Serving the people of Crich Parish

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PREFERRED SPATIAL STRATEGY FOR HOUSING AND ECONOMIC GROWTH AND DRAFT POLICIES CONSULTATION

PREFERRED SPATIAL STRATEGY FOR HOUSING AND ECONOMIC GROWTH AND DRAFT POLICIES CONSULTATION

Representation of Crich Parish Council - Submitted to Derek Stafford AVBC 06/09/22

Note: Derek Stafford wrote to the Parish Council stating "I acknowledge the circumstances whereby the Parish Council does not meet until 5 September 2022 and it would therefore be reasonable to allow any representations from the Parish Council to be received by 7 September 2022."

  1. 1. Representations relating to both the proposed Housing Growth Site: The Common Crich (25 dwellings) and to the proposed Housing Growth Site: Crich Road Fritchley (16 dwellings)

Prior to the AVBC Full Council meeting on 8 June 2022 (Agenda Item 10 (a) Amber Valley Borough Local Plan) Crich Parish Council sent the following representation agreed at its meeting on 6 June 2022:

"It is requested this representation is sent to all Members of Amber Valley Council prior to consideration of the above-named item of Council business.

Paragraph 6.30 of the report states "the preparation of the updated SHEELA has informed the conclusions as to which of the potential sites should be included in the new Local Plan to support the preferred strategy for housing and economic growth." Paragraph 6.31 of the report states "The updated SHEELA will be available to view on the Borough Council's website once it has been finalised." Crich Parish Council is most concerned that the recommendations of the above report are based on a report that has not been completed and is not available for inspection by AVBC Members or by interested parties. This is clearly a failing in terms of sound decision making and of natural justice.

Crich Parish Council requests details of:

  • The process by which the 15 further sites referred to in paragraph 6.29 of the report have been identified;
  • The criteria for assessment and the scoring of those 15 sites and other sites considered; and
  • Details of the "targeted engagement with a range of technical consultees" referred to in paragraph 6.29 of the report."

AVBC advised this request would be treated as an FOI request (Ref: JDJ/FOI/259/22). A response dated 1 July 2022 stated "Officers have assessed all of the potential sites submitted for consideration via the Strategic Housing & Economic Land Availability (SHELAA) process in accordance with an agreed methodology that is consistent with the national guidance on 'Housing and economic land availability'. The agreed methodology is available to view via the 'SHELAA' page on the Borough Council's website. The updated SHELAA, including the assessments of those potential sites which were submitted to the Borough Council after 1 April 2021 (and which are therefore not included in the published 2021 SHELAA), as well as any revisions to the assessments for those potential sites as set out in the 2021 SHELAA, will be published on the Borough Council's website when the consultation and engagement on the preferred spatial strategy and draft policies to be included in the Local Plan is commenced. The parish council will receive a notification of this by email. In order to fully identify and assess the range of constraints to and opportunities for development on potential sites, the Borough Council requested a number of statutory and other bodies to consider the potential sites and identify any constraints to development, including to indicate whether such constraints could be addressed and if so, what mitigation or other measures may be required. The Borough Council also requested any comments from those bodies regarding any opportunities that might arise through development of the potential sites, which could contribute to a more sustainable pattern of development, including improvements to the local economy, improvements to physical and/or social infrastructure and the protection and/or enhancement of the environment."

Once the AVBC consultation commenced the promised information was not available on the AVBC website. The Parish Council were advised the information had been removed as it included errors. It is evident Amber Valley Councillors have agreed the consultation exercise without the necessary supporting information.

AVBC had a staffed stall at Crich fete on 16 July 2022. It was evident many attending the stall expressed views in total opposition to the proposed housing growth development sites in Crich Parish. The scale of development in the last few years in Crich Parish has been huge. The Neighbourhood Plan clearly demonstrates that housing needs have been more than adequately met through recent completions and planning permissions within the Parish. It was evident the proposals for two more sites to be developed in Crich Parish has caused widespread anger within the local community. It is hoped those views will be listened to by AVBC Councillors.

The assessment of sites undertaken by AVBC does not include adequate consideration of important relevant aspects of the Crich Parish Neighbourhood Development Plan policies. The Neighbourhood Plan was made by AVBC following a referendum that revealed more than 97% support for the plan within the parish. To ask developers and landowners where they would like to build is no way to prepare a plan for the Amber Valley Borough area. What is needed instead is a clear sustainable strategy designed to meet the needs of the area. Paragraph 59 of the NPPF states "it is important that a sufficient amount and variety of land can come forward where it is needed, that meets the needs of groups with specific housing requirements." The assessment undertaken by the Borough Council fails on the grounds that development is proposed where it is not needed. The assessment of sites fails to recognise recent and current housing supply in Crich Parish. With a considerable supply of dwellings with planning permission but not commenced the requirement of Policy NP2 relating to benefit outweighing harm is not met.

  1. 2. Representation Specific to Proposed Housing Growth Site: The Common Crich (25 dwellings)

The proposed allocation is contrary to the Crich Parish Neighbourhood Development Plan in the following respects:

The proposed site is contrary to Policy NP1 which states development needs should be met within the settlement development boundaries. The site is outside the Settlement Development Boundary.

The scale of development is contrary to Policy NP1 which states development will normally be in the form of individual dwellings or small groups of dwellings on small infill sites. The issue of scale of development was a major concern of the public throughout the preparation process of the Neighbourhood Plan. The site will accommodate more than a small group of dwellings and is not an infill site.

The site is contrary to Policy NP2 as it will harm landscape character by extending onto the lower slopes to the west of Crich.

The site is contrary to Policy NP2 which requires land outside the Settlement Development Boundary to be treated as open countryside, which will be protected for the sake of its intrinsic character and beauty. No rational analysis could conclude the proposals to build on the site outside the Settlement Development Boundary (defined as countryside) is protecting the countryside for the sake of its intrinsic character and beauty as required by Policy NP2.

The site is contrary to Policy NP2 as it lies within the protected Green Gap between Crich and Whatstandwell which forms an important link to Crich Chase SSSI and is defined as a Special Landscape Area in AVBC policy. The proposed allocation will significantly harm the openness of the landscape character that protects the setting of Crich.

The latest landscape assessment commissioned by AVBC and prepared by Wardell Armstrong identified the site as being of high sensitivity. The site is contrary to Policy NP3 in that it will represent a significant visual intrusion into the landscape setting. Development on the site will directly and extensively significantly have an adverse impact on the identified important view corridor number 13 from the publically accessible viewpoint on Chadwicknick Lane.

The assessment is in conflict with Policy NP9 as avoidance of harm to important habitat is not demonstrated.

The proposals are in conflict with Policy NP11 as development of the site will harm the setting of the important Stephenson's Railway (Crich Mineral Line) heritage asset and will harm the setting of Grade II Woodbank House.

Map 14 of the Neighbourhood Plan shows the site is more than 800 metres from Crich Market Place. Being in a location more than a 10-minute standard walking distance to Crich Market Place the site is not in a sustainable location in terms of access to services and facilities.

The SHELAA assessment for site AVBC-2020-0017 states the nearest watercourse is 500m from the site and that discharge to the existing combined system is undesirable. The assessment recognises the conflicts with the Development Plan not least the issue of coalescence between Crich and Fritchley, and built and natural environment matters that act as constraints on development.

  1. 3. Representation Specific to Proposed Housing Growth Site: Crich Road Fritchley (16 dwellings)

The proposed allocation is contrary to the Crich Parish Neighbourhood Development Plan in the following respects:

The proposed site is contrary to Policy NP1 which states development needs should be met within the settlement development boundaries. The site is outside the Settlement Development Boundary.

The scale of development is contrary to Policy NP1 which states development will normally be in the form of individual dwellings or small groups of dwellings on small infill sites. The issue of scale of development was a major concern of the public throughout the preparation process of the Neighbourhood Plan. The site will accommodate more than a small group of dwellings and is not an infill site.

The site is contrary to Policy NP2 which requires land outside the Settlement Development Boundary to be treated as open countryside, which will be protected for the sake of its intrinsic character and beauty. No rational analysis could conclude the proposals to build on the site outside the Settlement Development Boundary (defined as countryside) is protecting the countryside for the sake of its intrinsic character and beauty as required by Policy NP2.

The site is contrary to Policy NP2 as it lies within the protected Green Gap between Crich and Fritchley. The proposed allocation will significantly harm the openness of the landscape character that protects the setting of Fritchley.

The site is contrary to Policy NP3 in that it will represent a significant visual intrusion into the landscape setting. Development on the site will have a significant adverse impact on the publically accessible views from the Common, Chadwicknick Lane and the footpath that links those two roads.

The assessment is in conflict with Policy NP9 as avoidance of harm to important habitat is not demonstrated.

Fritchley is not a sustainable location for new housing development with no employment sites or buildings and the settlement does not even have a single shop.

In addition, the site has been subject to severe flooding twice in the last few months. It is understood the incidence of further severe flooding events is an ongoing risk.

The SHELAA assessment for site AVBC-2020-0042 states high impact on Surface Water Infrastructure: No accessible watercourse or separate surface water system near to the site boundary. Discharge to existing combined system undesirable. The assessment recognises the conflicts with the Development Plan not least the issue of coalescence between Crich and Fritchley, and built and natural environment matters that act as constraints on development. It is not accepted as stated in the SHELAA assessment that the contours of the site limit the visual impact of development. Indeed, the reverse is true as the contours of the site make it fully visible from the Common, Chadwicknick Lane and from the public footpath that links those two roads.

  1. 4. Representation Specific to SHELAA Site AVBC-2020-0031 found not to be suitable as a housing growth site.

The SHELAA assessment of this site is supported, although reference should be to the Green Gap between Fritchley and Bullbridge. It is considered there are additional factors to those identified in the report that make this site unsuitable for development.

Posted: Wed, 07 Sep 2022 12:29 by Sam Teece

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