Response to the changes to the Core Strategy Local Plan Part 1

Not sound on the basis that the numbers being worked to are considerably
over and above factual projected need.
Additional HMA Need
Amber Valley Borough Council are already planning to overbuild by 1,191 homes
against the Boroughs stated need for 2011 2028, to support the total need for
the Derby HMA.
How can it be objective that Amber Valley is also expected pick up all of the
outstanding Derby HMA need of 1,474 homes.
Derby City and South Derbyshire District Councils have refused to increase their
capacity; why cant Amber Valley also refuse.
If Amber Valley were to pick up a proportionate additional allocation based on its
own stated need (total HMA need = 33,388 AV need = 7395), it would only be
22% of the outstanding HMA need of 1474 homes, ie 324. This figure is probably
achievable without the need for additional strategic housing land.
If Amber Valley does pick up its own need + existing planned overbuild +
outstanding Derby HMA = 10060 homes.
Completed, committed, allocated and existing proposals = 7533.
The shortfall between these two = 1665 homes.
The additional strategic sites = 2860 homes. This is 1195 (72%) more than actual
need. Why?

Land North of Denby
Why are AVBC suggesting that all of the land north of Denby should be allocated to
the outstanding need for Derby HMA, when it is more than needed (Site = 1800.
Derby outstanding need = 1474)
Why isnt the extra 326 being allocated against the Amber Valley need?

Not sound on the basis that the numbers are not fact / evidence based or
objectively assessed
Projected Numbers for Amber Valley
The overall numbers for Amber Valley have been queried since responses were
first asked for in 2012, and factual evidence has still not been produced that
supports the numbers as being based on evidence, and therefore an objectively
assessed need.
In the initial Preferred Growth Strategy document, workforce increase due to
economic growth was predicted to be around 0.2% by the ONS, but against this,
Amber Valley set a target of 10%.
In 2013, the figures used to calculate housing need were changed to follow the
Derby HMA Strategic Housing Market Assessment Update Final Report July 2013,
prepared by GL Hearn Limited. This report showed that workforce increase due to
economic growth was predicted to be 2.8%, but the target that continues to be
used by Amber Valley is 10%.
No additional evidence is provided in this current draft, to support this massive
mis-match between what the Hearn document forecasts for economic growth and
what appears to be simply a stated Council ambition.
On this basis alone, the strategy cannot show an evidence based, objectively
assessed need, and the requirement for additional strategic sites is not proven.

Brownfield Sites
It seems both remarkable and unlikely that the Council have been unable to
identify more than one brownfield site in its proposals for additional strategic sites,
when there are many through the Borough, eg:
o Butterly Engineering
o Stevensons Dyeworks
o American Adventure

5 year Supply
It seems illogical to focus the 5 year supply on large strategic sites, when they are the
ones that require additional infrastructure, are likely to meet with most opposition
through planning and are the most difficult to identify.
Not sound as the opportunity for the local community to participate was
curtailed both by the Council acting unconstitutionally by barring members of
the public from the Council meeting where the Proposed Changes were voted
on the very short timescale allowed for consultation following the vote.
Repsonses specific to Pottery Farm (SLHAA Ref AVBC/2008/0230) and
Bullsmoor / Cherry House Farm (SLHAA Ref AVBC/2011/0016 & AVBC/2013/0007)

Not sound on the basis that facts that are considered in some parts of the
Proposed Changes have been ignored when considering these sites.
Constraints
Why is it that the Council has noted the constraints of
o The capacity of the A38 to take additional traffic
o The setting of Keddleston Hall Historic Park and Garden
o The setting of Mackworth Conservation Area
o The scope for any further expansion of educational facilities at Ecclesbourne
School
But has failed to take account of the similar issues in Belper:
o The capacity of the A609 to take additional traffic.
o The setting of the Derwent Valley Mills World Heritage Site
o The scope for any further expansion of the educational facilities at Belper
School and Pottery School.

Not sound on the basis that the facts about the location of these sites are
being obscured by the way they stated
Logic Being Applied
The Pottery Farm site was originally considered in the Options for Housing Growth
published in 2011. The key constraints at that time were:
o Its inclusion in the DVMWHS buffer zone and the impact that the development
could have on the Outstanding Universal Value of the World Heritage Site.
o The significant impact that development could have on the surrounding highway
network.
As the Pottery Farm development has been reduced in scale from that proposed in
2011, it is now considered that the site could address any constraints in relation to
the impact on the surrounding highway network.
This logic completely ignores the fact that Bullsmoor and Cherry House Farm are
contiguous with the Pottery Farm development and this will actually be a larger
development as a whole than the one proposed, in 2011.

Not sound on the basis that it contains no infrastructure delivery planning to
accommodate additional traffic, additional pressure on schools or additional
pressure on medical services
Traffic
The Core Strategy fails to address the road infrastructure issues within Belper,
specifically roads, which would be severely negatively impacted by either of the
proposed strategic sites at Bullsmoor / Cherry House Farm, and Pottery Farm.
It is no longer feasible to take a piecemeal approach to infrastructure planning,
where each housing development is studied and justified individually. The Core
Strategy needs to include a whole term assessment of the total impact on
infrastructure, if all of the sites identified on the SHLAA were to be adopted.
This is also a critical issue for the towns economy, which is increasingly
dependent on tourism and visitors to the town. It runs directly against Core
Strategy 6.11 Policy SS5, which states that The strategy for regeneration in
Belper is to promote it as a tourist attraction..
If adopted, these two sites would add a total of 450 houses, so an estimated 900
vehicles to the roads, emptying onto Belpers Roads, at completely inappropriate
locations:
o Kilbourne Road on either side of Pottery Infant School.
o Kilbourne Road onto the roundabout that is within 100 metres of the entrance
to Belper Senior School.
o Kilbourne Road via Sandbed Lane, the junction of which is on the brow of a
blind hill.
o Via Parks Road, which empties onto Bargate Road past the main childrens
recreation area for the Parks Estate and then where Gibfield Lane into town
which is horribly congested, or back onto Sandbed Lane (see above) past
another childrens recreation area.
This is going to negatively impact the whole of West and South Belper:
o Openwoodgate and Whitemoor estates via John OGaunts Way and Over Lane.
o Nottingham and Spencer Roads directly.
o Parks Estate, Holbrook and Bargate, via Sandbed Lane, Parks Road and
Bargate Road.
o Holbrook via Killis Lane.
o All traffic heading out of the town centre to the A38.

Not sound on the basis that it directly negatively impacts the preferred
economic strategy for Belper.
World Heritage Status
This development would reduce the unique characteristic of Belper that is a part
of its World Heritage Status, ie the industrial setting within a green landscape, its
arrested urbanisation.
o This runs against Core Strategy 6.4 Safeguarding Key Amber Valley Assets,
which ..include the Derwent Valley Mills World Heritage Site and its defined
buffer zone
Hill Top Farm (a piece of land contiguous to the new proposed strategic sites)
applied for planning permission for 70 homes. The planning was turned down,
appealed and dismissed.
o The Inspectors report on the appeal noted that ..incremental loss of the
surviving landscape setting will undermine one of the significant physical
attributes of one of the World Heritage Sites key values.
Parts of the Pottery Farm site are visible from Crossroads Farm and Dalley Farm,
which are listed as key properties within the area on the DVMWHS Management
Plan.
The site is also visible from, Spencer Road, Marsh Lane, Crich Lane, much of
Whitemoor, the Windmill area, Farnah Green, as well as the roads that directly
back onto it: it impacts on the stated unique characteristic, from the viewpoint of
about 1/2 of the town.
o This runs against Core Strategy 10.4, Policy E4, which states that
Development proposals that will have an unacceptable impact on landscape
character (and) visual amenity.will not be permitted.