Lowland Derbyshire and Nottinghamshire Local Nature Partnership
Regeneration and Growth Team
Amber Valley Borough Council
Town Hall
Market Place
Ripley
DE5 3JT
NG2 Business
8 Experian Way
Nottingham
NG2 1EP
14th October 2015
Dear Sir,
RE: Sustainability Appraisal Local Plan Part 1: Core Strategy September 2015
The Lowland Derbyshire and Nottinghamshire Local Nature Partnership will support the Borough
Council to achieve sustainable development through strategic local planning. We aim to ensure that
your area’s natural environment assets (i.e. natural capital) are accounted for in strategic planning
so that they can support people both economically and socially. The Local Nature Partnership (LNP)
has identified eight natural capital assets in our area which through ecosystem services provide
essential goods supporting your local economy and people. Your plan can impact the condition of
your capital which is essential for long term sustainable economic growth and supporting your
objectives for the economy, employment and health and wellbeing. During plan preparation,
therefore, your strategic objectives, local plan and Sustainability Appraisal (SA) must ensure
adequate consideration of your natural capital and where it needs to be increased, maintained or
improved to ensure your development proposals are sustainable, and long term environment and
economic costs are prevented or minimised.
We have reviewed the SA report (August 2015) and the non-technical summary (September 2015)
and make the following responses.
Duty to Co-operate
The LNP was formed and in existence from October 2012. We have no record of a request under the
duty to co-operate for the local plan preferred options statutory consultation (regulation 18) and
pre-submission draft consultation (regulation 19).
Can you clarify if your duty with regard to the LNP was discharged from January 2013?
SA objectives
The LNP welcomes the Sustainability Objectives 3 (green infrastructure), 5 (biodiversity) 7 (landscape
character), 8 (natural resources) and 9 (climate change). The LNP views the safe guarding of natural
resources as a primary objective to ensure that their condition does not deteriorate and impact on
those ecosystem services that support local economic growth or the health and well-being of the
local population. In order to ensure development is sustainable it is of upmost importance that
Amber Valley BC has a full understanding of its natural capital assets, their extent and condition, and
how the local plan will affect them.
Sustainability baseline
We commend the evidence gathering and evaluation the Council has undertaken for some natural
capital assets to establish a baseline. We have commented and raised issues of concern as follows:
(a) Minerals: The SA recognises the existence of coal, limestone and sandstone mining activities.
There appears to be no baseline evidence within the SA report identifying the full extent and
spatial distribution of these minerals and others including shale gas. Further we can find no
evidence or consideration of a safe guarding policy for these mineral assets and that you
have evaluated if development impinges on the mineral resource or identified reserves.
Can you share the extent and quantity of your mineral resource and reserves and if
development impinges either, including any areas identified for unmet housing need?
(b) Sub-soils: We acknowledge the importance of the geological features in your area
particularly in the creation of a distinctive landscape and its tourism value, particularly in the
Peak Fringe area. We were unable to identify any reference to geological SSSIs and RIGs in
your baseline evidence.
Can you clarify the number of Regional Important Geological sites and Geological SSSIs
within your area?
(c) Soil: We welcome that objective SA objective 8 to manage and preserve the quantity and
quality of natural capital includes high grade agricultural land within its scope. The issue that
that development will impact greenfield land of high grade agricultural classification,
particularly in the south west of the Borough is noted. However, we cannot identify in your
evidence the quantity of agricultural land by classification, and any that would be lost
through the proposed development options. We welcome the commitment to use
previously developed land and to continue to clean up the existing contaminated land. Again
it is not evident in the SA the quantity of contaminated land within the Borough that could
be improved through development.
Can you share the extent and quantity of agricultural land by classification and
contaminated land, including the additional quantity of any areas lost or improved
through the local plan and unmet housing need?
(d) Ecological habitats: We welcome objective 5 to conserve and enhance the quantity and
quality of your ecological habitats. Your baseline evidence identifies 4 important habitats
plus veteran trees together with your SSSIs and LNRs. We could find no evidence of the
baseline quantity and spatial distribution of your habitats, including those outside the scope
of SSSIs, LNRs and LWS. The LNP following the Natural Capital Committee habitat definitions
has a list of 6 prime ecological habitats (woodland, lowland heath, upland heath and
moorlands, semi-natural grasslands, blanket bog and enclosed farmland), some of which, for
example grasslands, are broken down into sub-habitats (calcareous, acidic, neutral or wet
grassland). We also welcome SA objective 3 to maintain and expand green infrastructure
and protecting green spaces, primarily in urban development areas.
Can you confirm if the 4 habitats you define in the baseline are the only habitats you have
identified in your area?
Can you share the extent and quantity of your ecological habitats including any additional
quantity of habitat lost or gained through the local plan development proposals?
(e) Species: Priority species are recognised within the biodiversity baseline but the number of
types of priority species and their distribution is not identified in the SA baseline evidence.
We welcome that priority species along with SSSIs and LWS is an appraisal criteria.
Can you identify the number of priority species types in your area and their spatial
distribution across the plan area and if any spatial distribution is impinged by the
proposed development?
(f) Freshwater: You have identified river ecological and chemical status as important natural
capital indicators including forecast 2015 predicted quality. This is the indicator the LNP use.
As with all natural capital indicators it would be helpful to see the previous year’s trend in
the baseline evidence. We could not find evidence of any groundwater sources that you
have and their chemical status which is another indicator of natural capital condition. We
also welcome the water resource availability concerns for a supply deficit throughout the
plan period. We cannot find the baseline evidence for the river and groundwater assets.
Can you identify the river length in your area by overall quality status (Bad to Excellent)
according to Environment Agency criteria?
Can you clarify if you have any groundwater or surface water abstraction sources and their
resource availability and chemical status by Environment Agency criteria?
(g) Air: We recognise that you have no Air Quality Management Zone (AQMA). We could not
see any baseline air quality monitoring data or any Central Government predicted air quality
data for your area. This is a significant omission in the SA report.
Can you identify the chemical substances you monitor for air quality and the current and
historical air quality trend for your area compared to statutory air quality standards?
Can you show an assessment of the impact to air quality from your proposed development
plan?
(h) Land: We understand that Amber Valley has 3 main landscape characters including areas of
significant heritage value such as Derwent Valley Mills World Heritage Site. However, we
cannot grasp from the baseline evidence if there has been significant negative or positive
changes in landscape character over the previous plan period. There is no visual assessment
or simulation of the potential impact from the development plan options.
Can you share the change in landscape character over the previous year’s using County
Council landscape character data?
The LNP recognises that Amber Valley is close to its plan adoption. We, therefore, recommend that
you include within your post adoption monitoring and future strategic planning the quantity, quality
and spatial distribution of your eight natural capital assets as key indicators. This natural capital
information is held by the LNP and supporting stakeholders such as Natural England, the
Environment Agency, Forestry Commission and Derbyshire County Council. Some of it is included in
your evidence base and the LNP can support you in this area. The LNP is developing its strategy to
identify how to increase, maintain and enhance our areas natural capital to ensure that
development is sustainable. We will share this strategy you in due course.
Impact of unmet housing need
We are, therefore, concerned that for some assets there is limited evidence in the report about the
full extent and condition of Amber Valley’s natural capital preventing a full assessment of the impact
of the local plan and the proposed unmet housing need increase.
Can you clarify the impact, positive and negative, that the additional housing will have on the
natural capital in your area?
The LNP would appreciate a constructive dialogue with Amber Valley Borough Council that through
mutual co-operation delivers a sustainable development plan to promote a strong economy to serve
the people of Amber Valley and their future generations.
I trust our response will help you deliver your goal to achieve sustainable development. I would be
grateful if you acknowledge receipt of our response. The LNP is looking forward to working with you.
If you have any further questions do not hesitate to contact Rosy Carter our LNP co-ordinator at the
above address.
Yours sincerely,
Tony Walker, Chair, Lowland Derbyshire and Nottinghamshire LNP board
Tony Hams, Vice-Chair, Lowland Derbyshire and Nottinghamshire LNP board