Derwent Valley Mills

N/A

• The ‘Landmark’ high-rise housing project located adjacent to the buffer zone of the property in Derby was approved in August 2020, despite the negative recommendation of the Development Management Officer. Construction has not yet commenced;
• A proposal for the ‘Belper Lane’ development of 118 houses in the buffer zone was denied by the local authority but approved on appeal by the Secretary of State despite opposition by Historic England and the Derwent Valley Mills World Heritage Site (DVMWHS) Partnership. Construction is ongoing;
• A proposal for 114 homes at Derwent Street in Belper was amended following the advice of the DVMWHS Partnership while another was not approved on the advice of Historic England.

• Historic England and the DVMWHS Partnership trained administrators and councillors of the four local authorities mandated with the protection and maintenance of the Outstanding Universal Value (OUV) of the property, and are exploring appropriate models for the provision of further training;
• Regular meetings are being held between the Derby Conservation Officer and the Validation Team to look at applications so they can be flagged and the DVMWHS Partnership and Historic England can be consulted;
• Historic England provides conservation and planning support to the Amber Valley local authority until 2024;
• All local planning authorities responsible for the property commenced reviews of their respective local plans in 2019. Local plans are required to be reviewed every five years:
  • The Amber Valley Plan Alternative Spatial Strategy Options for Housing and Economic Growth has been published for public comment. The target date for adoption of the new Local Plan is September 2023,
  • The Belper 2021 Neighbourhood Plan presents project evaluation criteria, including criteria that address the need to protect and conserve the World Heritage property, and identifies brownfield sites for development,
  • Derby, in collaboration with Historic England, commissioned a Skyline and Significant Views Study, which informed a Tall Buildings Study. A masterplan for this city centre is under preparation. These studies and plans will inform the new Local Plan,
  • The Derbyshire Dales Local Plan is in the early stages of evidence gathering and a ‘Climate Change’ Supplementary Planning Document was adopted in July 2021;
• Sensitivity mapping has been implemented, for instance, in the Derby Skyline and Significant Views Study.

• Attempts to address the poor state of conservation of the Belper Mills complex, which is in private ownership;
• Actions to counter illegal development activities;
• Conservation and restoration work at several components of the property.

During 2022 and 2023, the State Party submitted notifications under the provisions of Paragraph 172 of the Operational Guidelines for:

• The ‘Amber Rock Resort’ proposal for a hotel/waterpark/accommodation in the disused Cliff Quarry, Crich, directly adjacent the buffer zone of the property. An ICOMOS Technical Review concluded that the proposal was not aligned with the maintenance of the OUV of the property;
• The adaptive reuse of the Belper Mills complex as mixed-use development with predominantly housing. This proposal was assessed by Historic England and the DVMWHS Partnership who have both advised that the proposals would lead to negative impacts on the OUV of the property;
• Two new high-rise development proposals in Derby (Bradshaw Way and Eagle Quarter), located in the setting of the property. In both cases Historic England, the DVMWHS Partnership and the Derby Urban Design and Conservation Team have advised that the proposals would lead to negative impacts on the OUV of the property;
• The structural integrity of the Darley Abbey Bridge, Darley Abbey, has led to its closure. A permanent proposal for its rehabilitation is being developed.

Development pressure within this property, its buffer zone and setting are cause for great concern. The State Party submitted details of the Belper Lane and 54-metre-tall Landmark developments to the World Heritage Centre, which were reviewed by ICOMOS in December 2018 and August 2019, respectively. In both cases, ICOMOS concluded that the proposals would negatively impact the OUV of the property and should not proceed. In the case of the Belper Lane proposal, ICOMOS concluded that the proposal would have a ‘significantly negative impact’. The proposal submitted to the World Heritage Centre for the Belper Land project foresaw the construction of 65 houses, whereas the approved project foresees 118. The impact can consequently be expected to be larger than that noted in the ICOMOS Technical Review. The approval of both these projects, against the recommendations of the DVMWHS Partnership and Historic England, amongst others, creates a problematic situation and precedent. The visualisations provided by the State Party of the new high-rise developments proposal in Derby indicate a large negative visual impact on the rural landscape quality of the property. They are not yet approved, and thus are not expected to proceed, but the development of such proposals highlights the critical misalignment between the development ambitions and the protection of the OUV of the property.

Other projects reported by the State Party, such as the approved project for 114 homes at Derwent Street in Belper, are located within the boundaries of the property. However, no notification was transmitted to the World Heritage Centre as per Paragraph 172 of the Operational Guidelines.

The refusal of several projects on the basis of the harm that they would cause to the property’s OUV and the reported legal proceedings against illegal developments are positive. The State Party’s engagement on the state of conservation of the large Belper Mills complex is noted, but the proposals submitted to the World Heritage Centre are considered not to be compatible with the OUV and should therefore not proceed and be reconsidered.

The management system for this property does not function adequately to safeguard its OUV and allows for damaging proposals to be approved and implemented. It is mandated to four authorities, all of which are developing new local plans. These are not coordinated and do not provide for cumulative impacts assessments on OUV. The new Belper 2021 Neighbourhood Plan includes areas for development inside the property. This Plan was however not submitted to the World Heritage Centre for review, despite there being a distinct possibility that it may impact on the OUV of the property.

Despite the exemplary action of the DVMWHS Partnership, the protection and management system is fragmented. The DVMWHS Partnership and Historic England have a non-binding advisory management role. The new Management Plan for the property, developed by the DVMWHS Partnership, has no legal status. The Plan itself states that there is no national core legislative protection for World Heritage properties. World Heritage is managed through the National Planning Policy Framework, which states that ‘substantial harm’ to OUV should be ‘wholly exceptional’ (Paragraph 200) but allows for ‘less than substantial harm’ to be weighed up against public benefit per project (Paragraph 202). This system does not adequately protect OUV and leads to its erosion through individual and cumulative impacts. While the new Management Plan recommends the use of Heritage Impact Assessments as a mechanism to assess potential projects, this has no legal standing within the national planning regime.

The State Party should be requested to halt all new developments, including those already approved, that may have a negative impact on the property’s OUV, and restructure its management to create a single coordinated management authority with legal jurisdiction and agency. This may require a review of the entire management system and a revision of the current Management Plan, which should likewise be given a legal status.

Development pressures on the property, coupled with the inability of the management system to safeguard its OUV, are reaching such proportions that, if not addressed as a matter of urgency, ascertained or potential threat, as defined in paragraphs 179 and 180 of the Operational Guidelines, could be confirmed.

The Committee may thus wish to remind the State Party of the provisions contained in Paragraph 172 of the Operational Guidelines and strongly encourage the State Party to invite an Advisory mission to the property to provide guidance on revising and strengthening the management system, in particular to curb development pressure.