13/6/2022 Send in objections + cancel National Trust subscriptions. They are Derbyshire County Council partners, in this completely unsustainable development plan. Prince Charles, so-called ‘climate champion’ is the NT President. We have asked him to resign his position. The planning application is now on the South Derbyshire website https://southderbyshirepr.force.com/s/planning-application/a0b8d000001VpfzAAC/dmpa20220318?tabset-ba98d=3
Our objection sent, below
Dear Sirs
We object to the planning application DMPA/2022/0318, Elvaston Castle, design and access including roads, car parks, affecting heritage assets
The proposed development does not accord with the provisions of
the development plan in force in the area in which the land to which
the application relates is situated.
The plans breach several planning and sustainability policies in the Derbyshire, South Derbyshire and Derby City Local Plans, the National Planning Policy Framework and the tenets of the Paris Agreement, which is now National Policy. The application is also incomplete as air pollution, transport, floodrisk, biodiversity and carbon emissions are not fully examined in the Sustainability Statement; a new spur is proposed, from the planned roundabout, by Persimmon Homes, adding to car traffic, air pollution and carbon emissions, while destroying more veteran trees and bat habitat.
The developer states that there is no public transport to Elvaston Castle. This is not true, as Trent Barton and Arriva buses enable access to the park
The plans will increase carbon/particulate/nitrogen dioxide black carbon emissions, at a time when the UK Government has declared a climate emergency. The UK Carbon Budget is already overdrawn and these unsustainable plans worsen the attainment of any targets.
The biodiversity crisis runs alongside the climate crisis; an ecological connectivity
CLIMATE EMERGENCY
There have been FOUR major UK storms so far, in 2022, three of them in one month, because of the worsening climate crisis. At time of writing, on the US East coast, 100 million people have been warned to stay indoors, because of excessive temperatures. Intense floods destroying infrastructure in Yellowstone, Flash floods caused by intensive storms affect northern and central Turkiye. 15 people have been killed in heavy rains, Guatemala. Excessive heat in Spain is on track to cross the UK this week.
Somalia is still suffering intense drought and malnutrition due to crop failure.
The plans fail to provide any calculation of the carbon footprint of the scheme or any assessment of greenhouse gas emissions.
ANCIENT WOODLAND, BIODIVERSITY
The design and access statement reveals the destruction of trees, ancient woodland at Rookery Wood, for the roads, and destroys habitat for rooks, an endangered Red List species, as well as biodiversity, nature, bat habitat, veteran trees. Biodiversity loss should be halted worldwide, not increased. The proposed loss of any ancient woodland is wholly contrary to para 180 of the National Planning Policy Framework (NPPF) and the equivalent policy in the Local Plan). The NPPF describes ancient woodland as an “irreplaceable habitat” a heritage asset that should only be lost or permitted to deteriorate in “wholly exceptional circumstances”. The applicants do not identify the “wholly exceptional circumstances” in order to justify the loss of ancient woodland. It follows that all reasonable alternatives to such loss or deterioration should be exhausted, in terms of design and layout. No consideration has been given by the applicants in terms of the assessment of alternatives to the proposed harm to ancient woodland. There is no assessment of the loss in Derbyshire county councils Environmental Statement.
Natural resources are being destroyed worldwide and it is vital that authorities recognise that children, youth and future generations will not have recourse to the same resources that past and current older generations do. (Brundtland Declaration) The new roads also increase dangers to children, cyclists, other pedestrians using the roads. The current path through the trees is safe, informal and naturally progresses from the bus stop, through Rookery Wood. The tranquility and peace of this woodland will be completely destroyed and sends a poor message to children, youth, that their future natural educational resources, do not count. There is little point to the Derbyshire Lowland Biodiversity Action Plan.
AIR POLLUTION, PUBLIC OPEN SPACE
The 800+space car parks, are planned for grassland which is a rich carbon resource, next to the picnic site and nature reserve. There already is a car park+overspill on the edge of the park, keeping pollution outside the centre of the park, not bringing pollution into the park, as these plans do. The plans for more concrete, also increase surface water run-off/River Derwent flooding floodrisk, at a time when the opposite is needed.
Elvaston Castle public park serves the polluted industrial city of Derby –a Government designated ‘Clean Air Zone’ in which Derby people and children are breathing substandard air, which does not meet UK Air Quality Standards. People from the most polluted and deprived city wards, go to the city parks, Elvaston Castle among them, as their ‘countryside’ as they cannot afford to access elsewhere. The poorest, most polluted wards are also those with the least public open space, not meeting UK Open Space Standards. Alvaston, the closest ward, is one of those. Others include Normanton, Rosehill, Arboretum, Derwent, Abbey.
Children are unequally affected by air pollution. Ella Adoo Kissi Debrah was the first person in the UK, to have air pollution listed as a cause of death; https://www.bbc.co.uk/news/uk-england-london-55330945
Derby people and children visit the parks of Derby to escape their polluted environs and breathe fresh air, provided by public open spaces and parks. The Office for National Statistics website allows people to work out how much pollution is removed in their UK area, by trees and vegetation -https://www.ons.gov.uk/economy/environmentalaccounts/articles/ukairpollutionremovalhowmuchpollutiondoesvegetationremoveinyourarea/2018-07-30
HIGHWAYS AGENCY
National Highways have objected to the proposal . Various concerns set out in their consultation response dated 11 April 2022 suggest that the Transport Assessment (TA) accompanying the Derbyshire County Council planning application, is defective.
Pursuant to Regulation 25 of the EIA Regulations, the Derbyshire County council Environmental Statement lacks the requisite environmental information for an informed assessment of impacts to be undertaken (eg biodiversity surveys, air quality etc)
TRAFFIC AND AQMA
The design and access statement is missing relevant information on the area, and totally ignores the closest city ward to the park, Alvaston, containing an Air Quality Management Area, which Derby City Council has agreed needs less pollution, not more. The plans induce traffic from the city, through Alvaston, to the B5010 and the A6. It is not helpful to merely state, (in the Derbyshire county council planning documentation Air Quality Assessment) that traffic is all within the levels recommended to be screened out
- 6.1 admits the assumption “that LDV vehicle trips to the Site could increase by 65% from current levels as a result of the Proposed Development” which is excessive and should not be screened out, as it could just make a critical difference to levels elsewhere
- 6.1, the assumption is made that traffic heading for the A6 will split up about equally 3 ways at 75 each and thus miraculously avoid falling foul of “a change of LDV flows of more than 100 AADT within an AQMA” – but of course it might not be equal, and this would mean more traffic heading for the Air Quality Management Area in Alvaston, which is already over local authority limits
- New World Health Organisation Air Quality Guidelines, revised September 2021, now state that NO2 should not be more than 10ug/m3 (instead of 40), and PM2.5 only 5ug/m3 (instead of previous 10, and UK’s 20)
NB The new Environment Act is going through consultation now on targets (to be in place by the end of October). Proposals are for the PM2.5 concentrations target the previous WHO 10 level, but not to be met till 2040, when evidence is that even just with planned measures all but 1% of the country could meet that by 2030. https://www.cleanairfund.org/publication/uk-healthy-air/ “lSet WHO-10 as the legally binding annual average concentration target for PM2.5 – to be achieved by 2030 at the latest – recognising that pursuing PM2.5 targets can bring about additional benefits by also reducing harmful PM10 (larger-particulate matter) and nitrogen dioxide (NO2).”
NB Derby city Air Quality Management Area is already exceeding NO2 levels
AGRICULTURAL FARMLAND
The Ukraine war and devastated food and wheat crops worldwide, through the worsening climate crisis is leading to a catastrophic future NB Canada harvests failures in 2021. It is vital that arable land is retained for crops, not destroyed for roads. The World Bank has warned of an impending world food crisis. The UK is a food-insecure country, relying heavily on food imports, which make up over 46%.
FLOODRISK AND PUMPING STATION TECHNICAL ‘SOLUTIONS’
Worldwide weather disasters are increasing. The River Derwent flooded Derby again this year and workers were evacuated from the Rolls Royce nuclear reactor again (previously in 2019 too) A new development, a MUNIO high-carbon, resource-intensive pumping station, is proposed for Derby city centre yet the fact that this will cause flooding elsewhere, to the communities downstream of Derby, including Alvaston, Elvaston, Thulston, the Rolls-Royce nuclear reactor, is not mentioned in this planning application. Therefore the flood risk information is incomplete. There is no report from the Environment Agency, so a fully informed decision cannot be made.
GREENBELT
The fact that the site lies within the Green Belt is also very significant and has not been fully addressed. Development in the Green Belt should only occur where there are “very special circumstances” (see NPPF paras 137-138 and 147-151). The Planning Statement accompanying the planning application largely glosses over this requirement
BLUE-GREEN INFRASTRUCTURE
Derbyshire County council does not recognise the fact that Elvaston Castle is part of river valley blue-green infrastructure, being taken up by cities worldwide. https://www.sciencedirect.com/science/article/pii/S1470160X21005367?fbclid=IwAR2TBmfwjldtzCHm19exk4ivL893McrtcEdxaPs9U81BhET-HxBJhtmk0zU
Allowing parkland to flood is vital, in order to save communities elsewhere https://www.bbc.co.uk/news/uk-england-derbyshire-60504835
DERBYSHIRE MINERALS PLAN
Currently out to consultation, this also contains plans to increase floodrisk to Elvaston and environs and is not taken into consideration by the planning application, therefore a fully informed decision cannot be made.
NATIONAL TRUST, PARTNERS WITH DERBYSHIRE COUNTY COUNCIL
The corporation is amongst those who do not recognise the climate emergency or the polluting effects of partnering and supporting Derbyshire County Councils unsustainable, carbon-sequestering trees/ancient woodland/grassland and habitat destroying plans, despite claiming that #everyoneneedsnature.
NATIONAL PLANNING POLICY FRAMEWORK, HERITAGE ASSETS, PARIS AGREEMENT LINKS The plans increase particulate pollution, acid rain, all contributing to further heritage asset deterioration, of a registered park and garden, containing ancient woodland. The NPPF on Heritge assets states that ‘A building, monument, site, place, area or landscape identified as having a degree of. significance meriting consideration in planning decisions, because of its heritage interest.
The definition of heritage assets ‘.. assets of historical, artistic or scientific importance that are held to advance preservation, conservation and educational objectives of charities and through public access contribute to the national culture and education either at a national or local level.
NPPF – ‘Heritage supports environmental quality, education, inclusive economic development, social cohesion, equity, community well-being and resilience.
Educational objectives include the Lowland Derbyshire Biodiversity Action Plan, however, as the National Trust are partners in this Plan, and partners with Derbyshire county council, on the unsustainable Elvaston Castle plans, see above; we believe that there is a conflict of interest
The plans destroy the principles, especially those of ‘preserve and protect’ of heritage assets, for the good of ‘social cohesion, equity, community well-being and resilience’. Derbyshire County Council and National Trust plans take no account of the above.
South Derbyshire District Council declared a Climate Emergency in 2019. Derbyshire County Council have not.
PARIS AGREEMENT – CLIMATE CRISIS + ECONOMIC SEGREGATION
The plans reveal that Derbyshire County Council – and their partners National Trust, who support the plans – have not taken into account effects on the communities, people and children, who will be harmed by their actions, in the loss of public open space and services, worsening climate change impacts and air pollution, re the Paris Agreement. We refer to the relevant sections here-
‘Climate change is a common concern of humankind, parties should consider respective obligations on human rights, the right to health,…of indigenous peoples, local communities, migrants, children, persons with disabilities and people in vulnerable situations and the right to development, as well as gender equality, empowerment of women and intergenerational equity’
The Paris Agreement is clear on human rights issues and this is National Policy. The Elvaston Castle plans are a massive imbalance, in that public land is effectively being taken from the poorest sectors, namely the sick, disabled, women, those without access to cars, and given to those more affluent sectors, who can afford car travel. Air pollution, noise and a degraded quality of life is driven to them, in return. Polluting car travel to the park is being actively encouraged. See also NPPF principles
Signing a Statement of Community Involvement is of little consequence, when the views of the community are steadfastly ignored.
FOSSILFUELS + THE CLIMATE CRISIS
A new study from the Tyndall Centre for Climate Research, at Manchester University, found that wealthy countries had until 2034 to stop all oil and gas production, to give the world a 50% chance of preventing devastating climate breakdown, while the poorest nations that are also reliant on fossilfuels should be given until 2050. Derbyshire County Council do not address the impacts of their development plans, which rely on CONTINUING fossilfuel use and the induction of car-based traffic..
The group Transport+Environment found that the rich drive more and own larger cars that consume more fuel. The richest 10% of EU households spend 8 times more on fuel than the bottom 10%, with a similar divide in the UK.
The current war in Ukraine is added to the need to curtail fossilfuel use and stop inducing more driving of cars/lorries.
DRIVING INEQUALITY AND AIR POLLUTION
Regarding inequality effects, the UK Government states the following in the March 2020 ‘Decarbonising Transport:Setting the Challenge‘ consultation https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/876251/decarbonising-transport-setting-the-challenge.pdf
“The Fifth Assessment Report of the Intergovernmental Panel on Climate Change defines co-benefits as being “the positive effects that a policy or measure aimed at one objective might have on other objectives”. Co-benefits of positive action on reducing transport emissions include: • Public health benefits through increased active travel and improved air quality; • Improvements to the economy and employment rates through industry and innovation;
• Reduction in inequality where those who generate less noise and air pollution are disproportionally impacted by pollution”
Plans for a shopping mall, for the wealthier in the community, next to the car parks and the Grade 1 St Bartholomews Church, are supported by the National Trust, together with Derby City Council. Yet this is not the purpose of a public park
As climatic breakdown continues across the planet, these plans send a message to the wider public, that Derbyshire County Council, Prince Charles the President of the National Trust, Derby City Council, the Mace Group and others, ignore the worsening climate crisis, and the people/children affected by the climate emergency and biodiversity crisis, choosing instead to continue nature, climate and resources destruction, while claiming otherwise.As ‘special exceptional circumstances’ have not been met, we submit that the current climate emergency is THE special circumstance and outweighs any other; and request that the application is refused.
We support other objectors
Derby & South Derbyshire Friends of the Earth
with contributions gratefully received from National Friends of the Earth and C Hopkins, Planning and Environmental Consultant, MA (Oxon) PgDip Law
30/3/22 The unsustainable Derbyshire County Council planning application for Elvaston Castle public park (which is situated in South Derbyshire) is considered a Derby park, though just outside the city boundary. The closest ward, Alvaston, has among the least public open space in the city. People/children go to Elvaston to escape the gross air pollution of Derby. Send objection letters to planningrepresentations@derbyshire.gov.uk and copy to South Derbyshire Council, addresses here soon
Crowdfunding link for legal action is here https://www.crowdfunder.co.uk/p/stop-elvaston-castle-environmental-destruction
Elvaston Castle Action Group https://elvastoncastleactiongroup.org/
Friends of Elvaston Castle Community Group, https://www.facebook.com/friendsofelvastoncastle
So much for the ‘Statement of Community Involvement’ from Derbyshire County Council, who have consistently refused to look at alternatives, put forward by the community.
We also ask people to consider cancelling their National Trust (NT) subscriptions, as NT supports the destructive plans and have never responded to letters sent to them. Prince Charles is the President of NT. Derby & South Derbyshire Friends of the Earth will be calling Prince Charles as a witness, in future court cases.
Template you can use here, or copy and paste various sections, more info shortly…
Dear Sirs
I object to the planning application CD9/0222/34, for roads and 1000+space car parks at Elvaston Castle, on planning and environmental grounds.
The proposed development does not accord with the provisions of
the development plan in force in the area in which the land to which
the application relates is situated.
The application states that it is for a ‘track’. A ‘track’ coming off a roundabout, is a road. The plans breach several planning and sustainability policies in the Derbyshire, South Derbyshire and Derby City Local Plans and the tenets of Paris Agreement, which is now National Policy. The application is also incomplete as air pollution, transport, floodrisk, biodiversity and carbon emissions are not fully examined in the Sustainability Statement; a new spur is proposed, from the planned roundabout, by Persimmon Homes, adding to car traffic, air pollution and carbon emissions, while destroying more veteran trees and bat habitat.
The plans actively promote car travel and will increase air pollution in a public park, to which people and children from Derby – a Government designated ‘Clean Air Zone’ in which people and children breathe substandard air which does not meet UK Government Air Quality Standards- go to escape air pollution in the city. Air pollution causes premature death and older people and children are particularly susceptible to air pollution https://www.bbc.co.uk/news/uk-england-london-55330945
The developer states that there is no public transport to Elvaston Castle. This is not true, as Trent Barton and Arriva buses operate there. I use the Arriva bus.
The plans increase carbon emissions, at a time when the UK Government has declared a climate emergency.
The destruction of trees, woodland at Rookery Wood, (photo above) for the road, destroys habitat for rooks, an endangered Red List species, as well as biodiversity, nature, bat habitat, veteran trees. Biodiversity loss is supposed to be halted worldwide, not increased. The 1000+space car parks, are planned for grassland which is a rich carbon resource, next to the picnic site and nature reserve. There already is a car park on the edge of the park, keeping pollution outside the centre of the park, not bringing pollution into the park, as these plans do. The plans for more concrete, also increase surface water run-off/River Derwent flooding floodrisk, at a time when the opposite is needed https://www.sciencedirect.com/science/article/pii/S1470160X21005367
Plans for a shopping mall next to the Grade 1 St Bartholomews Church are supported by Prince Charles, President of the National Trust, who also support the plans, together with Derby City Council, yet they have declared a climate emergency. The plans are in breach of the Paris Agreement, which is now adopted UK Government Policy.
As climate breakdown continues across the planet, these plans send a message to the wider public, that Derbyshire County Council, Prince Charles and National Trust, Derby City Council, the Mace Group and others, do not care about the climate crisis, or the people affected by the climate emergency and biodiversity crisis, choosing instead to continue the destruction of youth and childrens future resources.
I would support plans which do not include the destruction of a public park, and resources needed by children, youth, future generations. Disabled, women, migrants and less able members of the community are discriminated against, in these plans. Yet they are supposed to be protected, as the Paris Agreement states. Kindly refuse the application
yours sincerely
ADD YOUR NAME
+ ADDRESS, AND ASK FOR A RECEIPT. YOU SHOULD ALSO GET AN EMAIL ACKNOWLEDGEMENT
If you want to send a letter instead, post it to
and ask for a receipt
More info shortly……Feel free to add anything from the following too. Always best to add your own comments as the claim can be made that ‘its all the same objection’ otherwise
Woodland, trees, nests at Rookery Wood, to be destroyed for the road – it’s not a ‘track’ as Derbyshire County Council claim…..
Sept 11 2020
The Masterplan Version 7 was approved by Derbyshire County Council Cabinet on Thursday Sept 10th 2020. Report details can be viewed here https://democracy.derbyshire.gov.uk/documents/g561/Public%20reports%20pack%2010th-Sep-2020%2014.00%20Cabinet.pdf?T=10 Officers report on Elvaston Masterplan 7 is on page 263-279. Latest news also on Friends of Elvaston Castle Community Group, https://www.facebook.com/friendsofelvastoncastle
One of the main points in the Officers Report is that the public does not trust the Elvaston Castle and Gardens Trust (ECGT)and no-one supports the Masterplan V7
Today, Saturday 18th Sept 2021, we handed out 800 leaflets at Elvaston Castle Woodland Festival, (see below) showing the woodlands that will be destroyed, at Elvaston Castle, including Rookery Wood. A Countryside Services worker said ‘habitat would be protected’. You couldn’t make it up. This is impossible. The road and car park plans will destroy nature, biodiversity, trees, meadows and public open space, causing more air pollution & increasing carbon emissions, though induced car traffic into an area of the park that is free from it ie
the meadows near the castle
(where the red arrowed route ends, on leaflet) Not ONE person we spoke to, supported the unsustainable plans. The Parliamentary Audit Committee on air pollution has reported that COVID19 mortality is closely linked to levels of air pollution. Thus, city dwellers are between 40-80% more likely to die from Covid, than rural, an observation that would go a long way to explain the higher mortality among members of the BAME community. The ECGT had a stall there too, we saw members of the public arguing with them and took away one of their large gold-embellished booklets, not printed on recycled paper. They don’t even name Rookery Wood, which will be destroyed to accommodate car-driving National Trust members, on a drive-through to the car parks. That will be a lovely drive, through the ruined woodland, trees, meadows and biodiversity
OCT 2020 We expect there to be planning applications submitted shortly for a road into the park, which will destroy greenways, public open space, trees, habitat, biodiversity and bring noise and air pollution straight into the middle of the park, which is relatively peaceful at the moment. The plans are for two 1000 space car parks next to the picnic area, nature reserve and surrounding fields (one of them often has horses on it) The following has been sent to Derbyshire County Council cabinet members, Mrs M Beckett MP, South Derbyshire Councillors and Derby City Council. More soon, please share….
Subject: Elvaston Castle Country Park and Gardens County Council Cabinet Meet 10 Sept 2020
Dear Councillors,
Firstly, apologies for another long read. We must also extend our gratitude for the current maintenance and upkeep of Elvaston Castle Country Park and Gardens. On a visit there, we saw the very best of what public parks offer, a showcase of the natural world, and the more formalised. The Victorian walled gardens, especially at this time of year, are a credit to the hard work of gardeners and other workers. While there we saw an elderly gentleman in a wheelchair, clearly happy and many families with small children, who were running around the park. Please pass on our thanks to all workers, gardeners, rangers.
Trust in politics is at an all time low. The very first section of the Officers report on Elvaston Castle Park and Gardens Masterplan acknowledges that the Derby and Derbyshire public do not support the Masterplan, at all.
The plans destroy public open space, trees, footpaths and greenways, replacing them with roads and 1000 space car parks. The noise and pollution will be excessive. On open/fair/festival days at Elvaston Castle, the fields next to the current car park are used instead for overflow parking, if needed. This keeps the cars, pollution and road/engine noise at the edge of the park, not in the middle of it. Public open space is at a premium in Derby City and many of the poorer more polluted wards, are lacking in Public Open Space standards. Although not within the city limits, Derby people utilise Elvaston Castle as their ‘countryside’. The new road will destroy footpaths, habitat, biodiversity and cause road accidents in an area where there are none. The A6 bypass caused the death of a young boy, within months of its opening
Hundreds of people use the A6 bypass footpath bridge to access the park daily, from Alvaston.
World Clean Air Day was on Monday. Derby is a Government designated ‘Clean Air Zone’ in which nitrogen dioxide pollution limits, are regularly exceeded. UK Air Quality Standards are not being met. The main cause is traffic. The UK All Party Parliamentary Group found that people living in polluted cities were up to 80% less likely to survive Covid19, than in rural areas. 64,000 premature deaths occur annually from air pollution. Yet the Masterplan would worsen air quality in a park that city dwellers go to, to escape the pollution in the city. The UK APPG findings also go a long way towards explaining the higher mortality among members of the Black, Asian and Minority Ethnic communities, as they mainly reside in polluted and deprived city areas. 1 in 8 deaths are linked to pollution https://www.bbc.co.uk/news/world-europe-54071380
Air pollution levels in Alvaston are already high, because of the A6, bypass and industrial development. Putting more traffic onto this road only worsens the situation for Alvaston residents, who will bear the brunt of pollution from the induced car traffic, lorries etc and see their chances decimated, of recovering from COVID19 if contracted.(UK APPG)
The UK Governments ‘Decarbonising Transport; setting the Challenge’ quotes the 5th Report of the Intergovernmental Panel on Climate Change (IPCC) co-benefits of “positive action on reducing transport emissions include public health benefits through increased active travel and improved air quality;…and reduction in inequality where those who generate less noise and air pollution are disproportionality impacted by pollution.”
The MACE report found that the main bulk of people in the park are there for WALKING, to enjoy fresher air than where they live. They are not interested in buying items, unless its an ice-cream or food. UK Government National Planning Policy Framework (2019) states ‘ ‘sustainable transport priority FIRST to pedestrian and cycle movements’ and reiterates ’strong support for the public rights of way network’ in other words, the greenways and footpaths that are to be destroyed by such plans.
Pg 9 of the full Cabinet report states that “Climate action would play a key role in the Covid-19 recovery process providing short and long-term economic, environmental and health and wellbeing benefits” Yet the politically-neutral Institute for Government published a report on Monday 7 September warning that the Government was “well off-track” to meet its target of netzero carbon emissions by 2050…” lacking policies, with constant changes of direction, and failing to gain public consent” (Guardian 8 September)
Climate, pollution and health issues are all linked https://www.ons.gov.uk/economy/environmentalaccounts/articles/ukairpollutionremovalhowmuchpollutiondoesvegetationremoveinyourarea/2018-07-30
Parkland and trees save the NHS MILLIONS in health benefit costs.
Thus trees and parkland help to REDUCE the growing demand on NHS services, and should be included in the annual assessment of value for money, which the council undertakes.(pg1 of full cabinet report) 100 plus trees and parkland, which the Masterplan would destroy. Yet the UK Government is currently promoting an ‘England Tree Strategy’ in which claims are made that tree cover will be increased, not reduced.
Elvaston Castle Country Park is in floodplain. https://riverlevels.uk/flood-warning-river-derwent-at-elvaston-castle-country-park#.X1eCEXlKgrT
In November 2019, 200 workers at the nearby Rolls-Royce nuclear reactor on Raynesway had to be evacuated when the River Derwent burst its banks and caused flooding. Parts of Derby city centre flooded. (NB The reactor was evacuated AGAIN in February 2022 and a pumping station is now planned for Bass Recreation Ground. This is a massive waste pf resources, as the high-carbon, resource intensive pumping station will of course, increase floodrisk to the reactor. Blue-green infrastructure, espoused in the rest of the world, is ignored. https://www.sciencedirect.com/science/article/pii/S1470160X21005367
We have called for the disused ex-Derby Telegraph car park, to be turned into a much-needed wetland, to slow the river down, before the railway bridge
Derby floods 21 1 2021
Destroying floodplain/washland at Elvaston Castle means that the river will ‘back up’ to other areas, such as the reactor, especially as the climate emergency worsens rainfall levels. Public safety would be at increased risk. The climate emergency will increase the number of times that excessive rainfall/run-off from rivers/roads flowing into Derwentwater dams, needs to be released.
The proposed roads/car parks are there for one intention only. To induce people in cars, to shop, in a public park, for which shopping is not a main attribute, and which is unsustainable. It also means that people in cars will be walking LESS, as the car parks would be right next to ‘amenities’, making a mockery of ‘active travel’. The car parks are planned to be situated in the heart of the park purely to ‘funnel’ car passengers through the courtyard shops, to buy more. Pg268 ‘the biggest income stream is car parking followed by catering’ The proposals indicate ‘town-cramming’ development onto a public park. The opportunity to introduce more active travel is squandered by these plans. To Induce more car travel into Elvaston Castle Park and Gardens is not sustainable or in line with the Governments stated intention to encourage ‘Active Travel’ that is, travel not reliant on individual motor vehicles. As these plans induce more cars, air pollution, noise, affect road safety and INCREASE carbon dioxide, they are in breach of the County Councils own policies on public safety, air pollution and its Manifesto on Climate Change and Carbon Reduction
There is no mention of the mandatory Climate Impact statement.
The Elvaston Castle Gardens Trust (ECGT) is not trusted by the wider Derby and Derbyshire public. To hand over such an important city park to an unknown quantity as the ECGT, who have no previous experience of running such a scheme, does not inspire confidence.
The benefit-cost ratio is incorrect as it takes no account of additional costs- the increasing costs of air pollution to human health, the negative effects of excessive carbon dioxide from unsustainable development and road safety effects, in addition to vague commercialisation ‘promises’ Indeed, it appears that the commercialisation plans will not make any monies for 5 years, (pg278) though it is unclear, we believe the project will founder. The plans do not mention the continuing need for social distancing, which will be with us for the foreseeable future, or possibly until a vaccine is found. Another lockdown may also be imminent, as the infection rate in England is 3000 on Monday, World Clean Air Day. The ECGT part of the report is glib about the current pandemic and inspires no confidence. They also send a poor message to future generations, that their plans to worsen effects of the climate emergency and car-induced pollution, carbon dioxide, destruction of natural resources and public services, are nothing to them. Surely the County Council would not do the same, abandoning its ‘duty of care’ and ignoring its own air pollution and climate ambitions (above & pg9 of full cabinet report)
More than ever, at this time of global pandemic and climate emergency, it is vital that Government and local/unitary Councils support and maintain life-giving public services such as parks, (see ONS link above) and extend their duty of care to the public.
We will continue to fight, and support groups such as the Friends of Elvaston Castle Community Group, https://www.facebook.com/friendsofelvastoncastle
and others, against unsustainable plans for roads and car parks in Elvaston Castle Country Park and Gardens, destroying parkland, public open space, greenways, footpaths, bridle paths, trees, habitat, biodiversity and air quality in a priceless Derby city park, on the edge of polluted Derby City.
Yours sincerely
D Skrytek
Derby & South Derbyshire Friends of the Earth
CC Mrs M Beckett MP
South Derbyshire County Council
Derbyshire County Council
Derby City Council Party Leaders
Derby & South Derbyshire Unfriends the Burning Earth 