The Consultation Draft Local Plan

Showing comments and forms 1 to 30 of 38

Object

Consultation Draft (February 2017)

Representation ID: 4663

Received: 10/03/2017

Respondent: Mr IAN LIMB

Representation:

Disappointment expressed over how the consultation process was not more widely advertised and publicised by NEDDC. Requests made that the consultation period should be twice as long.

Full text:

I am writing to you as a resident of Dronfield and with regards to the NE Derbyshire Local Plan Consultation Draft Feb 17.

I must state that I find it extremely disappointing that the Consultation Process is not more widely advertised and publicised by NEDCC. My family and I only became aware of the Local Plan and Consultation Process as a result of a leaflet put through our letterbox by other residents trying to make the neighbourhood aware of the situation.

The Consultation Process runs from 24th Feb 2017 to 7th Apr 2017. A period of 42 days to allow the public to review, understand and respond on these proposals is an extremely short period of time and believe the period should be extended to 12 weeks in line with most due process periods.

Having reviewed the relevant sections of the draft I must record my strongest opposition to the proposal for converting "Greenbelt" land into land allocated for future housing. The proposed greenbelt locations adjacent to Hill Top Road/Longacre Road/Southwood Avenue, Hallowes Lane and Eckington Road are most inappropriate and will undoubtedly destroy the neighbourhoods.

My parents moved to Dronfield in 1964 and purchased a newly constructed Wimpey house at Hill Top. Since then I have lived the majority of my life in Dronfield. As I grew up I witnessed the expansion of Dronfield from a village to a town with major residential development in the Gosforth Valley and Dronfield Woodhouse. As I remember Dronfield was infamous for being the largest new private housing estate in Europe in the 70's. I attended Gosforth School in the 70's and thereafter witnessed the closure of this and the Gladys Buxton Secondary Schools. The Gosforth School land and surrounding open space in the Leabrook Valley were sold off to National House Builders and used, in a large part for major new housing developments. Admittedly some of the playing fields were retained and now offer an exceptional venue for local sport. Dronfield has continually grown since with smaller more speculative developments in keeping with the town size. As a resident it is clear to see that the towns current infrastructure and local services are under constant and unrelenting pressure to serve the current population let alone another potential 1o% increase in the population over the next 15 years as set out in the local plan.

The Housing Provision for Dronfield set out in the plan is a total of 860 new homes proposed by 2033. This represents an increase in circa' 10% of the current housing stock and therefore a major and significant strain of local infrastructure and services. All the new housing is proposed on current "greenbelt" land which NEDDC are seeking to re-allocate for housing.

In my opinion Dronfield is a unique place and stands alone. It has never been a suburb of Sheffield and or similarly Chesterfield. It has always been protected by its greenbelt from the surrounding areas and I believe this must remain the case for Dronfield in order to prosper and maintain its identity as I and most of its residents believe it should. The eradication of greenbelt is a "one way" process in that once lost it will never be returned to its original and intended use. When one looks at the Dronfield area map and the proposed loss of greenbelt it is clear that this land take is detrimental to the locality and out of character with development in the past. For example, the area of land at the top of Hallowes Lane involves the loss of major part of the Golf Club which has been present in Dronfield for over 100 years. Whilst this is private land, it should not be left to commercially minded individuals to decide the future of such an historic and important area of the town. The other proposed area represented by the strip of land between Hill Top Road, Longacre Road and the Hallowes golf course is the outer extremes of the south ward and represents beautiful open space and a buffer to the A61 together with access to the Monk Wood and Barlow beyond.

I currently live on Hill Top Road and the idea of increasing vehicular traffic in order to access the proposed 190 new homes (400 cars) cannot be accommodated without a major upgrade of the roads to ensure public and more importantly child safety. Dronfield Hill Top also no local amenities except for the Hyde Park Public House and the few small businesses on Highfields Road. The nearest amenities are located in the Civic Centre and generally accessed by vehicle due to topography of Dronfield. The proposal would not only increase normal travel volumes but also local travel essential to access amenities.

I am also aware of Brownfield sites in Dronfield which haven't been brought forward for residential development. For example, the former Padley & Venables site on Callywhite Lane was purchased and demolished for residential development. I am aware that the de-contamination costs of this site make development unviable but why aren't the Local and District Council seeking regeneration funding to clean the site and assist the developer in bringing forward development instead of proposing eradication of greenbelt?

I also believe the proposed extension of Callywhite Lane Industrial Estate and the new access off Sheffield Road close to the Nature Park to be extremely detrimental to the environment of Dronfield. This will no doubt involve the loss of a very important nature area and promote access to Callywhite Lane from the south and via Unstone. Currently there is a substantial amount of unlet space and property on Callywhite Lane and therefore the plans to expand and improve vehicular access to be most inappropriate.

All in all I think the proposal to give up greenbelt for residential development on the scale proposed is completely unnecessary and contrary to the Council's responsibility and obligation to maintain greenbelt for the purposes of defining local settlement and maintaining the character of the places where we all live. For the reason I am extremely opposed to the proposals in the Local Plan and shall be doing all I can to support the substantial number of Dronfield residents and town councillors who also share the same feelings.

I also intend to attend the Consultation Meeting on 14th March 2017 at the Dronfield Civic Hall to reiterate my opposition to these proposals, in particular the loss of greenbelt.

Comment

Consultation Draft (February 2017)

Representation ID: 4998

Received: 28/03/2017

Respondent: Chesterfield Gospel Hall Trust

Representation:

Generally:
Overall a very balanced and well thought out document. The only comment is that insufficient emphasis is placed on bold proposals to alleviate the situation on the A61. We would strongly recommend a working together with Chesterfield Borough Council on these issues.

Full text:

Sub-Regional Target:
Add: S3 - Recognise the economic and social importance of the A61/A617 link road and the importance that this project has to the sub-region and place all importance on any opportunities to lead and ultimately facilitate the provision of this vital piece of infrastructure within as short a time frame as possible.


4.43:
Amend as follows

4.43 The Local Transport Plan sets out future proposals for new infrastructure and includes an A61-A617 Avenue link road as a longer term County Council project. However, this plan recognises the strategic potential of the infrastructure investment to the economic and social wellbeing of the area and the Council will take every opportunity to lead and facilitate its delivery.

Policy SS4:
Amend as follows

h) Do not prejudice the construction of a link road from the A61 to A617 and take every opportunity to lead and facilitate its delivery.

Generally:
Overall a very balanced and well thought out document. The only comment is that insufficient emphasis is placed on bold proposals to alleviate the situation on the A61. We would strongly recommend a working together with Chesterfield Borough Council on these issues.































Comment

Consultation Draft (February 2017)

Representation ID: 5000

Received: 28/03/2017

Respondent: Mrs Jane Singleton

Representation:

Comments made on the Dronfield drop in session and whether it was long enough. Comments made that there was a queue to get in and the wait to speak with one of the planners was lengthy. Statement made that although drop-in sessions were not centre specific this was not publicised enough. Concern that the public does not get enough of a say in the process, further concerns raised over length of the Local Plan document and the planning language included, making it difficult for many to understand. Statement that the engagement process is flawed. Concern whether comments carry weight, questions raised over when the public comments will be available to view.

Full text:

Re: Public Consultation on the Local Plan Draft
I wish to draw your attention to the above in respect of the drop-in sessions and the Local Plan document which is for public consultation.
As a resident of Dronfield I do not consider that one drop-in session of three hours for the size of the town's population is sufficient to give all those who wish to attend an opportunity to do so. I did attend on Tuesday 14th March at the Civic Hall and had to queue to get in. The wait to speak with one of the planners was lengthy. People left without having their questions answered. Whilst I am aware that the drop-in sessions are not centre specific, and that you can attend the Eckington drop-in session and discuss Dronfield, this has not been
well-publicised.
For something as important as the Local Plan which aims to shape our communities into the future, the opportunity to take part in the process is minimal.
Your Local Plan as a document for public consultation is highly exclusive to many people because of its length, the use of acronyms and the heavy loading of planning jargon. It is a document which requires high level analytical skills and an understanding of planning policies. Its length is overwhelming. Whilst the document may be available online and in many languages, the engagement process is otherwise flawed. Why can a neighbouring authority deliver a plan of 6 chapters in a hundred pages less (excluding the excellent glossary of terms and appendices) in much simpler language?
It is questionable whether in fact our comments will carry any weight at all when surveyors have recently been observed on land ear-marked for housing in Coal Aston when the consultation process is not even complete. Is it the 'done deal' we keep hearing about across the Dronfield community? Please advise when we might expect to see the public comments available to view on your website.

Comment

Consultation Draft (February 2017)

Representation ID: 5003

Received: 28/03/2017

Respondent: Mrs Helen Bell

Representation:

Statement made over concerns about the consultation process methodology. For example a period of 6 weeks is nowhere near enough time to enable myself and other residents to comment on a 270 page plan and associated studies which underlie the plan.

Full text:

I love Dronfield. I love living here. I have lived here my whole life. I love the green spaces, the community spirit, the village feel and I especially love being surrounded by countryside. I can leave my house, walk for 5 minutes and I'm in open countryside. Surrounded by wildlife, birds of prey and peace and quiet. So hence my shear horror and disgust at the thought of ruining this by building on green belt land. So here is my VERY STRONG OBJECTION to your ridiculous plan.

Firstly I have very deep concerns about the consultation process methodology. For example a period of 6 weeks is nowhere near enough time to enable myself and other residents to comment on a 270 page plan and associated studies which underlie the plan.

Dronfield does need more affordable housing but not on green belt land. There are numerous brown field sites within the town that have been completely over looked. For example there were proposals to build houses on the old Padley & Venables site on Callywhite Lane. This would be a continuation of houses built in 2005 on Frithwood Drive. The factory was demolished and the site cleared. There was planning application 13/00539/FL submitted to the council and you refused it, back in 2013. If you are so desperate to build houses, why are you not re-visiting such applications? Bloor Homes are prepared to build on a brown field site, yet you refused it. Other brown field sites include the area of Holmley Bank and the Alma area which was housing until the late 1960s. There are also smaller sites within the town which should be taken into consideration. Why the 10 units threshold? An accumulation of developments on smaller sites could help meet housing requirements in a more sustainable manner and also be building work for small local builders.

The green belt land around Dronfield is full of wildlife. For example buzzards, sparrow hawks, brown owls, barn owls, bats, rabbits, foxes, shrews, field mice, badgers and many other species of insects and birds. All of which I have seen with my own eyes. When I was child in the 1980s, we never saw buzzards or sparrow hawks in Dronfield. These birds have taken a good 20 years to return to the area after the building of the Hallowes estate. Can we really afford to wait another 20 years in the hope they will return again after the desecration of their environment this time round?

The removal of green and recreational spaces also goes against your Plan. Paragraph 7.6 notes that Dronfield is significantly lacking in green space, outdoor sports and Childrens' play space therefore such space will need to be very strictly protected. Yet the plan proposes building on the golf course, on the sports facilities in Coal Aston, on farmland with access to the Dronfield Round Walk, in part of the Moss Valley Conservation Area and on the Dronfield Nature Park.

Dronfield does not have the infrastructure to cope with another 860 homes. If each home has at least 2 people living there with one car, that's 1,720 more people needing a doctor and a dentist. Currently it is near impossible to get a doctor's appointment on the day you are sick, and if you need a general appointment, then you are waiting 2 maybe 3 weeks or even longer. Plus there are no dentists taking new clients.

The roads in and around Dronfield are narrow and over congested now. The village struggles with the number of cars. Driving around Dronfield is very stop start as you allow traffic to pass. The pavements are not wide enough in parts for 2 people to pass. Imagine adding another 860 plus cars in the mix!

The majority of people in Dronfield work outside of the town. The main form of commuting is by car. We have one main road in and out of Dronfield. On the southern of the town there is only 1 road to Chesterfield. Not everyone has the luxury of working in the centre of Sheffield and Chesterfield so cannot use the train. Plus it is cheaper to use your car than the cost of rail travel. And you cannot park in the train station's car park as it has room for about 50 cars double parked. There is no way the car park can be expanded. The roads around the station are used for additional parking causing the area to be dangerous to walk around.

I'd also like to know how you expect the lorries etc. to get to the proposed housing sites? Do you even know what the roads are like in Dronfield? As there is NO Infrastructure Study, you obviously don't. The lack of an infrastructure study which looks at the impact of 860 more housing units in Dronfield whose infrastructure is already under stress is a serious weakness of this plan. I worry now about my children walking to and from school. This will become worse once we have diggers, brick Lorries, labourers vans etc. The pollution levels will soar impacting not only on the environment but also on the health and wellbeing of the town's population. But don't worry, we can all wait a month or two to see the doctor!

How can the Council ensure 'an adequate mix of housing types, sizes and tenure' in the new developments planned for Dronfield? For example following the call for housing land the developer Redmiles proposed 449 houses on land below Shakespeare Crescent (green belt plot g) in a plan indicating low density and larger houses which would sell at market price. Given developers' ability to demonstrate that a reasonable proportion of affordable housing is unachievable commercially, there is a significant risk that any new housing development in Dronfield will be mainly for sale at market prices.

Dronfield Infant and Junior schools are the only schools for the catchment of the new housing sites g, h and i. Currently Dronfield Junior School's year 6 has 98 pupils. They are only supposed to have 90 as a maximum. So how can you build all these houses for 1 infant and 1 junior school? Ok, so they could go to school in Dronfield Woodhouse. Yet all these pupils will still go to the same secondary school, Dronfield Henry Fanshawe. So you may argue that primary education won't be affected but we all know in the long run it will and secondary education will be ruined. Please don't forget that you are also proposing to build houses at Unstone and their secondary catchment school is also Dronfield Henry Fanshawe. Thus causing even more issues in an already oversubscribed secondary school and heavier congestion outside of the school.

We no longer have an open police station. If we want to report crime we have to go to Chesterfield. The police station isn't manned at night. We have to rely on police coming from Chesterfield in the case of emergency.
We have one fire engine. This worries me now, let alone when another 860 homes have been built. Chesterfield's fire station has been moved into the centre of Chesterfield so is even further away than it was before.
We have lost the HSBC bank and the Natwest bank is to close in the near future and the Royal Bank of Scotland is reducing its opening hours to 10am til 4pm - when most people are at work.

You, the council, took the decision to close the Dronfield Children's Centre. Again another useful resource you have removed that would be even more in demand should the population of Dronfield grow.

I'd also like to know why surveyors have been seen on the land at Hill Top and Coal Aston if we are still in consultation? This makes your whole process look fudged and corrupted from the start.

On a whole I hope you can see common sense and help Dronfield keep its distinguished boundaries. Once you release one plot of green belt, we all know that you will continue to do so and we will lose the boundaries between Sheffield and Chesterfield. We are already encroaching on Unstone with your plans. We will ruin this beautiful area and once the birds and wildlife and countryside have gone, we will never ever get it back.

LEAVE THE GREEN BELT ALONE..................PLEASE

Comment

Consultation Draft (February 2017)

Representation ID: 5034

Received: 28/03/2017

Respondent: Mrs Jane Singleton

Representation:

Questions raised over change in circumstances from September 2012 consultation on the Local Strategy to the 2017 draft Local Plan. Questions raised over 2012 predictions in population and how it correlates to the proposed 860 houses in Dronfield. Question raised over the change in figures from 285 houses to 860 and whether this will all be affordable if green belt is used. Questions raised over exceptional circumstances and questions of why the new local plan is not following the same policies as the 2012 local strategy. Questions raised over why the Alma site is not included in the plan. Statement that the Council by action is going against a plan which is still at the draft stage. Statement that Council has no sound or accurate evidence of local housing need and that all developments should start with 100% affordable housing.

Full text:

Re: Local Plan Consultation Draft
I wish to draw your attention to sections of your own documents which are available as supporting evidence for the basis of this local plan.
A Consultation on the Local Strategy which took place between 2 August and 13 September 2012 sought comments about the overall development issues and aims, how much new development there should be and where, and whether Green Belt land should be used to provide local affordable housing. At that time, your audience told you that there was strong local support for the retention of the Green Belt and any planned release of Green Belt land was only to meet identified local needs that could not be met within settlements.
You state that there was a predicted drop in population and the number of households with the overall trend being lower by 1,100 and households by 1000 up to 2031. There would be a slight increase in population up to 2020 and a decline from 2024. Based on this data of lower figures and a decline in the later years of the same plan period, I would like to know on what basis you have now arrived at a figure of 860 additional houses for Dronfield which represents an increase in population or housing stock of around 10%. Are you saying that all 860 homes are necessary and will be affordable if Green Belt is being taken? What about the previous figure for 285 houses. Is this no longer correct? It would appear that what you are now saying is that you need to provide for a 200% increase to equate with a slight increase followed by a decline in population.
In a previous iteration Green Belt sites were submitted through the SHLAA process but were discounted. Point 5.57 stated that National policy was clear that development in the Green Belt could only be justified in exceptional circumstances. The intention of the Council was to reconfirm existing Green Belt boundaries. You stated that limited opportunities to deliver affordable housing to meet local needs in the Green Belt may be justifiable in some circumstances. Again the current plan seems to be a complete U-turn on the sensible and responsible planning of the past. Here the key words are limited, affordable and local needs. What we have in the current plan is development on a vast scale with allocations of around 200 houses per site. It is market value, developer led, low density, large homes on big plots. This is not limited, not likely to be affordable and it is unproven that in fact there is a local need.
Point 6.31 stated that the construction of new buildings in the Green Belt should be regarded as inappropriate. There were exceptions for limited affordable housing for local community needs. The Council set out to assess whether some development primarily for affordable housing could be accommodated on sites covered by the Green Belt without undermining the overall role and purpose of the Green Belt.
The expectation was geared towards limited, affordable housing for local needs. In the current iteration of the plan, the Alma site which had housing until the late 1970s is a brownfield site in a central location, well-placed for existing infrastructure and access to a supermarket. The site could accommodate forty units under a clause for local rented/affordable homes for residents with a Dronfield connection. This is an ideal site. Where is it on the Local Plan? Has the Council explored this with the Town Council before coming for Green Belt land? This together with the 25 houses presumably for rent behind existing council houses on Stubley Lane would give a total of 65 with a further 6 in the proposals for the Manor.
The Manor complex will deliver six one and two bed apartments, but the Council is likely to build four family sized houses with south facing gardens to be sold at market value. Why not further affordable units at a higher density given the need, or even bungalows for an ageing population which is stated in the plan? This Council by action is going against a plan which is still at the draft stage.
I draw your attention to point 6.32 from the previous plan that the Council remains of the view that the high level of local need for affordable homes and the limited supply of unconstrained land could constitute exceptional circumstances sufficient to outweigh the Green Belt designation, in accordance with the NPPF. It is further stated that this could only take place on the basis that any development coming forward would be limited in scale and would deliver affordable housing, secured to meet local needs, with100% being the starting point for negotiation, and where any market element remains subsidiary to the primary affordable housing provision.
Firstly prove that there is a high level of need for affordable homes. Again there are comments about developments being limited in scale, serving local needs and starting at 100% affordable. Where in the latest plan is a responsible Council seeking these outcomes and where are they actively demonstrating that there is the 100% proviso first? The Manor development is a case in point.
The last iteration of the plan stated that: limited affordable housing within the Green Belt in the North will be permitted where:
a)They would provide affordable housing which would meet a genuine local need which is supported by an up to date housing needs survey that would not be met by a market housing proposal;
b)They are of a size, type, tenure, occupancy and cost suitable to meet identified local needs;
c)They are directly adjacent to the built up part of settlements; and are modest in scale, in keeping with the form and character of the settlement, and local landscape setting;
d) It can be demonstrated that the properties will be allocated to those who are in local housing need, and will remain affordable in perpetuity;
e) Proposals in the Green Belt do not have an unacceptable impact on the openness of the Green Belt. A small, subsidiary element of market housing may be permitted on such sites within the Green Belt in the North and West Sub-Areas only, where it can be demonstrated that
f) The market housing element is limited in proportion to that which is essential to enable the delivery of a viable affordable housing scheme to meet local needs, as demonstrated through a viability assessment;
g) Proposals are of a size, type, tenure, occupancy and cost suitable to meet identified local needs and (where applicable) be designed to ensure the integration of affordable and market housing such that they differ only in terms of tenure, i.e. not design, type or size.

I would like to ask this Council why there is nothing like this in the current draft plan?
The previous iteration makes a case for small scale development to satisfy a proven need.
This Council has no sound or accurate evidence of local housing need. Sites within the settlement development limits have not been fully explored e.g. The Alma. This Council is not even following its own rules as laid down in the plan with regard to proposed development in Dronfield and therefore it does not provide the exceptional circumstances necessary to take vast swathes of our beautiful landscape, which is highly valued not in monetary terms, but for health and well-being which is sustainable providing we retain it.

Comment

Consultation Draft (February 2017)

Representation ID: 5045

Received: 29/03/2017

Respondent: Don Longley

Representation:

The whole plan needs to be made clear and written in plain language that people understand.

Full text:

As a resident of Dronfield for 40 years. I feel I must Have a say!

Most people I have spoken to, don't understand the massive extent of this proposal.

These are large pieces of land! Just looking at Hallowes golf course this will disappear! leaving just a small section.

What good will that be? Many golfers think it is just a small piece of unused land.

The whole plan needs to be be made clear and written in plain language that people understand.

At this stage I must object strongly to any removal of green belt.

Comment

Consultation Draft (February 2017)

Representation ID: 5056

Received: 29/03/2017

Respondent: Alexandra Pollard

Representation:

Concern raised over the amount of planning terms used in the Local Plan making it difficult to understand.

Full text:

Since my last correspondence I have read and thought a lot about your development proposals and have honestly become more alarmed and frustrated by the day. Firstly, at the overwhelming length, overuse of acronyms and sheer volume of planning jargon used to present your case for altering the boundaries of the Green Belt. This plan is far from reader friendly and I believe it's your intention for it to be this way in order to bury your ludicrous proposals deep within and make it as difficult as possible for the general public to read and understand it.
I am also extremely irritated that since sending my email and letter I have received no acknowledgment from the Council Planning Policy Team. I can only hope that this is due to the sheer volume of objections you are receiving on a daily basis from fellow appalled Dronfield residents.
I understand and fully appreciate there is a need for housing but what I cannot comprehend is your justification for choosing the Green Belt. You have not demonstrated the exceptional circumstances required for the development of Green Belt, you have not published a Brownfield Review and you have not produced an infrastructure study to support these proposed plans. Your growth strategy indicates that there are 1,000 vacant properties across Bolsover and NE Derbyshire together with parcels of Council owned land. Why are these not being brought on stream to address housing demand? Instead you are targeting Dronfield's green spaces that provide so much happiness and enjoyment to the residents, families and children that live there, not to mention the visual impact you would be inflicting on the whole town.
I have read the local plan vision and am shocked by how obviously the plan conflicts with the objectives set out to achieve it. There is no evidence of any strategic co-operation with neighbouring authorities, the desire to protect local amenities conflicts with your plan which removes them and I do not see how the desire to increase tourism can be achieved by removing sections of Green Belt including existing recreation facilities such as an 18 hole golf course.
I live adjacent to Green Belt land and enjoy and appreciate its virtues every day. I would expect the next iteration of the plan to be better thought through and not contain any Green Belt land for removal. Until then I will continue to fight to protect it and I intent to write to my MP with the hope that the matter be elevated to a national forum.

Support

Consultation Draft (February 2017)

Representation ID: 5117

Received: 30/03/2017

Respondent: Mr C Pratt

Representation:

I support the draft local plan.

Full text:

I support the draft local plan.
I support the re-categorisation of Ashover and Kelstedge as level 3 settlements and Alton ,Fallgate and Littlemoor as level 4 settlements which now realistically reflect these communities.
I support the removal of housing growth for the rural west of the district.
I would seek the removal of paragraph 5.74 of the plan which potentially allows some market housing to be built in open countryside and replace it with adequate provision for affordable housing within the settlement development limits from the outset.

I hope this plan will be adopted with minimum delay.

Support

Consultation Draft (February 2017)

Representation ID: 5119

Received: 30/03/2017

Respondent: Mrs Muriel Pratt

Representation:

I would like to express my SUPPORT for the plan. I hope this plan will be adopted with minimum delay.

Full text:

I would like to express my SUPPORT for the plan.

1. I support the recategorisation of settlements within the Ashover parish as level 3 and 4 settlements and this realistically reflects these communities.

2. I support the removal of housing growth for the rural west of the district. This again makes more sense.

3. I think paragraph 5.74 should be removed as this potentially allows some market housing to be built in open countryside. It should be replaced with adequate provision to build affordable housing within the settlement development limits from the outset.

I hope this plan will be adopted with minimum delay.

Object

Consultation Draft (February 2017)

Representation ID: 5134

Received: 30/03/2017

Respondent: Amy Nolan

Representation:

Comment made that a consultation period of 6 weeks is not enough time for residents to properly consult on the plan. There is feeling in Dronfield that the local council is not listening and that politicians in power have absented themselves from dialogue with residents. This is simply not acceptable for an organisation that seeks to communicate with its public effectively. Statement made that the Dronfield plan is unsound and the objectives aren't deliverable.

Full text:

Re: Objection to the NEDDC Local Plan
I write to register my objection to the North East Derbyshire County Council's proposed local plan. Specifically, I object to the removal / reduction of the Green Belt surrounding Dronfield, and I object to the proposals to build housing developments in the areas indicated on the plan.

According to the National Planning Policy Framework (NPPF), the government attaches great importance to Green Belts. 'The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.' (www.gov.uk). Green Belt land around our historic town of Dronfield not only serves to restrict urban sprawl; it also preserves and protects the town's identity through prevention of merge between Dronfield, Unstone and Sheffield; and it assists in safeguarding our Derbyshire countryside from encroachment.

Construction of new buildings on the Green Belt is regarded as inappropriate by the NPPF. The only exceptional circumstances to this rule is for limited infilling in villages. The proposals set out in the Local Plan for Dronfield outlines development within the Green Belt that is neither limited nor exceptional, it is extensive and will have a huge impact on the openness of the Green Belt. 860 new homes, over five sites (four of which are on Green Belt land) to introduce thousands of new residents to the area is irresponsible and unsustainable. It is simply a panic response to a national housing shortage combined with pressure from profit hungry property developing land owners. Just two years ago (26.3.15), housing requirement for Dronfield was for 285 dwellings. 34 had been built the previous year, another 70 had planning permission, leaving 181 to allocate into the Local Plan at the time. This requirement has now multiplied drastically to 860. What is the reasoning behind this?

Unmet housing demand does not qualify as an exceptional circumstance. By taking the parcels of land proposed for development from Green Belt, NEDDC is irresponsibly contravening national planning policy guidelines for Green Belt functionality as outlined in the NPPF.

If these sections of Green Belt land are given up for housing development, it will no doubt set a precedent for more Green Belt to be taken in the future. The Green Belt is particularly narrow in places, so this would effectively merge Dronfield with Sheffield and/or Chesterfield and the smaller neighbouring villages. The character of Dronfield will then change from a rural town surrounded by quality green space around its fringes (the very reason it has been ranked 9th most desirable place to live and work in the UK in a recent study by the Centre for Economic and Business Research and the Royal Mail), to an over congested, over populated urban sprawl.

The Green Belt is also in place to encourage the recycling of derelict and other urban land. Where is the study of brownfield sites to identify areas for development as an alternative to Green Belt conversion in Dronfield? This option should most certainly be investigated before even considering the conversion of green belt land. The neighbouring urban area of Unstone (Chesterfield Borough Council) has extensive and readily available brownfield sites for potential development; the old boat yard and garden centre on the main road in particular (these in particular would benefit from housing development with the prospect of 1300 new jobs across the road at the Peak Resort, currently being built). Sheffield City Council is piloting a brownfield register which ensures all potential brownfield plots are identified for development. Sheffield is one of fifteen councils with the most brownfield land in England, as identified in the final complete publication of National Land Use Database statistics. As neighbouring councils have a duty of co-operation, how can NEDDC justify building on Green Belt with acres of brownfield land so close by? It's hardly an exceptional circumstance.

If neighbouring councils have a duty of co-operation to reach a common goal; where is the evidence of partnership working between NEDDC and Chesterfield Borough Council? They have identified brownfield sites within their Local Plan, with enough space to build more than enough homes for their allocation. There are also some brownfield sites ripe for regeneration within Dronfield; although admittedly these are smaller, the NEDDC Local Plan fails to explore these as viable options. Planners at the NEDDC Public Consultation admitted that a brownfield site survey had not been funded. Why has NEDDC gone for the easy option of planning to build on Green Belt? I have my suspicions it is all to do with the amount of profit to be made.

Much of the land within proposed development sites south of Dronfield Green Belt is actively farmed, or is woodland. Removal of farmland, as well as woodland areas and other green space has an immediate impact on the water cycle in the area; less trees and vegetation means flooding. Large, ancient woodlands being replaced by urban areas full of impermeable materials such as tarmac, concrete and brickwork means less infiltration into the land, more overland flow and therefore more flooding, which would likely affect the main entry road into Dronfield from Unstone taking into account the local gradient. Pollution levels will rise as vegetation acts as a natural filter; this is a particular worry for children and those with asthma, breathing difficulties and heart disease.

The NEDDC plan actually states that 'Dronfield is significantly lacking in green space.' Removal of green space (of which south Dronfield, where the majority of development is planned, has the smallest share of the whole town) has many overwhelming effects. Dronfield Green Belt land isn't just aesthetically pleasing, and home for a variety of species of flora and fauna (including 'at risk' species); it is land that is used by numerous people. Golfers, horse riders, cyclists, joggers, walkers (some with dogs), new mums with babies, wildlife spotters, families spending quality time together all use the green space marked for development. Green Belt land and the roads leading to it provide us with access to the Dronfield Round Walk. Studies show that Green Belt is hugely important for the physical and mental wellbeing of its users, not only for recreation. With mental health illness on the rise, especially in children, the new housing our country needs should not be built on quality Green Belt. A European study featured in The Guardian on 21st March 2017 concluded that access to nature reduces depression and obesity. We are a family with two young children, and a walk around the public footpath on the golf course is a purposeful family activity, which we do often (for a variety of reasons ranging from exercise for ourselves, walking our dog, de-stressing after a tough working day, enabling the children to emit some energy, talking about and therefore consolidating our children's learning from the school day, to take a break in the fresh air as I work from home.....). The roads we use to gain access to the green space are safe enough for our children to walk, scoot or ride bikes on; these routes are under threat.

Government policy on the creation of local plans states that 'the Local Plan should make clear.....what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development.' The proposed NEDDC Local Plan does not have any such infrastructure plan, with the verbal discussion with the planners confirming this will be considered at a later date. Road access, provisions such as schools, GP surgeries, dentists; all needs to be considered before the Green Belt is converted. NEDDC cannot simply just remove Green belt on the basis of developing a plan later. This is unacceptable and contravenes government policy.

The Local Plan and the supposed suitability of Dronfield for new housing development relies heavily on the current amenities that Dronfield offers, the presence of a railway station in particular. However, parking facilities at Dronfield Railway Station cannot accommodate any more passengers. As so many rail passengers use their car to drive to the station, the car park is already overflowing with current usage. There is no extra space to expand to accommodate the cars of even more passengers. Train operators are soon going to add cross hatching in the centre section of the car park to reduce available spaces further. The Local Plan specifies developments on the outer fringes of Dronfield, the furthest distance to the station, which together with the topography discouraging people to walk, means even more cars. The idealistic view that people will walk to the station to commute to work in Sheffield or Chesterfield by rail is essentially flawed.

The railway track in the north of England will soon be electrified. However, Arriva, Northern Rail and Network Rail are currently analysing the possibility of moving Dronfield Railway Station to an out of town location, as the current station has listed bridges that prevent the electrification taking place. This currently has no workable solution, and as such, the station cannot be used as the basis for justifying Dronfield as a suitable place to develop new housing.

Other amenities Dronfield offers are supposedly attractive for local development. I strongly believe that the amenities we have cannot sustain any more people. Dronfield Medical Practice, our GP surgery at the Civic Centre, is absolutely full; to get an appointment we must ring at 8am when it opens, and keep redialling until we get through, by which time it's highly likely that all the appointments for the day have been booked up (this process can last 45 minutes). It is not possible to book for the next day. So if we struggle to get an appointment now, where will all the extra residents living in the proposed houses go for their doctor's appointments? It isn't likely that there will be funding for a new GP surgery, so presumably they will just be expected to squeeze in to current resource, which is not sustainable for the surgery, the doctors, or the community. Recruiting GPs is also very difficult these days. None of this has been considered apparently, without an infrastructure study.

The second bank in Dronfield has just announced closure (HSBC closed earlier in the year, NatWest will soon be closing). We have no counter service in the town when this closes, meaning people have to travel further afield to deposit cheques, pay in cash etc. This is not convenient for small businesses and the self-employed, who have regular amounts of cash and cheques to pay in. The elderly, who prefer to do their banking face to face, and those who don't have internet access will struggle with the closure of the banks locally. So the plan cannot be based on a service that, soon, will no longer exist.

The council run gym and swimming pool are used to capacity. Bookings for exercise classes are accepted a week before the class is run; places are released at midnight, and on average, by around 12.30am the popular classes are fully booked up. In the new year, even regulars can't get booked on for all the new faces following new year resolutions. This is less than ideal for current members, even before more members are applying for the same places on classes throughout the year.

Hallowes Lane site partially lies within an area that has been defined by the Coal Authority as high risk, containing potential hazards arising from former coal mining activity. This is likely to have implications for new residents applying for mortgages; lenders aren't keen to lend finance secured on properties where environmental search results are returned with problems highlighted.

A major concern that I have issue with, is the education provision in the catchment of the proposed building sites. The primary school provision for the south of Dronfield sites is already full to bursting. Both Dronfield Infant School and Dronfield Junior School are already massively oversubscribed, classes are very large (mostly over 30).

Dronfield Junior School currently does not even currently have the space to house all the pupils at the school in one room at any one time. The hall is not big enough to hold a whole school assembly. When events are held at school, such as school discos, the children have to arrive and leave in year groups, they can't all enjoy time together. At lunchtime, midday supervisors have to split the children into four separate rooms to enable everybody to eat within the lunch hour. Accepting yet more pupils into an already overflowing building just would not be possible, it will be detrimental to the experience of existing pupils and potential new ones.

If planners only have to allocate provision for a new school for 1000 new homes, and 860 dwellings are planned (so no new school), where are all the extra children going to receive an education? There will simply be too many children in the catchment. There is absolutely no space to extend at either Infants or Juniors on School Lane. The buildings already encroach onto the playground space; at Infants the playground doubles as a car park (which is less than ideal), and at Juniors, temporary (portacabin) buildings house more children. OfSted encourage learning through play, much of which is delivered outside (particularly at Infants); so extending into the playground would be detrimental to this method of teaching. Neither school has a grass field on site for outdoor learning or PE; The Junior School owns the very sloping field at the top end of School Lane, but this (being open to the public) is covered in dog faeces, and as such is not used much in order to protect the health and hygiene of pupils. An increase of over 30 children in each academic year group means another whole class per cohort, which the schools simply cannot accommodate. If there's a risk that not every child living in Dronfield could be accommodated, even if it's small numbers, that's totally unacceptable for residents old and new.

Once again, since neighbouring councils have a duty of co-operation with each other, NEDDC should be talking to Sheffield, Chesterfield etc. regards the impact on their school places if Dronfield Henry Fanshawe School (the one and only secondary in Dronfield) ceases to accept pupils out of catchment area. Are there other secondary schools in Sheffield / Chesterfield with capacity? But no, this scenario hasn't been considered as no infrastructure study has been completed.

The areas for development are unsustainably distant from the school sites, which again, encourages car use for the school run. On street parking is already strained, and the routes to school from the proposed sites involve roads which are unsafe to walk with children (narrow footpaths, or no footpath at all) e.g. Hallowes Lane, which would be used to access the Shakespeare Crescent and Hallowes Drive sites).

Another serious concern I have is how roads in Dronfield are not fit for 1000+ more cars. 860 new houses will mean many more cars in Dronfield and extension to the industrial estate will mean more HGVs and commercial traffic. Traffic congestion and road safety throughout the town will worsen, especially in busy places such as High Street, and around schools, shops and the post office. Many roads are particularly narrow, and added to this how residents park on the road outside their houses in the residential areas (some partly on the pavement, some on the road itself), means it is often necessary to weave in and out to get to a destination in the town. Parking is already a struggle, especially around schools, near shops and for the train station. Whilst a developer may be expected to provide the road network from their new developments to existing roads, there will be presumably be no deliverable improvements to the rest of Dronfield, which isn't acceptable. I believe that these plans ultimately put lives at risk due to inadequate infrastructure, to which I believe councillors will be held liable. They will be responsible if development goes ahead, which then correlates with an increase in road traffic accidents in Dronfield.

There has been no consideration given to the topography of the area; many people choose to drive rather than walk, even for short distances, as the area is so hilly. This means that a larger population using the same amenities will worsen pollution caused by motoring. I do not believe that increasing the frequency or providing different routes for public transport will alleviate this issue. The vast majority of people in Dronfield use their own personal car as a means of transport. Many parents drive to school to drop off their children, then drive on to their workplace afterwards; this is simply not feasible using public transport.

The map of proposed build areas, assumes Hilltop Road as the main route into the developments proposed for the south of Dronfield. According to highway records, this road is currently classified as an adopted non-classified highway, with no restrictions on what types of vehicles and use it. However, this is misleading as it is a single lane farm track for much of the road, and cannot sustain any vehicles larger than cars, small horseboxes and some caravans. The wider, straighter part of the road is congested already, so much that refuse lorries have to mount the pavement to allow cars to pass. If HGVs were to be accommodated along the route (deliveries for building supplies, concrete mixers for foundations etc.), the road would most definitely need to be widened, and pavements added, which would alter the character of the area and prove very costly (and impossible in places due to homes/gardens already there). It also has a steep gradient, which is not ideal for icy conditions in winter. Shetland Road (a long steep gradient), which we assume will be the main route into the Hallowes build site, annually becomes so icy that cars and vans struggle to get up/down. Buses redirect their route when freezing temperatures hit, and many residents leave their cars at the bottom of the hill on Hollins Spring Avenue, in order to ensure they can get to work the next morning. Has any consideration been given to what will happen to the hundreds of extra cars if they too can't get up the hill in winter? There is no car park at the bottom, so they will end up clogging up Hollins Spring Avenue.

Finally, I believe the communication of The Local Plan to members of the public, is questionable. I do not feel a consultation period of just 6 weeks is enough time for residents to read, absorb, understand and react to 270 pages and associated studies. The plan may be available to read online, but to the average person who is not familiar with the terminology, acronyms and specialist jargon used throughout the Plan, it doesn't make for an easily digestible read. A charge of £18 for a paper copy for those who don't have internet access is extortionate. The public consultation held in Dronfield was very short, very busy and many people didn't get the opportunity to talk to planners. I managed to raise my concerns to one representative (with 'Planner' on his ID badge), who just kept re-iterating that he had just been asked to help out as they were short staffed, he hadn't actually worked on the plan, and very worryingly had very little local knowledge. He hadn't visited the sites in question, he wasn't aware of the over-full schools, or the problems trying to get a GP appointment. This is just not acceptable when representing a team who are making town-changing decisions. Other residents who spoke with planners left with the impression that the plan for Green Belt development was a 'done deal', and that lip service was being paid to the consultation process. Surveyors have been seen in Coal Aston, although the consultation period still has time to run, which makes a mockery of the process. There is an overwhelming feeling in the town that our local council is not listening and that politicians in power have absented themselves from dialogue with residents. This is simply not acceptable for an organisation that seeks to communicate with its public effectively.

In view of all the above points, concerns and considerations, I believe it to be unacceptable for the council to propose the removal of sections of Green Belt land surrounding Dronfield. I believe this plan is unsound for Dronfield as objectives are not deliverable, what is being proposed is irresponsible without a sound infrastructure plan included at the consultation stage, and it is contrary to national planning policy in respect of Green Belt legislation.

Comment

Consultation Draft (February 2017)

Representation ID: 5163

Received: 30/03/2017

Respondent: Severn Trent Water Ltd - Birmingham office

Representation:

Thank you for giving Severn Trent Water the opportunity to comment on your consultation. We currently have no specific comments to make, however we have set out some general information and advice below.

Full text:

Thank you forgiving Severn Trent Water the opportunity to comment on your consultation. We currently have no specific comments to make, however we have set out some general information and advice below.

Comment

Consultation Draft (February 2017)

Representation ID: 5175

Received: 31/03/2017

Respondent: Morton Parish Council

Representation:

Since the initial local plan started in 2011 total housing completions within Morton have reached 53 with a further potential planning application for another 48, this should be taken into account within the plan. If an additional 100 homes are built, it would grow the village by 20%+ which cannot be supported by the infrastructure.

Full text:

In response to the recent publication of the local plan for North East Derbyshire we would like to offer the following comments for discussion and review:

4. Spatial Strategy

Distribution of Growth & the Settlement Hierarchy.

Ref 4.27 - Morton has been categorised as level 2 as a "Settlement with a good level of sustainability". This ranking is obtained from findings in the settlement and hierarchy study (December 2016). We believe this categorisation is incorrect and should be reviewed.

5. Living Communities

Ref 5.44 - The area identified for development has been categorized by the Coal Authority as high risk, as the land contains potential hazards from former coal mining, making it potentially costly and unsuitable for development.

9. Infrastructure and Delivery
9.44 - Public Transport

When allocating development sites accessibility to bus services has been a key consideration.

From the Settlement and Hierarchy study the following points are made:

Morton is a linear settlement in the southern part of the District.

The results give 5 buses passing through Morton, 55, 55x, 149,150 and SP1. 

Only the 149 and150 actually pass through the village but they only run every 2 hours. 
The 55, 55x and SP1 services run hourly but only stop at the Corner Pin which is at the far end, on the outskirts of the village before travelling towards Pilsley. They do not pass through the village and due to the linear nature of the village they are not accessible to most villagers. 
The proposed location for the new builds is some distance away from the 55, 55x and SP1 bus routes and will not be serviced by these buses.

Although the study is based on timetables they do not take into account the bus routes which do not pass through the village. The unique geography of Morton village (i.e. linear) would suggest a subjective view may be more appropriate.

We believe judgements should be made about which services to include or not, especially when they do not serve the village. This should be taken into account within the scoring mechanism The current scoring is 24 which should be revised to 8 excluding the 55,55x and SP1.

9.68 - Plan Delivery and the role of developer contributions.
"the Council will require the developer to contribute towards infrastructure"

This has not been the case on previous developments within Morton when the Section 106 agreed contributions have been removed during the build process. This is particularly important for the schooling provision within Morton as an earlier study "Settlement role and Function Study Dec 2013" stated that Morton school had a net capacity of 70 and was oversubscribed by 24.3%. This was the third worst in the whole NE Derbyshire area and only three schools in all categories have less capacity. The school is unable to accept any new pupils and local villagers currently have to find alternative school places elsewhere.

General comment

Since the initial local plan started in 2011 total housing completions within Morton have reached 53 with a further potential planning application for another 48, this should be taken into account within the plan. If an additional 100 homes are built, it would grow the village by 20%+ which cannot be supported by the infrastructure.

It is with respect we would ask the issues raised above to be considered and for North East Derbyshire to downgrade the Level 2 categorization for Morton to level 3.

Comment

Consultation Draft (February 2017)

Representation ID: 5202

Received: 03/04/2017

Respondent: Mr Eric Singleton

Representation:

The quality of the English and the arguments within the plan fall way below that which should be produced by competent and qualified professionals. Plan complex and consultation is not an inclusive process.

Full text:

Comment Scope As a resident of Unstone, my comments are primarily regarding the plan for the Dronfield area; I have not reviewed sections that deal specifically with other areas.
Overall Summary The plan does not make a case that there are exceptional circumstances to justify the removal of land from the Green Belt around Dronfield. The council concedes it has not considered alternative options in the area. The plan is a developer's charter to maximise profit by building on easy to develop green field sites. It will be especially beneficial to developers who have purchased green belt land at agricultural prices in the expectation that the council would eventually capitulate in the face of their lobbying.

The plan does not cite any evidence of changes in local circumstances to justify the increase from the 285 additional dwellings in the Dronfield settlement in the plan issued for consultation between 12/02/2015 and 26/03/15 and the 860 proposed in this plan. The settlement targets in this plan appear to be a distribution of an overall target based on existing settlement size: that is not planning, it is quota allocation of the crudest form. Whilst the council suggests there is a need for 6,000 additional dwellings in the NE Derbyshire area, developers do not appear to agree. If there was significant unmet demand developments such as the Waterside scheme in Chesterfield would have been nearing completion by now, not still open land.

The council acknowledge the green space, outdoor sports and children's play space in Dronfield falls below current standards, yet proposes to make matters worse by planning to build on a golf course in Dronfield and sports ground in Coal Aston whilst making no commitment to provide further outdoor facilities. This is contrary to one of the requirements of sustainable development: to protect and enhance the environment.

The council acknowledges that there is currently no agreed plan nor any binding commitments or safeguards to ensure improvement of the infrastructure necessary to accommodate the additional demand from the planned 860 additional dwellings in Dronfield. The plan must be as unambiguous in its commitment to implementing infrastructure improvements as it is with respect to the number of dwellings proposed. Anything less than this is a plan to inflict environmental damage and congestion blight on the community.

The plan contains multiple contradictions and inconsistencies and includes statements in breach of the policies contained therein.

The plan contains numerous statements with meaningless verbs e.g. the council will encourage, support (without quantification); seek. The use of this language renders what, at first sight, appears to be council commitments to implement controls and safeguards, completely impotent. The persistent use of this language renders the plan misleading.

Consequently, the plan is unsound.
The whole document The quality of the English and the arguments within the plan fall way below that which should be produced by competent and qualified professionals. In particular, the use of the word 'sustainability' ad-nausea is an example of how the plan is full of bland 'planning speak' with little consideration as to the purpose of the statement or point being made. Significant portions of the plan look suspiciously like a copy and paste of boilerplate text.

The council's planning department should review the plan issued by Chesterfield Borough Council and its own plan issued for consultation two years ago; both are significantly better than the current plan.

1.5 Statement "the Council has produced this document for public consultation"

As a core document for a public consultation it is woefully inappropriate. The text is full of planning jargon; acronyms and references to a significant number of related documents.

For example, section 6 makes repeated references to B1, B2 and B8 usage of employment land. Not until 6 pages into section 6 are these terms defined in policy WC2, below paragraph 6.26. Non-B8 classes (paragraph 6.16) are not elaborated.

At least one referenced document (Derbyshire Infrastructure Plan) is not included on the evidence page on the council's website, nor does a search on its name return a link.

To comment effectively on this document requires critical reading and analytical skills associated with a degree level education.

The FAQ leaflet available at the public consultation is equally challenging to comprehend. Paragraph 2 comprises one 56-word long sentence of 'planning speak' punctuated by one semi-colon and one comma.

Whilst the Local Plan and FAQ leaflet is offered in 5 alternative languages and large print, it is also written without consideration for anyone without higher educational level comprehension skills.

Consequently, the consultation is not an inclusive process. The consultation process is therefore fundamentally flawed.
1.14 Statement "The NPPF states that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development".
There is no such thing as the sustainable use of a non-renewable resource, such as the proposed building on land that is currently Green Belt around the Dronfield settlement. The land at Hallowes in Dronfield particularly is currently used for recreational activity; the land adjacent to Shakespeare Crescent in Dronfield is actively farmed. These resources are irreplaceable; once lost, neither will ever be recovered.

The NPPF paragraph 7 states there are three dimensions to sustainable development: economic, social and environmental. The latter includes a requirement to minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.
The proposal to build 860 more dwellings (an increase in 10%) without a commensurate increase in local employment will drive up commuting, CO2 emissions and pollution; that is not sustainable and is contrary to the above NPPF requirement.
1.16 Duty to Co-operate. The only evidence in the plan of the council discharging this duty is co-operation with Bolsover District Council with respect to the Coalite Regeneration Area (paragraph 4.58). There is no evidence of any co-operation with either Chesterfield or Sheffield Councils. This is a major oversight, particularly with respect to the plan for Dronfield.
2.15 The statement "Just under a quarter of households cannot afford market housing" i.e. just over 75% of households can afford market housing. A recent Shelter report suggests on average 80% of families across England are unable to afford newly built homes in their local area. This statement demonstrates that affordability in North East Derbyshire is dramatically better than the national average.
2.17 Statement "The town centres of Clay Cross, Dronfield, Eckington and Killamarsh are all in need of continued support and investment to build upon their strengths, and to help sustain and regenerate them into the future."
However, the plan contains no commitments on investment. A plan to build 860 additional dwellings in Dronfield without a commitment to invest in the infrastructure will negatively impact the quality of life of existing residents; driving up congestion, pollution and CO2 emissions. This is contrary to the council's stated objective D1 Sustainable Growth; D8 Addressing Climate Change
2.20 The council notes that Dronfield is the only town with a railway station. However, there are no connecting public transport links from the outer reaches of the town. Consequently, train users who live more than a few minutes' walk from the station use their car to reach the station creating a serious problem with on-street parking. A failure to commit to addressing this issue whilst proposing a circa 10% increase in households is contrary to the council's stated objective D12 Sustainable Transport and in breach of policy SS1 clause C.
3.5 Statement "much needed affordable homes". The data provided in paragraph 2.15 indicates affordability is not an issue in NE Derbyshire.
3.5 Statement "and regenerate and renew their [Dronfield, Eckington and Killamarsh] towns' centres". The plan contains no binding commitments or obligations that will ensure the delivery of this vision.
3.5 Statement "In planning for growth new high quality housing will have successfully integrated itself into these settlements minimising its impact upon the strategic functions of the Green Belt, and creating strong defensible boundaries for the future."
The council will be aware that a developer owns Green Belt land adjacent to Shakespeare Crescent that is beyond the proposed development boundaries. Any removal of land from the Green Belt will set a precedent. Strong defensible boundaries will only be established with a clear policy of making no changes to the Green Belt.
3.9 Statement "seeking to narrow the gap between the more deprived areas and the more affluent areas". Why is this an objective of the plan? It smacks of left wing social engineering.
3.9 Objective D7 Settlement Identity
The proposal to remove land from the Green Belt adjacent to Shakespeare Crescent is contradictory to this objective. From significant areas in Apperknowle and Hundall Dronfield and Unstone will appear to merge if this land is developed.
The council's planning policies have historically failed to meet this objective; within this plan Coal Aston is shown as within the Dronfield settlement boundary. The plan does not provide evidence as to how it will meet this objective in the future.
3.9 Objectives D8 Addressing Climate Change, D13 Local Amenity

4.5 Policy SS1, Sustainable Development, clauses c and g

Policy SS3 The plan issued for consultation between 12/02/2015 and 26/03/15 stated there was a need for 285 dwellings in the Dronfield settlement between 2011 and 2031, with a residual requirement for 181 after accounting for those built or planned. This plan now states 860 dwellings are required, but provides no justifiable change in local circumstances (i.e. additional employment in the area).
Policy SS3 states that employment growth will be on four strategic sites to the South and East of Chesterfield. It therefore follows that the plan for 860 additional dwellings in Dronfield is environmentally unsustainable; will increase commuting to Sheffield, Chesterfield, and through Chesterfield to the strategic development sites, resulting in increased congestion, pollution affecting large numbers of North Derbyshire residents and increased CO2 emissions. This is inconsistent with objectives 3.9 D8 and D13, and in breach of policy SS1 clauses c and g.
3.9 Objectives N1 Statement "To ensure the vitality and viability of Dronfield, Eckington and Killamarsh town centres by supporting improvements compatible with their local employment, retail and service functions". Explain what the council will do to ensure these improvements are implemented. The plan contains no binding commitments or obligations that will ensure the delivery of this objective.
3.9 Objectives N3 Statement "To improve the quality of employment land in the north of the District and address infrastructure deficiencies to allow for the expansion of existing sites, such as at Callywhite Lane, Dronfield". Explain what the council will do to ensure these deficiencies are addressed. The plan contains no binding commitments or obligations that will ensure the delivery of this objective. The deficiencies at Callywhite Lane are decades old; the council has demonstrably failed to address them to date.
4.4 Statement "The Local Plan's vision and objectives are centred on .... supporting the health and wellbeing of the District's communities".
The planned addition of 860 dwellings in Dronfield without major investment in infrastructure (e.g. an additional exit and access to the A61 dual carriageway) will blight Unstone which is centred around the major routes from the south into Dronfield. This is contrary to the stated vision and objectives.
4.5 Policy SS1, Sustainable Development, clause a: "key business sectors" is meaningless; define "key".
4.12 The statement "The Local Plan aims to provide new jobs" is both false and misleading. The most this plan can potentially achieve is to ensure the development of an environment sufficiently appealing to attract additional employment. The additional congestion in the Dronfield area is likely to do the opposite.
4.12 Statement "[The Local Plan] acknowledges the 61% of people who commute out of the District to work".
Consequently, the Local Plan also acknowledges that providing an additional 860 dwellings in Dronfield without a commensurate increase in local employment will increase commuting, congestion and CO2 emissions. This is inconsistent with objective 3.9 D8 and in breach of policy SS1 clause (c).
4.18 The Plan notes that all the larger employment development sites are to the East or South of Chesterfield. On what basis does the Council justify a 200% increase in the planned dwellings for Dronfield since the plan issued for consultation between 12/02/2015 and 26/03/15?
4.21 Statement "The Council's Growth Strategy has the intention of raising job densities (jobs/worker) within the District"
The plan to build 860 homes in Dronfield will significantly reduce the job density within the settlement.
4.26 The statement in paragraph 4.26: "the Local Plan aims to direct new growth to the district's most sustainable settlements based on the Settlement Hierarchy" and repeated in paragraph 7.4 conflates settlement size with 'sustainability'. This plan offers no evidence to demonstrate that enlarging an already large settlement by building on land currently designated as Green Belt is more 'sustainable' than other options. As noted in the response to paragraph 1.14, there is no such thing as a sustainable use of a non-renewable resource, such as the proposed building on land that is currently Green Belt.
4.28 Statement "Level 1 Settlements ... are considered to be the most sustainable locations for new development ... because they generate the greatest needs for new housing, jobs, services and facilities."
This statement is misleading: the size of a community does not necessarily correlate to job volume creation. The plan does not provide evidence that Dronfield will generate the number of jobs commensurate with 860 additional dwellings. The chronic underutilisation of the Callywhite Lane employment area in Dronfield is evidence of the councils' past failure to provide an environment attractive to new businesses.
4.59
4.69
Policy SS3
Policy SS9 As noted in 4.59: "The essential characteristics of Green Belts are their openness and their permanence..." and in paragraph 4.62: "National Guidance is clear that Green Belt boundaries should only be altered in exceptional circumstances."
The evidence base referenced in policy SS3 does not fulfil the requirement for "exceptional circumstances" that are necessary to take land out of the Green Belt.
As acknowledged in Policy SS9 "The NPPF tells us that inappropriate development is harmful to the Green Belt and should not be approved except in very special circumstances. LPAs should respect the permanence of the Green Belt."
The proposal to take land out of the Green Belt around Dronfield is in breach of policy SS9 and the exceptional circumstances stated therein.
Policy SS9 does not implement Local Plan Objective D6 as claimed. The proposed removal of land from the Green Belt adjacent to Shakespeare Crescent in Dronfield breaches the permanent nature of the Green Belt, rendering any Green Belt land adjacent to existing settlements at risk to further encroachment. The council will be aware that a developer owns land adjacent to Shakespeare Crescent which extends beyond that being proposed for removal from the Green Belt. Once development is permitted on part of this land, the developer will inevitably seek to develop the remaining land in their ownership in the future. The council's policy is encouraging and rewarding developers who speculatively purchase prime Green Belt land, at agricultural land prices, in the expectation that councils will eventually capitulate to pressure to develop these sites.
4.64 Statement "This evidence led the Council to undertake a review of the Green Belt during 2016 and provides the exceptional circumstances necessary to justify alteration of the Green Belt boundaries."
This statement is nonsense. A review does not "provide exceptional circumstances". Exceptional circumstances either exist or they do not. This statement is overt evidence of the council's flawed logic in proposing land be removed from the Green Belt. This plan does not make the case that there are exceptional circumstances.
4.65 The statement "This means that if we wish to achieve a more sustainable pattern of development and provide a sufficient level of development in the North of the District to meet needs, we must accept that this will have an impact on the Green Belt." is further flawed logic. As argued in the comments above, the planned 860 dwellings in Dronfield is unsustainable. There is no inevitability to the loss of Green Belt land. The Local Plan contains no evidence that alternatives have been explored.
4.66 Contrary to the assertion in this paragraph, the land adjacent to Shakespeare Crescent in Dronfield does perform a valid Green Belt function. From significant areas in Apperknowle and Hundall Dronfield and Unstone will appear to merge if this land is developed. This land is also currently actively farmed; one of the fields proposed to be removed from the Green Belt has recently been ploughed.
4.73
4.74
4.75
Policy SS11 Statement in 4.73 "the Local Plan seeks to protect settlement identity and avoid further settlement coalescence". Definition of Local Settlement Gap functionality in 4.74.
As noted above, the proposed removal of land from the Green Belt adjacent to Shakespeare Crescent in Dronfield will lead to Dronfield and Unstone appearing to merge. It will also provide a separation of no more than circa 200 metres along the B6057 between Dronfield and Unstone.
The council has patently failed to protect historic settlement identities: Coal Aston is shown as within the Dronfield settlement boundary within the plan; paragraph 4.70 acknowledges loss of settlement separation in the south of the District. The plan is repeating this mistake on the southern boundary of Dronfield.
The council acknowledges in 4.75 that it has been incompetent at preserving settlement gaps. Consequently, policy SS11 is worthless.
Given the council's inability to maintain settlement gaps, the land adjacent to Shakespeare Crescent must remain in the Green Belt to protect the settlement gap between Dronfield and Unstone.
4.78 Statement "Outside Settlement Development Limits, countryside and/or Green Belt policies apply and all proposals for development will be considered against these requirements set out [sic] in Policies SS14".
Taking land out of the Green Belt outside the current Dronfield settlement limit is the exact opposite of this statement.
4.79 The plan states "Further land outside Settlement Development Limits is therefore not required to meet this [housing provision] need." Consequently, there is no need to take land out of the Green Belt around Dronfield.
4.80 Statement "The Settlement Development Limits identified on the Policies Map have been carried forward from the 2005 Adopted Local Plan. However, this only applies to settlements that fall within categories 1, 2 and 3 as set out in table 4.1." Dronfield falls into category 1. Consequently, the plan states the council does not intend to change the settlement development limit of Dronfield. Therefore, on what basis does the council justify the proposal to take land out of the Green Belt?
5.6 The council's figures show that windfall developments between 2011 and 2016 account for 5% of the proposed needs, but windfalls have not been factored into the plan. The council also states minor sites have not been relied upon nor have "major sites with planning permission which do not accord with the spatial strategy." This latter statement is clearly a reference to sites such as Callywhite Lane in Dronfield where there is little prospect of attracting new businesses and land has remained undeveloped for 10 years or more despite developers submitting planning applications for housing.
The NPPF states that ""Very special circumstances" will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations." Contrary to this guidance, the council has opted to target Green Belt land for development without a rigorous assessment of other contributions to meeting its targets.
5.7 The plan states "There are also a number of sites across the District that have planning permission where there are deliverability concerns and / or a history of unimplemented permissions." The council offer no evidence of actions to understand and resolve the issues leading to this situation, further evidence of inadequate consideration of other options before targeting Green Belt land.
5.8 There is no sound evidence offered for only considering sites capable of accommodating 10 or more dwellings. This indicates the council has been unable or unwilling to fully assess all options before proposing to take land out of the Green Belt.
5.65 Statement "Many households in North East Derbyshire who lack their own housing or live in unsuitable housing cannot afford to buy or rent housing at market rates." is ambiguous without defining "many". It is misleading and, by any reasonable interpretation, contrary to paragraph 2.15 where the council states that just over 75% of households can afford market housing.
Policy LC3 As the council notes, the NPPF states the construction of new buildings in the Green Belt should be regarded as inappropriate apart from a small number of specific exceptions. The scale of development proposed is way beyond that covered by the "limited infilling in villages" exceptional condition in the NPPF. The proposal to develop Green Belt land around Dronfield does not meet the remaining exceptions and is therefore in breach of the NPPF.
5.85 The statements "The Council will seek to ensure that the housing needs of older people and people with disabilities are met" and "It will encourage developers and other agencies to provide dwellings which will enable more people to remain in their homes" are meaningless.
State exactly how the council will ensure this housing need will be met.

It is notable that Rykneld Homes are building four family-sized market value homes on the former Manor Farm site in Dronfield. The site is in close proximity to shops, a medical centre and public transport links. As such, the site is an ideal location for housing for older people, people with disabilities, or affordable housing; yet the council, through its partner Rykneld Homes, chooses to build larger market value properties. Council leader Graham Baxter has said of this scheme: "The key strategic approach to this project is to create a high quality scheme of housing for open market sale, to provide a significant financial surplus". When presented with an excellent opportunity to provide housing for older people or those with disabilities, the council chooses instead to maximise its income from the site. This is indicative of what can be expected to happen if development is permitted on land which is currently Green Belt.
5.86 Statement "The SHMA indicates that there is a particular shortage of market housing and intermediate housing which is suitable for older people". The council is responsible for contributing to this situation. The council has permitted a significant number of bungalows adjacent to Frith Wood and in other areas of Dronfield to be converted to two storey dwellings; more recently bungalows have been demolished to be replaced by family houses (e.g. Carr lane near Stubley Lane). The plan should incorporate an unambiguous commitment by the council to mandate developers to provide a specified proportion of dwellings suitable for older people of the types listed.
5.86 Statement "Access to high speed broadband will allow access to emerging online healthcare initiatives". State what the council proposes to do to ensure this access is provided. If the council do not intend to implement measures to ensure this access, the statement is irrelevant.
5.87 The statement "the Council encourages all new dwellings to be made accessible and adaptable." is a further example of the meaningless statements peppering this plan. I suspect the council meant to say it will encourage developers; it is impossible to encourage a dwelling to do anything.
Policy LC4 Statements "The Council will support the provision of housing for older people" and "The Council will also support the provision of specialist housing"
Quantify what the council means by "support". In the context used support means "give assistance to", requiring a commitment of resources; outside the voluntary sector resources cost money. Define the budget the council intends to set aside for this support and the governance that will determine how funds are accessed and best value is ensured.
Statement "development proposals of 10 or more dwellings should provide 20% accessible and adaptable dwellings". "Should" means this is an optional requirement and therefore not to be relied upon. This statement is of no value unless "should" is replaced with "shall".
To summarise; within policy LC4 the council has not made any quantifiable commitment to ensure the housing needs of older people or those with special needs will be met.
6.2 & 6.8,
Policy WC2 Statement "Existing employment sites will be protected for employment uses". There is no point in protecting land which has remained unused for extended periods and where there is little or no prospect of it being used for employment. The old Padley and Venables site on Callywhite Lane in Dronfield has not been used for employment purposes for at least 10 years and has been the subject of a planning application for housing development. The council acknowledges the challenges of this site in paragraph 6.8 and notes the need for significant investment.
Within the evidence base for policy WC2 the council acknowledges that the NPPF states planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. It also notes public feedback that "considerations should be made over whether a site should be protected where it is clear that employment uses cannot / will not come forward."
The plan currently states the council's intention to continue protecting Callywhite Lane for employment use but does not include a commitment to the investment it acknowledges is necessary to resolve the issues causing the chronic underutilisation of the site. This is in breach of the NPPF guidance quoted in policy WC2 and completely disregards the public feedback acknowledged in this policy.
The council should therefore release this land for housing to reduce the pressure on prime Green Belt land.
6.5
3.9 Objectives D8 Addressing Climate Change, D13 Local Amenity

4.5 Policy SS1, Sustainable Development, clauses c and g Statement "Furthermore the low job density figure reflects that resident jobs relate strongly to nearby employment centres such as Sheffield, Chesterfield and the M1 corridor." Confirms that building 860 new dwellings in Dronfield is environmentally unsustainable; will increase commuting to Sheffield, Chesterfield, and through Chesterfield to the strategic development sites, resulting in increased congestion, pollution affecting large numbers of North Derbyshire residents and increased CO2 emissions. This is inconsistent with objectives 3.9 D8 and D13, and in breach of policy SS1 clauses c and g.
6.7 & 6.8 Statement "...and principal employment growth locations at:
* Callywhite Lane, Dronfield"
This assertion is false. Callywhite Lane has been underutilised for many years because it is not attractive to new businesses.
The council is clearly aware of the challenges at Callywhite Lane and acknowledges in paragraph 6.8 "the need for significant remediation and investment of these large scale previously developed sites". However, he plan includes no infrastructure investment commitment to resolve this situation. The current underutilisation will therefore continue.
The council will be aware of a proposal to build a new office block on the corner of Wreakes Lane (reference 17/00283/FL). It is notable that this employment development is not on Callywhite Lane.
6.13,
Table 6.1 Statement "Dronfield and Killamarsh are the main focus for employment (B1 & B2) in the North". Therefore the council should state the investment it is planning to make to resolve the difficulties with Callywhite Lane (ref. paragraph 6.8). Without such a commitment, the statement is disingenuous as is including it in table 6.1.
6.20 Statement "the allocation at Callywhite Lane in particular will provide a significant improvement to the quality of the employment land portfolio of the District."
Provide the evidence to support the assertion that Callywhite Lane provides this improvement. This statement contradicts the statement in paragraph 6.8 acknowledging the challenges of the site.
6.22 Statement "Policy WC1 allocates 6 hectares (net) of land for B1, B2 and B8 uses at Callywhite Lane".
To propose storage and distribution development (B8) at Callywhite Lane defies belief. The junction of Green Lane, Callywhite Lane and Chesterfield Road in Dronfield bottom is wholly unsuitable for large vehicle movements. Owing to the narrowness of the road along Dronfield bottom these vehicles also represent a significant hazard to other road users and the large number of pedestrians who frequent the area, in particular the children of Dronfield Henry Fanshaw School. If the proposed link road between the eastern end of Callywhite Lane and Chesterfield Road ever materialises, much of this traffic will then be routed past Unstone Junior School and through the residential area of Unstone Green; an equally unsatisfactory solution.
6.23 The council acknowledges the lack of progress since 2005 on the Callywhite Lane Extension yet the plan contains no infrastructure investment commitment (as it notes is necessary in paragraph 6.8) to resolve these issues.
6.23 Statement "Issues over access in particular need to be resolved but there is a likelihood that with the anticipated electrification of the East Midlands Main Line and (in the longer term) HS2, such issues will be resolved."
How on earth does HS2 have an impact on the access to Callywhite Lane when the planned route is several miles to the East of the site? Provide evidence to justify this implausible assertion. The council will also be aware that the electrification of the East Midland Main Line has been postponed.
7.2 What is the purpose of a historical description of Dronfield which appears to pre-date the development the large areas of housing off Snape Hill Lane and Stonelow Road, and also Gosforth Valley? This reads suspiciously like thoughtless copying and pasting as do other areas of the document.

The Green Belt to the south is to prevent Dronfield from merging with Unstone, a separate settlement dating back to the Domesday Book, not Chesterfield as stated - or do the council's planners now intend Unstone to be absorbed into Dronfield as it has allowed to happen with Coal Aston, now showing this once independent settlement as falling within the Dronfield settlement boundary?

The reference to passing trade on the B6158 (Green Lane) does not make sense; I suspect the author means the B6057, the old Chesterfield to Sheffield Road. Whilst the council may consider this a trivial error to note, it is indicative of the lack of rigour and poor quality of the document.
3.9 D12
7.3, 9.36,
Policy ID6 The council notes the presence of a train station in Dronfield, but it fails to acknowledge that there are no public transport links between the main housing areas and the station and the problems this causes.
Train users who live more than a few minutes' walk from the station drive to the station and park nearby. There is limited parking at the train station. FODS (Friends of Dronfield Station) have advised that the current free of charge car parking area is to return to the control of Northern Rail, who intend to implement charges and stop parking along the middle of the car park, thereby reducing its capacity. Therefore, the streets near to the station are choked with the cars of train users; this is a safety hazard for both pedestrians, including pupils of Dronfield Junior School and their parents, and other road users.
Whilst the station is "highly valued" and provides "excellent links to Sheffield and Chesterfield as well as locations further afield" as stated in paragraph 7.3, its usefulness is limited by the lack of an integrated public transport policy and plan. This plan does not address this issue and, in proposing the development of 860 additional dwellings without doing so will result in further exacerbating current problems and damage to the environment.
The plan does not "provide the framework for more sustainable transport choices" for Dronfield as stated in paragraph 9.36, fails to meet objective D12, and is in breach of policy ID6, paragraphs c and d
7.4 Statement "The tight constraints of the Green Belt have restricted development in recent years leading to rising house prices and unmet housing needs. The lack of available land within the existing settlement means that meaningful levels of housing growth can only be accommodated by looking around the edge of the town within the Green Belt."
The council's proposal to develop on the Green Belt is in breach of the Government's Housing and economic land availability assessment guidance (https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment) which states: "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the "very special circumstances" justifying inappropriate development on a site within the Green Belt".

The council has not demonstrated it has sufficiently considered all other options before proposing to remove land from the Green Belt. The council concedes in paragraph 5.6 that it has not considered windfall and it has dismissed the contribution of smaller sites as stated in paragraph 5.8. The continued protection of land at Callywhite Lane for employment when there is little or no prospect of it being used for this purpose, particularly when a developer has previously sought permission to build dwellings on part of the site, is in breach of NPPF guidelines.

The council's proposal to develop on the Green Belt is also in breach of the Housing White Paper 2017 which states:
"1.39 Therefore we propose to amend and add to national policy to make clear that:
* Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
o making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
o the potential offered by land which is currently underused, including surplus public sector land where appropriate;
o optimising the proposed density of development; and
o exploring whether other authorities can help to meet some of the identified development requirement.
* and where land is removed from the Green Belt, local policies should require the impact to be offset by compensatory improvements to the environmental quality or accessibility of remaining Green Belt land. We will also explore whether higher contributions can be collected from development as a consequence of land being released from the Green Belt."
7.4 Statement "These [parcels of land selected for removal from the Green Belt] have been selected on the basis that they would cause least harm to the strategic functions of the Green Belt".
The council concedes this plan will harm the Green Belt, yet the plan shows the council has not considered alternative options: see comments against paragraph 7.4.
7.6 Statement "Dronfield is significantly lacking in green space, outdoor sports and children's play space."
The statement indicates the council is fully aware that the Dronfield area is already over-developed. Consequently, any further development is not sustainable as claimed. This plan proposes further environmental and well-being damage with the planned building on sports fields at Coal Aston and a golf course. This is the exact opposite of one of the requirements of sustainable development: "protecting and enhancing the environment".
Moreover, whilst proposing yet more development in Dronfield, the council make no commitment to rectify a situation it notes falls below current standards.
7.7 Statement "Overall, the town centre is performing well."
This statement does not reflect the situation in the civic centre where there are currently three empty units, three charity shops and a betting shop which make up 50% of the units.
7.7 The council acknowledges "the condition of the civic centre needs addressing" and should therefore state what level of funding it will provide to do so or how it will mandate developers, who will profit from building the proposed dwellings, to fund the necessary regeneration. The plan contains no commitment to address this issue. The plan completely fails to address the need to improve the infrastructure to accommodate the additional demand from the planned 860 additional dwellings.
7.8 Statement "but the spread out form of the town ... needs addressing in order to maintain the vitality and viability of the town centre".
Then state the council's plans to address the spread-out form of the town centre. Surely development outside the settlement development limits will increase the spread out form of the town?
Table 7.1 Item 1, first bullet: "review of bus services" without a stated commitment to act on the output does not result in the "Improvement of public transport"

Item 1, second bullet: is the council funding the proposed new link road to Callywhite Lane? If it is not, how will it be funded?

Item 1, fourth bullet: what does "Improved public realm" mean?

Item 1, fifth bullet: Explain how an "audit of vehicle speeds" improves balance between car and pedestrian space.

Item 3, bullet 1: "Improvement of the market offer" - how does the council propose to do this?

Item 4, bullet 1: Explain how "review and consolidation of previous audits" will result in making more of existing heritage assets.

Item 4, bullet 2: and what follow-up action will be implemented to secure new uses of historic buildings and spaces?
Policy SP1 Paragraph e(i) where does the council expect "proposals that maximise the benefits from, and protect and improve access to, the railway station" to come from if they are not included in the plan? This plan should include appropriate proposals, not rely on them coming from other sources. Define how the council will support these proposals. As it stands this statement is meaningless - there is no guarantee any proposals will be put forward and no quantification of the support the council will provide.

Paragraph e(iii): statement "Encourage proposals that facilitate the provision of new green space" is meaningless. The council will be fully aware that developers will seek to maximise profit by building as many dwellings as possible within regulatory constraints; they should be obligated to provide new green spaces.

Paragraph e(iv): State how the council will "Encourage uses within the town centre that enhance the offer of the town as an evening destination, particularly leisure facilities" i.e. what types of business will the council attract and how will this be done?

Paragraph f: How does the council intend to ensure developers that profit from building new accommodation will also "contribute to the successful delivery of the Dronfield Regeneration Framework's key themes and proposals" as stated?
8.11 Statement "National policy states that valued landscapes should be protected and enhanced, and requires Local Plans to include criteria based policies against which proposals for any development on or affecting local landscape areas will be judged."
The Drone valley landscape is highly valued by a large proportion of its residents. The council has not fulfilled this National Policy obligation with respect to the proposed development on Green Belt which will have a significant impact on the visual appearance and perception of the landscape.
Figure 8.1,
8.23 It is difficult to discern the different grey shaded areas, however it appears the area around Dronfield is classified as "Coalfield Village Farmlands". This is a grossly misleading classification of the Drone Valley - all the settlements pre-date the development of the coal fields: both Dronfield and Unstone appear in the Domesday Book. The field boundaries visible on both sides of the valley can be traced back to medieval times. The council's proposal to take land out of the Green Belt around Dronfield will destroy portions of this historic landscape. This is in breach of the National planning guidance referenced in paragraph 8.23: "National planning guidance advises that local planning authorities should set out a positive strategy for the conservation and enjoyment of the historic environment"

Figure 8.2,
8.53,
Policy SDC11 Figure 8.2 shows that 'use less energy' as the largest opportunity to reduce carbon emissions.
Paragraph 8.53 states "The Local Plan can make a major contribution to mitigating and adapting to climate change by shaping new and existing development across North East Derbyshire in ways that reduce carbon emissions". Whilst the local plan can make a major contribution to reducing carbon emissions, the current plan for the Dronfield settlement will do the exact opposite.
The current Green Belt land on which the council proposes housing developments will currently be a net CO2 sink. The council's proposal to build an additional 860 dwellings on the outskirts of the Dronfield settlement without a commensurate increase in local employment and no binding commitments to provide public transport from the outer reaches of the settlement to the railway station and existing bus services to Chesterfield and Sheffield will increase commuting, CO2 emissions and pollution.
Consequently, this proposal is not sustainable development and is in breach of policy SDC11.
8.59,
Policy SDC12 The plan notes there is a flood risk in the Dronfield area, however, paragraph 8.59 appears to be a NE Derbyshire Council statement of abdication on this matter, noting that the County Council and Environment Agencies hold the associated flood risk management responsibilities.
Policy SDC12 paragraph (d) states "There is no net increase in surface water runoff for the lifetime of the development on all new development. Run off rates for development on greenfield sites should not be exceeded, and where possible should be reduced from existing."
The proposed building of 860 dwellings on current Green Belt land will inevitably result in significant areas of hard surfaces replacing absorbent land. Consequently, it seems completely unrealistic that current run off rates will not be exceeded. However, the council appears to be relying on this flawed policy; the plan makes no provision for managing the additional run off that will result.
Policy SDC13 The proposal to build 860 dwellings on Green Belt land around Dronfield is in breach of clause (k) of this policy - a requirement to conserve historic landscapes.
8.65,
9.9,
9.37,
9.45,
9.57
Paragraph 8.65 reference to "A Guide to Sustainable Housing Layout and Design"; paragraph 9.9 reference to "Green Infrastructure Study"; paragraph 9.37 (and others) reference to "Derbyshire Infrastructure Plan"; paragraph 9.45 reference to "Local Transport Plan"; paragraph 9.57 reference to "Local Transport Plan 3".
None of these documents are included on the local plan evidence page of the council's website, nor does a search on their name return a link to the document. How does the council expect the public to comment on a plan referencing multiple documents that cannot be found on the council's web site?
This is further evidence that the consultation process is fundamentally flawed.
Why has the council not included a list of references to external documents, including links to where they can be found on the council's web site? A list of references is basic practice when citing external sources within a document.
8.70 Statement "The existing, and likely future, air quality in an area should be considered through Local Plans".
The council's proposal to build an additional 860 dwellings on the outskirts of the Dronfield settlement without a commensurate increase in local employment and no binding commitments to provide public transport from the outer reaches of the settlement to the railway station and existing bus services to Chesterfield and Sheffield will increase commuting and therefore degrade local air quality. The above statement infers the council's plan will seek to improve air quality, not reduce it as it currently plans to do in the Dronfield area.
8.73 Statement "the NPPF acknowledges that good planning should aim to prevent the adverse effects of noise from being unacceptable".
The increased commuting that the current plan will cause in the Dronfield area will have a significant negative noise impact on the residents in Unstone who live along the B6057. The plan contains no evidence to demonstrate that this has been considered or assessed.
Policy SDC14 Statement "Where adverse effects are identified, development will only be approved where suitable mitigation can be achieved which would bring emissions or impacts within acceptable levels".
This policy can only be fulfilled in relation to the proposed additional dwellings in Dronfield through binding commitments to interventions that prevent a significant increase in road traffic through Unstone.
9.5 Statement "The Council is continuing to work with statutory undertakers, utility companies and other agencies to prepare an Infrastructure Delivery Plan which will support the proposed development identified in the Local Plan."
In other words, there is currently no agreed plan nor any binding commitments to provide the infrastructure necessary to support the proposed expansion in housing. Consequently, the plan presented is incomplete, unsound and should be withdrawn and re-issued for further consultation when appropriate commitments on infrastructure provision have been secured.
9.6 Statement "Potential sources of funding for strategic infrastructure could include Local Enterprise Partnerships and the Regional Growth Fund and Growing Places Fund, central government, ..."
In other words, the council has no idea how strategic infrastructure needs arising from the proposed increase in dwellings will be funded.
Consequently, the plan presented is incomplete, unsound and should be withdrawn and re-issued for further consultation when appropriate commitments on infrastructure provision have been secured.
Policy ID1 Statement "Development proposals that would result in the loss or isolation of
existing green infrastructure will not be permitted unless ... a compensatory amount of green infrastructure of an equivalent or better quality can be provided in the local area"
The council's plan contains no such provision with respect to the green infrastructure it is proposing to destroy on the outskirts of the Dronfield settlement. The proposed development at Dronfield is in breach of this policy.
Policy ID1 Statement: "The NPPF tells us that ... policies should be based on up to date assessments of the need for open space, sports and recreation facilities, and opportunities for new provision. LPAs should protect and enhance public rights of way and access, and should not permit development on existing open space except where it is surplus to requirements, or will be replace [sic] by equivalent of superior facilities"
The plan contains no assessment of the need for open space, sports and recreation facilities; it actually proposes destroying both existing sports and recreation facilities at Coal Aston, Hallowes golf course and Green Belt open spaces, none of which are 'surplus to requirements'.
Consequently, the plan for Dronfield is in breach of this NPPF requirement and fails to meet objectives D6, D9, D13 as claimed in this policy.
Objective D16 referenced in this policy does not appear anywhere in the document!!
9.19 Statement "The Council is committed to the protection and enhancement of open space, sports and recreation facilities".
This statement is blatant hypocrisy when the council plans to destroy existing sports and recreational facilities at Coal Aston and Hallowes golf course.
9.22 Statement "The Council has commissioned a Playing Pitch Strategy and an Indoor Sports Facilities Strategy to assess current levels and quality of provision in relation to demand."
In other words, these 'strategies' have not completed the commissioned assessments
Statement "The Council is also in the process of reviewing open spaces, recreation sites and facilities. The outcome of this work will inform the next iteration of the Local Plan."
Further evidence that the current plan is incomplete, contains no binding commitment to providing these facilities, and is therefore unsound.
Policy ID3 The statement "The Council will seek to protect and enhance existing open spaces" is meaningless. State exactly what is meant by "seek" i.e. binding commitments on the council and mandated obligations on developers.
Policy ID3 The Green Belt open spaces around the Dronfield settlement and the playing fields at Coal Aston which the council proposes to destroy are not 'surplus to requirements' nor does the plan contain any obligations for them to be "replaced by equivalent or better provision in terms of quantity and quality in a suitable location". Consequently, the plans for the Dronfield settlement are in breach of this policy.
9.29 Statement "The Local Plan does not designate Local Green Spaces, but any forthcoming Neighbourhood Plans may do so."
The plan does not contain any commitment to respect these designations. The council must make its position clear on this matter.
9.30 Statement "Where new Green Infrastructure is proposed, clear funding and delivery mechanisms must be in place for its long term management and maintenance".
Then state how the council expects the funding and delivery mechanisms to be provided.
9.36 Statement "The relationship between planning, transport and infrastructure is acknowledged as crucial in creating successful and sustainable places that work for everyone. Whilst the planning system cannot directly change people's travel behaviour, it can provide the framework for more sustainable transport choices.
The plan for 860 additional dwellings on the outskirts of Dronfield without a binding commitment to provide public transport links to the development areas does not provide a framework for more sustainable transport choices.
9.37 Statement "but there is an acknowledgment that this understanding will need to be developed further through Local Plans and also through detailed assessments such as modelling and Transport Assessments".
In other words, the council has inadequate data on how the plan for additional dwellings and therefore there is no basis for planning needed improvements to existing highway and public transport networks, services and facilities.
Consequently, the plan presented is incomplete and therefore unsound.
9.38 Statements "Derbyshire County Council is responsible for transportation, which includes producing the Local Transport Plan." and "the District Council has only limited control over highways or transport matters".
In other words, the council has no obligation to assess transport requirements arising from the planned increase in dwellings.
As a local resident, I have no interest in the division of planning responsibilities between the different council bodies; I expect them to work together to produce a coherent and complete plan. The current local plan is evidence that this is not happening. This paragraph makes a strong case to merge the current bodies into a single council with responsibility for all aspects of planning.
9.39 Statement "Sustainable modes of travel such as walking, cycling, public transport, car sharing, and alternative fuel vehicles can be provided through good planning and design".
However, the current local plan contains no commitment to provide public transport links to the proposed development areas on the outskirts of Dronfield. This is bad planning. The paragraph reveals that a Transport Assessment will only evidence the damage these plans are doing to the environment.
9.40 Travel Plans appear to be equally toothless; there is no commitment in the plan to ensure the infrastructure is upgraded to meet the increased demand arising from the additional dwellings planned, to the detriment of current residents and the environment.
9.41 Statement "Access to sustainable forms of transport must be integrated into the design of new development".
Therefore, the council must commit to providing public transport links from the proposed development areas on the outskirts of Dronfield to the existing transport hubs in the centre. This plan contains no such commitment and is therefore flawed.
9.44 Statements "Where possible, bus routes should penetrate new development sites through permeable routes" and "Where appropriate, developers will be asked for a financial contribution so the Council and bus operators can work together to improve bus provision for a particular site."
The plan should be as unambiguous about these commitments as it is for the number of dwellings proposed. The council has access to national statistics that will enable it to quantify the requirements for public transport and other infrastructure facilities, but it has failed to address these matters in the plan.
9.45 Statement "Where applicable, proximity and access to rail services should also form part of planning applications"
9.51 Statement "The future focus will therefore be on limiting parking supply at destination."
This policy is myopic and, as acknowledged with limiting parking on residential estates, will result in difficulties as is already the case in Dronfield in the proximity of the Railway Station. The focus should be on providing viable alternatives to car use i.e. frequent and affordable public transport services linking the outer reaches of settlements such as Dronfield with existing transport hubs.
Policy ID6 The council has acknowledged it does not have authority of the strategic highway network; it therefore cannot implement clause (f) of this policy. Therefore this clause is misleading and should be removed or re-written.
Policy ID6 Statement "You told us that ... The Plan should aim to reduce the use of the car and encourage walking, cycling the use of public transport."
Yet the plan contains no binding commitments to encourage any of these. The council appears to be relying on encouraging developers and other authorities to achieve this aim.
9.53 Statement "Funding or developers [sic] contributions will be sought, as appropriate, to support the delivery of key transport infrastructure improvements."
This statement lacks substance and shows no binding commitment to deliver infrastructure improvements. The plan must be as unambiguous in its implementation of infrastructure improvements as it is with respect to the number of dwellings required. Anything less than this offers no assurance against the environmental damage and congestion blight that would be result from a significant increase in dwelling numbers with no commensurate improvements to infrastructure. Consequently, the plan is incomplete and unsound.
9.54 Statement "Proposals for improvements to transport infrastructure will be supported where it can be demonstrated to be necessary".
Define 'supported' i.e. the level of funding the council will commit to these improvements.
Define 'demonstrated to be necessary' i.e. what criteria will determine an improvement is necessary.

Statement "recognising that transport issues to not stop at administrative boundaries"
I suspect this should read "do not stop"
9.56 Statement "The legacy of coal mining has left a number of disused rail routes throughout the District, which have the potential to be returned to beneficial use to reduce the number of journeys made by road, increase the movement of freight by rail, or increase opportunities for recreation."
Like so many statements in the plan, the above fails the "so what" test. Does the council intend to implement measures to develop these rail routes for the purposes identified? If so, state what these measures are. If the council has no plans to develop disused routes, the statement is irrelevant.
Policy ID7
This policy merely states the basis on which new transport infrastructure will be permitted. Despite proposing the development of 6,600 additional dwellings 50ha of employment land this plan contains no commitment to implement any new infrastructure or improve existing infrastructure. Consequently, this is a plan to increase pollution and congestion, adversely impacting the quality of life of the region's residents.
9.68 Statement "Where new development necessitates new or improved infrastructure ... the Council will require developers to contribute towards any necessary site specific infrastructure".
This does not address improving local infrastructure outside the proposed development sites to meet the increased demands arising from the planned developments.
9.71 The Infrastructure Delivery Plan must be part of the consultation process, not published after the local plan is adopted. With the IDP, the council is presenting a partial picture to the public and leaving many questions unanswered. Consequently, the current consultation process is flawed.
9.73 Provide details of the Community Infrastructure Levy: who pays this; on what basis are charges calculated?
The paragraph seems to suggest the developers pay the levy and, if it is set too high, it will deter development. However, the details requested can only be inferred; they should be explicit. The author assumes the public have prior knowledge of CILs.

Statement "the Council will therefore also carry out work to assess the viability of the Plan as a whole, and whether there would be enough economic incentive to provide new development with infrastructure requirements in place. This work will help to inform whether a levy will be introduced and what rates would be applied".
The first sentence is difficult to decipher, but the council appear to be suggesting that if developers object sufficiently strongly the council will not pursue infrastructure funding via CILs. The outcome of this policy is entirely predictable; developers will provide the minimum on-site infrastructure necessary to meet any applicable mandatory regulations.
9.76 Statement "Where a scheme is agreed to be unviable or marginal, the Council will review the policy arrangements"
Yet another statement rendering purported safeguards and policies in this plan ineffective. Developers must be required to deliver schemes meeting immutable requirements that ensure the provision of appropriate infrastructure. If these requirements result in schemes being unviable, then there is insufficient demand in the market to justify the schemes. The precedent for this approach is well established in many sectors where minimum standards are enforced through regulation, and products or services that do not meet these standards cannot be offered.
9.77 While paragraph 9.76 is retained, paragraph 9.77 does not provide sufficient protection: "essential" is not defined; paragraph 9.76 renders all the stated infrastructure policies mutable.
The paragraph also states "schemes will not be supported"; that does not mean they will not be permitted, rendering the paragraph ineffective.
Policy ID8 Paragraph (c) of this policy also limits a developer's obligation to on-site infrastructure in accordance with the limitations noted in paragraph 9.68 above.

Comment

Consultation Draft (February 2017)

Representation ID: 5276

Received: 03/04/2017

Respondent: Network Rail

Representation:

No comments to make.

Full text:

Thank you for consulting Network Rail on the NE Derbyshire Local Plan.
Following a review of the proposals I can confirm that Network Rail has no comments to make

Comment

Consultation Draft (February 2017)

Representation ID: 5293

Received: 02/04/2017

Respondent: Stenfold Resources Ltd

Agent: Charlotte Stainton

Representation:

Local Plan Format
In reading and seeking to comment on this draft Local Plan it has been difficult to understand the proposals for level 3 and 4 settlements as well as the countryside areas.

The lack of comprehensive plans to cover the whole District is not a transparent approach and it is not useful to simply say that there would be 'no changes'. It is not reasonable to have to refer back to the previous version of the Local Plan.

Full text:

North East Derbyshire Local Plan Representation - Fallgate
This letter is a representation to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of my client Mr Philip Barltrop.

Local Plan Format
In reading and seeking to comment on this draft Local Plan it has been difficult to understand the proposals for level and 3 and 4 settlements as well as the countryside areas.

The lack of comprehensive plans to cover the whole District is not a transparent approach and it is not useful to simply say that there would be 'no changes'. It is not reasonable to have to refer back to the previous version of the Local Plan.

Settlement Boundaries
It is not clear whether it is proposed to have a settlement boundary for the smaller settlements (and which will have a settlement limit and which ones won't). Paragraph 4.8 indicates that the settlement boundaries are still under review. Without this information and a plan to show the boundaries it is not possible for interested parties to comment fully on this Draft Plan.

Draft Policy SS13: Development in Small Villages & Hamlets indicates that "Within very small villages and hamlets (defined under level 4 in the Settlement Hierarchy at Table 4.1) development will be restricted to limited infill development of 1 or 2 dwellings unless in accordance with the policies of an adopted Neighbourhood Plan".

It is not clear however how a Neighbourhood Plan will be able to allocate sites for larger developments in small villages and hamlets, as this potentially may 'not be in conformity with the Local Plan'. It's not a sound strategy to say only limited infill development will take place across the whole of the west of North East Derbyshire.

There is the potential that the small villages and hamlets will simply stagnate and will not be able to deliver the much-needed homes to accommodate the children of existing residents as they grow up and create households of their own. This is not a sustainable approach to take.

The January 2017 Pre-submission Draft Ashover Neighbourhood Plan indicates a settlement boundary for Fallgate and also the allocation of a 5-dwelling housing site (granted permission 15/01302/OL). This was therefore the clear intention of the Neighbourhood Plan Steering Group. It is understood however that the Neighbourhood Plan Steering Group now have some concerns about continuing with these proposals for risk of their Neighbourhood Plan being found 'not in conformity' with the Draft Local Plan. This needs to be clarified for the Ashover Neighbourhood Plan Steering Group because the approach taken to the Draft Local plan appears to be preventing the Steering Group from being able to take their desired approach to small local developments. Policy SS13 however seems to envisage that Neighbourhood Plans will show housing allocations in areas which are not included in the Local Plan Strategy.

My client owns the site for which planning permission 15/01302/OL was approved and also various other areas of land at Fallgate, including infill plots that would be incorporated into the Ashover Neighbourhood Plan settlement limit for Fallgate.

We therefore request that full plans are provided for across the District to clearly show proposed settlement limits. It is also requested that a settlement limit is provided for Fallgate and clarification is provided for the Neighbourhood Plan Steering Group to ensure that the Neighbourhood Plan can proceed in accordance with the community wishes.

We look forward to hearing from you.

Comment

Consultation Draft (February 2017)

Representation ID: 5339

Received: 04/04/2017

Respondent: Dronfield Civic Society

Representation:

Comment on the Consultation Process. Statement that the document is not easy to understand and that without an infrastructure plan it is meaningless. Statement that Dronfield should have had a longer drop-in session and consultation.

Full text:

I wish to comment on the Local Plan about which I have many concerns, mainly around the impact on Dronfield, where I live. However, I will restrict my comments to a few key areas.

The Consultation Process

The Plan itself is a very dense document, not accessible to the layman , and is supported by many, equally dense, other documents. The Plan also lacks an infrastructure plan which, in my view, renders it almost meaningless. How is anyone supposed to comment meaningfully on a Plan which does not include any proposals as to how it will be delivered? Also, allowing only six weeks for comments and putting on one three hour drop in session in Dronfield does not fit my view of an adequate consultation process.

Building on the Green Belt

A previous iteration of the Plan showed many more houses being built in the South of the District. What has changed so that the current Plan shows most housing being built in the North of the District?
The proposed housing development in Dronfield is for 860 house ALL built on the Green Belt. How can this be? What evidence is there in the Plan that you have carried out a review of brownfield sites across the District, which could support housing development? What evidence is there in the Plan that the Council has carried out its statutory duty to consult with neighbouring authorities, namely Chesterfield and Sheffield, about the possibility of building houses on their borders? What are the exceptional circumstances which support the proposals to build on the Green Belt?
What account has been taken in the Plan of the 1,000 empty houses which exist across North East Derbyshire and Bolsover? And land currently in Council ownership?

Callywhite Lane Development

I am concerned that, even if the proposed development happens, this will not attract the kind of high quality jobs which will be need by the occupantss of the proposed 860 new houses in Dronfield. The jobs will be insufficient in number and of the wrong type. This will inevitably lead to increased commuting between Dronfield and Sheffield and Chesterfield, putting increased pressure on an already overstretched road and transport infrastructure.
I am also intrigued to know how the coming of the electrification of the Midland Main Line and HS2 is going to help to solve the problem of the inadequate access to Callywhite Lane.

General

From my perspective the Draft Plan has little to benefit Dronfield in it and many things that are detrimental to the town and its surrounding areas. It needs to be modified significantly.

Comment

Consultation Draft (February 2017)

Representation ID: 5349

Received: 04/04/2017

Respondent: Rikki Dobson

Representation:

Statement that there is too much planning jargon for a start, simple plain English would have been better.

Full text:

I am writing to object to your proposal to build housing on Dronfield's Green Belt land.
First of all we have a Green Belt to stop townships such as Dronfield merging into surrounding areas.
Second the Green Belt is there to provide a special place for wildlife, flora and fauna. I have noticed over recent times a return of many rare birds to the Green Belt around Dronfield such as Buzzards and Finches etc. Once the Green Belt is concreted over we will lose this wildlife forever. We the residents of Dronfield have a "duty of care" to protect the countryside, for the sake of future generations.
My third point is by building on this land, which is largely farmland, would be a great loss to our long term plan to be more self sufficient. We as a country are importing more and more food and farm land is crucial for long term self sufficiency. If there is no grass then there will be a reduction in cattle etc which feed on it. If there is less livestock there will less home produce in your supermarkets and local butchers etc. It really is that simple.
Point four. Pollution will increase in Dronfield due to the increase in housing and the increase the in cars on the roads of Dronfield. This will threaten the wellbeing of the residents in Dronfield, most especially young children and the elderly.
This leads me to point five. The roads in Dronfield are busy enough and this additional increase of anything from 1000 to 2000 vehicles will cause real problems to our already congested roads.
Point six. As well as congested roads we will also have over crowded schools.
Where will these new schools be built? There is no mention of them in your plan, which by the way is very difficult to read and understand for your average normal person. There is too much planning jargon for a start, simple plain English would have been better.
Point seven. I recently spoke to my G.P. and he was concerned because the GP services in Dronfield are already struggling to cope will the current population of Dronfield. So please, where will our new Health Centre be located ? Where will the new Doctor's come from to man them.
Point eight. The disruption that this proposed development will cause will be extreme, our roads will be choked with lorries and vans whilst the construction takes place. Roads will have to be widened, bus routes changed and temporary traffic lights everywhere.
Chaos will reign in Dronfield.
Point nine. This will create a terrible danger for our children, many of whom walk to and from school. Road safety will become worse for everyone.
Point ten. Finally my last point is quite simple the people of Dronfield DO NOT WANT THIS DEVELOPMENT. This was proven by the negative reaction toward the plan from the public attending your consultation session at Dronfield Civic Hall on Tuesday 14th March and the large number of signatures on the petition.
So please do not take away our Green Belt for a development which has been badly planned from the start. It will only get worse for everyone from the residents of Dronfield, who will suffer, to N.E.D.D.C. and its planning department who will be blamed for destroying the town of Dronfield.
My advice would be to re-think and look at alternative vacant sites across the area or build on brown field sites, there are alternatives to building on Green Belt.
Finally I have lived in Dronfield for over 56 years and really do hope you will read this letter and take note of my complaints, they are very real and very serious. Do not make a mistake of ignoring them or those from other concerned residents of Dronfield.

Comment

Consultation Draft (February 2017)

Representation ID: 5368

Received: 04/04/2017

Respondent: Barlow Parish Council

Representation:

Further to your letter dated 24th February 2017, I would like to inform you that the Parish Council have no objections to the plan. However it would be helpful to show a map of the limit of the Greenbelt boundaries for Barlow.

Full text:

Further to your letter dated 24th February 2017, I would like to inform you that the Parish Council have no objections to the plan. However it would be helpful to show a map of the limit of the Greenbelt boundaries for Barlow.

Object

Consultation Draft (February 2017)

Representation ID: 5413

Received: 06/04/2017

Respondent: Planning & Design Practice Ltd.

Agent: Planning & Design Practice Ltd.

Representation:

Object to the revised spatial distribution and the inclusion of substantial green belt releases around Eckington, Dronfield and Killamarsh. The spatial approach taken in February 2015 should be continued.

Full text:

Object to the revised spatial distribution and the inclusion of substantial green belt releases around Eckington, Dronfield and Killamarsh. The spatial approach taken in February 2015 should be continued.

Support

Consultation Draft (February 2017)

Representation ID: 5556

Received: 05/04/2017

Respondent: Environment Agency

Representation:

We can confirm that we support the vast majority of policies at a strategic level. However, we have several suggestions for alterations and/or additions that we consider will deliver better environmental outcomes and increase the 'soundness' of the Plan, from an environmental perspective.

Full text:

Thank you for consulting us on the Consultation Draft of the North East Derbyshire Local Plan, on 24 February 2017. We understand that the purpose of the document is to set out the proposed strategy for growth and development across the area.

We can confirm that we support the vast majority of policies at a strategic level. However, we have several suggestions for alterations and/or additions that we consider will deliver better environmental outcomes and increase the 'soundness' of the Plan, from an environmental perspective. For our full detailed comments on the content of the Local Plan, and the proposed policies, please see the information enclosed in the attached Appendix.

Whilst you can find our detailed comments in the appendix, we would like to take this opportunity to highlight some particular areas/sites where environmental constraints exist. We recognise that we have already commented on some of these sites during previous versions of the Local Plan, however, we have revisited and updated comments where necessary to ensure clarity and consistency, and to take account of updated national policy and guidance.

With particular reference to flood risk, we have concerns that a handful of proposed housing sites are located in flood risk areas. We support the fact that several sites in flood risk areas are not currently proposed for allocation, but in particular, we have identified the following sites as having some sort of flood risk constraint or implication:

Site ref Constraints Notes

CX/2104 Partly FZ2 Proposed for housing
KIL/2305 Partly FZ2 Proposed for housing
SS8 Large areas of FZ2 and FZ3 Proposed for housing

GRA/2301 Areas of FZ3 Not currently proposed for allocation
NW/1603 Areas of FZ3 Not currently proposed for allocation
ECK/1603 Areas of FZ3 Not currently proposed for allocation
TUP/2301 Areas of FZ3 Not currently proposed for allocation

In summary, should any of these sites be put forward for allocation, the flood risk sequential test will need to be undertaken in accordance with both the National Planning Policy Framework (NPPF) and Draft Policy SDC12 of the emerging Local Plan. We request to see evidence of this test being carried out, prior to any examination, to ensure that the Plan is based on a sound evidence base.

If your Authority ultimately determine that the sequential test has been passed then a site specific flood risk assessment (FRA) will be required as part of the flood risk exception test, to support any formal planning application. The FRA will be required to demonstrate the safety of the development and future occupants, and should focus on flood risk reduction, both on and off site. Ultimately, if sites are to be allocated within Flood Zones 2 and 3, we would wish to comment on the site specific policies to ensure that FRA requirements are appropriately covered. We are therefore keen to meet with your Authority to discuss how you intend to apply the flood risk exception test to those sites which are subsequently allocated.

We would also like to take this opportunity to present the following site specific advice on flood risk and climate change.

Site specific comments for CX/2104:
We support the statement within the supporting Sustainability Appraisal (SA) which suggests that development will only be permitted if it 'passes the sequential test' - we would like to see this evidence submitted in advance of any allocation, to ensure that the any allocation can be supported by robust and defined evidence.

Site specific comments for SS8:
It is our opinion that housing must not be sited in areas of Flood Zone 2 or 3, until such a time as adequate sequential test evidence has been submitted to, and approved in writing by, the Local Planning Authority (LPA). Such an approach would be consistent with the principles of both the NPPF and Objective 12 of the supporting SA. Furthermore, the supporting SA recognises that the development 'may have adverse impacts' on important features. We therefore strongly recommend that a 10m buffer zone should be implemented either side of the watercourse on this site, to prevent development in these areas. This will help support the aspiration for the LP to deliver long term sustainable development. We therefore request that such a requirement should be outlined in a site specific policy.

In summary, we look forward to developing our partnership working with you. Should you have any questions, or would like to discuss the comments set out above, please contact me on the number below.

Yours sincerely



Mr Rob Millbank
Planning Specialist

Direct dial 02030 255036
Direct e-mail rob.millbank@environment-agency.gov.uk




APPENDIX - detailed EA comments on sites with particular environmental constraints/opportunities

Policy SS4 - The Avenue
We are aware of the complex planning history surrounding this site as we have participated in many discussions, and responded to several planning applications, in the past few years. We are supportive of the plan to accommodate significant development at this site, subject to the site being fully remediated prior to any development taking place. We strongly support this policy at a strategic level as its successful implementation will assist in delivering significant environmental benefits, in accordance with The Avenue Area Strategic Framework (AASF).

Whilst we note the intention to address transport and community infrastructure, we also feel that the provision of adequate sewerage infrastructure is a key factor in delivering sustainable development. One of the key sustainability principles of the AASF is to ensure that appropriate infrastructure is provided in a timely way to minimise the impact of development on existing infrastructure. Continued co-operation with Yorkshire Water is therefore required to deliver this site in a sustainable manner. We therefore strongly recommend that a bullet point should be added which requires development proposals to identify, and submit details of, adequate foul drainage solutions as part of any future planning applications.

Policy SS8 - Coalite Regeneration Area
We support this policy and agree that a piecemeal approach to development on this site should be avoided, given the complexities involved. Whilst there are flood risk constraints to a section of the site, we are pleased to note that housing is not going to be allocated on this site, in the first instance. We support this approach, as there is still work to be done in terms of demonstrating the flood risk sequential and exception tests. In contrast to this, we recognise that there are major environmental gains to be had from bringing this site forward and so we are supportive in principle. We continue to welcome a collaborative approach for this site and we therefore request that we are included in any future discussions relating to either remediation and/or water quality implications of the River Doe Lea.

Policy SS12 - Development in Unallocated Land within Settlements with defined Settlement Development Limits
We support this policy. Whilst the re-use of previously developed land can be considered sustainable development, an avoidance of high flood risk areas should still be the favoured approach. Whilst we trust that this matter can be adequately addressed through other policies (such as SDC12) within the plan, we strongly recommend that a bullet point should be added to this policy to indicate that sights outside of flood risk areas will be given preference in the first instance. This change would help to avoid potential conflicts with other policies within the plan, or the overarching aims of the National Planning Policy Framework (NPPF).

Policy SDC4 - Biodiversity and Geodiversity
Whilst we support and welcome the principles of this policy at a strategic level, we recommend that the wording 'wherever possible' should be removed from the opening paragraph. We recognise there may be scenarios where the provision of a net gain is unachievable, and the NPPF already recognises that, but the onus should be on the developers to demonstrate that on a case by case basis in this local area. This is ultimately a local policy with the potential to secure significant betterment for the local environment, and the wording 'wherever possible' is loosely defined and may ultimately result in a failure to secure the environmental enhancement that both the NPPF and the Local Plan aspire to deliver.

Policy SDC12 - Flood Risk
We fully support and welcome this policy. The policy is informed by an appropriate evidence base, is clearly worded and makes reference to key areas of national guidance contained within the NPPF. We are pleased to see that flood risk avoidance is key to the policy aspirations.

Policy SDC14 - Environmental Quality
We consider the wording of this policy to be very weak. Whilst it is a positive measure that developments would be expected to 'prevent unacceptable levels of water quality', there is no reference to supporting guidance or legislation. It also implies that there may be 'acceptable' levels of water pollution. It is our opinion that any development proposals likely to impact surface or ground water should consider the requirements of the Water Framework Directive (WFD). In all cases where development is adjacent to WFD-designated water bodies, it is expected that they will ensure there is no deterioration in water quality, as an absolute minimum. The Environment Agency will not support proposals that will negatively impact the water quality of WFD monitored watercourses in particular.

The main objective of the WFD is to achieve good ecological status in all surface water bodies and this policy has the potential to assist this objective. We recommend that the Borough's network of watercourses i.e. rivers, streams, ditches, drains and canals are reflected in the policy, in an attempt to ensure that their water quality is enhanced and protected.

In light of this, we strongly recommend that the following policy wording should be added: 'Development proposals will be expected to contribute positively to the water environment and its ecology, and should not adversely affect surface or ground water quality, in line with the requirements of the Water Framework Directive'. This change would give developers greater clarity on what is expected of them in these situations, whilst also adding weight to the policy.

Finally, the evidence base also needs to be updated to make reference to the Water Framework Directive (WFD).

Policy SDC15 - Contaminated Land and Unstable Land
We support the inclusion of this policy, and considerate it highly necessary given the contamination issues associated with many of the proposed site allocations. This policy will also assist delivery of the overarching WFD objective for groundwater to achieve 'Good' status.

Additional EA comments on water resources
We have noticed that there is currently no policy relating to the provision of water resources, or promoting increased water efficiency. However, the importance of water to North East Derbyshire is otherwise well recognised within the draft Local Plan.

Paragraph 8.61 in particular states that 'In particular the Local Plan has an important role in the key actions of promoting water efficiency,' which links nicely to strategic objective D8 and its aspiration to '...address, mitigate and adapt to the effects of climate change on people.' Strategic objective 5 within the supporting Sustainability Appraisal (SA) (2017) also recognises the importance of safeguarding natural resources, including water supply.

Table 1 of the Environment Agency's report 'Water stressed areas - final classification' (dated 2013) shows the areas of England serviced by both Yorkshire Water and Severn Trent Water as areas of 'moderate water stress' in various scenarios. This high level assessment is based upon individual assessments of water bodies. Figure 2 shown below shows the specific water bodies across the Derbyshire area that are classified as being under water stress.


Figure 2: Map showing final water body stress classification at a water body scale.

The importance of water management is also recognised by North East Derbyshire Council in the 2012 SA scoping report. The report highlights the need to support the highest possible levels of water efficiency measures.

In addition to inclusion as a key issue in the SA, the 2015 Humber River Basin Management Plan (RBMP) also recognises the significant challenges associated with water resources. Section 1.4 entitled 'significant water management issues' states that 'reduced flow and water levels in rivers and groundwater caused by human activity (such as abstraction) or less rainfall than usual can mean that there is not enough water for people to use... in the long term, there will be less water available to abstract for drinking, industry and irrigating crops.' With particular reference to climate change, the RBMP goes on to state that 'studies to learn more about the effects of climate change on the river basin district are underway. In the meantime, it makes sense to implement measures that are flexible or increase resilience to extreme weather events and future warming.'

Section 3.5 goes on to recommend measures that could be implemented to prevent deterioration of the water environment. The following two measures are listed in particular:

- All sectors take up or encourage water efficiency measures, including water industry work on metering, leakage, audits, providing water efficient products, promoting water efficiency and education;
- Local government sets out local plan policies requiring new homes to meet the tighter water efficiency standard of 110 litres per person per day as described in Part G of Schedule 1 to the Building Regulations 2010.

In terms of planning policy on the matter, Paragraph 99 of the National Planning Policy Framework (NPPF) states 'Local Plans should take account of climate change over the longer term, including factors such as ... water supply. New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures....'

Having considered the information set out above, there appears to be an opportunity for this local plan to help deliver exceptional sustainable development that is resilient to future climate change. We therefore recommend that, due to the evidence presented above, the Local Plan should include, in policy, a requirement for all new residential development to meet the tighter water efficiency measures of 110 litres per person per day.

We therefore recommend that the following wording should be added to a new standalone policy, or added to existing draft policy SDC14 under a new sub heading of 'protecting the water environment':

- Protecting the Water Environment
Development proposals will be expected to demonstrate that water is available to support the development proposed, and that they meet the Building Regulation water efficiency standard of 110 litres per occupier per day.

Finally, we are aware that some local councils have previously highlighted they are concerned about costs to developers if they ask for higher standards. However, for water efficiency, we would like to highlight that the cost of achieving 110 litres per person per day is just £0 - £9 per dwelling, when compared to achieving the baseline building regulations standard (125 litres per person per day).

Support

Consultation Draft (February 2017)

Representation ID: 5583

Received: 05/04/2017

Respondent: NHS Hardwick Clinical Commissioning Group

Representation:

The local plan presents high level objectives for health and wellbeing which support the CCGs strategic objectives and our continued strategic partnership.

The local plan considers social infrastructure and states an aim of providing services wherever practicable, in multi-use, flexible and adaptable buildings, or co-located with other social infrastructure uses which encourage dual use and increase public access. We fully support this approach and would like to work with the district council to ensure that the assets of all organisations in our strategic partnership are used as efficiently as possible and freeing resources for the delivery of services to residents.

Full text:

NHS Hardwick CCG and NHS North Derbyshire CCG welcome the opportunity to comment on the North East Derbyshire Local Plan consultation draft.
The local plan presents high level objectives for health and wellbeing which support the CCGs strategic objectives and our continued strategic partnership.
The commitment to protect and enhance of open space, sports and recreation facilities and green routes promoting health lifestyles and opportunities for physical activity aligns with our priority around preventing ill health and helping people take good care of themselves. The local plan considers social infrastructure and states an aim of providing services wherever practicable, in multi-use, flexible and adaptable buildings, or co-located with other social infrastructure uses which encourage dual use and increase public access. We fully support this approach and would like to work with the district council to ensure that the assets of all organisations in our strategic partnership are used as efficiently as possible and freeing resources for the delivery of services to residents.
We welcome the local plan objective around sustainable transport and a commitment to linking bus services and major housing developments; we would ask that the location of health premises is considered in any changes to current public transport provision.
The CCGs would like to further develop our relationship with the local authority planning department, particularly in relation to the housing developments identified in the local plan consultation draft; we would like to establish a forum for more proactive and strategic discussions around the impact of significant housing developments on primary and community health services. Further conversations are needed on the relationship between our strategic objective of keeping people in their own homes and the ability of existing and future local housing stock to support that.
We believe that any new applications for housing at the following developments will require a contribution to health; we would like to see this reflected in planning policy, and would like an opportunity to discuss these developments with planners at an early stage;
Strategic Site Allocations
* The Avenue, Wingerworth
* Former Biwaters Site, Clay Cross
* Markham Vale, Long Duckmanton
* Coalite Priority Regeneration Area
Settlements identified for new housing provision.
* Clay Cross
* Dronfield
* Eckington
* Killamarsh
* Calow
* Holmewood
* Morton
* North Wingfield
* Pilsley
* Renishaw
* Shirland
* Stonebroom
* Tupton
* Wingerworth.

Comment

Consultation Draft (February 2017)

Representation ID: 5684

Received: 05/04/2017

Respondent: Mr Edward Throp

Representation:

Concerns over consultation process and why there were not more options for face to face meetings with Council representatives.

Full text:

I am writing to lodge my objections to the proposed sites that have been marked as suitable for development in the local plan. In particular the sites around Dronfield hilltop. Not only are these sites on current greenbelt land but the current infrastructure just is not suitable for such a large development The number of properties suggested would result in close to a 30% increase in population in the dronfield south area. Currently the schools are full or close to full, the access roads in that area are narrow with numerous parked vehicles and any significant increase in traffic would inevitably lead to a significant increase in the accident risk that you would be responsible for.
Based on the 2011 census data then there would be around an extra 900 vehicles to cater for. Dronfiled has already had a report commissioned that highlights narrow pavements and poor road layout as an issue with the current traffic levels.
I can see how once the green belt starts to be developed no matter what assurances are given this will be the thin end of the wedge with further development inevitable.
If as stated in guidance for selecting suitable sites, proximity to schools, doctors, infrastructure, proximity to local shops and public transport have been considered then how can the Hilltop sites even be considered particularly for social housing where the occupants surely need to have easy access to all the above facilities and also potential jobs.
There are a number of large undeveloped sites on Callywhite estate that have been abandoned for over 10years. Despite this there are suggestions of extending the industrial area, when these sites should be developed first or used for residential housing.
Finally Dronfield has just been placed in the top 10 best places in England to live, A massive expansion of the town would significantly change the character of the town and is something I am sure there current residents would not appreciate.

( - )

I am writing in response to the NEDDC local plan. There are a number of areas that I feel are cause for concern and I would like to raise objections to.
My first concern is over the sheer number of additional properties that are planned for Dronfield and particularly the significant proportion of these that are concentrated in 3 sites within the Dronfield South area. Why do the council feel that it is reasonable to increase the number of properties and hence residents in this region of Dronfield by close to 30% (based on 2011 census data)?

Dronfield is an attractive place to live as highlighted recently by the Royal Mail commissioned survey that ranked Dronfield the 9th most desirable place to live in England. Any attractive area will inevitably see a demand for housing as people naturally want to live in nice neighbourhoods. That does not mean that the character of the town that makes it attractive should be threatened by massive expansion and unnecessary destruction of green space. If you draw comparison to towns in the Peak District, where there is also significant demand for property, no one would consider it reasonable to expand say Bakewell by building on the surrounding green space, so why is it OK for Dronfield?

If the issue is related the accessibility to affordable housing for the growing children of existing Dronfield residents, why not focus on building a much smaller number of affordable homes that could be built on smaller brownfield plots?

The council talks about sustainable development. How is the word sustainable justified in this context? Surely a sustainable development should not only consider the detail of the property construction with respect to the environment but should also consider how the residents of the development will live and work. It is well documented that Dronfield is predominantly a commuter town with residents commuting to neighbouring Sheffield or Chesterfield. Taking a wider view it would make more sense to work to provide housing close to employment areas, shops and other amenities where residents can travel without the need to use cars. Further developing housing in an area such as Dronfield will only contribute to more CO2 emissions being generated. How can this be classed as sustainable when global warming is one of the most significant threats to humanity?

Has NEDDC worked with neighbouring councils particularly Chesterfield to investigate if there are brown field sites that could be used to provide suitable housing. In particular sites that directly border NEDDC on Chesterfield Rd? These sites are directly on a bus route and will be close to the new Peak Resort where employment could be found.

Why has the North of the region been targeted for development on not only green field sites but specifically green belt land when brownfield sites are available in the south of the region. Is this in any way linked to the profitability for developers building in areas that have higher property prices?

Specific areas of objection:

1. Use of Green belt land.
What are the "exceptional circumstances" that justify the reclassification of the green belt land? The fact that people want to live in an area surely cannot be classes as exceptional otherwise we would be building across all areas of attractive countryside in the UK.

Access to green space is shown to be beneficial for both physical and mental health. Some other key stated objectives of the green belt are "to prevent urban sprawl" and "to "maintain settlement identity". Building on the land off Shakespeare Crescent will significantly reduce the gap between Dronfield and Unstone making it visually appear as an almost continuous settlement as you travel down Chesterfield Rd.

The green belt land forms an access point to the network of bridle paths and footpaths that surround Dronfield including the Dronfield round walk. These or not under used forgotten paths but well used paths and Bridleways providing the quality of life the current residents enjoy. Obesity and combatting it is a key public health issue. Is it responsible behaviour of the council planners to suggest building on land that provides sports facilities in Coal Aston, a golf course and part of the moss valley conservation area and farmland that provides access to the round walk?
It has been highlighted in other reports that Dronfiled is lacking in greenspace, outdoor sports and children's play space.

What has the council done to ensure that empty properties are put to good use? The recent government white paper not only stresses that the use of greenfield sites should be in "exceptional circumstances" and that the planning policy should favour brownfield developments, but it also offers councils additional council tax for putting to use empty properties.

I believe that across the Dronfield woodhouse, Dronfield and Coal Aston area alone there are a potential 133 empty properties, the number across the whole of NEDDC is significantly higher. Can the council say that it has taken all appropriate measures to ensure that these properties are brought back into full use?
Can the council give assurance that before plans to permanently destroy the greenbelt move forward, that all measures will be taken to utilise the current empty housing stock?

2. Infrastructre
The local plan as it stands is set to increase the housing and population of the Dronfield area by around 10% (close to 30% if you consider the Dronfield south sub region).

Transport
Has the council undertaken a commission a traffic and air quality model to investigate the suitability of the current road network to support such a significant increase in population and inevitably vehicle movements, particularly when considered alongside the proposals to further develop the Callywhite industrial estate? If such as study has not been commissioned is one planned before the plans move forward?

The council is in possession of a report that already highlights the congestion and road safety issues surrounding the junction between Chesterfield road, Green lane and Callywhite. The same document also highlights the issues of narrow pavements around the area.

Whilst Dronfield has a train station, all the proposed development sites are about as far from the station as it is possible to get and the sites at Hilltop, Howllowes golf course also involve negotiating steep gradients. The consequence of this is that if residents of the new properties are to utilise the train it is highly likely they will drive to the station. There is already a significant issue around parking at the station, where it seems the council is incapable of agreeing with current land owner's ways to extend the car park. The fact the car park ends up full, has a knock-on effect for all the surrounding streets and a potential road safety issue for children having to cross these streets to get to the secondary school.

Are the access routes to the proposed development sites suitable for an increased bus service. The image below shows the issues faced by the bus service with current levels of traffic as it attempts to negotiate Highfields road, Dronfield.

Access to Dronfield at present is either from Unstone direction via Chesterfield Rd or from Sheffield. To access the identified sites g,h, and i, traffic will be concentrated up Cemetery Rd and Hallowes Lane from the South and Gosforth lane from the north.

Specific access concerns for Proposed site

i. Land off Hilltop Road
The main point of access to this site will be via Gosforth lane or via Cemetery Rd/Hallowes lane leading to Hollins Spring and then via either Shetland rd or Highfield rd to get to Hilltop road. Whilst below Hollins spring road Gosforth lane is relatively wide, once past Hollins spring road it narrows significantly making it unsuitable for large vehicles to pass or for any significant increase in traffic. The other access roads are essentially housing estate roads. These are generally narrower, and suffer from significant numbers of parked cars. Hilltop road itself is only just wide enough to allow 2 cars to pass. The bin lorry frequently mounts the pavement to allow cars to pass. The pavements on Hilltop road narrow in numerous places coupled with cars parking 2 wheels up the kerb to avoid significantly blocking the road can make this challenging as a pedestrian, worse if pushing a pram or for someone in a wheel chair. Thankfully the current traffic levels make it relatively safe to use the road for short periods of time.

Where is the exact planned access point to this development site planned to be?

h. Hallowes Lane
Access to this site will again either be from Cemetery Rd/Hallowes Lane or from the north via Gosforth Lane and either Hilltop Road or Hollins spring/Highfield and Sailsbury Ave. Hilltop Road is narrow with numerous parked vehicles along with narrow pavements. Where Hilltop Rd continues past Southwood Ave, it further narrows with a very narrow pavement leading to no pavement. This is currently used by dog walkers, walkers, cyclists and horse riders as a major access point to footpaths and bridleways beyond. Currently beyond Southwood Ave there is very little traffic. The proposed development on the Hallowed golf course would significantly change the amount of traffic making this narrow road a potential major access point with all the road safety issues that would bring. Hilltop road is also the main access point to one of the Scout groups meaning that there are significant numbers of children needing to cross this route.

Hallowes lane is narrow, again with a narrow pavement that switches sides, leading to a section with no pavement. The junction with Scarsdale lane is often blind for traffic pulling out due to the parked vehicles. Additional traffic flow up this route will only result in a preventable accident. Preventable by not developing land that has unsuitable access routes.

Development in both the Hollowes Lane area and the Hilltop area will have a detrimental impact on the quality of life for a significant number of residents in South Dronfield in addition to the significant increase in risk of serious accident or injury due to the potential traffic increases. Given the current road layout and adjoining properties etc. I do not see a way to mitigate this.

3. Air quality.
The increased traffic from both the domestic housing plans and the proposed extension of the Callywhite industrial estate will lead to significant increases in traffic at key points particularly around Dronfield bottom. This is likely to lead to stationary traffic at peak times and due to the valley aspect of Dronfield inevitably lead to an increase in air born pollutants. The council has a due to care to ensure that air quality remains within the legal limits. It is possible that the result of the proposed developments that air quality at certain points in the town could exceed the current limits.

4. Schools Doctors and other services
One of the descision criteria sited in the local plan is consideration of ease of access from the proposed sites to doctors, schools, local shop etc. Can the council explain why building on the edge of the town where there is no easy access to any of these facilities is acceptable?

Has the council considered the provision of nursery or school places for the extra population. Dronfield has a number of primary schools all which are currently at or close capacity. The majority of the proposed housing is concentrated in the Dronfield south region, where the only primary school (Dronfield infant) has no room to expand, little green space and is generally oversubscribed. Do the council expect the residents to drive their children to schools further afield further increasing pollution and traffic?

Similarly the secondary school is oversubscribed at present and it's catchment area would also include the new homes at Coal Aston as well as Dronfield. Will there be funding to allow this school to expand? If so on what land?

We all know that it can be challenging to get a doctors' appointment and that health and social care services are under pressure. How do the council expect these services to cope with a 10% population rise?

Other services will similarly suffer, currently to access many of the facilities/classes for pre-school children at the leisure centre there are waiting lists including key life skills such as swimming. This will only get worse resulting in more children not getting critical physical exercise and life skills. How does making access to these facilities fit in with maintaining a healthy population and addressing the obesity issues that affect the population.

5. Consultation process
I attended the open session in Dronfield but due to the number present was unable to speak to any council representative. I have found the online methods not intuitive to provide comment. If you do not have access to the internet then your options to comment on a very significant change proposed to the area are limited. Many older residents will not have been able to add their feedback. Why were there not more options for face to face meetings with council representatives?

6. Other comments
Over the last 60 years Dronfield has seen a 179% increase in its population compared to 23% across the whole of Derbyshire, with several recent developments utilising a number of brownfield sites around the area. Why should further expansion be forced on Dronfield residents at the expense of green belt land?

There is a feeling that it does not matter what the people of Dronfield want, that the whole consultation process is merely going through the motions. What do the council plan to do to prove this wrong? Why would a developer buy green belt land if they did not believe they would be able to build on it? Why would they get that impression?

Can the council outline and make public the additional funding it would receive as part of the "New homes bonus" from the government if this development goes ahead?

I hope the council take on board the significant opposition to these plans, not just by individuals but also the town council and civic society.

Object

Consultation Draft (February 2017)

Representation ID: 5961

Received: 05/04/2017

Respondent: Ms Rhian Harding

Representation:

Concern raised over complexity of the plan and the consultation process. Statement that the process can not meet equality and diversity standards as it is exclusive of so many people.

Full text:

I have just tried to comment on the draft local plan online but just wanted to comment that for people who don't have experience working in local authorities or reading strategic plans it would be incredibly difficult and daunting. I can't believe that there is isn't a summary report with a more transparent way to comment on the key objectives. This consultation process can not meet equality and diversity standards as it is exclusive of so many people.

I worked on Strategic decision making boards in Sheffield and North East Derbyshire for years but I have given up half way through this process as it feels like wading through treacle. I would like to make a formal complaint on behalf of many of my family, friends and neighbours who are totally put off by this process but who have many objections, concerns and valid issues to raise about the development plans for Dronfield and Coal Aston,

A simpler, fairer process should be part of a true consultation and I am disappointed that this isn't the case.

Comment

Consultation Draft (February 2017)

Representation ID: 5989

Received: 06/04/2017

Respondent: Advance Land & Planning Limited

Representation:

We suggest that the overall provision of housing for the District should be increased. The housing provision for Holmewood should likewise be increased and our client's Site NW/2103 (enlarged as indicated on the attachment), should be acknowledged as suitable, available and achievable and so allocated for at least 230 dwellings, capable of delivery in the first 5 years of the Plan.

Full text:

See attached documents.

Support

Consultation Draft (February 2017)

Representation ID: 6049

Received: 06/04/2017

Respondent: Chesterfield Borough Council

Representation:

Whilst acknowledging that there are some areas where the draft plan identifies that further work is needed (ie: update of the SHMA, retail study and the provision of Gypsy and Traveller sites), overall the council is of the view that the plan has been positively prepared, is justified, effective and consistent with national policy as expressed in the National Planning Policy Framework.

Full text:

See attachment.

Comment

Consultation Draft (February 2017)

Representation ID: 6211

Received: 06/04/2017

Respondent: CPRE South Yorkshire & Friends of the Peak District

Representation:

The Plan needs a clearer placemaking agenda
Policies SS1;SS4-SS8;SP1-SP4;SDC13;ID1-ID8
In CPRE's view the structure of the Local Plan needs to be improved in order to articulate the way in which this suite of policies should work together to achieve genuine placemaking. Whilst we would generally support each of policies, we are not satisfied that they will be effective when set against the unseemly haste with which all local planning authorities are seeking to increase the rate of development. It is therefore essential that the totality of what NED is aiming to achieve, in terms of sustainable places, through the proper, integrated implementation of these policies, is clearly articulated.

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6235

Received: 06/04/2017

Respondent: EPC-UK Explosives Plc

Agent: Leith Planning Ltd

Representation:

We have evaluated the Plan in the context of Paragraphs 160 and 172, where these are considered to be directly referable to Rough Close Works and EPC-UK's operations. As it stands there are serious concerns that the Plan has not been prepared in line with the requirements of the NPPF in relation to hazardous substance sites. This therefore raises questions over the consistency of the Plan with the Framework; as required by Paragraph 151.

Objections raised to any form of new development within and adjacent to the hazardous consultation zones associated with Rough Close Works.

Full text:

See attachment.

Comment

Consultation Draft (February 2017)

Representation ID: 6240

Received: 06/04/2017

Respondent: EPC-UK Explosives Plc

Agent: Leith Planning Ltd

Representation:

EPC-UK supports the Council in meeting their strategic objectives and development aims and targets, and welcome and support improvements made to the draft Plan to now make reference to our clients operation and to impose some provisions within the policy framework which seek to take account of the hazardous nature of the site.

Would be willing to meet with officers to explain our concerns with the draft Local Plan in more detail, and to seek to agree further amendments to the Plan such that we can withdraw our current objections.

Full text:

See attachment.

Support

Consultation Draft (February 2017)

Representation ID: 6245

Received: 03/04/2017

Respondent: Messrs S & K Whittam & Grayson

Number of people: 2

Agent: IBA Planning Limited

Representation:

S Whittam and K Grayson support the shift to a single new Local Plan.

Full text:

See attachments

Object

Consultation Draft (February 2017)

Representation ID: 6259

Received: 04/04/2017

Respondent: Geoff Hall

Representation:

Disappointment with the Dronfield consultation event. Suggestions that a speaker should have given a presentation to people.

Full text:

RE: Consultation Draft North East Derbyshire Local Plan: Dronfield

My Wife and I attended a recent Consultation Event at Dronfield Civic Centre and, whilst the displayed information was comprehensive, we were extremely disappointed that there was no speaker to address the large numbers present.

It would have been helpful all round if this had been arranged because the strong feelings of residents present could have been reported back to your team. I am afraid our view, and that of many we spoke to, was that a divide and rule approach had been adopted which actually antagonised many who had been hoping for a presentation followed by questions from the floor.

The Draft Local Plan, insofar as it would affect Dronfield, is unacceptable simply because there would be an erosion of the Green Belt which was originally instituted in order to combat "urban sprawl" and to preserve green spaces for recreational and agricultural use.

You will recall that Dronfield was the location in the sixties and seventies of one of the largest private housing developments in Europe. The town was also, at the same time, deemed to have a through traffic problem so severe that the Dronfield/Unstone bypass was constructed which, at the time, involved one of the most extensive land cuts to accommodate the highway.

The town still has a big problem with traffic which would doubtless be exacerbated by a further increase of incoming traffic if a large number of new properties ware to be built.

Furthermore local services would be under even greater pressure than they are at present: not least doctors, dentists and schools. In fact Dronfield Henry Fanshaw is already one of the largest secondary schools in the country.

Finally it must surely be recognised and appreciated that Dronfield's status as the ninth most desirable postcode in England is something to be proud of and that anything which would adversely affect it should be ruled out emphatically.

Please recognise the strength of feeling in this ton against the Draft Local Plan.