Sustainability Appraisal

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Comment

Consultation Draft (February 2017)

Representation ID: 5454

Received: 05/04/2017

Respondent: Natural England (Lincoln office)

Representation:

The Sustainability Appraisal at this stage of the Local Plan has involved the appraisal of a selection of alternative development options. We acknowledge that the objectives within the SA framework generally cover our interests and we particular welcome the inclusion of objectives on climate change, pollution reduction, biodiversity & geodiversity and landscape character. However we suggest that you may want to consider including green infrastructure and green/open spaces within the objectives list to ensure that this topic is fully considered throughout the appraisal exercise.

Full text:


Natural England welcomes the North East Derbyshire Local Plan and has made the following comments for your consideration on the Consultation Draft, Habitats Regulations Assessment and the Sustainability Appraisal:

3. Vision and Objectives
Natural England generally supports the vision particularly the aspiration to provide accessible Green Infrastructure and biodiversity networks and to strengthen the District's role as a gateway to the Peak District.

We have the following comments on the Local Plan Objectives:
D8: Addressing Climate Change - we suggest this objective should also reference the provision of green infrastructure to assist with climate change adaptation.
D11: Environmental Protection - we are pleased to note that the wording within this objective has been clarified from the initial draft document by including "nature conservation sites".

SS1: Sustainable Development
Natural England considers that this policy provides a clear framework for the achievement of sustainable development and particularly welcomes the provisions for the protection and enhancement of green infrastructure and local landscapes (h) and protection of the best quality agricultural land (i).

SS4: The Avenue, Wingerworth
We welcome bullet point (g) which provides pedestrian and cycle routes through green infrastructure where there would be no impact on biodiversity. We also support point (j) which aims to maintain and improve existing areas of habitat and species and promotes measures for habitat creation. This site has great potential to make positive green infrastructure and biodiversity gains for the benefit of both wildlife and local residents therefore these opportunities should be maximised during the earliest stages of the development.

SS5: Former Biwaters Site, Clay Cross
We welcome the provision in this policy at bullet point (j) for a wildlife corridor and buffer zone beside the River Rother and we suggest that this should link to the wider green infrastructure network.

SS6: Markham Vale, Long Duckmanton
We acknowledge the provision for structural landscaping and green infrastructure as set out at point (c) and suggest that this should link to the wider green infrastructure network.

SS7: Land to the south of Markham Vale
We acknowledge the provision for structural landscaping and green infrastructure as set out at point (d) and the protection of the adjacent Local Wildlife Site and biodiversity interest of the Doe Lea corridor.

SS8: Coalite Regeneration Area
Whilst we welcome the protection of the biodiversity value of Doe Lea corridor at point (d), this site has great potential to make positive green infrastructure and biodiversity gains and therefore opportunities to incorporate green infrastructure during the development of the masterplan should be maximised.

LC1: Housing Allocations
j. Land north of Eckington Road, Coal Aston, Dronfield
We note that this proposed allocation for 180 houses is in close proximity to the Moss Valley Woods SSSI and ancient woodland. We would wish to ensure that any future development proposals can demonstrate that there will be no adverse effect on the interest features of this nationally designated area in terms of increased recreational disturbance and air or water pollution. We note that the potential impact of this site has been mentioned within the Sustainability Appraisal (paragraph 3.4.28)

WC6: Visitor and Tourism Economy
Natural England generally supports the approach that this policy takes of enhancing tourism whilst protecting designated sites and landscape character and extending green infrastructure. We also welcome the restoration of the Chesterfield Canal.

SDC2 - Trees, Woodland & Hedgerows - support
Natural England welcomes this policy which offers protection to ancient woodlands and veteran trees and complies with paragraph 118 of the NPPF.

SDC3: Landscape Character
We welcome this policy and note that the policy draws upon the evidence set out in the Derbyshire Landscape Character Assessment. We also welcome reference to the National Character Areas at paragraph 8.12 of the accompanying text.

SDC4: Biodiversity & Geodiversity
Natural England generally supports the approach that this policy takes and particularly welcomes the intention to provide net gains in biodiversity. However we suggest there are a couple of points that you may want to consider which would clarify and strengthen the policy wording:
 The wording should distinguish more clearly between international, national and local sites to reflect more clearly the advice set out in paragraph 113 of the NPPF. Whilst the status of European sites is shown, the importance of Sites of Special Scientific Interest (SSSIs) which are national designations is not clear. The policy needs to set out that any proposal that causes significant harm to a SSSI will not normally be granted permission.

 The policy wording should be clarified to explain that the avoidance-mitigation-compensation hierarchy should be applied generally to planning applications so that it more accurately reflects the guidance set out in paragraph 118 of the NPPF: "if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused". The current wording appears only to apply to protected species.

SD10: Decentralised, Renewable and Low Carbon Energy Generation
Natural England generally welcomes safeguards within this policy for the ecology of the area including protected species, sites of biodiversity value, and ancient woodlands. We suggest the policy should strengthen the wording concerning landscape protection to ensure that adverse effects are addressed satisfactorily, including cumulative landscape and visual impacts.

SDC12 Flood Risk
We welcome point (e) of the policy wording which makes provision for green infrastructure gains within areas set aside for surface water management. We would suggest that there could also be opportunities for biodiversity gains within these areas.

We also welcome the provision for the incorporation of Sustainable Drainage Systems (SuDS) within developments to manage surface water drainage, and suggest that the policy should encourage the maximisation of biodiversity and amenity value within these areas.

Policy SDC13: High Quality Design and Place-Making
We generally welcome this policy particularly the integration of green infrastructure into developments (points g & j), opportunities for biodiversity enhancement (l) and the provision of SuDs and green and brown roofs (n).

LP14: Environmental Quality
We are pleased to note that this policy covers water, air, noise and light pollution. We particularly welcome the inclusion in paragraph 8.72 of the requirement for HRA if development proposals are likely to increase air pollution in the vicinity of a Natura 2000 site. We also welcome the reference to tranquillity in the section on noise pollution.

We acknowledge that the protection of agricultural land has been mentioned within policy SSI but we also suggest that the plan should include the protection of soils. We note that the accompanying sustainability appraisal at paragraph 6.49.1 explains that this policy would reduce air, soil and water pollution however the policy wording should more accurately reflect this aim.

Soil is a finite resource, and fulfils many roles that are beneficial to society. As a component of the natural environment, it is important that soils are protected and used sustainably. The plan should recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process. Soils of high environmental value (e.g. wetland and carbon stores such as peatland) should also be considered as part of ecological connectivity. We advise that policy refers to the Defra Code of practice for the sustainable use of soils on construction sites.

IDI: Green Infrastructure
Natural England welcomes this policy as it provides protection for existing Green Infrastructure (GI) and encourages the incorporation of new, high quality GI at the earliest stages of development. We are also pleased to note the intention to link to ecological networks and to protect landscape features such as trees, hedgerows and watercourses.

We welcome the reference to the Green Infrastructure Study (2012) and are pleased to note that this will be updated We are also pleased to note that this policy protects and enhances public rights of way and access.

Policy ID2: Chesterfield Canal
We generally support this policy as it will contribute to both the biodiversity and green infrastructure of the District.

ID6: Sustainable Travel
Natural England generally supports the approach that this policy takes but suggests that the provision of pedestrian and cycle routes may allow for opportunities to link to the wider GI network through green verges and natural footpaths.

Habitat Regulations Assessment
We note that the intention is for the HRA screening to be revisited at publication stage of the plan. We advise that the HRA is an iterative process and would need to be updated to inform the plan as it progresses. The HRA should be used to refine options as they are developed to ensure that the requirements of the Habitat Regulations are met. If the HRA is not revisited until the publication stage when the allocations are finalised it would not be informing the options.

Sustainability Appraisal (SA)
The Sustainability Appraisal at this stage of the Local Plan has involved the appraisal of a selection of alternative development options. We acknowledge that the objectives within the SA framework generally cover our interests and we particular welcome the inclusion of objectives on climate change, pollution reduction, biodiversity & geodiversity and landscape character. However we suggest that you may want to consider including green infrastructure and green/open spaces within the objectives list to ensure that this topic is fully considered throughout the appraisal exercise.

Comment

Consultation Draft (February 2017)

Representation ID: 6390

Received: 07/04/2017

Respondent: Tracey Marsden, Nicola Shepherdson & Mark Woodhead

Agent: Caroline McIntyre

Representation:

Within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

Full text:

SUMMARY
The site covers an area of land of circa 4.09 hectares and is located on the edge of Ridgeway, to the north of High Lane and to the west of Camdale Rise and Camdale View. Access to the site is from Camdale View through an existing gated entrance. The site was included within the Green Belt within the 2005 Local Plan.

The site is well located for both the Housing Market Area of NEDDC and Sheffield, and is available, suitable and achievable.

It is considered, for the reasons set out in the detailed representations below, that the assessment of the site has not had full regard to the site's close proximity to Sheffield and the potential this offers to meet any additional housing requirements through the Duty to Cooperate.

Furthermore the assessment of the site and the role it plays with regards to the purposes of the Green Belt has been based on a substantially larger parcel of land, which falls outside the ownership of our clients, and has not addressed the potential for the partial release of land within our clients' site

In summary it is considered that the site should be released either in full or in part from the Green Belt through the forthcoming review of Level 3 Settlement Boundaries, as noted within the Local Plan.


REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

The following comments are made specifically with regards to the content of the draft Local Plan.

Duty to Cooperate and Further Housing Growth: The Plan refers at Paragraph 1.16 to the Duty to Cooperate and outlines that a Statement of Compliance with the Duty to Cooperate will be issued at the next stage of the Plan preparation.

Whilst it is acknowledged that the Localism Act 2011 and the Planning Practice Guidance1 require that this is demonstrated before the Plan is submitted for examination, the Committee Report on the NEDDC Local Plan from 5 August 20152 has identified this as a potential issue from the outset. The Committee Report stated with regards to the Duty to Cooperate that:

"Although no formal requests have so far been received which confirm any quantum or timescales, requests could be expected from both Derbyshire Dales District Council and Sheffield City Council. In order to provide a robust basis for assessing available capacity the Council would need to have undertaken a Green Belt review in order to demonstrate that all reasonable alternatives had been assessed."

The Green Belt Review (2017) also makes reference at Paragraph 2.10 to a 'reconciliation process' which will need to take place between NEDDC and Sheffield City Council ("SCC"). However no evidence that this has been undertaken is included within the Review or what the implications of this may be for the Plan.

Given the location of our clients' site on the northern periphery of the District and immediately adjacent to the boundary with SCC it is essential to understand at this early stage of the Plan preparation:
* the extent of discussions with SCC and the requirement for any additional housing to be delivered by NEDDC; and
* whether this could impact upon the spatial strategy as set out within the Plan at Policies SS1 and SS3.

Furthermore as outlined at Paragraph 4.22 of the draft Local Plan "The District Council's economic and Local Plan objectives also provide sufficient flexibility to accommodate changes, as the result of on-going work related to job growth and housing across the Sheffield City Region for example."

The Plan will need to remain flexible in order to respond to any increased housing need and our clients' site is well located to meet any housing growth to serve the needs of SCC should this be an issue which arises as the Plan progresses. At present it is not possible to see how the Plan will be sufficiently flexible to respond to these issues.

Relationship and Reliance upon Sheffield: At Paragraph 2.6 the character of the North Sub Area is noted, in particular the reference to the fact that "...The rural area lies entirely in the Green Belt and the towns and other settlements have generally been developed up to their boundaries, meaning that there is few development sites still available within their existing built up areas..." and that "These towns relate closely to the Sheffield conurbation and just under a quarter of people commute out of the District to work in the city."

This is reflected in the Local Plan Vision at Paragraph 3.4 where again the reference is to the objective to share in the economic benefits of the regeneration and sustainable growth of the wider Sheffield City Region.

District Wide Objective D12 'Sustainable Transport' makes reference to increasing the opportunities for travel using sustainable forms of transport by securing improvements to public transport, walking and cycling infrastructure particularly to maintain and improve connectivity with the main urban areas within the Sheffield City Region and to the south and east of the District.

Spatial Strategy: Within Policy SS3 'Spatial Strategy and Distribution of Development' and Tables 4.1 and 4.2 Ridgeway is defined within Table 4.1 as a Level 3 Settlement. This is one which has limited sustainability and places Ridgeway on a par with other more rural settlements. The Settlement Hierarchy Study (2016) places no weight on the location of Ridgeway on the edge of Sheffield and its proximity to a range of public transport links and facilities a short distance away in locations such as Mosborough, Gleadless, Birley, Frecheville and Hackenthorpe.

In the context of the support and relationship of the District with Sheffield, as outlined above, the approach in Policy SS3 and the Settlement Hierarchy Study (2016) is questioned in that there is little regard to the sustainability of settlements such as Ridgeway which are located closer to Sheffield and the potential for good accessibility to services, jobs and transport outside of the District.

Review of Boundaries to Level 3 Settlements: The Draft Local Plan states at Paragraph 4.80 that the review of smaller settlement boundaries is still to be undertaken.

Although Maps for two settlements - Cutthorpe and Holymoorside - are provided, there is no reference within the Draft Local Plan to the decision to release land within these settlements following the Green Belt Review. This is considered further below.

The decision not to allocate any sites or remove land from the Green Belt within the Level 3 Settlements at this stage of the Plan preparation, particularly where these are well located to the adjacent Authorities, does not provide the flexibility to respond to accommodate changes required through the Duty to Cooperate or the Sheffield City Region work (see Paragraphs 1.16 and 4.22 of the Local Plan).

Consideration should be given to the removal of land from the Green Belt as part of the review of smaller settlement boundaries, which is still to be undertaken. Alternatively, the scope of Policy SS10 'Safeguarded Land' should be extended to allow for greater flexibility for the Plan to respond to any future changes to without the need for a full Green Belt Review to be undertaken.

Housing Figures: The Housing Figures within the Plan appear to be based upon the 2013 Strategic Housing Market Area Assessment ("SHMA") and the sensitivity testing in 2014 and not on an updated assessment. This document is now four years out of date, and an updated Assessment should be completed as soon as possible to determine the more localised need for new housing. This will be an important consideration in the review of the boundaries to the Level 3 Settlements.

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Policy SS14 'Development in the Countryside': As drafted it is considered that there is conflict between this Policy and Policy SS9 'North East Derbyshire Green Belt'. Any proposals on land which fall within both the Green Belt and also the Countryside would be covered by conflicting policy with regards to 'limited infill' development, with there being no support for such development proposals under Policy SS14.

Furthermore, there is more scope for development in Level 4 Settlements under Policy SS13 which would allow for development of 1 to 2 dwellings than there would be for Level 3 Settlements which would be more sustainable locations in terms of access to facilities and public transport.

The wording of Policy SS14 should be amended accordingly to make reference to infill development being acceptable where this meets the other objectives and considerations of Policy SS9.

Policy LC3 'Exception Sites for Affordable Housing': the continuation of an Exception Site policy is welcomed. However the reference to an element of market housing only being allowed on sites outside of the Green Belt is disappointing. The financial impetus from an element of market housing in order to deliver an affordable housing scheme on sites within the Green Belt is no different to the requirement on sites outside of the Green Belt.

Furthermore it is considered that the other policies within the NPPF and elsewhere within the draft Local Plan could be used to constrain the extent of any such proposals on the Green Belt as these would need to meet an identified local need and be assessed in terms of the acceptability of any impact on the Green Belt.

Policy LC3 should also be clarified as to how proposals for specialist housing would be considered within the Green Belt. It is considered that as an exception Green Belt land is often well located to deliver such accommodation, and again any such proposals would be considered against the other policies within the Plan.

Policy SDC5 'Development within Conservation Areas': The terminology used within this Policy does not reflect the approach set out within Section 12 of the NPPF. The wording of this policy should be amended accordingly to reflect the NPPF.

SUSTAINABILITY APPRAISAL (2017)

The Sustainability Appraisal ("SA") also acknowledges at Paragraph 6.4.3 that the SHMA is now somewhat out of date and is being updated, which may affect the housing targets within the Local Plan going forward.

Furthermore within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

GREEN BELT REVIEW (FEB 2017)

Within this document our clients' site is included within the parcel of land assessed under RID/GB/002. This parcel of land included both their land at Camdale Rise (Ref ECK/2201) and a significant area of land to the west between the rear of the Settlement Boundary and the boundary with Sheffield City Council.

The overall conclusion on Parcel RID/GB/002 is that this scores 'Red' in an assessment against the Purposes 1 to 3 of the Green Belt by having a role in checking unrestricted sprawl, preventing neighbouring towns from merging into one another and assists in safeguarding the countryside from encroachment.

The 'Common Approach to Green Belt Review across the Sheffield City Region' (August 2014) was prepared to set out a cohesive approach across the region to the Green Belt review process. This outlines a staged approach which can be summarised as:

* Stage 1 - Identify general areas within the Green Belt
* Stage 2 - Technical site assessment
* Stage 3 - Re-appraisal of resultant land parcels.

The NEDDC Green Belt Review notes at Paragraph 2.10 that "Whilst Officers at Sheffield City Council acknowledged there were some differences between their approach and this Study, they accepted that these are not necessarily inconsistencies and merely reflect a slight difference of approach taken in reaching the same end point and are nevertheless in accordance with the SCR. In order to minimise any potential inconsistency with Sheffield's approach, the Study will undertake a 'reconciliation process' between Green Belt sites/parcels on either side of the Sheffield/NEDDC boundary, ensuring that conclusions are broadly comparable..."

Within the NEDDC Green Belt Review large parcels of land are considered, for example Parcel RID/GB/002 covers an area of 8.702 ha. However there does not appear to be any consideration of smaller elements within each parcel which may score different in terms of the purposes of the Green Belt and therefore may be suitable for removal without impacting on the overall objectives of the Green Belt in that location. The Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Furthermore, there is a lack of consistency in the approach to selecting parcels for assessment. Had the same approach been taken to our clients' site (along with land to the west) as that taken for Parcel HOLY/GB/024 within Holymoorside, which covered an area of 0.877ha, the conclusions regarding our clients' site ECK/2201 may have been different and the land closest to the existing built up area of the Settlement Boundary to Ridgeway would be scored differently to the land at the northern most edge of the overall Parcel of land being considered.

A detailed consideration of how the removal of our clients' site at Camdale Rise from the Green Belt would be considered against the five purposes of including land within the Green Belt was set out in the representations made in respect of this site on 23 December 2015. The detail of this has not been repeated as part of this submission, but the key points relating to the entire site are summarised below.

In addition in considering this site as a whole, without the additional land included under RID/GB/002, it may be that parts of the site ECK/2201 closest to the existing Settlement Boundary would have even less of an adverse impact on the purposes of the Green Belt in this location and removal from the Green Belt of these alone would be considered acceptable.

In summary site ECK/2201 can be considered as follows:

* Purpose 1 'To check the unrestricted sprawl of large built-up areas': The site is adjacent to the urban area of both land within Ridgeway falling in NEDDC and SCC. It is bounded by clear and strong change in the topography to the east, residential properties on Camdale View, Camdale Rise, Ribblesdale Drive and other residential properties to the south and south east. The site is adjacent to agricultural land to the north and west, but existing hedgerows and additional strong landscaped boundaries can be formed to further enhance the existing physical edge of the site, minimising any impact on the openness of the Green Belt. To the north beyond the furthest extents of the site is The Birley Wood Golf Club which forms a strategic gap to settlements on the edge of Sheffield, limiting the urban sprawl in this direction.

The existing boundary in this location is defined only by the extent of built development and there are no topographical or landscape features which reinforce this boundary.

It is therefore considered that new strong boundaries, and ones which are stronger than those currently in place could be established through the release of all or part of the site from the Green Belt. For these reasons it is considered that the application of a Red score for our clients' site on this point is incorrect.

* Purpose 2 'To prevent neighbouring towns merging into one another': The assessment has been carried out on the basis of the entire parcel of land at RID/GB/002, rather than any consideration of smaller elements within this. Furthermore, the existing residential area to the east, which falls within SCC, has a relationship with adjacent settlements of below the distances outlined as the criteria within the Review.

The removal of the ECK/2201 site from the Green Belt and its new boundaries would still prevent neighbouring towns merging into one another. The urban area of High Lane already merges with Quarry Hill and no physical gap currently exists between these settlements, with residential development forming a continuous line of development alongside the northern urban edge of the B6388.

It is not considered that the release of this site, in whole or part, will lead to the coalescence of settlements in this location given that a large gap will still exist between the northern edge of the site and the nearest settlement. The Birley Wood Golf Course is also located beyond White Lane which ensures the gap between settlements is maintained and will prevent any coalescence of settlements in this location.

* Purpose 3 'To assist in safeguarding the countryside from encroachment': Part of the overall site is already contained by the existing development to the south and east. The release of site ECK/2201 from the Green Belt may have minor impact on safeguarding the countryside from encroachment, but this needs to be considered in the context of the Council's need for Green Belt release to meet their housing requirement over the plan period and any need for additional housing which arises from the Duty to Cooperate.

Furthermore, the Housing Site assessment makes reference to the north western part of the site encroaching into the countryside. It is considered that should this be a barrier to the entire site being taken out of the Green Belt then the areas of the site closest to the Settlement Boundary should be considered without this peripheral part of the site.

* Purpose 4 'To preserve the setting and special character of historic towns': The conclusion within the Review is supported in that the release of the site from the Green Belt is unlikely to have any significant impact on the historical part of Ridgeway village.

* Purpose 5 'To assist in urban regeneration, by encouraging the recycling of derelict and other urban land': No comment is provided on this given the approach taken within the Review with regards to this purpose.

In summary it is requested that the Green Belt Review of Parcel RID/GB/002 be reconsidered with regards to the potential for the removal of smaller elements of the Parcel, forming all or part of Site ECK/2201, from the Green Belt. This would be on the grounds that the elements of Site ECK/2201 closer to the existing Settlement Boundary could be removed without having the same impact on the purposes of the Green Belt as those for the wider RID/GB/002 site.

Furthermore, the release of land within the location would help NEDDC have the flexibility to meet any housing which may come out of the updated SHMA and the Duty to Cooperate process.

Housing Sites Assessment Report (Feb 2017)

Within this document our clients' site is assessed under Ref ECK/2201 - Land at Camdale Rise. The whole of the site put forward has been assessed as a single proposal in its entirety and we maintain that the entire site remains available, suitable and achievable. However it is requested that the also Council review the option for the partial removal of the site from the Green Belt should it be that this would reduce the concerns outlined in the Assessment with regards to the Green Belt and countryside.

The assessment of the site is considered incorrect for the following reasons:

* Green Belt: The site is assessed in its entirety within the Green Belt Review under RID/GB/002. For the reasons set out above it is considered that this assessment does not consider the differences across the parcel and the assessment should be revisited, with regards to the potential to remove all or part of site ECK/2201 from the Green Belt.

* Access: The assessment states that 'No satisfactory access can be achieved, because the site has no frontage to an adopted highway. Third party land would be required.' This is incorrect. Access to the site can be obtained from the highway via the existing gated access from Camdale View which is in the control of our clients. This existing gate provides access to a made track across part of the site, already accessed by public utility authorities.

* Services: No acknowledgement is made of the proximity of Ridgeway and the site to Sheffield and the range of public transport and services within the wider area within Sheffield.

* Nature Conservation: Whilst the site boundary included as part of the original Call for Sites submission does include an area of woodland, this forms part of the boundary to the site. This area could be excluded from any area removed from the Green Belt.

* Achievability: The site does not require third party land for access. This should be amended.

In summary, for the reasons outlined above it is considered that the conclusion not to consider Site ECK/2201 further as a Housing site is based on an incorrect assessment of the site and should be revisited.

SETTLEMENT HIERARCHY STUDY (2016)

As outlined above, our client is concerned that the assessment carried out under this document does not given any weight to the location of Ridgeway, and in particular High Lane, on the edge of Sheffield and its proximity to a range of public transport links and facilities a short distance away in Mosborough, Gleadless, Birley, Frecheville and Hackenthorpe.

The draft Local Plan notes the heavy reliance on Sheffield for employment and outlines objectives within the Plan to maximise on the relationship with Sheffield and the Sheffield City Region as a whole.

It is therefore considered that greater weight should be afforded to Ridgeway as a sustainable location that could deliver housing which is well located to Sheffield.

SUMMARY

In summary it is considered that the site remains available, suitable and achievable and should be released from the Green Belt to meet the district's housing needs over the plan period.

We would therefore urge the Council to review the draft Local Plan and Evidence Base documents in the light of the above submission and consider the removal of all or part of our clients' site from the Green Belt as part of the review of Level 3 Settlement Boundaries which is still to be undertaken at the next stage of the Local Plan process.

Comment

Consultation Draft (February 2017)

Representation ID: 6446

Received: 07/04/2017

Respondent: Mr & Mrs N Beecroft

Agent: Caroline McIntyre

Representation:

The SA acknowledges at Paragraph 6.4.3 that the SHMA is now somewhat out of date and is being updated which may affect the housing targets within the LP going forward.

Furthermore within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

Full text:

This representation relates to land to the west of the Millstone, Wadshelf (Ref BRAM/2301) and should be read alongside submissions made previously in respect of this site at the Call for Sites stage in January 2016.

The Site

The Site is located on the western side of the village of Wadshelf and sits adjacent to the Settlement Development Limits for Wadshelf, as identified on the Local Plan Proposals Map (2005). The Millstone, and White House beyond this, to the east of the Site fall within the Settlement Development Limits for the village.

The Site is bounded to the east by the Millstone and the White House, which is separated from the Site by the drive to the Millstone. To the south is Main Road and beyond this a number of farm and residential dwellings. To the west is the Village Hall and village play area, and beyond this further housing to the junction with Baslow Road. Despite the role of the Village Hall within village life, this does peculiarly fall outside of the Defined Settlement Boundary. To the north is agricultural land which slopes up in gradient away from the Site.

The Site is low grade agricultural grazing land and is currently unused. An existing power line crosses the Site.

Given the Site's position and relationship with both the village of Wadshelf and key village facilities we consider that its inclusion within the Green Belt and exclusion from the Settlement Development Limits of Wadshelf - along with the properties to the west of the site - is an anomaly.

We consider that the Site is available, suitable and achievable for housing and as part of the review of the settlement boundaries there is a strong case to exclude the Site from the Green Belt. We set out our justification for this below.

REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

The following comments are made specifically with regards to the content of the draft Local Plan.

Housing Need: Review of Boundaries to Level 3 Settlements: Within Policy SS3 'Spatial Strategy and Distribution of Development' and Tables 4.1 and 4.2 Wadshelf is defined within Table 4.1 as a Level 3 Settlement.

The Draft Local Plan states at Paragraph 4.80 that the review of smaller settlement boundaries which is still to be undertaken. Therefore there has been no review of the boundaries of most Level 3 settlements as part of the current draft Plan.
The Plan has been prepared on the basis of the 2013 Strategic Housing Market Area Assessment ("SHMA") and the sensitivity testing in 2014 and not on an updated assessment. This document is now four years out of date, and an updated Assessment should be completed as soon as possible to determine the more localised need for new housing. This will be an important consideration in the review of the boundaries to the Level 3 Settlements.

Furthermore, the previous draft 2011 - 2031 Local Plan Part 1 Initial Draft (February 2015), which was informed by the Evidence Base, outlined that there was a need for 5 new dwellings in Wadshelf over the plan period. It is noted within the document that this figure was limited due to the lack of Sites available within the Settlement Development Limit and the Green Belt designation around the village. It is assumed that this need will be reassessed in the light of the revised Local Plan SHMA and updated housing targets process.

Although it is noted that Maps for two settlements, Cutthorpe and Holymoorside, are provided but there is no reference to these within the Draft Local Plan. As discussed below, it is considered that our clients' site, along with the land to the west, is not materially different to the area of land proposed for removal from the Green Belt at Holymoorside (Ref HOLY/GB/024). This area of land to the west of Wadshelf contains the Village Hall and playground and further existing housing as well as our clients site and forms part of the village.

Consideration should be given to the removal of this land from the Green Belt as part of the review of smaller settlement boundaries, which is still to be undertaken.

Policy SS9 'North East Derbyshire Green Belt': The wording of this policy with regards to the exceptions listed from (a) to (f) should reflect the wording of Paragraph 89 of the National Planning Policy Framework ("NPPF") (2012). At present the policy as drafted does not reflect the NPPF and the wording of some parts of the policy is unclear.

Policy SS14 'Development in the Countryside': As drafted it is considered that there is conflict between this Policy and Policy SS9 'North East Derbyshire Green Belt'. Any proposals on land which falls within both the Green Belt and also the Countryside would be covered by conflicting policy with regards to 'limited infill' development, with there being no support for such development proposals under Policy SS14.

Furthermore, there is more scope for development in Level 4 Settlements under Policy SS13 which would allow for development of 1 to 2 dwellings than there would be for Level 3 Settlements which would be more sustainable locations in terms of access to facilities and public transport.

The wording of Policy SS14 should be amended accordingly to make reference to infill development being acceptable where this meets the other objectives and considerations of Policy SS9.

Policy LC3 'Exception Sites for Affordable Housing': the continuation of an Exception Site policy is welcomed. However the reference to an element of market housing only being allowed on sites outside of the Green Belt is disappointing. The financial impetus from an element of market housing in order to deliver an affordable housing scheme on sites within the Green Belt is no different to the requirement on site outside of the Green Belt.

Furthermore it is considered that the other policies within the NPPF and elsewhere within the draft Local Plan could be used to constrain the extent of any such proposals on the Green Belt as these would need to meet an identified local need and be assessed in terms of the acceptability of any impact on the Green Belt.

Policy LC3 should also be clarified as to how proposals for specialist housing would be considered within the Green Belt. It is considered that as an exception Green Belt land is often well located to deliver such accommodation, and again any such proposals would be considered against the other policies within the Plan.

Policy SDC5 'Development within Conservation Areas': The terminology used within this Policy does not reflect the approach set out within Section 12 of the NPPF. The wording of this policy should be amended accordingly to reflect the NPPF.

SUSTAINABILITY APPRAISAL (2017)

The Sustainability Appraisal ("SA") also acknowledges at Paragraph 6.4.3 that the SHMA is now some what out of date and is being updated which may affect the housing targets within the Local Plan going forward.

Furthermore within the SA there is no assessment of the approach to focus on the larger settlements and not to provide any site allocation for Level 3 settlements. There are also no discussions regarding the assessment carried out under the Green Belt Review and the conclusions drawn from this process. These issues should be considered within the SA.

GREEN BELT REVIEW (FEB 2017)

Within this document our clients' site is included within the parcel of land assessed under WAD/GB/006. This parcel of land included both their land at land to the West of the Millstones (BRAM/2301) and a significant area of land to the north, north east and north west.

The overall conclusion on Parcel WAD/GB/006 is that this scores 'Red' in an assessment against the Purposes 1 and 3 of the Green Belt by checking unrestricted sprawl and assists in safeguarding the countryside from encroachment.

The 'Common Approach to Green Belt Review across the Sheffield City Region' (August 2014) was prepared to set out a cohesive approach across the region to the Green Belt review process. This outlines a staged approach which can be summarised as:

* Stage 1 - Identify general areas within the Green Belt
* Stage 2 - Technical site assessment
* Stage 3 - Re-appraisal of resultant land parcels.

Within the NEDDC Green Belt Review large parcels of land are generally considered, for example Parcel WAD/GB/006 covers an area of 2.4 ha. However there does not appear to be any general consideration of smaller elements within each parcel which may score different in terms of the purposes of the Green Belt and therefore may be suitable for removal without impacting on the overall objectives of the Green Belt in that location. The Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Furthermore, there is a lack of consistency in the approach to selecting parcels for assessment. Had the same approach been taken to our clients site (along with land to the west) as that taken for Parcel HOLY/GB/024 within Holymoorside, which covered an area of 0.877ha, the conclusions regarding BRAM/2301 may have been different.

In summary within a more localised assessment of BRAM/2301 the site can be considered as follows:

* Purpose 1 'To check the unrestricted sprawl of large built-up areas': Wadshelf is a remote, freestanding rural settlement and is not in close proximity to other settlements. The village of Wadshelf already extends beyond the Settlement Development Limits to the west of the current boundary. The removal of the Site from the Green Belt would not result in the sprawl of Wadshelf, as a number of existing dwellings and community facilities are already located to the west of the village, and to the west of the Site, outside of the Settlement Development Limits.

* Purpose 2 'To prevent neighbouring towns merging into one another': No comment as the Green Belt Review scored this a 'Green'.

* Purpose 3 'To assist in safeguarding the countryside from encroachment': As stated above, the existing settlement of Wadshelf already extends to the west of the Site, outside of the Settlement Development Limits for the village. The northern edge of the Site has a strong boundary and the elevation of the land to the rear of the Site would reduce any visual impact of the proposals. The removal of the Site from the Green Belt, and its inclusion within the Settlement Development Limits, and any subsequent development on this Site would not pose a significant or unacceptable threat to the countryside.

The consideration under 3a should not be afforded any weight when the percentage of an area selected it entirely related to the area selected in the first place. Had the land at Wadshelf which forms part of the village, but falls outside the Settlement Boundary, been considered in the same way the site at Holymoorside was then the percentage of the site covered by development would have been significantly higher.

* Purpose 4 'To preserve the setting and special character of historic towns': Although recorded as an Amber score, it is considered that the Conservation Area boundary for Wadshelf covers a larger area than the Settlement Development Limits, and as such any considerations regarding the setting of Wadshelf would remain governed by the relevant heritage policies. Furthermore, any development on the Site would not dilute the character of the settlement as a small agricultural settlement.

* Purpose 5 'To assist in urban regeneration, by encouraging the recycling of derelict and other urban land': No comment is provided on this given the approach taken within the Review with regards to this purpose.

The Green Belt Review Part 1 identifies that based on a range of Growth Scenarios, ranging from A to C, that in order to maintain the vitality and viability of smaller settlements through further small scale development Wadshelf would need to deliver between 7 and 23 dwellings over the Plan period.

However the review process concludes that for Wadshelf and a number of other settlements:

"There are no sites identified which are suitable for release which could accommodate the housing requirements of these settlements. As such, the housing need identified under Scenarios A, B and C would have to be accommodated in nearby settlements or alternative options set out in the Part 1 Report considered."

Had our clients' site been considered using the same approach adopted for HOLY/GB/024 then the conclusions with regards to Wadshelf within the Review may well have been different.

Therefore, in summary it is requested that the Green Belt Review of Site BRAM/2301, forming a Parcel along with land to the west of the site which functionally falls within the village of Wadshelf, be reconsidered on the same grounds as the approach taken to Parcel HOLY/GB/024.

It is considered that the release of this land from the Green Belt would regularise the position within with regards to the extent of the village and the Green Belt boundary. Furthermore the release of any land from the Green Belt forming part of this smaller parcel of land would largely relate to existing dwellings, the Village Hall and playground and with a limited opportunity for new development.

Housing Sites Assessment Report (Feb 2017)

Within this document our clients' site is assessed under Ref BRAM/2301 - Millstone, Wadshelf.

The assessment of the site is considered incorrect for the following reasons:

* Green Belt: for the reasons set out above, it is considered that there has been no consistency with the site selection process when considering parcels of land within the Green Belt Review. As a result the negative conclusion regarding parcel WAD/GB/006 works against the assessment of our client's site.

* Access: Whilst the site does not currently have access from the highway, access could be created using the same principles applied to developments to the east and west of the site. it is therefore considered that this is not an issue in respect of this site.

* Design: The policy conclusions with regards to the Conservation Area and design appears to take a more negative view than the comments elsewhere within the document. These note that "If any development of the site would be sought then it should be delivered with good design and low density." This could be achieved and a scheme sensitively designed to have regard to the views of the site and the conservation area. It is therefore considered that the policy conclusion is overly negative with respect of this issue.

* TPOS: The TPOs referred to within the Policy Conclusions relate to land which falls outside of the land being considered. Whilst they may be a consideration in terms of any future proposals for the site, in their own right they are not a constraint to the development of Site BRAM/2301.

* Services: Wadshelf scores the same as Cutthorpe within the Settlement Hierarchy Study (2016) and yet the decision has been taken to remove an area of land from the Green Belt within Cutthorpe which is largely covered by built development and forms part of the existing settlement (Ref CUT/GB/003 and Housing Study BRAM/2401). Whilst it is acknowledged that the removal of this site has resulted from the Green Belt Review rather than the Housing Sites Assessment, it is clear that the removal of sites from the Green Belt within other Level 3 settlements is being progressed within the draft Local Plan.

In summary, for the reasons outlined above the conclusion not to consider Site BRAM/2301 further as a Housing site is based on an incorrect assessment of the site and should be revisited.

SUMMARY

In summary it is considered that the site remains available, suitable and achievable and should be released from the Green Belt to the district's housing needs over the plan period. Furthermore the removal of our clients site would ensure that the approach taken to Wadshelf is consistent with that taken in Holymoorside and Cutthorpe.

We would therefore urge the Council to review the draft Local Plan and Evidence Base documents in the light of the above submission and consider the removal of our clients' site from the Green Belt as part of the review of Level 3 Settlement Boundaries which is still to be undertaken at the next stage of the Local Plan process.

Object

Consultation Draft (February 2017)

Representation ID: 6516

Received: 07/04/2017

Respondent: Historic England

Representation:

SA Objectives - SA Objectives 10 and 11 relating to the Historic Environment is welcomed.

Not clear how unknown archaeology in respect of NPPF Para 139 has been considered as part of the assumptions for SA Objective 10: Cultural Heritage.

Recommended that further HIA work is required for the proposed allocations;SS6,SS7.

Historic England does not agree with the 'neutral' outcome identified for SS7 and recommends that further HIA work is undertaken for the site.

6.12.2 - The first sentence indicates an incorrect interpretation of heritage asset setting. It is recommended that the text be revised(see submission).

6.40.1 - Incorrect grammar that implies that Conservation Areas, Listed Buildings and other heritage assets will not be acceptable, it is suggested that the text be reworded. appropriately reworded.

All references to 'historic assets' should be revised throughout the document to read 'heritage assets' in line with NPPF terminology

It's not clear how the outcome for SA Objective 10 in SDC6 indicates very positive effects. Suggestion that these sections are reconsidered and revised in the next iteration of the SA.

6.42.1- SM's relevant legislation should be included here for consistency if relevant legislation is being included for Conservation Areas and Listed Buildings.

6.44.1- It is recommended that further work be undertaken on this aspect for clarity in the next iteration of the SA.

SA FRAMEWORK- Recommendation that SA Objective 10 criteria wording 'preserve' be replaced with 'conserve' inline with NPPF-terminology and that used in the Draft LP. Recommendation that indicators in the SA framework tie in better with the indicators set out in the Draft LP Policies supporting text for consistency. Recommendation that in Q10d, the number of Conservation Areas at risk be included as an indicator.

Full text:

See attachment.