This post is longer than usual. We make no apology for that. While we hope everyone reads it in full, we understand that may not be the case.

𝗧𝗵𝗲 𝗱𝗲𝘁𝗮𝗶𝗹 𝗶𝘀 𝘁𝗵𝗲𝗿𝗲 𝗶𝗳 𝘆𝗼𝘂 𝘄𝗮𝗻𝘁 𝗶𝘁 - feel free to browse the headings and dip in where of interest.

𝗜𝗻𝘁𝗿𝗼𝗱𝘂𝗰𝘁𝗶𝗼𝗻

Since our last substantive post on 15 May, several important developments have occurred. This post addresses:

• A statutory consultee response from National Highways regarding the Strategic Road Network
• A statutory consultee response from Derbyshire County Council regarding strategic infrastructure
• A relevant AVBC planning decision for a site in Kirk Langley

𝗧𝗵𝗲 𝗡𝗮𝘁𝗶𝗼𝗻𝗮𝗹 𝗛𝗶𝗴𝗵𝘄𝗮𝘆𝘀 𝗮𝗻𝗱 𝗗𝗲𝗿𝗯𝘆𝘀𝗵𝗶𝗿𝗲 𝗖𝗼𝘂𝗻𝘁𝘆 𝗖𝗼𝘂𝗻𝗰𝗶𝗹 𝘀𝘂𝗯𝗺𝗶𝘀𝘀𝗶𝗼𝗻𝘀 𝗿𝗲𝗽𝗿𝗲𝘀𝗲𝗻𝘁 𝗲𝗻𝗰𝗼𝘂𝗿𝗮𝗴𝗶𝗻𝗴 𝗻𝗲𝘄𝘀 𝗳𝗼𝗿 𝗼𝘂𝗿 𝗰𝗮𝗺𝗽𝗮𝗶𝗴𝗻.

𝗡𝗮𝘁𝗶𝗼𝗻𝗮𝗹 𝗛𝗶𝗴𝗵𝘄𝗮𝘆𝘀 𝗥𝗲𝘀𝗽𝗼𝗻𝘀𝗲

National Highways has now provided its long-awaited response to the planning application. While it has not formally objected at this stage, it has identified significant shortcomings in Wheeldon’s Transport Assessment and has requested further evidence before reaching a final conclusion.

To be clear - National Highways has not approved this development. Their response confirms that significant questions remain over the Transport Assessment and they have requested further information, along with a three-month holding period before they can reach a final conclusion.

Key concerns identified include:

• Whether traffic impacts on the A38 have been properly assessed
• The effect of other local committed developments and cumulative traffic growth
• Inconsistencies in Wheeldon’s traffic forecasting and assessment timescales
• Uncertainty around the development’s opening and phasing

Importantly, National Highways only assesses the Strategic Road Network (i.e. the A38). It does not consider the local impacts on Horsley Road, Tants Meadow, Kilburn village, school routes, pedestrian safety or everyday congestion - issues which remain at the heart of SKHGB’s objections and where we will continue to focus our efforts.

The response also highlights the importance of 𝗴𝗲𝗻𝘂𝗶𝗻𝗲 𝘀𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗹𝗲 𝘁𝗿𝗮𝗻𝘀𝗽𝗼𝗿𝘁 𝗰𝗵𝗼𝗶𝗰𝗲𝘀, reinforcing our concerns about a 200-home car-dependent estate served by a two-hourly bus service with no evening or Sunday provision.

The bigger picture is clear: nearly a year after submission, a major statutory consultee still does not have enough evidence to reach a final position. This strengthens SKHGB’s long-standing view that the application is inadequate, that significant concerns remain, and that there are insufficient grounds for planning permission to be granted. On that basis, the application should be rejected.

𝗪𝗵𝗮𝘁 𝗦𝗞𝗛𝗚𝗕 𝗶𝘀 𝗱𝗼𝗶𝗻𝗴 𝗻𝗲𝘅𝘁

SKHGB is carefully reviewing the detailed points raised by National Highways and will continue to ensure that the remaining transport concerns are fully examined. We will challenge any attempt to present this response as a transport "green light" and will continue to press for proper consideration of local traffic impacts, particularly on Horsley Road, Tants Meadow, school routes, pedestrian safety and existing village congestion, alongside wider concerns around sustainability, infrastructure pressures and the cumulative impact of development in the area.

We will also continue to engage with the Planning Officer, consultees and our professional advisers to ensure that all outstanding issues are properly addressed before any decision is made.

𝗗𝗲𝗿𝗯𝘆𝘀𝗵𝗶𝗿𝗲 𝗖𝗼𝘂𝗻𝘁𝘆 𝗖𝗼𝘂𝗻𝗰𝗶𝗹 𝗦𝘁𝗿𝗮𝘁𝗲𝗴𝗶𝗰 𝗜𝗻𝗳𝗿𝗮𝘀𝘁𝗿𝘂𝗰𝘁𝘂𝗿𝗲 𝗥𝗲𝘀𝗽𝗼𝗻𝘀𝗲

Derbyshire County Council has now submitted its updated strategic infrastructure response, and it raises some of the 𝘀𝘁𝗿𝗼𝗻𝗴𝗲𝘀𝘁 𝗰𝗼𝗻𝗰𝗲𝗿𝗻𝘀 𝘀𝗲𝗲𝗻 𝘁𝗼 𝗱𝗮𝘁𝗲.

Most importantly, DCC concludes that, in its current form, the development 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁 𝗺𝗲𝗲𝘁 𝘁𝗵𝗲 𝘀𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗿𝗲𝗾𝘂𝗶𝗿𝗲𝗺𝗲𝗻𝘁𝘀 𝗼𝗳 𝘁𝗵𝗲 𝗡𝗣𝗣𝗙 because it fails to provide safe, attractive and realistic alternatives to private car use.

This represents a significant shift in the debate. It is no longer simply residents saying that the development is unsustainable - Derbyshire County Council’s own strategic infrastructure assessment identifies serious sustainability and infrastructure concerns.

Key concerns include:

• A clear risk of a car-dependent development
• The limited two-hourly 138 bus service
• Significant pressure on local schools and libraries
• The cumulative impact of existing and future developments
• Kilburn Footpath 44, which is connected to Horsley Footpath 6, including the pinch point at the Woodhouse Road exit, has been identified by DCC as a "fundamental constraint"

Derbyshire County Council has stated that it will require £𝟮.𝟮 𝗺𝗶𝗹𝗹𝗶𝗼𝗻 𝗼𝗳 𝗾𝘂𝗮𝗻𝘁𝗶𝗳𝗶𝗲𝗱 𝗺𝗶𝘁𝗶𝗴𝗮𝘁𝗶𝗼𝗻 𝗰𝗼𝘀𝘁𝘀 𝗳𝗼𝗿 𝗮𝗱𝗱𝗶𝘁𝗶𝗼𝗻𝗮𝗹 𝘀𝗰𝗵𝗼𝗼𝗹 𝗽𝗿𝗼𝘃𝗶𝘀𝗶𝗼𝗻.

DCC has also highlighted a number of further requirements that have not yet been costed, including footpath improvements, pedestrian crossings, cycle and bus connectivity measures, digital infrastructure, waste infrastructure and monitoring arrangements.

Further Section 106 obligations relating to public open space, play provision, sports facilities, green infrastructure, biodiversity enhancement, long-term management and monitoring are also likely to be required. These costs have not yet been formally quantified and would be added to the overall mitigation total, increasing the development's already substantial infrastructure and mitigation burden.

Also of note is the request from Derby & Derbyshire Integrated Care Board for £200,000 to address the likely impact of the new population in terms of number of additional consultations.

𝗧𝗵𝗶𝘀 𝘀𝘂𝗴𝗴𝗲𝘀𝘁𝘀 𝘁𝗵𝗮𝘁 𝘁𝗵𝗲 𝘁𝗼𝘁𝗮𝗹 𝗼𝘃𝗲𝗿𝗮𝗹𝗹 𝗺𝗶𝘁𝗶𝗴𝗮𝘁𝗶𝗼𝗻 𝗯𝘂𝗿𝗱𝗲𝗻 𝗼𝗻 𝗪𝗵𝗲𝗲𝗹𝗱𝗼𝗻 𝗺𝗮𝘆 𝘂𝗹𝘁𝗶𝗺𝗮𝘁𝗲𝗹𝘆 𝗲𝘅𝗰𝗲𝗲𝗱 £𝟳.𝟭 𝗺𝗶𝗹𝗹𝗶𝗼𝗻 𝗮𝗻𝗱 𝗰𝗼𝘂𝗹𝗱 𝗮𝗽𝗽𝗿𝗼𝗮𝗰𝗵 £𝟵 𝗺𝗶𝗹𝗹𝗶𝗼𝗻 𝗶𝗻 𝘁𝗼𝘁𝗮𝗹.

Most of these measures would have to be secured through Section 106 obligations, planning conditions or separate highways agreements, meaning they would need to be funded by Wheeldon.

Importantly, DCC has also indicated that widening Footpath 6 may require third-party land acquisition on Woodhouse Road, creating the potential for additional land purchase costs and delivery risks (if land were even available). These outstanding items would add significant further costs to the development, meaning the true mitigation burden is likely to be substantially higher than the figures currently identified.

The bigger picture is clear: a major statutory consultee has now concluded that the application fails to meet key national sustainability objectives. This significantly strengthens SKHGB’s long-standing concerns that the proposal remains fundamentally flawed.

𝗪𝗵𝗮𝘁 𝗦𝗞𝗛𝗚𝗕 𝗶𝘀 𝗱𝗼𝗶𝗻𝗴 𝗻𝗲𝘅𝘁

SKHGB will carefully examine whether any mitigation measures that are subsequently proposed by Wheeldon are realistic, deliverable and genuinely capable of overcoming DCC’s concerns, particularly the issues surrounding Footpath 6/44. We are undertaking a detailed site survey to record the existing pinch points, width restrictions and accessibility issues. We will continue to challenge any attempt to downplay these findings and ensure that all infrastructure, sustainability and accessibility issues are fully considered before any decision is made.

𝗗𝗲𝗿𝗯𝘆 𝗧𝗲𝗹𝗲𝗴𝗿𝗮𝗽𝗵: 𝗞𝗶𝗿𝗸 𝗟𝗮𝗻𝗴𝗹𝗲𝘆 𝗵𝗼𝘂𝘀𝗶𝗻𝗴 𝗮𝗽𝗽𝗿𝗼𝘃𝗮𝗹 - 𝗹𝗲𝘀𝘀𝗼𝗻𝘀 𝗳𝗼𝗿 𝗞𝗶𝗹𝗯𝘂𝗿𝗻 & 𝗛𝗼𝗿𝘀𝗹𝗲𝘆

The recent approval by AVBC of a Wheeldon application for 49 homes at Kirk Langley is a reminder that strong local opposition alone is unlikely to stop unsuitable development. Concerns about infrastructure, traffic and village impact were acknowledged, yet the scheme was still approved. The site was not allocated in the Local Plan and was approved despite AVBC having a strong five-year housing land supply.

The debate also demonstrated the importance of planning evidence. Wheeldon argued that the development was sustainable, would provide high-quality homes and significant public benefits, including 40% affordable housing (20 houses). Critically, AVBC officers advised council members that, in the absence of objections from statutory bodies such as Derbyshire County Council, there were insufficient planning grounds to refuse the scheme on sustainability grounds. Also, AVBC stated that housing targets are not a ceiling and that it intends to support further growth.

The key lesson for SKHGB is clear: our case must continue to be evidence-led and focused on specific planning harms.

Kilburn and Horsley is fundamentally different. The proposed site is a major Green Belt development on land that has previously been rejected through the SHELAA process and identified in the Green Belt Review as making a significant contribution to Green Belt purposes. (Kirk Langley is not Green Belt.) Importantly, Wheeldon has effectively abandoned its earlier contention that the site constitutes Grey Belt, leaving it to be assessed as Green Belt land that continues to serve an important Green Belt function. This significantly weakens one of Wheeldon's original core justifications for the scheme.

Unlike Kirk Langley, there are significant unresolved concerns from statutory consultees, including Derbyshire County Council and National Highways, around highways, sustainable transport, accessibility, schools, and wider infrastructure impacts. In Kilburn and Horsley, DCC has gone further by concluding that, in its current form, the development cannot be considered compliant with the sustainability requirements of the NPPF.

The Kirk Langley decision is therefore a warning. We cannot rely on arguments that "enough houses have already been built" or that a site is simply not allocated. The strongest case remains a robust, factual demonstration that this particular Green Belt development would cause significant harm that cannot be adequately mitigated.

𝗣𝗹𝗲𝗮𝘀𝗲 𝗦𝗵𝗮𝗿𝗲

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