avbc local plan response - amber valley borough … local plan – march 2017 chapter 3 spatial...

Making a Difference for Amber Valley

AMBER VALLEY BOROUGH LOCAL PLAN – DRAFT LOCAL PLAN CONSULTATION RESPONSE FORM

Please return your completed form to arrive no later than 4:30pm on Friday 28 April 2017 to: The Local Plan Team, Amber Valley Borough Council, Town Hall, Market Place, Ripley, Derbyshire DE5 3BT or to [email protected]

Your Details:-

Title

First Name

Surname

Job Title (if relevant)

Organisation Denby Footpaths Group

Property Name / Number

Street

Locality

Town

Post Code

Telephone Number

E-mail Address

Agent Details:

Agent’s Title

Agent’s First Name

Agent’s Surname

Job Title

Company

Property Name / Number

Street

Locality

Town

Post Code

Telephone Number

E-mail Address

DLP0386


Data Protection

Please note that your submitted comments will be used in the plan process for the lifetime of the Local Plan in accordance with the Data Protection Act 1998. Your response cannot be treated as confidential as they will be available for public inspection and may also be made available to Derby City Council and South Derbyshire District Council in the preparation of their Local Plan. Please note that the number of comments submitted is anticipated to be high and therefore it will not be possible to acknowledge receipt of or respond to your representation. QUESTIONS Please answer the questions that are relevant to what you are interested in; you do not need to answer all of the questions. AMBER VALLEY BOROUGH LOCAL PLAN DRAFT LOCAL PLAN – MARCH 2017 Chapter 3 Spatial Portrait for Amber Valley Please give your comments quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary. Chapter 4 Spatial Vision for Amber Valley Please give your comments quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary

No comments

4.3 Inclusion of pedestrian and cycling links is welcome in the vision. However, bridleways are not

included in the statement yet form important linkages. Bridleway provision should be included in the

vision and plan as a whole.

4.5 Landscape and areas feeding into the Derwent Valley Mills World Heritage Site should be considered

in the vision and the impact of development in such areas on the surrounding landscape character

considered.

4.8 The vision of protection and enhancement of buildings of architectural or historic importance is not

met in Land North of Denby when considering the impact on Park Hall Grade 2* listed building.

4.10 Bridleways should be included in this vision statement.


Chapter 5 Strategic Objectives Please give your comments stating which objective(s) they refer to and state what (if any) changes you consider are necessary Chapter 6 Spatial Strategy Policies Policy SS1 Presumption In Favour Of Sustainable Development Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary Policy SS2 Housing Land Provision & Distribution Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary

5.1.6) Much of the natural environment that residents currently enjoy in Denby falls in the development

site Land North of Denby and will be lost. Development here will not lead to cohesion of the community

or promote equality. The development will essentially be detached from Denby's many settlement areas

and form a community of its own.

5.1.7) This objective regarding protection of local distinctiveness of spaces and places...in relation to

landscapes and heritage is not met for Land North of Denby. The objective of enhancing environmental

quality rests with successful remediation of the tar pits as a precursor to development.

5.1.8) This objective cannot be met with deletion of greenbelt (SS10) resulting in the loss of woodland,

habitats and wildlife corridors.

No comments

6.2.9 states that a minimum of 7395 dwellings are to be provided by AVBC. Following review this figure

remains the same and is supported in 6.2.15.

6.2.20 states a provision of a minimum of a further 1982 dwellings to meet the target. However, the

additional sites proposed deliver 3916 dwellings, equating to 1134 over and above the proven need.

How can this figure be justified if there is no demand and why are developments over and above the

target requirement being promoted? The need for an additional 1900 dwellings and mixed use

provision resulting from deletion of greenbelt isn't proven and therefore not fully justifiable as a need

other than as a financial incentive to a developer to take on site Land North of Denby. (6.10.8) No

exceptional circumstance can be claimed if proven need can be met without implementing SS10

greenbelt deletion.

Appendix 1 shows that the 5 year supply to March 2022 is already 512 over and above the target

required.

6.2.25. ‘exceptional circumstances’ cannot be demonstrated to justify amending the Green Belt

boundary, having regard to the purposes of Green Belt as set out in the NPPF for Land North of Denby

since need can be met without any deletion.

6.2.28 as comments for 6.2.25


Policy SS3 Settlement Hierarchy Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary Policy SS4 Business & Industrial Land Provision & Distribution Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

Policy SS5 Other Locations To Support Economic Growth Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy SS6 Development In Town Centres Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy SS7 Primary Shopping Frontages Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

6.4.7 "However, taking into account land that has already come forward for new business and industrial

development between 1 April 2011 and 31 March 2016 (2.73 ha)" This figure cannot be correct as 5.4ha

of land have recently been developed at H L Plastics for a warehouse extension. (Resulting in loss of

greenbelt). Transfer of operations associated with this site from Cotes Park also leaves that land free for

industrial land provision.

6.4.15" Together with land already developed since 2011 (2.73 ha)" comment as for 6.4.7

Denby Pottery development potential is 17.82ha for business (and some identified retail) use but does

not seem to be included as part of the local plan calculations.

6.3.3 Denby Village should be classed as 'other villages and settlements' as is the case for Denby

Common. It does not share the same facilities and services that Denby Bottles/Rawson Green does to be

classified in the same way as a 'key village'.

No comments

No comments


Policy SS8 Development On The Edge Of Or Outside Town Centres Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy SS9 Green Belt Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

6.9.2 ‘exceptional circumstances’ are cited in this paragraph whereas SS9 cites 'very special'

circumstances.

This is not consistent use of terminology and the plan should cite which classification of circumstances

are correct to apply.

Appendix 1 Scoping Report: Changes as part of the Sustainability Appraisal Report suggest a word

change from 'exceptional' to 'very special' but do not make any distinction as to what meets/constitutes

each term or clearly indicate why the downgrade/reclassification is required or justified.


Policy SS10 Amendment To The Green Belt Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

6.10.8

Deletion of green belt and commercial viability should be considered as mutually exclusive events and

not seen as dependant on each other.

This should not set a precedent for developers of other sites to use at a later date to demonstrate

'exceptional circumstances' to result in financial gain.

Comments made for Policy SS2 demonstrate that housing need can be met without additional provision

as a result of green belt deletion.

"The promoter has referred in particular to the costs of remediating the tar pits, as well as the

improvements that would be required to existing transport infrastructure to address the additional

traffic movements generated by new development, including the provision of a new junction on to the

A38, which the promoter considers to be an essential element of any necessary improvements." Should

the word 'improvements' read 'development' ?

6.10.11

"- whilst the proposals would result in a narrowing of the gap between Denby/Kilburn and the edge of

the urban area of Belper to the west, the provision of a link road between a new A38 junction and the

A609 could provide a strong defensible boundary,". This is only a physical boundary and does not give

the visual boundary that green belt offers and secures for the landscape and vistas from outlying areas

including Street Lane, Horsley Woodhouse, Openwoodgate, Holbrook and Bargate. There is further

visual impact to parts of Denby to the south of the proposal. Attempts to minimise the loss of visual

impact will be limited. This physical boundary does not address the east/west impact on Street Lane and

Openwoodgate merging, the east/south meeting of Street Lane and Denby or the western merging with

Holbrook.

"the proposals would result in only limited encroachment into the countryside, primarily to the north,

where much of the land has been subject to opencasting of coal and although this land has been

restored, it is not of high environmental quality." This statement regarding environmental quality is

debatable since the area includes ancient woodland and sites recognised for their biodiversity. It is in

conflict with statements in para 8.3.6 of the Draft Sustainability Appraisal Report.

6.10.12 'Would' is used throughout this paragraph. Paragraph 5.8.12 of the Draft Sustainability Appraisal

report uses 'could' in reference to the same conditions. This is not a consistent use of language and

causes ambiguity between the two reports. E.g. "...release of additional land in the Green Belt to the

north of Denby could support the remediation..." (SA)"... the proposals would enable the remediation..."

(LP)

6.10.14 Whilst "The area proposed to be deleted from the Green Belt (76 hectares) represents less than

1% of the total area of land currently designated as Green Belt in Amber Valley (8650 hectares)", this is

significant when looking at the Denby site as it makes up for more than 30% of the total area and a

significant loss to Denby Parish as a whole.


Policy SS11 Countryside Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

Chapter 7 Growth Site Policies

Policy HGS1 Housing Growth Sites Please give your comments on the content of the policy and supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy HGS2 Cotes Park, Birchwood Lane, Somercotes Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary

Policy HGS3 Amber Valley Rugby Club, Lower Somercotes Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS4 Somercotes Hill, Somercotes Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS5 Belper Lane, Belper Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS6 Bullsmoor, Kilbourne Road, Belper Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary

No comments

No comments

No comments

No comments

No comments

No comments

No comments


Policy HGS7 Newlands/Taylor Lane, Heanor Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS8 Whysall Street, Heanor, Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS9 Hall Road, Langley Mill Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS10 Asher Lane Business Park (North), Ripley Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS11 Asher Lane Business Park (South), Ripley Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS12 Butterley Hill, Ripley Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS13 Nottingham Road/Codnor Gate, Ripley Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS14 Radbourne Lane (North), Mackworth Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary

No comments

No comments

No comments

No comments

No comments

No comments

No comments

No comments


Policy HGS15 Radbourne Lane (South), Mackworth Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS16 The Common, Crich Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS17 Derby Road, Duffield Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary Policy HGS18 Land north of Denby Please give your comments on the content of the policy, supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary to the site boundary

No comments

No comments

No comments

a) the remediation of the tar pits must be done before any housing is built and should be included as a

condition of development not as a later agreement.

c) infrastructure improvements are also needed on the B61709 Derby Rd. The site will not just serve

Belper, it has a much wider impact. Improvements at junctions with and on Derby Rd are essential

before housing is built on the site.

d) financial contribution for secondary school provision should be limited to John Flamstead Community

School rather than the wider term 'in the locality' used in the policy.

e) 'other community facilities' should be specifically identified in the policy.

f) there is more than one disused transport route on the site. Both need to be protected. The map used

in appendix 3 and referenced in IN2 is incorrect in its portrayal of the disused transport route. (see

comments in IN2). The phrasing 'as a potential multi-user route for pedestrians and cyclists' implies that

this will not necessarily happen as part of the development yet is essential. Again, there is no mention of

horse riders. It would seem that AVBC need to seek clarification of use of terminology when referring to

the status of public rights of way from Derbyshire County Council Highways Dept.

h) this paragraph is welcomed as an inclusion in policy. Since the Core Strategy, much work has been

done to already enhance public rights of way in Land North of Denby and protection offered as policy is

noted.


Policy EGS1 Economic Growth Sites Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Chapter 8 Housing Policies

Policy H1 Housing Development Within Urban Areas & Key Villages Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy H2 Housing Development Within Other Villages & Settlements Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy H3 Housing Development Outside Settlements Please give your comments on the content on the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy H4 Housing Types, Mix & Choice Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

The figures calculated should be reviewed in line with comments made for SS4

8.1.1 please note our comments for 6.3.3 : Denby Village should be classed as 'other villages and

settlements' as is the case for Denby Common. It does not share the same facilities and services that

Denby Bottles/Rawson Green does to be classified in the same way as a 'key village'.

Policy: Denby Village should not be included in the policy as a key village

8.2.1 please note our comments for 6.3.3 : Denby Village should be classed as 'other villages and

settlements' as is the case for Denby Common. It does not share the same facilities and services that

Denby Bottles/Rawson Green does to be classified in the same way as a 'Key Village'.

Policy : Denby Village should be included as an Other Village & settlement

No comments

No comments


Policy H5 Affordable Housing Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy H6 Viability Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

Policy H7 Self-Build & Custom Build Dwellings Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy H8 Gypsies, Travellers & Travelling Showpeople Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Chapter 9 Economic Development Policies

Policy ED1 East Mill/North Mill, Belper Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

8.6.3 "Whilst the viability of development will be a material planning consideration, the primary

consideration remains with the Development Plan and where viability issues are such that the policy

requirements of the Development Plan cannot being fully complied with, there is a presumption against

approving the proposal".

This policy will be fully tested in the case of HGS18

8.6.4 "Additionally, lack of viability alone will not be sufficient to justify granting planning permission

with reduced on and off site contributions and/or affordable housing provision. It must also be shown

that the development coming forward with reduced Section 106 contributions will still help achieve the

aims of the Development Plan".

This is a key statement in consideration of HGS18

The above two statements are not adequately reflected in the policy wording.

No comments

No comments

No comments


Policy ED2 West Mill, Belper Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED3 Derwent Street, Belper Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED4 Development Within Existing Business & Industrial Areas Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED5 Other Business & Industrial Development Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED6 Rural Employment Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

The Proposals Map used for Denby is misleading. It does not show the extent of the H L Plastics site or

include Denby Pottery.

This should only be permitted where there is no loss of greenbelt and a phrase to the effect included in

the policy.

No comments


Policy ED7 Relocation Of Non-Conforming Uses Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED8 District & Local Centres Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED9 Local Shopping Facilities Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED10 Loss of Retail Uses Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED11 Restaurants and Cafés (A3), Drinking Establishments (A4) and Hot Food Takeaways (A5) Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy ED12 Tourism Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

No comments

No comments

No comments

No comments


Chapter 10 Renewable Energy Policies

Policy R1 Renewable Energy Developments Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Chapter 11 Environment Policies

Policy EN1 Managing Flood Risk Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN2 Historic Environment Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN3 Derwent Valley Mills World Heritage Site Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

11.2.7 This is an important statement that could be better reflected in the policy wording.

PHS019 Site Assessment (Historic Environment) for Land North of Denby is not comprehensive

c) "development that will improve public access to or the interpretation and promotion of the

significance of the World Heritage Site and its assets"

This is an important policy relevant to HGS18 since the historic transport routes link directly into the

World Heritage Site.


Policy EN4 Listed Buildings Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN5 Conservation Areas Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN6 Archaeological Features Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN7 Registered Parks & Gardens Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN8 Protected Open Break Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN9 Special Landscape Area Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

No comments

No comments

No comments

No comments


Policy EN10 Landscape Character and Features Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN11 Biodiversity Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN12 Pollution Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

Policy EN13 Derelict, Unstable & Contaminated Land Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN14 Hazardous Substances Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

11.6.8 "The Amber Valley Ecological Network, as shown on the plan at Appendix 2" There is no plan at

Appendix 2

No comments

"Development will be permitted for proposals involving the reclamation and/or re-use of derelict,

unstable and contaminated land, providing that where it is suspected or known that land is

contaminated, a detailed and independent assessment is undertaken on behalf of the applicant to

identify the nature and extent of contamination and any remedial or mitigating measures which need to

be undertaken".

This policy should state that following the steps taken by the applicant as above, that the remedial or

mitigating measures are actually carried out and implemented.

No comments


Policy EN15 Shop Fronts Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN16 Advertisements Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy EN17 Quality & Design Of Development Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Chapter 12 Infrastructure Policies

Policy IN1 Sustainable Transport Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN2 Disused Transport Routes Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

b) AGAIN no mention is made of bridleways

The majority of this policy cannot be implemented for HGS18

b) Again no mention of bridleways

d) It is noted and welcomed that bridleways are included

The map referenced in appendix 3 is incorrect. It shows the disused transport route ending at Smithy

Houses. The route actually goes through Marehay and to Ripley and is well established and known.

A second disused transport route on Land North of Denby is not shown on the map.

12.2.1 states that the disused transport route goes between Derby and Coxbench. This is in

contradiction to both the map in appendix 3 and the actual facts.


Policy IN3 Cromford Canal Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN4 Green Infrastructure, Parks & Open Space Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN5 Sport & Recreational Open Space Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN6 Safeguarded Land For Educational Facilities Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN7 Safeguarded Land For Cemetery Extensions Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN8 Community, Leisure, Health & Cultural Facilities Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary

No comments

No comments

No comments

No comments

No comments

No comments


Policy IN9 Leisure Facilities Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN10 Equestrian Development Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN11 Communication Infrastructure Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN12 Infrastructure Delivery Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Policy IN13 Developer Contributions Please give your comments on the content of the policy, the supporting text quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider necessary Any Other Comments On The Draft Local Plan

No comments

No comments

No comments

Measures to deal with remediation of contaminated land should be included in this policy.

Any shortfall for meeting the requirement to remediate contaminated land in HGS18 is not acceptable.

No provision for this is made in this policy.

It is unreasonable to expect respondents to complete this lengthy form and try and identify which

section their comments should be put in. The form is a barrier to respond. A more user friendly version

should accompany the Pre-Submission Local Plan.

Not all Submission Documents relating to the Draft Local Plan were available at public meetings.

The public meetings were not well advertised by AVBC .

Some spelling errors are in the Draft Local Plan Document.


DRAFT SUSTAINABILITY APPRAISAL REPORT

Please give your comments in relation to the following questions Have the reasonable alternatives for growth been identified and sufficiently appraised? Is there any additional evidence or environmental information which you consider should inform the site, policy or the broad options appraised? Does the appraisal sufficiently describe the anticipated effects of the Local Plan?

With regard to sufficient appraisal: Para 1.10.3 identified the allocation of sites as 'a strategic

undertaking, ie a process that omits consideration of some detailed issues in the knowledge that these

can be addressed later'. Applying this criteria does not allow the reader of the Local Plan to be fully

informed. Omitted detailed issues should be mentioned if not addressed. Also, many of these facts are

known to the Council following responses to the Core Strategy Report and could have been

incorporated.

8.3.6 iv states 'a development on the scale proposed at Denby could require significant highways and

other infrastructure provision'. It will require such provision.

8.3.6 ix also uses 'could' having regard to provision of new schools, a new local centre, and other

community and leisure facilities. It will require such provision. (referring to Denby).

8.3.6 ix 'There may be also be a need for further healthcare provision although this is uncertain.' At this

stage of the Plan and considering all other assessments done, it is remiss of the council to disregard the

importance of healthcare provision.

.

Evidence to support that the 5 purposes of greenbelt identified in 5.8.2 have been appraised and taken

into consideration. Purposes 1 to 3 are not withheld in SS10 Amendment to Greenbelt.

Land taken into use by H L Plastics recent extension resulting in greenbelt deletion should be included.

Development at Denby Pottery should be considered and included.

Not in the case of Issue 6 and Policy SS10 greenbelt deletion. The table presented does not demonstrate

that option 2 to delete greenbelt to North of Denby is significantly a better option than option 1 to

retain the green belt.


Have appropriate mitigation measures been identified or are there other measures available to address the likely effects of the Local Plan? Do you have any comments on the emerging proposals for monitoring the effects of the Local Plan? Please also give any other general comments on the report quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary DRAFT INFRASTRUCTURE DELIVERY PLAN Please give your comments quoting the relevant paragraph numbers as appropriate and state what (if any) changes you consider are necessary

Can Amber Valley Borough Council show that the use of South Derbyshire's Planning Policy Officer in

compiling this report has been entirely subjective. This is called into question in 5.3.16 Broad Options

Appraisal for Housing Apportionment Options. Clearly, option 1 to maximise growth in South Derbyshire

is the best option yet option 3 is chosen

Table 8b 'will require a new primary school to be provided on site and the expansion of John Flamstead

Community School'. (referring to Denby) This is not reflected elsewhere in the Local Plan or Draft

Sustainability Report and goes to highlight the inconsistencies across the documents.

3b Delivery schedule of transport infrastructure in Amber Valley has no mention or provision for Denby.

Considering that HGS18 is the largest of the proposed sites this is not acceptable.

7b Delivery of Health and Emergency Services 'will be established following consultation'. This is a key

factor in assessing site viability and an important factor for consultees to respond to. It should be

referred to and included in a policy statement in the Local Plan.

9b Environment Infrastructure states that the tar pit remediation cost is unknown. This is a key factor

and should not be left for the developer to establish after the Local Plan is adopted. If costs make the

site unviable then the whole of the Local Plan is not sound with the inclusion of an unviable site ie

HGS18