
Mr M Mike Beavis
J Bentley
F Beckett
Tony Bentnall
Lindsay Billsborrow
Mr George Blount
Natasha Bednall
Gary Beresford
Tom Bingham
Mr Jamie Blount
Mr J Beeby
John Beresford
Kelly Birch
Mrs C Blount
M Beeley
E K Beresford
B Birch
Mr I Ian Bell
Kate Berkin
Mrs W Birch
Mrs P Bell
Mr / Mrs B / J Bilbee
Mrs C Bestwick
Geoff Blissett
Blount
Mr &Mrs Boam
Mrs C A Boddington
Cllr G Graham Bell
Lisa Bestwick
Mr Ralph Birch
Mrs P Bell
Michelle Bestwick-Walters
Mrs J Jean Birks
Mr P Philip Boles
Dr Bell
Cameron Beswick
Mrs D Birks
Ms L Lynn Bollard
Steve Bell
Mary Bell
Ms C Caroline Bell
Erwin Bene
Mr & Mrs J G Bennett
John Beswick Steele
Mary Bishop
Boik
Sarah Bolt
Mr A Bettison
Mr & Mrs Bishop
K Kim Bond
Mrs L R Bettison
O Biss
Mr Ryan Bond
Mr / Mrs T M / D Bevan
Mr R J W Black
Mrs L Lyn Bond
Mr D David Bewick
Miss C Black
Mr L Laurence Bond
Appendix A
Mr Adam Bond
Richard Bott
Bradley
Mrs M Briers
Mr M Malcolm Bonnington
Ms B Beverley Bott
L Bradley
Mr R Robert Briggs
Ms A Alyson Bott-Stevenson
W Bradley
R Briggs
R Bonsall
Margaret Bonsall
Peter Bowden-Smith
Alan Bradley
Mrs Amie Briggs
Karen Bradley
P Briggs
Mr John Bonser
Mr A S AS Bowler
Mrs L J R Bonser
C Bowler
Miss Sophia Bonser
Ian Bowler
Nicola Bradshaw
Mrs Janine Bonser
Alan Bowley
Helen Braithwaite
Mr Paul Bonser
Mr & Mrs A P Bowley
Mr Derek Bonser
Jennifer Bown
William Bonser
F Finlay Boxall
Nicole Bonser
Mr M S Boot
Booth
Boxall
Scott and Lianne Boxall
Boxall
Mr M Malcolm Bradley
Mr J John Brassington
Brassington
John Briggs
Julie Briggs
Mrs P M Briggs
Mrs Briggs
Robert Briggs
Ms J Jill Brassington
Anna Bristow
Mr P Peter Brassington
Mark Britland
Colin Brassington
Mr & Mrs P & C E Bratt
Diane Broadhead
Mrs A E Broadhead
Dylan Booth
L Laila Boxall
Carl Brearley
Mrs J Broadhurst
Suzanne Bore
Mr & Mrs S, L, F, & L Boxall
M B Brennan
Mr & Mrs Brookes
Mr & Mrs D J Bore
Mr & Mrs J C & KJ Bore
Andy Bore
Keri Bretnall
Paula Brooks
Mr & Mrs N Boxall
Zoe Boyes
Samantha Brewer
Clifford Brooks
Mr D Bradbury
Sandra Brewster
Christine Brooks
Jez Borysiak
David & Pauline Bradbury
George Bostock
Bradbury
Ann Bridgeford
Valerie Broom
Mr & Mrs Bosworth
Bridget Braden
John Bridges
James Broome
C & S Bosworth
Polymnia Bradford
Elspeth Brien
M W Brougham
Cllr Alwyn Bridge
Mr W Brooks-Kinder
Mrs Marilyn Brown
Appendix A
Mrs S Sandra Bull
Mr David Brougham
A C Burton
Jonathan & Jemma Brown
Ms H Hellena Bull
Katie Brougham
Mrs Patricia Burton
Mr J Jonathan Brown
M Bull
Mrs V Brown
Beryl Bullman
S Brown
A W Bullman
David Brown
Peter Bullock
Ann Brougham
Burton
J Brougham
Mr T Trevor Bush
Olivia Broughton
Mrs G Busuttil
M A Broughton
Adam Busuttil
Mrs A Brown
Mr I Ian Bunting
Paul Brown
Fiona Bunting
Dennis Brown
Janet Butler
John Brown
S Stuart Butler
Mrs A Brown
E.J. Brown
Steven Bunting
L Butt
Mr I Brown
Lee Brown
T J & M Brown
R G Brown
Tom & Gillian Brown
R Rachel Brown
Laurie Brown
Mr D David Brown
Mrs H Brown
Mr G Graham Brown
C & S Brown / Barton
Brown
Mrs P Brown
Mrs H Helen Bunting
mr & Mrs C Butt
V Burgin
M Butt
M Burgoyne
G Butterfield
Caroline Burke
Marcella Buttery
Jo Burkinshaw
K Buttery
A Amanda Burley
Mrs Margaret Buxton
John Bryan
Paige Burley
Kim Buxton
Darren Burley
Buxton
C & M Buckland
Brown
Judith Buckley
Brown
J Buckley
Rokia Brown
Mick Buckley
Kevin Brown
Jim Bull
Nicola Burns
MS N Buxton
Ms Sally Burns
Neil Buxton
Olly Burrell
Buxton
Mr A Burston
Ms S Sharon Brown
Sidney and Monique Brown
Karina Bull
R Burt
Mr Stanley Buxton
S Sam Byard
Mr Anthony Burton
Mr R Richard Byard
Richard / Vanessa Bull
Christine Byard
Appendix A
Miss Lianne Capewell
John Chamberlain
Stephen Claridge
Mrs J Janice & Emily Byron
Mrs P A Capewell
C Chambers
Helen Claridge
Mr J R Byron
Mr & Mrs C & H Carman
G Chambers
Mr D David Clark
M Chambers
Mr N Niall Clark
L.J Cade
Stephen Carnelly
O I Calladine
Mrs B Brenda Carpenter
Ms J Jayne Calladine
Ms E Emma Carr
Ross & Emma Chambers
Rebecca Clark
Mr & Mrs Chandler
Alison Clark
W C Calladine
Lynda Carter
M Madeleine Chandler
Staphanie Clark
M Callaghan
Denise Carter
J Channell
Joseph Clark
Michael Callahaan
Carter
Denise Chapman
L Clark
Mr P J Philip John Carter
C P Chapman
Mrs J Clark
Claire Campbell
Mr & Mrs K Carter
Mrs B Charles
Christine Clark
Mark Campbell
J B Cartland
Miss A Chase
Paul T Clark
Janette Campbell
Alan Cartledge
Mr P Paul Callister
Campbell
Mrs E Campbell
Alison Chase
Alyx Clark
Mr K Cartledge
D Diane Cheetham
Linda Clark
S & P Cartwright
Ms P Cheetham
Mrs Janett Clark
Campbell
Gaynor Cauldwell
Trevor Childs
Peter Clark
Campbell
T & J Tom & Janice Caulfield
Childs
Ms M Melinda Clark
Mr A Campbell
Brian Caulton
Mr G Chill
Georgina Clarke
Ms D Donna Canlin
Gina Chadwick
Miss Susan Chinchen
Samantha Clarke
T Cann
David / Janine Chadwick
Mrs Y Capewell
Andy Chadwick
Mr / Ms J / D John / Diane Churchill
Mr Vincent Capewell
Louise Chamberlain
Ms D Dawn Churchill
Mr R Roger Capewell
M Chamberlain
Mr David Clapham
Richard Christian
G Clarke
Carol Clarke
Mrs N Clarke
Peter Clarke
Appendix A
M Colcioual
J Janet Clarke
Mr A Anthony Connor
Miss Helen Cooper
Miss Kirsty Conquest
J Cooper
Mr M Colclough
Ginette Clarke
M & S Colclough
Pat Clarke
Jonathan Cook
Chris & Griff Cooper & Ererett
David and Angela Cole
Susan Clarke
Mr P Paul Cook
Cope
Lorna Cole
Mrs Nicola / Kieran / Lauren Clarke
E Cook
A P Cope
Tracy Cook
D Cope
T O Cook
Mr S Steve Cope
V & L A Cooke / Inquieti
Mr & Mrs H Harold Cope
Jane Coleman
Ms Monique Clarke
M Coleman
Natalie Clarke
Mr / Mrs D / C David / Christine Colledge
Miss Jade Clay
David Colledge
Michelle / James Claypole / Throw
Clare Cooper
Chris Copeland
Becci Colledge
H Clemens
Mr P Paul Cooper
Mr & Mrs Corns
Mr T Tony Cooper
Claire Cottam
Mr & Mrs M Mark & Maxine Colledge
Mr & Mrs K & K Clements
Anthony Colledge
Mr Roy Clements
David / Christine Colledge
C Corinne Clemson
J Jonathon Clifford
Mr & Mrs P & L Phil & Louise Cooper
Mr J John Cotton
D Cooper
Mrs J Jean Coulson
Sally Cooper
Mr R Coulter
Kathleen Cooper
S Coulter
L Cooper
Mr Edward Cowey
Mr M Mike Collier
Collier
Mr & Mrs Clifford
Mrs B Brigitte Collier
Mr K Kevin Clifton
M Collins
D Clowes
M & C Collins
Ms S Coates
Rachel Collins
Mr A Cockayne
Michael Collins
I Cocker
Richard Collis
C Cohen
Jenny Collyer
Justin Cooper
Mrs S Cooper
Celia Cox
Mr G Geoff Cooper
Amy Cox
Mr J A Cooper
J Colombo
Mr M Matt Connell
Mr A Alan Cox
Mr & Mrs G Gordon Cooper
John & Leni Cooper
Mr & Mrs Coker
Geoff Cowlishaw
Mr D Cooper
Mr Matthew Cox
Mrs S Cox
Lindsey Cox
Molly Cox
Mrs Jean Crowshaw
Mr Brian Cummings
Appendix A
Mr N Nigel Davidson
Colin Daybell
Mr P A Davies
Diane Daybell
F W Cox
Christine Cummings
Katy Davies
Lee Cummings / Wheatley
A Davies
Mrs Glenda Dean
Mrs L Coxlead
William Deans
Jim Crabtree
D & E Dave & Elaine Cunnah
Davies
Rebecca Deans
Mrs N Nicola Crabtree
Mrs Jocelyne Cunningham
Mr T Davies
Gillian Deans
Mr J H John Cunningham
Mrs B Davies
Leah Deaton
P & J Cracknell
Phil & Jackie Cracknell
Russell Currins
Karen Davies
Jonathon Deaville
Ms K Kay Crago
Curtis
Mr T Davies
Mr Brian Deer
Craig
Richard/ Erica Cuthbert/Sommer
James John Davis
Sarah Delrosso
L G & C Davis
P Dempsey
Pete Dakin
B & H Davis
Anna Dempsey
Linda Dakin
Beth Louise Davis
Amy Dennis
Mr N Daley
P Davis
Jackie Dennis
Mr M Michael Dalton
Sheila Davis
Phil Cresswell
Mr / Mrs A Daddy
Mr & Mrs S Cresswell
Mr & Mrs Cresswell
E Crews
Ann Crisp
Mrs S Dennis
Robert Critchlow
Gilles Daniel
Graham Davison
Robert Derbyshire
S O Davy
Karen Devonport
Mrs Margaret Croft
Mr, Mrs and Miss P Daniel
P Croft
Dianne & Robert Darke
B Beverley Dawes
Mr / Mrs J John Devonport
Crombie
Mr Dasson
H Dawn
Karen Devonport
Ms Louise Cross
Laura Dauson
Ms J Jill Day
Mrs Patricia Dewis
T David
G & N Day
Mrs M Dexter
Christal David
T Day
M Diamond
Issy Davidson
T Day
Andy Dickenson
Thomas Cross
B Crossland
Mr C Colin Crowder
J A Crowfoot
R Dickerson
Appendix A
C East
Hannah Ellis
Kathy Eastwick
C Elmeel
Paul Eastwood
Mrs M Else
E Draper
Dickinson
R Draper
Mrs D G Gillian Dickinson
B Dilks
Mr R Ross Drenic
R B Dilks
Mr Peter Dring
Mr C Clifford Dobson
Mrs Fern Drummond
Mr R Eaton
R S Ely
Mr & Mrs Edgar
Mr & Mrs M & C Emery
Mrs A Emmas-Williams
Mr & Mrs Edmondson
Andrew Dodman
David Dryburgh
H R Emmas-Williams
S Stuart Edwards
Jan Dodsley
Mr David Dudek
Cllr C Chris Emmas-Williams
Mrs Egner
Mr P Dodson
Carol Dun
Roland & Sheila Emmas-Williams
Ian Elder
Neil Doherty
Joan Dungworth
T Tracy England
K Eley
R W Doleman
June Dunlop
Mr P Paul English
Sam Eley
Mr G Graeme Donald
E M Dunstan
J S Eratt
Clive Eley
Ms K Karen Donald
G Dunstan
Jamie Eratt
Jaya Eley
Mr N Dore
J Dunstan
J Erratt
Mrs A F Annette Eley
Mrs S Dore
M Dunstan
J S Erratt
B Elliott
Mr J Dore
Mr P Paul Durant
Duro
Mrs Y M Elliott
P Pat Ethelston
Mrs P Pamela Durose
Mr C Elliott
C & K Durose
Miss Sarah Elliott
Mr Trevor Durose
Mr B Brian Elliott
Mr B Bob Dossetter
S &M Evans
Mrs A H Dossetter
K Evans
Dr Alexander Dossetter
T Evans
May Douglas
A Evans
Liam Dwane
John & Pauline Elliott
Ian Douglas
Mrs S Everett
P R Dye
Mr Roger Elliott
David Dykes
T Elliott
Robert Eadsh
E Ellis
Mr M Michael Downes
Paul Ewings
Tracey Downing
Dr Una Doyle
Elaine Ewings
mrs P Ewins
Appendix A
D & B Fox
Mr P J Ewins
Laura Flemming
Simon Fogell
Ms A J Eyre
Ian & Rachel Flemming
P Fontana
R L S Eyre
Kathryn Fletcher
Dr
Mr & Mrs Eyre
B B Fletcher
Fox
Mr N D Norman Fox
Mrs Q Fontana
Francis
Andy Fookes
H Freeman
Kathy Fairweather
Mr T Terry Fletcher
Mrs M Forbes-Park
Mr Michael Frost
Ms T Tina Faloon
Janet & David Fletcher
A Farmer
Mr / Mrs A / D Fletcher
Brigid Farnan
L Fletcher
David Farrelly
Steven Fletcher
Mrs P Ford
Ron Ford
Ford
John Farrow
Mrs L Fletcher
J Farrow
R & K Fletcher & Bock
Stephen Fathers
Mr G Gary Flinn
Mr N Neil Fearenside
A Flint
Mr & Mrs Feeney
D Flint
Mrs D Frost
Shirley Forster
Miss Megan Frost
Barry Forster
C Fullwood
Roger Foster
Anglea Gallacher
Robert Foster
M & J Gallagher
Martin Foster
Andrew Fiddes
Miss K Kirsty Galvin
Ms K L Foulkes
Mike Ganley
R Ruth Fowler
Sandra & Roger Garner
Floob / Swift
Mr R Flood
Brian Field
Mrs R Flood
Mark & Michele Fowler
K Kyle Fowler
Mrs L Linda Garnett
Michelle Garratt
Mrs B Flounders
P Phoebe Fowler
Kevin Finn
J & R Flynn
Craig Finn
Claire Flynn
I Ian Fisher
R Foden
Mr & Mrs L Fitzgerald
Sally Fogell
M Fowlkes
Mr D G Galley
Revd Dr A Alan Flintham
Andrew Field
Mrs L Field
Christopher Frost
Forman
Mr Steven Foster
Viviane Ferris
Sarah Frost
Ms J Jacqui Garrett
Jean Garrett
Ms P Patricia Fox
Mrs S L Garton
Mrs J M Fox
Mr B Garton
Appendix A
Mrs K A Katie Gartside
German
Mrs Wendy Goddard
Anthony Gray
Mrs Gascoyne
Graeme German
Mr Derek Goodall
Helen Greasley
S Gascoyne
Paul Ghuman
Chelsey Goodall
Dr & Mrs R & M Gaunt
Jaspel Singh Ghuman
Jean Goodall
Pamela Greaves
Y Gay
Ms P Patricia Giaquinto
Philip Gedard
Mrs Julia Gibb
Colin & Emma Gooding
Sheila Geehan
Mr P Paul Gibbons
Liam Goodland
Nigel Gell
Mrs E Gibbs
Mrs M G Mary Grace Goona
Rebecca Green
Gell & Meanwell
M Gibbs
V Goona
P Green
Tim Gent
K Gilbert
Kathy Gorman
Pat Green
Jade Gent
Mandy Gile
Mr Lewis Gough
Roger Greenfield
Mrs S Gent
Peter Gill
K Gould
Karen Greenwood
Mr R Roy Gent
D Gill
J Grainger
Janis Gregory
J E & D Gill & Stewart
Mrs A Grainger
G Gregory
Maurice Gent
Mr R Rex Goodall
Mr & Mrs G Greaves
Mr & Mrs Green
Ruth Green
Mr P Peter George
Susan Gillway
C W George
Pete Giumall
Mrs S George
M Glenn
Kerry Grainger
Thomas George
Mr Jason Glennie
Emily Granger
Mr T Trevor Griffin
Mark George
J G Glew
Jennifer Grant
Mr P Peter Grimadell
Adrian Gloss
Jonathon and Julie Gras/Beadell
Mrs S Grimadell
B Gration
Ms R Rachael Grime
Tony Gration
Ms A Alison Grimley
Mrs M George
Miss T George
Mr & Mrs P J L Glover
K Kai George
Beryl & Ian Goadby
Mr D George
Mr Mark Goddard
Andrew Grainger
Andrew Green
Mr & Mrs S & JA Grainger
Louise & Andrew Gratton
Mr / Mrs L Gregory
Mr Eric Gregory
Aiden Grice
Edward Grimwood
Appendix A
Olivia Grimwood
Richard Hallam
Mr O Oliver Harding
Mr M Mark Harrison
H / R Hannah / Russell Hallam
Ms K Katrina Harding
Dawn Harrison
Mrs K L Kay Hallam Black
G T Hardstaff
Patrick Harrison
I J Grundy
P D Grundy
Gurl
Hallam-Gray / Gray
J Hardstaff
Mr & Mrs Harrison
Mr Christopher Hardstaff
W Wendy Harrison
A Guy
J Hamilton
Guy
Mr & Mrs Hammersley
David Hardwick
Tom /Gillian Harrop
Mr S Simon Hammond
Linda Hardy
Mr D L Harry
T J Hamp
D Hardy
J Hart
Mrs W A Hamson
Helen Hardy
Mrs V Hart
Mr S Hamson
Louise Hardy
Mr T Hart
David Hardy
Ms L Lorraine Hart
Mr & Mrs Hart
R Hachett
P Hakes
Mrs Hazel Haley
Mr R O Dick Hall
Angela Hall
Miss Deborah Hall
Jenny, Eric & Charlotte Hancock
Tony Hall
Mrs Margaret Hand
Keith Hardy
G F Hall
Mr T Tim Handbury
David Hardy
Lisa Hartley
Matthew Hartley
A Hall
Handley
P J Hardy
Mr & Mrs Hartshorn
John Hall
Mr P Peter Handley-Wright
J Hardy
Stephen Hall
Ms L Linda Handley-Wright
Mrs R A Harnan
D David Hann
R A Harnan
Howard Hall
Keeti Hannah
Ms W Wendy Harnan-Kajzer
A Angela Hall
Beryl Hannant
Mr M Harrington
Patricia Hall
Mr T Hanrahan
R Hallam
P G & C Hanson
Harris
M Hallam
Ms L Linda Harahan
Carol Harris
Murray Hallam
Mr D Harby
Jeff Harris
Linda Hartshorn
Mr G Glyn Hartshorne
Mr & Mrs P A Hall
Mr M Harvey
Peter Harvey
Mr & Mrs L & S Harvey
Mr J John Harrington
Debbie & Steve Harvey / Dawson
Gemma Haslam
Shelly Haslam
Mrs l Haslam
Mr P Haynes
Appendix A
D Hewitt
J Hill
D H & M F Hibbert
Mr P Hilton
R & S Haslam
Cliff Haynes
David Haslock
J Julie Hayward
Hibbert
David Haswell
Mr P Peter Hayward
Frazer Hicken
Ms Sarah Hatfield
Ms M Margaret Hinchcliffe
Ellie Hind
H H Haywood
Mrs D Hicklin
Kirstie Hind
Rachel Hatfield
Andrew Haywood
Mr Hicklin
J Jennifwe Hindell
Colin Havercroft
Andrea Haywood
Mr D David Hickton
Ben Hinds
Mr & Mrs D David Higginbotham
Ann Hinds
Mary Hawkins
Ms Alison Haywood
R Hawley
Stuart Haywood
Mr R Roger Higgins
S G Stuart Hinds
Mrs J Hawley
Stuart Haywood
Mr D Derek Hill
D Hinds
R Hawood
Andrea Haywood
Mr & Mrs Hill
Kay Hitchcock
M Hayes
L Lee Hazeldine
Mr T Tim Hill
Mrs Y Yvonne Hithersay
Jon Hayes
A Amy Hazeldine
Mr P A Hill
Mr J Jonathan Hodgkinson
Jon Hayes
Mr L Heaton
Mrs Dawn Hill
D Hodgkinson
J / S Jon / Sally Hayes
Mrs J A Heaven
Mr Matthew Hill
L / A Hodgkinson / Forrest
Sue Hayes
Henderson
` Hill
Mr & Mrs P / M Hodson
A Hayes
Mike Hendy
David Hill
Mr N T Hodson
Hayhoe
Miss R Hayhoe
Miss S Hayhoe
Mr P Paul Henshaw
Mr & Mrs S Henson
Mrs Dorothy Hill
Hill
Hogben
Mrs M Hogben
Pam Hesselden
Miss W J Hill
M Hogg
Hayhoe
Graham Hesselden
Mrs Emma Hill
Wendy Hogg
Hayhoe
David Hewett
R Hill
Charlotte Hogg
L Hewitt
I Hill
M P Hogg
Mr Hayhoe
Mrs S Hogg
Appendix A
Ms C Catherine Howe
Mr M Malcolm Hunt
Mrs F Holmes
Hogg
Mr K Holbrook
Paul Homes
Peter Howe
Ms E M Holden
Mary Homes
Mr F Holdroyd
Janet Honey
Mr R Richard Howe
Mrs G Hunt
Mr Frank Hunt
Bernadette Hunt
Mr K Howley
Mr J John Hunt
Miss H Hoyes
Mrs A Holdroyd
K Keith Hoofan
F & B D Hunt
Jennifer Hubbal
Keith Holes
Miss Skylen Hoolam Skylen Hoolam
Mr & Mrs Malcolm / Susan Hunter
E Emma Hubball
Barbara Holland
Pauline Hoolan
Mr Darren Hunter
Mr Mike Hubball
Mr J Jack Holland
Peter & Valerie Hopkins
A E Hunter
B Hubbard
Mr M Michael Holland
R Hopkins
Ms Dawn Hunter
Mr Neil Hudson
J Holland
Tessa Hopkins
Mr & Mrs F M Hurst
Lyn Hudson
Stuart Holliday
Mr Alan Hopkinson
Husbands
T / J Trevor / Jose Hudson
Mr Geoffrey Alan Hollingsworth
Chris Hopper
John Huskins
M Hudson-Green
D J Hollingworth
Horace Neville & Barbera Millward
Anna Horadczh
Gareth Hughes
Ms S Sue Huskins
N Hornsaw
Les Hughes
Ms A Hollis
Jane Hutchinson
Gill Holmes
Frances and Duncan Hutchinson
Julie and James Horsley
Mr L Hughes
Mr N Neil Holmes
D Hutchinson
Mr M Horsley
Elliott Hughs
A Agnes Holmes
Mr Duncan Hutchinson
J Horsley
Mrs Judith Hughs
Mr Anthony Horton
M & E Hulse
Mr M Mark Howard
Guy Humphreys
Mr J Joseph Howard
Hunt
M & C Howard
Gareth Hunt
Sue Howard
Jonathan Hunt
Claire Holmes
Gordon Hutchinson
Mrs M A Margaret Holmes
L Huthwaite
John Holmes
Lucia Iantosca
Mr & Mrs P Holmes
Mr D A Dudley Ibbett
D Dale Holmes
T Trevor Holmes
Mrs G Ibbett
Elvin Ibbotson
Appendix A
M Jeffries
Nigel Johnson
D B Jones
A Jeffries
D Johnson
Amanda Jones
Mrs L Jeffries
Mrs M Johnson
H Helen Jordan
C L Jeffries
Ms C Coral Jones
A Jordan
Mrs C Ingram
S Irving
James Isam
Ms H Helen Jackson
Ms J A Jenkins
Tina Jones
Mr David Jowett
Mr Jackson
Mr Jenkins
Mr & Mrs S & M Jones
J Jenkins
Robert & Ann Jones
Jennifer Jowett
Mr J John Jackson
Mr & Mrs G Joynes
Vickie Jackson
Dorcas & Chris Jennings
Mr M Mark Jones
J Jennings
Mr Paul Jones
Mr & Mrs R M Jepson
P Jones
Cllr Stuart Joynes
Mrs Jackson
Judkins
Mr Ian & Helen Jackson
Mr M Jackson
Charlotte Jerram
A Adrian & Alison Jones
Susan James
Mrs F Freda Kay
Mrs T Jewkins
Mr Simon Jones
Mr M W Johnson
Mrs R M Jones
M D Johnson
mrs B Jones
Sandra James
S A Keeling
Anita James
Mr E Edward James
Jeremy, Jasper & Freya James
M Maisie K
nighton
Jand D Keeling
P Kelly
Johnson
Mr & Mrs Jones
Michael Kelly
Mr D James
Miss Brenda Johnson
S Jones
Anne Kennedy
Bob Janes
Peter Johnson
T Jones
Jaspal Singh Ghuman
R Johnson
P Jones
Sara / Paula Jay / Browne
K Johnson
Jones
J & L Jeaves
Mrs P Johnson
Mr Gavin Kenning
R Kenning
Rebecca Kenny
Mrs J Jones
Mr F Francais Kenny
Mr I K Jeffery
Geraldine Johnson
A & D S Jeffery
Johnson
Mrs Lorraine Jeffrey
Celia Johnson
Stuart Jones
Stephen Kent
Mrs P Jones
Mrs K Kent
George Jones
Mr & Ms S/A Stephen/Andrea Kent/Smith
Appendix A
C & S Kerr/Davies
J E Kirk
S Kruczkowskil
Mrs J Kerry
Callum Kirk
Mr Micheal Kunica
Mr C Lawman
B & J Kyte
E M Lawrence
Mrs J Kyte
P Lawrence
Mr E D Kettlewell
Mr & Mrs B & S Kirk
Karen Lawler
Ben Kew
Emma Kirk
Mrs A Kiel
Brianna Kirk
Sally Lally
Ms B Brenda Lawrence
Mrs K Kerry Kiernan
Jennifer Kirk
Sarah Laman
Mr David Lea
David Killer
Mr S Sean Kinder
Mr Phillip Kirk
Alsastair Lamb
Mike Leahy
Mr B Brian Kirkland
A Lambert
Mrs I Iris Leam
Mrs R Kinder
Geoffrey Kirsopp
Mr L G A Lambert
Mr F Lean
T Kinder
G W, D A & N L Knight
B J Lambert
Mr & Ms D / Y David & Yvette
Leatherland/Hunt
Sam King
A R Knight
K Landeg
Alicia King
Ms T Theresa Knight
Neville & Margaret Lander
Dane King
J Jasmine Knighton
E K King
Mr S Scott Knighton
Anne Lane
Adele King
Ms L Lisa Knighton
P Peter Large
Shane King
Mrs B Knighton
Robert Large
Mr Jack Lee
Linda Lee
Mr J John Lander
Mr S Stephen Lee
Stephen Lee
Mr P Peter Lee
Mr G Gareth Lee
Tom King
Barbera Knoules
Mary King
R Knowles
Peter Large
Mr/Mrs/Mrs B / L / M Bob/Linda/Mary
Large/Burt
Kathleen Kinton
A Amy Knowles
Mr S Latham
Karen Kinton
Mr Ronnie & Jane Knowles
Mrs A Latham
Simon Lee
Mr David Lee
Mrs Pamela Lee
Andrew Lee
Karen & Tom Kinton
Thelma Knowlson
Janice Laven
A Kinton
S Kowalski
R Lavender
Alisha Kirk
Mr S Kruczkowski
John Lavender
Ebony Lee
Lees
Appendix A
Brian & Valerie Leeson
Emma Longdon
K Ludlam
Ms C Cynthia Maddock
S Longstaff
Mr K Ludlam
R Longstaff
Mr C Ludlam
Ms J Jane Maggs
Lexi Ludlam
Mr J John Maher
G R Lefevre
Madge
Mr & Mrs M Leggett
Shaun Lemmon
Mrs Dawn Lonsdale
C Lemmon
K Lonsdale
Master J W Ludlam
Mahon
Mr J Lemmon
Mr R Raymond Lesley
Jock Lewis
Dr Steven Lonsdale
Max Ludlam
Mr N Norman Loomes
D & M Ludlam
Malin
Mr Marl Lillywhite
Helen Lord
Mrs G Lineker
Peter James Lord
Kiera Ludlam
J Manan
C Lioyd
Graham Love
Stephen Lycitt
S Manan
Mark Little
Carol Love
Alwyn Lycitt
Mr Sydney Manchester
Daniel Lloyd
Kerry Lovell
Mr G Glynn Lydiate
Mrs T Mann
Mrs D Lomas
N & P Norman & Pam Lovelock
Mr Anthony Lynch
Mr J P Mann
K & R Lomas
Gregory Lowe
Kathleen Lynch
Pippa Mansel
G Lowe
Lorraine MacAlister
Ann Mansell
Lomas
Mrs J A Ludlam
P Pamela Makin
K R & R Kath Lomas
Sharon Lowe
Mr & Mrs Paul & wendy Lomax
John Lowe
G Long
Kim Lowe
Mr & Mrs G J E MacDonald
Mr B Markham
Martin Long
J W Lowett
Ms J Janet Macdonald
R, D & C Marksman
S M & J Long
Mr David Loydall
Mr & Mrs Y & P Machin
John Marooney
Dr M Martin Longbottom
Mr M Martin Lucas
Mr Bevis Mackie
Marriot / Wetton
L A Longbottom
Tamia Longdon
Sarah Lucey
Mr / Mrs R / J Roy / Jane Luckett
Mrs A Macdonald
Mr & Mrs Mallett
MacDonald
Phillip Marcett
Ms S Sarah Marchbank
Ms / Mr L / C Linda / Chris Macleod / Simcox
H Marriott
Mr A J Alan MacMaster
Colin Marriott
Appendix A
O Oscar Meakin
Jon Marriott
Mr Henry Masters
Mrs M McGowan
Paul Marsh
D Maxwell
Linda McGrath
Mr Marshall
Mr B Brian May
Darren McGrath
Ms N Nina Marshall
Mr S Simon May
C Meakin
Ms E Elizabeth Mears
Miss Amy Measures
Mrs A McGuinn
Mrs A Measures
Chelsea Marshall
May
Ms D Diane McHarg
M Mee
Richard Marshall
Mr and Mrs Maycock
H Holly McKeown
A S Marshall
Mr P Maycock
Mr Edward McLaughlin
Allen Marshall
J H Maycock
David Mc'Loughlin
Marshall
S Steven Mayes
Mc'Loughlin
Ms C Christine Mee
Nadia Meghet
Mr J R John Ronald Melrose
Ms M Mary Melton
L Layla Marshall
Aiden Mayes
Steve Marshall-Clarke
Sharon Mayes
K & S Marson
Gareth Mayes
Mr S Stuart Martin
Peter Mercer
R J Meads
John Messenger
Diane Meakin
G Godfrey Meynell
Mr Philip Samual McAleese
C Martin
Karen McBride
Ann Martin
Elaina McCabe
Jenny Martin
Lian McCabe
Mr Glenn Martin
B.P,R.E & J.T McMahon
D & C McNaught
Dr Alan Meakin
M Midgley
T Meakin
R Robert Miles
Jacob Meakin
Mr J John Milford
John Meakin
Mr S Miller
Meakin
K & L Miller
Meakin
Mrs A Miller
McCormick / Hatton
Gareth Martin
J McCulloch
Gary Martin
Mrs Eileen McCulloch
Richard Mason
Mr & Mrs B McDonald
Sylvia Mason
Mr Daniel Mc'Fall
Mr B Meakin
Mrs A Meakin
Mr Meakin
R Massey
Mr M Mark Mills
Robert Mills
Margaret McFarlane
Mr I Ian Meakin
Mr R Richard Massey
Millership
Mr J John McGill
N Mills
Mr and Mrs Millward
Appendix A
Valerie Elaine Milnes
C Morehen
Mr D Murfin
Miles and Stephanie Milton- Barber
D Morgan
Peter Murfitt
M Mindes
David Morgan
Molly Murfitt
Newton
M Newton
John Newton
Simon Newton
N A Mirfin
Mrs A Anne Morgan
J Murray
Hollie Newton
Yasmin Mitchel
Sarah Morgan
Sam Mustafa
Alison Mitchell
Bryan Morley
Weronika Myska
D C Newton
Mrs J C Newton
Mr Ian Mitchell
Mrs Morrell
Jula Myska
M J Mitchell
J G Morris
Natalia Myska
Chris Mitchell
Mike Morris
Helen Nahas
Dave & Gina Mlejnecky
Susan Morris
A Nakin
Mr R Roger Newton
Mrs S A Shirley Newton
Newton
Mrs M L Nicholls
Paul Mohan
Mr Mosley
Mr C Clive Narrainen
Jon Mole
Mrs S J Mosley
A M & C Naylor
I / J Ian / Jo Molyneux
Mr I R Ian Mosley
B & L Lynne Naylor
J Monsheimer
Mrs H A Moss
J Naylor
Ms A Annie Nichols
H Nichols
Annie Nichols
R Noble
K P Monsheimer
Moss
Cody Needham
Mr M Montague
R Moss
Kahla Needham
Mrs J Moody
John Mottat
A Ashley Needham
Chloe & Brendan Moore
C Mottershead
Master B Needham
B Moore
R & L Moulder
A D & M A Neville
W Moore
Mr Matthew Mozley
Tony / Margaret Neville
Mr Richard Moore
Ms N Natasha Muir
Newbold / Parker
Charlotte Noke
Ronald Noon
H Hazel Noon
Ms Ida Noon
D David Noon
J Noon
J Noon
Ben Moore
Ms Lyndsey Mulholland
Mr John Newton
Mr & Mrs Norchedge
Mr Dean Moran
Maureen Murfin
Mr D Newton
Appendix A
A Anouska Norman
Craig Orson
Giles Paling
W North
G A C Orton
Valerie Palmer
J North
B & O Osborne
Alison Palmer
G Palmer
T Parkin
Jean North
Colin Osborne
Scott / Michael Palmer / Wood
Charlie Parkin
Phillip O Brien
J W Osborne
Claire O’Connell
J W Osbourne
Chris Oakley
A Oscroft
Mrs P Parkin
Ms L Louise Parkin
Mr James O'Brian
Philip O'Brien
Ms C Catherine Palombo
Claire Parkin
A & J Parker
David Parkin
W & G Parker
Pat Parkin
J M Parker
Chris Parkin
Elisabeth Parker
Roy & Pauline Parnell
Vince Parker
Suzanne Parnell
Mr Keith Otterwell
Mrs Sharon Otterwell
Mr / Mrs B / C Ben / Claire O'Connell
Mr Karl Ottewell
Mr Chris O'Connor
Mr J Ottewell
B Oderm
Mr David Ottewell
Tracey O'Donnell
S R & D R Owen
Gill O'Hagan
Mrs Victoria Oxley
Mr C Christopher Parker
George Parkes
J & S Parkin
J Parkin
Oldknow
Stephen & Debbie Parrans
David & Elaine Parrish
Mrs Sarah Parrott
Parry
Pace
S Parkin
Mr & Mrs T Olney
L Pacey
Mr J John O'Melia
Richard Pacey
Emma Parry
Mr Leigh Parry
S Parkin
Graham Partridge
Q G Parkin
S O'Neil
G V Gail Packard
Mr R Parwell
C M Parkin
Steve O'Neill
N Packham
Ms J Jean Pass
Hazel Parkin
Debbie O'Neill
Bob and Ann Paget
Jean and John Pass
Mrs J Parkin
Mr R Robert Oniel
B B Painter
Uri Patel
Ms L Louise Parkin
Orme
John Painter
Andrew Patterson
Kat Parkin
C T Orridge
Mr P Palfreyman
Mr A Andrew Patterson III
T Parkin
Amy Paulson
Appendix A
K Katie Peggs
R Porter
L Linda Pilkington
Mrs Susan Paxton
Pepper
Mr / Mrs D / L David / Linda Postlethwaite
Mr & Mrs John Pilkington
Mr Bob Paxton
Joe Pepper
Darren Potter
D Pinion
Mr J John Payne
Peter Pepper
John & Brenda Potts
Michael & Kay Pirnie
J Payne
Kimberely Percivel
Norman S Perkins
Ellen Pitt
John Potts
John Perks
Grace Pitt
A J Perrins
Plant
T & M Perry
Rex Ploughman
Mr Colin Payne
J Pounder
Maureen Payne
Wendy Pountain
L Payne
David Pountain
Darren Payne
Sarah Powell
Petts
Mr R Plowman
M J Payne
A D Powell
Mrs V M Phelps
Mr G Geo
Geoff Payne
Mrs J E Plowright
Power / Bell
Phillips
J Plowright
Bob Poxon
Mr M Matt Peacock
Mr R Phillips
Luke Plowright
Raymond, Lesley, Richard Poyner
G Peacock
Dean Phillips
Mrs E Plumb
Ms J Jayne Pearce
D Dean Phillips
Mrs C Pollicott
Mr Jim Pears
E Phillips
Richard Pollicott
John Pearson
R Phillips-Forsyth
Sarah Pollicott
Dave Peck
H Phipps
Victoria Peel
V Pickard
Stefan Pozylo
Jayne Preece
Mike Press
Katie Press
Graeme
Grahame Pegg
Rachel Pollicott
Ms G Gemma Pollock
Katie Press
Joan Ponney
P Preston
Keith Ponney
Gerald Price
M Poole
Doug Price
Sandra Poplar
Joyce Price
Julie Portedus
Mr R J Price
Susan Picker
Mrs J P Pickering
Ann Pegg
Mrs M Monica Pickering
D A Derek Pegg
T & D M Pierce
M Maria Peggs
Mr R Richard Pike
C Priestley
Appendix A
Mr & Mrs Rawson
Mr Ken Richards
A Rawson
Mrs J H Richards
T Rawson
Mr and Mrs N Richards
J Rayson
K Richardson
Dr M Malcolm Read
J / S Jo / Steve Richardson
Mrs Tina Pursglove
Mr & Mrs A & D Priestley
Mr & Mrs L & J Leslie & June Pursglove
Jody Prince
Mr Dominic Purvis
J A Prince
Dr R Rosemary Pykett
Mrs K karolyn Prince
mr & Mrs E Pynegar
Eric Pritchett
N Proctor
Mrs J Quarmby
Mr D David Proctor
Rev Robert Quarton
L Protheroe
T Quinn
Brian Reaney
Mr & Mrs A J Richardson
Kelly Redfern
J Richardson
Mrs L Riches
Avis Redfern
Mr / Mrs P / E Peter / Elaine Riches
Mr & Mrs T & E Redshaw
Shelley Prow
Mrs J Radford
M Riches
Mr R W Reed
Dr K Kate & Terry Pudney & Conn
Sandra Rainsford
Mr & Mrs A Richford
Sarah Reeves
Mr & Mrs Pulford
Danny Rainsford
Ashley Riley
Jane Reid
Mr T D Pulford
Margaret Ralph
G & S Riley
Mr and Mrs Revill
Gillian Pullan
K M Ramsay
Alan Riley
Lisa Revill
Pullan
Daman Ranby
S Riley
Mr R Reynalds
Mr T Thomas Pullen
Laura-Jane Ranby
Mike & June Riley
Tom and Victoria Rhodes
Brenda Punter
K & S Ratcliffe
Mr John Riley
Ms E Elizabeth Rice
David Punter
Mr and Mrs M & R Ratcliffe
Dawn & Scott Ratcliffe
Mr N Riley
A Rich
Purcell
Mr and Mrs Riley
Mr A Aubrey Ratcliffe
Richards
Terry Purcell
Katherie Robb
Lynne Rathbone
Mrs Jean Richards
C Purdey
Mrs L Roberston
Rathbone
Paul Richards
Mrs Heather Purdy
Kathryn Roberts
V Virat Raut
Mr David M Richards
Mary Ann Ravnkilde
Mr S P Richards
E Purley
Mrs A Alison Purser
P R Roberts
Janet Robertson
Appendix A
Mr S Scott Ryder
Peter/Katie Robertson/Borsley
J Rodgers
Mr J John Roulston
Mr Malcolm Robins
N Rodgers
S A Anne Round
Mrs D Robinson
Craig Rodgers
Glyn Round
Ian Robinson
Philip Roe
K Rowbotham
Wayne Robinson
Andrew Roe
S Rowe
Alex Robinson
Steve Roebuck
Kay Rye
Ms C Catherine Rylance
Mrs Smantha Sabel
D Sage
G Saheed
Rowe
Stuart Saint
Mr W Robinson
Mr Stephen Rogers
Teresa Rowe
Brogan / James Salmon
Peter Robinson
J Rogers
Helen Robinson
Mr Kevin Rogers
Rowe
Ms B Becky Rowell
Chris Rowland
Esther Robinson
Sophia Romanos
Jill Robinson
Boris Romanos
D Daniel Robinson
A G Romanos
Robinson
Jono Romanos
Robinson
P P Romanos
Donna Robinson
Christine Rooth
Ian Salt
P J Rowley
Richard Salt
Ron Rowsell
J Salt
Nick Rowton
Laura Salt
Mr D David Ruck
Mr C Cliff Roper
I Robinson
Mr Philip Rose
L H Russell
A A Russell
Leslie Robinson
Mr / Mrs W / I Robinson
Rebecca Rochford
Mrs Susan Salt
Cheryl Rowland
Ms J Jane Rowton
Robinson
Mr R A Salmon
Mr K Sampson
Samson
Mr & Mrs A J & D Sandell
Sanders
Geoffery Rotherham
RT Rutherford
D Sanders Fox
Mavis Ryalls
Mrs E Sanders Fox
Anthony Ryalls
J Sanderson
Mr & Mrs K & P Sansam
Geoffery Rotherham
Amye Rothwell
Adrian Rochford
Mrs Andrea Rothwell
J Rockley
Mr James Rothwell
Mrs S Ryalls
Jon Sargisson
Ryder
Mr & Mrs K Rode
A Rothwell
Chris Sargisson
Appendix A
Ms S Diane Sharpe
Mary Saunders
Roy Severn
Maggie Shields
David Shaw
Norman Saunders
Brenda Severn
Alan Shiels
Bronia Shaw
David Saxby
B Severn
Mr T Terry Shiels
Richard Shaw
I Saxton
B Brenda Severn
Mr B Shilling
Lisa Shaw
Philip & Samantha Saxton
M Severn
Herbert & Brenda Shipley
Mr S Steve Shaw
Oliver Schafer
Severn
Mr W Shipley
Michael Shaw
Sam Scott
S Severn
M Margaret Shipp
Shane Shaw
C & T Scott
E Severn
Nichola Shore
Mr M Matthew Shaw
Craig Scott
S Severn
Ian Short
L Lucy Shaw
Ms J Jacqui Scott
T Severn
Mr P Paul Severn
Susan Siddal
Mrs D & T J Shaw
Mrs A Scrivens
Megan Siddans
Janet Severn
Mr K Shaw
Miss Karen Scrivens
Alan Siddon
L Severn
Shaw
Mr G E Scrivens
Mr John Sidsaff
R Roy Severn
Mr J J Shawing
Kathy Shand
Mr Russell Sheffield
F & P Seals
Mrs L Sidsaff
Mr Adam Searson
Sidsaff
Mrs K Sharman
Sheldon
Mr & Mrs Searson
Rose Simmons
Mrs D Sharman
Mr Andrew Sheldon
Miss D Sharman
R Shelley
Mr T K Sharman
Mr C Shelton
Jody Seaton
Steve Simms
Ant Seaton
Freddie Simon
Mr & Mrs Selby
Charlie Simon
Nicola Sharp
Gemma Shelton
Pauline Sharp
S Shelton
David Sharp
L Shelton
Jamie Sharp
Glynn Shepherd
Mr and Mrs S W Shieldon
Alan Selby
Graham Simons
J M R Selby
Ms Mary Simpson
Selby
Mr & Mrs D David Selvey
Christine Simpson
P Simpson
Lynn Skinner
Appendix A
Mrs L A Smith
K Keith Simpson
Mrs J M June Smith
Robert Skinner
Mr A H Simpson
Jamie Smith
Christine Smith
Mrs J Jane Smith
Gladys Smith
Mr & Mrs I & T Ian Smith
Gill Slack
S Simpson
Mrs G M Gillian Slack
T H Simpson
Mr & Mrs Peter Smith
Smith
Julie Slack
Mr Simpson
A E Smith
J Smith
Mr James Smith
Edna Smith
Steve Slack
June Sims
Mr E Slater
Mr G Geoff Sims
Lynne Smith
Ben Smith
Slater
Connor Sinclair
Richard Smith
Mrs J Joan Smith
Ms S Sharon Slater
John Sinclair
Mr Michael Smith
Miss L K Smith
D Slater
Ms A Alexandra Sinfield
Graham Smith
P & G Smith
Angela Smith
J & I Smith
D Smith
David Smith
Mr I Ian Sleeman
Mr J Joshua Sinfield
Smadley
S Sisson
Beverley Sisson
Smalley
Mrs B A Smith
Mr P Sisson
Mr C T Colin T Smallwood
Mrs Tracy Skelton
Mrs Klara Smedley
Tracey Smith
Cllr P Paul Smith
Martin And Annette Smith
A Smith
D R Smith
Skelton
Mary Smedley
Linda & Dennis Smith
M & K Smith
K Skelton
Claire Smedley
Mrs Carol Smitham
Mr T Troy Smith
S L Skelton
S Smedley
Mr Darren Smitham
Mr K Keith Smith
C Craig Skelton
Miss Susan Smedley
Mr David Smitham
Smith
S Stephen Skelton
J Smile
M G Smithhson
Mr P Smith
I Skelton
George & Joyce Smith
Ms L Smithirst
Richard and Angela Smith
Mrs L Skevington
Smith
Ellen Smith-Marooney
D Debbie Smith
Joanne and Keith Skevington
Andrew Smith
Julie Smithson
David Smith
Sean Smyth
Appendix A
Mr P J Spencer
Georgia Stirland
S Steele
Ms M Smythe
Jesse Spencer
Stirland
Jonathan Steele
Mr P Snape
M & J Spencer & Bonsall
Vanessa Stirland
P Steeples
Soar
Deborah Spendlove
Mr & Mrs R Spink
M Stocks
Nigel Stephens
J & H Soar
Mr & Mrs Stollyfield
Philip & Lorraine Spowage
N Stephenson
D Srlvely
Stephanie Stephenson
Mr R Staley
P Stephenson
Mrs J Staley
T Stephenson
David and Sharon Soar
Stone
Lesley Soar
Mrs R Stone
Erica Sommer
Ellen Stone
R E Southworth
David Stone
Geraldine Stamp
Dom Sterland
A Sparham
Mr and Mrs Stone
Mr Alan Stanbrook
Mrs J Stevens
P & A Sparham
J Stone
D Stanchard-Roberts
Josephine Stevens
Louise Standing
C Stevenson
Lynda Staniforth
Mr & Mrs J Stevenson
Ms K Karen Sparkes
D Stone
Michael Spence
Mrs R Stone
Joe Spence
Stone
Mr Peter Stanton
Mr P Paul Stevenson
Mr J S John Stanway
M Stevenson
P Stapleford
A Stevenson
J Stevenson
Martin Spence
H Stone-Payne
Ann Spence
Mr & Mrs Storer
Robert Spence
Storer
Philip Stapleton
Joe Spence
Julie Stevenson
Mr &Mrs Storey
Mr Mathew Stapley
Jinny Spence
Miss V J Stevenson
Ina & Terry Stradins / Hirst
Mr K Stevenson
H Strafford
Donald Statham
Alison Spencer
S & D Statham
K & S Sue Spencer
Richard Stewert
C Strange
Stephanie Statham
Kevin R Spencer
D & T Daniel & Tia Stirland
Stratulis
Peter Staton
J Spencer
P A Stirland
P A Steed
S L Street
Ms E Edwina Strike
Appendix A
Stephen Taylor
Linda Thompson
Taylor
E Thompson
Elisa Taylor-Smith
Douglas Thomson
M Tadman
Lauryn Stuart
N Tanley
S Stubbs
Sandra Tapper
J Stubbs
Taylor-Wilde
Miss G Thorley
Ms Margaret Tarlton
Mr C Clive Sturgess
Mr Martin Taylor-Wilde
R Thornhill
Margaret Ann Tarlton
Stuzaker
A & L Suddes
Miss Julia Tarlton
Rachel Tennick
J D Sumpter
G Tatham
Mr P Peter Sumpton
Robert Tatler
Mr M Sutcliffe
Marion Taulbut
Lola Thornhill
Mrs S Thomas
Rob Thornhill
M Thomas
Christine Thornhill
C Thornton
Mr W D David Thomas
Paul & Linda Thorp
A Thomas
Chris Sutton
Mr & Mrs Taylor
Thorpe
A Thomas
Allan Sutton
Richard & Jan Taylor
Cllr Valerie Thorpe
Mr L Thomas
R Swain
Lesley Taylor
P Thorpe
Mr A Andrew Thomas
G F Swain
K & J Taylor
Coral Thorpe
Marcus & Tracey Thomas
Swango
Simon Taylor
J.A Thorpe
Mr & Mrs R Thompson
Mr P Peter Sweeting
Mr Stephen Ralph Taylor
Mr T S Terrence Samual Thorpe
Richard Thompson
Miss Ashleigh Swift
Mr S Stuart Taylor
Mr Richard Thorpe
Eileen Thompson
Mrs G Swift
Amanda Taylor
C Thorpe
Robin Thompson
P Pam Swift
Taylor
Mr & Mrs N Taylor
Mr & Mrs G Throw
Emma Thompson
G & R Swindell
M W Thums
Jill Taylor
A Thompson
Taylor
Mr Russell Thompson
Taylor
Mrs Sheila Thompson
David Taylor
K Thompson
P Sykes
Johnathon Tillion
Symons
R Timms
I Symons
D Symons
Ms W Wanda Tobolkiewicz
Mr J Toft
Appendix A
Valerie Trevan
Joanna Utting
Sara Troman
Julie Vallance
Dudley Troth
Ian Vallans
D & J Trueman
Katerina Van Rensberg
Mr J Truman
J & E Vardy
N Trussell
Mr W Varley
Timura Trussell
Mrs E Varley
Ms J June Tomlinson
Mrs B Walker
P G Tomlinson
Mrs D Dorothy Walker
Mrs Gaye Tomlinson
Mr J John Walker
Mr Mark Tomlinson
Mr / Mrs C / A Chris / Ann Walker
Cllr M Martin Tomlinson
Ms L Laura Walker
Mr P Paul Tomlinson
Mr C Chris Walker
Mr Ken Tomlinson
Mr George Thomas Jeffery Walker
Mr Martin Trussell
Rita Varnam
Lorriane Tomlinson
Phil Walker
Mr Jake Trussell
Mr M Melvin Tomlinson
Rev Keith Vernon
D J Village
Joanna Wall
Nicola Tuck
R J Tomlinson
A Village
Mr A Andrew Wall
Mrs Village
Mrs Helen Wall
Mr & Mrs D David Village
Mr I Wall
Ken Tucker
Miss S Sherrie Tomlinson
Mr & Mrs J R Tunstall
Sharon Tomney
A Annie Turnbull
Glen Tomney
Ronald & Wendy Wagg
Mrs Barbara Waller
Richard Wain
Mr Alexander Waller
Mrs Lisa Turner
James Tomney
A W Turner
Joshua Toms
Amanda Wain
John Wallis
Julian Turner
M Tomsett
Ms J Judith Walker
R & A Walter
S Walker
Mr & Mrs Walters
Mr P L Walker
Mr & Mrs J Walters
Turner
Mr / Mrs M / P Maurice & Pat Tooze
Donna Turner
Stephen Toplis
G Turner
Victoria Topping
Mr & Mrs Townsend
Beverley Walker
John Walters
L Walker
N Walters
C Walters
Annette Turner
Tony Travis
Mr R Richard Turner
A C Travis
Mr & Mrs Lisa / Daniel Turton
Mrs A M Walker
Elaine Walters
Walker
Gwen Tresidder
Mr M Malcolm Turvey
M Warburton
J A Walker
Appendix A
Jenny Ward
Chris Waters
M Webster
David Ward
Mr D G Watkins
H Webster
P Watson
Emma Webster
Chris Ward
Mrs S Watson
George Wedd
Ann Ward
A Watson
Mike Weightman
M J June Ward
G Watson
Helen Weir
C Ward
R & J Watson
Darren Weir
K J Ward
Mr & Mrs Watson
Mrs P Ward
K M Watson
Brian Weldin
Neil Ward
Mr Robert Watson
S M Wells
K Wardle
B M Watson
Mr & Mrs Andy & Susan Wells
J Wardle
R A Watson
Mrs Jane Wells
Mr Wareham
R Watson
Mr Christopher Wells
Mrs A Wareham
L Watson
Nicholas Wes
Edmund Warriner
I Watson
J Weston
M Warrington
Paul Watson
G Weston
M Matt Waterfall
Susan Watson
T Weston
D W Waterfall
John Weaver
Mr Andrew Weston
Mr / Mrs C H / P Waterfall
Weaving
Mrs M Westwood
Brian & Wendy Wetmore
Mrs J Ward
Mr & Mrs A Whawell
Doreen & Des Wheatley
Mr Nathan Wheatley
Mr S Stuart Wheatley
Carol Wheatley
Mr Adrian Welch
M & E Wheatley
Wheeler
Gerry Charles Whelon
Jenny Whitaker
Peter & Dorothy Whitaker
White
Mrs P White
S Sophie White
E & A White
M & R White
Jonny White
Sarah Weston
White
Mark Waterfall
Mr A Alan Web
Mrs Maria Weston
Mr & Mrs D R White
Jane & Graham Waterfall & Davies
Alan Webb
Mr Steven Weston
Julie Webster
Mrs M Margaret Weston
Jenny Weston
White
C West-Oram
Lisa White
Martin White
Mrs Y Yvonne Waters
Denise Waters
Ms S Sue Webster
Janet Wignall
Mr G Graham White
Appendix A
M Wingfield
Celia Winkworth
Dawn Woolis
C K Winson
B & J Woollacott
Ms D Donna Wilber
John White
Caitlin Wildsmith
Paul Whitebrook
Winson
Mr & Mrs A J Woolley
Beverley Withers
Mr Stuart Woolley
P Wilkinson
Master L Whitehead
Willers
Judith Whitehead
J / V Wood
Isobel Tamar Woolley
Matt & Maria Wood
Jethro Woolley
E Willgoose
S Whitehead
E Willgoose
Miss C Whitehead
M & J Wood
Mrs J Judith Woolley
Samantha Wood
Mr & Mrs B & G Bob & Gina Woolley
Julie Wood
J & J E Woolley
Elizabeth Williams
Keiran Whitehead
Harvey Williams
Joyce Whiting
Daniel Williams
Samantha Whittaker
Mrs M Maria Wood
Mrs Kerry Worley
Mrs J L Williams
M Whittaker
Michael Whittall
A Amanda Whitworth
Mrs C Chris Whysall
Marie & Keith Whysall
Chris Wood
D Worley
Rob Wood
K Worley
S Wood
Miss A Ania Worthington
Mrs J M Jennifer M Wood
Mr / Mrs D & V Worthington / Mills
Mr A Alexander Wood
Ms J Julie Wozniczka
Ms J L Josephine Williams
Mark Williams
Mr R S Williams
Ian Willis
Mr K Wibberley
Wilson
Mr J Wickstead
Wilson
C J Wood
Mrs S Wickstead
Mr M Wilson
M & N Wigens
Miss N Nicola Wilson
Peter Wigglesworth
Mr John Wiltshire
Mrs D Wigley
M & J Wiltshire
Mrs D Wigley
Mr H Winfield
R Wigley
Mrs Judith Wing
Wragg
M Wood
K Wray
Jim Woodburn
Vanda Wright
Mr E Woode
M Wright
G N Garrick Woodruff
Mr C Colin Wright
Wendy Woodward
Mr Paul Wright
A Woodward
Adam Wright
Woodward
A & J Wright
Arthur Wright
C Wright
Mr Pete Wright
Mr Thomas Wright
Fay Wright
Mrs Leanne Wright
Mr George Wright
Ms J Jenny Wyatt
R T Wycherley
Julie Wyer
Tom Wyke
J & I Yarnell
Margaret Yates
Philip & Sheila Yendle
R Young
Mr A S Young
S Young
Mr P Zimmerman
Appendix A

Local Plan Part 1 Pre-Submission Core Strategy Regulation 19

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