PAULINE LATHAM OBE MP

PAULINE LATHAM OBE MP
Working hard for Mid Derbyshire
11
HOUSE
OF COMMONS
LONDON
SWIA
OAA
Mr julian Townsend
Executive Director (Operations)
Development Management
The Community Planning Team
Amber Valley Borough Council
Town Hall
Ripley
Derbyshire
DES 3BT
Friday, 5th September 2014
Our ref: PL/SHB
AMBER VALLEY CORE STRATEGY CONSULTATION STREET (AVBC/200S/00SO),
AVBC/2013/0007),
BULLSMOOR/CHERRY HOUSE FARM (ABVC/2011/0016
&
POTTERYFARM, BELPER(AVBC/200S/0230)
I would like to make representation
highlighted
BELPER DEVELOPMENTS, DERWENT
in relation to the above proposed development areas
in the recently revised Amber Valley Core Strategy.
large number of my constituents
copies of the correspondence
regarding
this matter and consequently
that I have received.
Planning Inspector at the appropriate
I have been contacted by a
I am attaching
I will be sending the originals to the
time. You will see from the enclosures the concerns
that residents have, however, in addition to these I would like to highlight other issues that
have been raised in relation to the 'soundness' of the Core Strategy. These are summarised
below:
Derwent Valley Mills World Heritage Site, Tourism and Wildlife
The proposed development
of 450 houses is wholly within the Derwent Valley Mills
World Heritage Site buffer zone which, if approved, would set a precedent for future
developments
historic
within the DVMWHS buffer zone. This contradicts
environment
as expressed in Planning Policy Statement
planning for the
5 and Local Plan
Policy EN29.
Il
l!]
Mrs Pauline Latham OBE MP - Parliamentary Office - Tel: 02072197110
Constituency Office - The Old Station, Station Road, Spondon, Derby DE2l 7NE Tel: 01332676679
I!l ... Email: pauline.latham.mpwparliament.ukTwitter:@pauline_lathamFacebook:facebook.com/pau1ine.latham.31
www.paulinelatham.co.uk
The
proposed
(housing)
development
and therefore
against development
would
would
not
be against
in the countryside
The Pottery Farm site was originally
published
in 2011.
This would
o
o
be within
the
existing
built
framework
Local Plan Policies H3 and HS and also
Policy EN1.
considered
The key constraints
in the Options
for Housing
at that time were:
be in the DVMWHS buffer
zone and the impact
that this would
have on the Outstanding
Universal Value of the World Heritage Site.
The significant
that
impact
Growth
development
could
have on the
surrounding
highway network.
The
Pottery
proposed
Farm development
in
constraints
2011
and
in relation
the proposed
the Pottery
it
has been
is now
considered
in scale from
that
the
to the impact on the surrounding
Bullsmoor
whole than the one originally
would
of its World Heritage
site
and this will
proposed
that
could
highway
and Cherry House Farm developments
Farm development
These developments
reduced
originally
address
network.
any
However,
are contiguous
in fact be a larger
with
development
as a
in 2011.
reduce the unique characteristics
Status, ie the industrial
setting
within
of Belper that is a part
a green landscape,
its
"arrested urbanisation".
o
This runs against
which
Core Strategy
6.4 Safeguarding
Key Amber Valley Assets,
". .include the Derwent Valley Mills World Heritage Site and its defined
buffer zone'.
The Hill Top Farm (a piece of land contiguous
applied
for
planning
permission
for
to the new proposed
70 homes.
The planning
strategic
was turned
sites)
down,
appealed and dismissed.
o
The Inspector's
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 Site's key values... ':
It should
be noted that
parts of the Pottery Farm site are visible
Farm and Dalley Farm, which
DVMWHS Management
are listed
within
Crossroads
the area on the
Plan. The site is also visible from, Spencer Road, Marsh Lane,
Crich Lane, a large area of Whitemoor,
to the roads that directly
from the viewpoint
as key properties
from
the Windmill
back onto it. It impacts
of about half of the town.
area, Farnah Green, in addition
on the stated unique characteristic
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."
These developments
Council
sites would
the Core Strategy's
Objective
directly
Strategic
contradict
Objectives,
three
of Amber
Valley
Borough
namely:
7
"To protect and enhance the environmental quality and tocsl distinctiveness of
spaces and places in the Borough in relation to landscapes and heritage, including,
but not limited to, the Derwent Valley Mills World Heritage Site and the Special
Landscape Area. "
o
o
Parts of the Pottery
Farm site are visible
Farm, which
are listed
Management
Plan.
The whole
of these
Site Buffer Zone.
Key Amber
as key properties
sites sit within
Assets,
which
within
the Derwent
This is also mentioned
Valley
from
Crossroads
the
Farm and Dalley
area on the
Valley
Mills World
in Core Strategy
DVMWHS
Heritage
6.4 : Safeguarding
".Jnctude the Derwent Valley Mills World
Heritage Site and its defined buffer zone'
Objective
8
"Toprotect, maintain, restore, enhance and create areas of nature conservation and
woodland in the environment, with a focus upon enhancing wildlife corridors and
networks of habitats, preventing further fragmentation and extending the
connectivity of habitats. "
o
The whole of these sites are currently
o
Most of the fields have boundaries
o
The space is crossed
o
Through
wildlife
Objective
its
corridor
by longstanding
by several natural
uninterrupted
Greenfield.
and woodland.
springs.
connection
and a continuous
hedgerow
habitat
to
the
Belper
Parks,
it provides
network.
9
"To ensure that a network of easily accessible and high quality open spaces, parks,
recreational areas,
green infrastructure and cultural facilities is maintained and
enhanced in the Borough. "
a
This
o
space
is
recreational
used
by
a high
Children
o
Dog walkers.
o
Walkers and runners.
Horse Riders.
o
Cyclists.
o
Visitors
o
The whole
not
of these
only
and
associated
with
falls
there
sites sit within
show
thriving
area relating
the
is an area
first
This is a critical
of
to Belper's
site
medieval
settlement.
Valley
it is also
ridge
Records
and
as a
Mills World
Heritage
Pottery
Medieval
and
furrow
dating
Farm
an area
back
of
historical
that
to
could
12th and
up to Sandbed
Park and Manor, which
be
13th
Lane as a
fell within
a larger
Frith.
issue for the town's
and visitors
the Derwent
DVMWH
the area of Bullsmoor
area known as Duffield
SS5, which
groups
facility.
within
Belper's
century
tourism
user
to Belper
Site Buffer Zone, a cultural
importance
different
going to and from Belper School and Pottery School.
o
area
of
area and green infrastructure:
o
This
number
to the town.
economy,
which
It runs directly
is increasingly
against
dependent
Core Strategy
6.11
on
Policy
The strategy for regeneration in 8e/per is to promote it as a
states that"
tourist attraction."
Flooding
Coppice
has
Brook has the highest
become
more
regular
since
Whitemoor
Lane etc towards
for surface
water
rainfall,
this
sites on the other
they include
risk rating
the
side of Kilbourne
regarding
development
previously
Rd would
causes
around
of John
effect
and flooding
Q'Gaunts
and at times
The proposed
this effect
drainage
Pottery
Agency
system)
letter
of heavy
development
many times
and even if
they would
not be able
Farm/Bullsmoor/Cherry
Please also refer to Mr Large's
Way,
have acted as a slow soak away
flooding.
multiply
SuDS ponds (sustainable
springs.
the Environment
have a different
Brook
to cope due to the fact that the hillside
is full of natural
expanding
and concrete
the Coppice
in proposals
from
Heage. Land would
but tarmac
overwhelms
flood
enclosed
dated
House Farm
21
st
August
this matter.
Sewage
The existing
capacity
proposed
sewage and surface
due to the
development
to a potential
new
housing
would
health hazard.
water system
that
potentially
must already
has already
been
cause an overload
be working
built
over
beyond
recent
its original
years.
on the sewage drains
The
and lead
Highways,
Schools and Public Services
The Core Strategy
fails to address
roads, which would
be severely
at Bullsmoor /Cherry
If adopted,
•
negatively
these two sites would
Kilbourne
impacted
issues within
by either
Belper,
of the proposed
specifically
strategic
sites
House Farm and Pottery Farm.
the roads, emptying
•
the road infrastructure
add a total of 450 houses,
onto Belper's
Roads, at completely
so an estimated
inappropriate
900 vehicles
to
locations:
Road on either side of Pottery Infant School.
Kilbourne
Road onto
the
roundabout
that
is within
100
metres
of the
entrance
to Belper Senior School.
•
Kilbourne
Road via Sand bed Lane, the junction
•
Via Parks Road, which
empties
is on the brow of a blind hill.
onto Bargate Road past the main children's
area for the Parks Estate and then where
congested,
of which
or back onto Sandbed
- Gibfield
recreation
Lane into town which
Lane (see above) past another
is horribly
children's
recreation
area.
•
This is going to negatively
•
Openwoodgate
•
Nottingham
•
Park's Estate, Holbrook
•
Holbrook
•
Kilbourne
impact
and Whitemoor
the whole of West and South Belper:
estates via John O'Gaunts
Way and Over Lane.
and Spencer Roads directly.
and Bargate, via Sand bed Lane, Parks Road and Bargate Road.
via Killis Lane.
damage
Road has seen
and subsidence
a huge
increase
to the road.
in traffic
which
has caused
The Water Board is currently
structural
looking
into this
as repairs are required.
•
Vehicle
access into the centre
of Belper is already
difficult
and there
is gross lack of
parking.
•
All traffic
heading
out of the town centre to the A38
•
The local schools
are full
space and facilities
•
The medical
available
I would
on school
centres
detailing
Kilbourne
no spaces
available
and due to limited
are already
over-subscribed.
There
is currently
no NHS dentist
in Belper at present.
information
surgery
with
sites are unable to expand.
like to also refer you to the enclosed
also has included
a vet's
to capacity
letter
from
Mr P J Spencer
that the roads have been a cause for concern
information
in 2007
Road leading
whereby
he submitted
but it was not approved
into Belper.
an application
dated 24th August
since 1998.
to change
due to the fact that
Mr Spencer
his house into
it was on the busy
Proposed
Numbers
<Information
exceed
Amber
Valley's
Proposed
Requirements
and
Derby
HMA
provided by a resident)
Amber Valley Build .v. Own Need
Amber Valley Derby
South
otal
Derbys
-'----,......Stated '11 - '28 Need
--% of Total Need
7395
16388
9605
22%
49%
29%
Stated' 11 - '28 Capacity
8586
10987
12341
31914
Outstanding
+ 119 1
- 540 1
+ 2 73 6
1- 14 74
0
0
10987
12341
Need
(Capacity-Need)
Proposed Increase
Proposed
1+ 1474
Capacity
10060
Proportionate
(each
Option +
area
takes
Outstanding
a
%
of
22%
of +
the1474=324
49%
of +
1474=722
33388
-
1+ 1474
29%
33388
+-------i
of
1474=428
+1474
Need based on its Own
Need)
•
Overbuilding:
Amber Valley is already planning
to build 1,191 homes more than it
needs to support the total need for the Derby HMA.
•
If Amber Valley is to pick up a proportionate
stated need, it would only be 324 homes.
the need for additional
additional
allocation
based on its own
This figure is probably achievable without
strategic housing land.
Actual Numbers Added
Amber Valley Need
--17395
Planned Extra Capacity
1+1 191
Proposed Increase
Total
1474
1-+0-0-6-0----------------------<
1
Completed,
~---------------
committed,
8395
allocated and proposed
Outstanding
Additional
requirement
1(10060 - 8395)
Strategic Sites
r
1665
12860
Over-allocation in additiona'j'2860 - 1665)
1195 (42%)
strategic sites
Why do the additional
seems most unlikely
than 40%.
strategic
sites add 1195 (42%) more houses than actual need? It
that strategic
sites will under-deliver
on expected
capacity by more
A further
local resident
has also produced
a set of figures
which show the total
in Belper has risen from 16,960 in 1991 to 23,417 today. However, the population
Valley had risen by 3.652
population
people.
This
means that
of Amber
64 per cent of the
increase in the Borough.
Inward and Outward
Migration
to Belper
I would like to refer you to the contents
of the enclosed letter from Or Andrew Francis dated
17th July
indicating
migration
has increased. This theory challenges
Brownfield
Belper has taken
population
that
inward
migration
to
Belper
has
decreased
whereas
outward
the need for such large developments.
Sites
Consideration
should
be given in the first
e.g. Butterly Engineering
and American
instance
to possible
alternative
brownfield
sites
Adventure.
Public Meeting
There was not sufficient
relation to the proposed
opportunity
for
members
of the
public
to make comments
changes to the Core Strategy at the AVBC meeting
in
as many people
were not allowed access.
In
conclusion
developments
therefore,
I would
on Bullsmoor/Cherry
like
to
strongly
Yours sincerely,
OO-..vJ:....o
brownfield
to appear for the oral part of the examination.
could please keep me informed
Lo.1~
PAULlNE LATHAM OBE MP
that
the
proposed
House Farm and Pottery Farm in Belper are not included
in the amended AVBC Core Strategy and that alternative
I would be willing
recommend
regarding
sites are found.
I would be grateful
all matters in relation to these developments.
if you