21 March 2012

Mr Derek Stafford
Asst Director Planning and Regeneration
Borough Development Department
Development Services
Town Hall
Ripley
Derbyshire
DE5 3SZ

Dear Derek,

REPRESENTATIONS FROM THE TOWN COUNCIL ON PLANNING APPLICATION AVA/2012/0084 – AN OUTLINE PLANNING APPLICATION FOR RESIDENTIAL DEVELOPMENT FOR UP TO 500 HOUSES AND ASSOCIATED WORKS AT LAND AT OUTSEAT’S FARM, MANSFIELD ROAD, ALFRETON.

Alfreton Town Council has considered the application, it had previously heard from large body of local opinion, at its Planning Committee held on March 14th 2012, all of whom were in opposition to the proposal. The Town Council opposes this application in the strongest possible terms, on the following considerations:

Departure from the Development Plan
Crucially, this application is a departure from the Borough’s Development Plan, which categories the land as ‘Greenfield Land’. The Town Council opposes the change that this application would require. The land should remain as ‘Greenfield Land’.

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Room 12 Alfreton House High Street Alfreton Derbyshire DE55 7HH
Telephone 01773 520032 Office Hours: Tuesday to Thursday 9-00 am to 12-30pm.
E Mail alfretontc@aol.com

Town Clerk: David T Holmes MBA Chartered FCIPD CiLCA
Assistant Town Clerk and Treasurer: Mrs Sheila Gent CiLCA

Core Strategy
The Town Council understands that the Borough Council, as Planning Authority is yet to finalise its Core Strategy and the completion of that important document is over 12 months away. The Town Council feels that the application should not be considered in advance of the Core Strategy, particularly as the existing definition of the land is as ‘Greenfield Land’. The Core Strategy, should, if it is to have any value, relevance and conviction with local people, be the key identifier for the use of that site. The absence of a completed Core Strategy leaves the Borough Council vulnerable to premature applications of this type. Alfreton Town Council calls upon the Planning Authority to defer any determination of the application until the Core Strategy is complete.
The Town Council calls upon Amber Valley Borough Council to involve the Town Council and public opinion in the creation of the Core Strategy.

Strategic Housing Land Availability Assessments (SHLAA)
The Town Council is aware that this site has been identified in the Borough Council’s Strategic Housing Land Availability Assessment as land that could be available for residential housing. The Town Council accepts that Strategic Housing Land Availability Assessments are a key component of the evidence base to support the delivery of sufficient land for housing to meet the Borough’s need for more homes and that such assessments are required by national planning policy, set out in Planning Policy Statement 3: Housing (PPS3). That said, the Town Council is concerned that the inclusion of this site in the SHLAA is only one component of the process. In the Town Council’s view, there is a danger that housing need drives the determination of the application, rather than the consideration of the long term planning merits of the application. The Town Council and local opinion sees the proposal as ‘shoe- horning’ a development of this type into an unsuitable site. The Developers are suggesting a building delivery period of around 10-15 years. The Town Council contends, that perceived shortage of housing, if indeed such exists, needs to be met in a shorter time frame.
Similarly, the Borough should re-assess the situation of housing availability in the Town and the wider Borough, taking into account the number of empty properties and opportunity to develop Brownfield sites. The Town Council understands that the target to build 5000 homes over the next 5 years, in the Borough, can be easily met without the need to build on this site. The interest already expressed in building on Brownfield sites in the Borough, would realise a further 3500 homes. Also, the Borough Council has already granted planning permission to build 2500 homes, some 2400 of which have yet to be completed; the Borough Council, as part of its housing strategy, should hasten the completion of those sites together with a drive to fill vacant or un-let properties.

Neighbourhood Planning.
The Town Council argues that the application is made in advance of the Neighbourhood Planning Process. The Coalition Government has made it clear that it wants to decentralise power to local people in determining whether they want developments of this type. It has been said that, one of the reasons so many people are dissatisfied with the planning system is that they feel planning is something that is forced on local communities, rather than involving them. Top-down regional strategies put pressure on local authorities to weaken protection for the countryside consequently it is better that local communities are given the power to decide where they want to see development and what they wish to protect.
In the Town Council’s view, and if Central Government’s objectives are to be believed, this application is ill-timed and should be deferred until the Neighbourhood Planning process and associated local referendum can be completed for the Town.

Other Planning Considerations

Unsafe vehicular access onto Mansfield Road and increase in traffic
This is a recurrent concern amongst local people and one echoed strongly by the Town Council.
The applicant is proposing a roundabout access; they assert that their Transport Assessment confirms that the network will work satisfactorily with the proposed development in place.
There are major local concerns that roads leading to the secondary access (Flowery Leys Lane and Birchwood Road) would become a ‘rat run’ and dangerous for local children in the vicinity of the local school, the applicant suggests that the problem would be eased by the alternative secondary access which would enter the site via the Leys Junior School.
The Town Council’s view is that the proposal will certainly cause substantial traffic issues on the existing roads and that danger to children will only be made worse by the proposal to install a secondary access at Leys Junior School. The Town Council asks that Amber Valley Borough Council does not simply rely on the applicant’s Transport Assessment and demands that Derbyshire County Council undertakes and publishes their own in depth Transport Impact Assessment, not only on the proposed roundabout but also the effect on estate roads, school children safety and importantly the effect on traffic congestion in the Town itself. The reason for this is that people locally have serious difficulties in relating the conclusions drawn in the report from the data presented in the report. Crucially, local people fear the proposal would create accident black spots and significant unacceptable traffic congestion, which do not appear to be acknowledged in the Traffic Assessment.
As stated earlier, the Developer refers to a 10 to 15 year delivery period, the impact of construction site vehicles would themselves lead to an intolerable situation for the residents of the nearby Flowery Ley’s Estate.
Ecological and Environmental Issues.
The Draft National Policy Framework at point 128 acknowledges that access to good quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. The planning system has a role in helping to create an environment where activities are made easier and public health can be improved. There is considerable local concern, given that some areas in  Alfreton rank in the Borough Council’s own Area Profile, as the worse deprived in the Borough which includes some of the most ‘health deprived’ residents in the Borough, with Alfreton people being shown as having the worst life expectancy of Borough residents . The Profile also shows the Town as being the most densely populated in the Borough, it is also contended that the Town has the least amount of public open space of the four Towns
There are major concerns regarding the air quality in this area, the application area, is aptly described as a ‘green lung’ and for that reason should remain as a ‘Greenfield Site’
The Town Council has been keen to defend access to this site by a supporting a claimed footpath, that claim has been determined by the County Council, although an order has yet to be made.
Local residents, who have knowledge of the flora and fauna in the area point to the irrevocable loss of habitat, some of which houses important species. The methodology of the Applicant’s Ecological Appraisal refers to a ‘desk study’ and a systematic walk on One Day 3rd August 2011. The Town Council supports the concern of local residents, that given the size and diverse environment of this large site, a much more systematic and extensive appraisal, taking into account the full seasonal affects on local wildlife should be undertaken. The Town Council is keen to state that it would oppose vigorously any plans to remove any Tree Protection Orders on this site.
The site is in the hinterland of the adjacent Carnfield Hall, a Grade2*listed building. The proposal would be at odds with the historic context of this important estate. This area of the Borough needs its heritage protecting and this application erodes the historic and environmental context of the area. The Town Council feels that the Borough Council should protect and enhance this important heritage asset and should prefer land of lesser environmental value for developments of this type.
Local resident’s point out the proximity to the Exchem (Rough Close Works) Explosives Factory and would require the Borough Council to seek a Health and Safety assessment of the associated risks, particularly the need for emergency vehicles to access that site should an incident occur. On the matter of emergency vehicles the Borough is reminded that the local ambulance service is housed on the Meadow Lane Industrial Estate and their free access onto Mansfield Road should be considered in the analysis of traffic movements in the Mansfield Road area.

Strain on local services
The Town Council feels that the strain on local services: schools, healthcare, recreation facilities, emergency services, water, sewers, gas and electricity etc. would be significant. The Town Council would seek an assurance that the Borough Council will commission an independent report on the effect the application would on these services.
The proposed development would introduce some 1500 new residents, some 1000 extra vehicles, to seek to diminish that effect by applying s 106 funds is over simplistic. To give one example raised by local residents - the increase in the size of the local population brought about by this development will demand an increase to the size of the Leys Junior School, a growth in pupil numbers would bring a consequent increase in school traffic in an already congested residential area. The Town Council would want to take a lead in coordinating local opinion in defining the application of any s106 funding and would want  to ensure that such funding is available at key growth stages of the scheme and not ‘locked away’ because of an incomplete development. The significant effects of this proposal would require that funds are available ‘up-front’.

Procedural matters
a. The Town Council would call upon the Borough Council to hold comprehensive site visits involving the Town Council and local residents.
b. The Town Council would reserve its right to speak during any public participation sessions held by the Borough Council when determining this application.
c. The Town Council would require that it continues to be consulted thoroughly throughout the determination of the application.

Yours sincerely,

David T Holmes
Town Clerk
c.c.
        Councillor Jim Anderson
        Rae Gee, Principal Planning Officer
        Rob Thorley, Community Planning Manager
        Peter Carney, Chief Executive