Erewash Local Plan review – our submission
Our response to the proposed inclusion of further Greenbelt sites in the Local Plan aims to acknowledge the challenging situation Erewash faces with projected housing demand whilst staying true to our mission to protect the character and amenity of our treasured local countryside.
After several local CPRE members and action groups contacted us with their concerns about the proposals put forward by Erewash Borough Council, we took time to carefully review the circumstances under which the review is taking place (also contacting Erewash BC for further information), as well as conducting in-person visits to key sites involved.
These were undertaken by one of our volunteers with considerable expertise in planning and we are very pleased with the balanced but firm response produced as a result and submitted to the consultation on 10th May 2021.
Due to the unprecedented interest in this issue among our members and other public groups, we wanted to share our response in full, as follows:
CPRE is the leading organisation that stands up for the Green Belts. Around 22%, or just under 3 million hectares, of England’s land area consists of countryside within 5km of large towns and cities with populations greater than 100,000. This countryside is often the most valuable to people as ‘the countryside next door’. But it is also on the frontline of pressures for development. Of these 3 million hectares, approximately half is designated as Green Belt. There are 14 Green Belts that together cover 13% of England, or just over 1.6 million hectares. The fundamental aim of Green Belt policy is, as set out in the National Planning Policy Framework issued by Government, to prevent urban sprawl by keeping land permanently open. There are stricter controls over new development, particularly housing, within Green Belts than within most of the countryside.
There should continue to be a general presumption against development on Green Belt land. CPRE have proven that there is currently enough brownfield land suitable for redevelopment for over 1 million new homes across England, at conservative estimates of density, and more new brownfield sites are coming forward all the time.
Overall, we are strong supporters of the current policies on Green Belt as they are set out in the National Planning Policy Framework (NPPF); we believe there are potential loopholes or weaknesses in the policy which need tightening. We have been increasingly concerned by research that is indicating an increase in the number of proposals to build on the Green Belt. Most proposals are being approved by local authorities and/or planning inspectors, and these in turn are setting a precedent for further releases elsewhere.
The NPPF states that Green Belt boundaries can only be altered in ‘exceptional circumstances. CPRE believes that this policy should be further strengthened so that assisting in the mitigation of, and adaptation to, climate change is also a specific purpose of Green Belt policy. Local authorities in areas constrained by Green Belt should not set planning targets for levels of growth beyond that which can be accommodated without harm to the Green Belt.
Local reviews of Green Belt should only take place if:
- they are part of a broader, Green Belt-wide development plan or policy.
- they are primarily based on the five purposes of Green Belt as well as any additional local criteria where relevant and agreed locally and seek to minimise harm to the Green Belt.
- the Green Belt boundaries did not significantly change in the previous Local Plan period
Erewash has been successful till now in previous plans to resist allocations of housing development in the greenbelt. This is due to allocation of large brownfield sites such as Stanton and a balanced approach to housing provision in the wider Nottinghamshire area covering other boroughs. However, Erewash is now struggling to deliver the housing supply targets set by government and a Revised Options for Growth has been presented as part of its Core Strategy Review. CPRE’s policy stance is to protect greenbelt land areas with an increase in control. In view of the national requirements laid out in the NPPF where development is to be allowed on greenbelt land it should be in exceptional circumstances. This should apply to allocations also.
The problem for Erewash is the lack of available sites. Long Eaton is constrained and forms a ribbon of development westward of Nottingham that needs to be safeguarded from joining up and leading to coalescence of settlements between Nottingham and Derby. Ilkeston requires a degree of economic regeneration and the Stanton ironworks site was established as an allocation to deliver much needed housing. However, half of this site has now been put forward by its owners for employment use which is an already established primary use on brownfield land. Given its location this would seem appropriate. Strategically, the greenbelt area in Erewash is more essential for the purposes of protecting the gap between Nottingham and Derby than areas of green belt in the south and east of Nottingham.
The revised proposed growth strategy using a number of greenfield sites at the edge of existing settlements has now been reduced to four sites, two of which CPRE wish to express concerns about. These are the extended site to the Land South-West of Kirk Hallam and the land North of Spondon just south of Spondon Woods.
The site at Kirk Hallam is proposed as a large urban extension for up to 1300 houses and locally controversial as it significantly increases the size of the settlement and impacts on the openness of the countryside. Our concern with this site is that a situation may arise where more greenfield land is taken. CPRE particularly resist the development of new roads in the greenbelt as this inevitably leads to further growth. A situation where there is further pressure on the greenbelt arises.
The site north of Spondon reduces a valuable gap between the houses and woodland, and whilst the impact on the openness of the greenbelt will be minimum, the gain in number of houses needs to be weighed against the impact on biodiversity and legibility of the countryside setting of the urban edge.
The options are:
- To look for more brownfield land.
- Look to other boroughs to meet demand through the duty to cooperate. Due to the recent pandemic, there are changes in town centres being turned into residential and this will have an impact on the Housing market which is not clear yet. The recently produced Greater Nottingham Strategic Plan Growth Options Consultations July 2020, between Broxtowe, Gedling, Nottingham City Council and Rushcliffe, does not include Erewash although it is part of its housing market.
- Increase densities within brownfield allocations. Where urban extensions into the Green Belt are decided through the local planning process to be the most sustainable option, CPRE would want them to meet the Smart Growth criteria set out in our Housing Policy Guidance note. In particular any new urban extensions should have medium or high densities and be well linked to public transport and other social infrastructure so that car use can be minimised. There should also be a significant contribution to meeting social housing need in the local area.
- Look towards smaller sites to have less overall impact on the countryside. Exception sites have always been acceptable on a small scale.
It is worth bearing in mind that the proposed changes in the Planning White Paper provides a level of uncertainty as to how growth patterns will develop in the future. One thing is clear is that with the climate crisis sustainability will become more important. That is why it is imperative that we look at the most sustainable growth options that have least impact on the countryside.
Regarding the Kirk Hallam Site, we have initial concerns regarding the impact of the development on the openness of the greenbelt. The fields are large, and the zone of visual influence is wide particularly to the west of the existing settlement where there are extensive views south and westward. We are also concerned that the site will be poorly integrated into the existing settlement and therefore will not appear as natural growth within the countryside. This will have an impact on landscape character. The natural capital of the Pioneer Meadows nature reserve and Sow Brook green corridor will be potentially cut off from surrounding countryside by housing which will lead to fragmentation of the existing green infrastructure. There are recreational walking paths into the countryside crossing the land at two points. The publicly accessible footpaths from existing housing areas have poor legibility with narrow paths from the existing streets and can be lost in any subsequent development, affecting the enjoyment of the countryside for existing residents of Kirk Hallam. The scale of the site is large (43hectares), almost half the size of Kirk Hallam. Although, presented as an extension of Ilkeston, the local situation is more relative to the settlement of Kirk Hallam and its setting within the countryside.
In respect of the land North of Spondon, this site is a long linear site between existing housing and Spondon Wood. Although, there are limited views of the countryside and therefore limited impact on the openness of the greenbelt, we wish to support residents in their objections to this site on the basis that it will impact on natural habitat, and also be a poor result on the pattern of development by bringing the urban edge directly up to the edge of the woodland. The fields provide a comfortable setback of the urban edge which is more legible as a definitive boundary to the urban area.
We consider that the previous core strategy in line with the Green belt review was the correct stance for Erewash to take. In view of not being able to meet housing targets a more strategic approach needs to be taken between neighbouring councils with a regional approach to housing delivery. One that respects green belt policy to preserve land between towns. The last full and comprehensive greenbelt review was in 2006 and we consider this should be the first stance. The Strategic Growth Assessments documents produced by Erewash assesses options for growth and each site only in relation to its own portion of greenbelt.
If Erewash were to include these sites into their core strategy review they should firm up their decision with stronger evidence-based assessments based on a more recent Strategic Green Belt review than the 2006 review, and more detailed site LVIA and landscape character assessments to be more informed on impacts on the countryside. Until a more detailed evidence base can prove that the release of this land meets the exceptional circumstances required then CPRE will maintain an objection.
Local people with concerns might wish to get actively involved in via Friends of Pioneer Meadows Nature Reserve Kirk Hallam and we would like to express our sincere thanks to this group and its members for supplying use with the photographs used in this article, with another lovely example below showing the land under review in use for growing hay.