Consultation Draft (February 2017)
Representation ID: 4666
Respondent: Mrs Linda Blatt
Questions raised over how wildlife would be protected if proposed housing allocations were to go ahead. Concerns raised over how the potential increase in traffic could impact on wildlife and existing residents.
Having lived in Coal Aston for over 15 years, the first thing that struck me when moving here was the amount of wildlife in the area. In my garden alone I have seen birds that I would not have seen in my previous home in the south east of England coming from what was a 'new estate', similar to your plans here. Along with Woodpeckers, all manner of finches and the like, I have had Pheasants, Sparrowhawks and at night, Owls in my garden and they have often been seen in the fields and trees at the back of the Village Hall. Not only that, there is a large colony of bats that frequent around the back of hall and can be viewed repeatedly feeding over the fields to the back of hall (I am sure you realise these creatures are protected by law. How do you plan to protect them when you intend to destroy their habitat?).
The increased traffic flow in the area during any potential construction will not only impact on the wildlife and also put residents at increased risk. We already have drivers that cut through the village driving dangerously, coupled with HGV traffic as well as the onsite workforce creating this development, the quality of life in the village will ultimately suffer. As you already mention in the plan "Dronfield has many positive assets, including two Conservation Areas (the town centre and a small area in Dronfield Woodhouse), together with a further Conservation Area in Coal Aston....". You identify these green belt areas are an asset, yet you wish to destroy green belt in Coal Aston an area rich in wildlife.
Consultation Draft (February 2017)
Representation ID: 4877
Respondent: Mrs Kathryn Clay
More consideration should be given to the issues outlined above before housing plans are given the go ahead. It strikes me that the current proposals are putting the cart before the horse.
I am concerned about the following with regard to the proposed plans for housing development in Killamarsh for the following reasons.
1. There is no mention of any improvement to the main road access to Killamarsh. The road becomes congested on a regular basis.If the number of residents increases bringing with them an increased number of cars this situation is only going to get worse.
2. There is no mention of increasing the number of school places and again the number of children will increase with an increase in housing.
3. The bus service is now one bus an hour serving Sheffield where the majority of people work. Whilst many people drive into Sheffield an increasing number use public transport.
Also the links to Crystal Peaks are served by this same bus therefore there is only the one bus an hour. We are encouraged to use public transport how can this be done if the transport is not there. Crystal Peaks is the nearest place for banking facilities etc.
Consultation Draft (February 2017)
Representation ID: 5004
Respondent: Mrs Helena Gayle Boulton
6 weeks is the mimimum period for a consultation yet this is the amount of time chosen to allow residents to try and understand this huge document and formulate a considered response.
In the one opportunity provided to meet planning officers at a meeting at Dronfield Civic Hall, this was very much presented as a done deal and when questioned why brown fields sites hadn't been looked at for development it was suggested that we (the residents) should go and find some suitable. I believe this to be the job of the council.
6 weeks is the mimimum period for a consultation yet this is the amount of time chosen to allow residents to try and understand this huge document and formulate a considered response.
In the one opportunity provided to meet planning officers at a meeting at Dronfield Civic Hall, this was very much presented as a done deal and when questioned why brown fields sites hadn't been looked at for development it was suggested that we (the residents) should go and find some suitable. I believe this to be the job of the council.
Consultation Draft (February 2017)
Representation ID: 5024
Respondent: Lisa Pitchford
Concern raised over using the website. Statement made that it would seem that it has purposely been made so that people cannot write any comments on the proposed plans do you can drive them through.
The ne-derbyshire.gov.uk/localplan website is one of the worst websites I have ever tried to use. It would seem that it has purposely been made so that people cannot write any comments on the proposed plans do you can drive them through.
I completely object to the local plan for the Dronfield community.
If these sections of green belt are given up for houses it will have a number of negative impacts across the local community.
Dronfield will be too large to cope, the traffic and car parking issues across the town are already dire. The small streets cannot cope with over another 1000 cars, plus the lorries for Callywhite Lane. Many cars already park on the roads causing dangerous obstructions and blind spots. The town will be gridlocked. The already terrible road conditions/pot holes will make it more like a third world country, let alone the increased pollution. The access to a lot of the proposed sites is down dead end roads that already struggle with the amount of traffic they see.
It will not be safe for children to go out and try and use any green land they can actually find, as we will loose so much and the wildlife will vanish, as the roads will be to busy and unsafe.
Studies show that green space helps mental health. If this were to impact on most of the residents in Dronfield what will they do as the GPs are already over stretched. All the new housing doesn't have any GPs to support them as surgeries are already so over crowded and it is hard to get an appointment. The schools are full, you'll be sending children out of their own town to try and find a space somewhere which is completely wrong and unsupportive of their future education and well being.
In the future where will it stop for green belt, Dronfield will have no green space and become so large it will become of the largest suburbs of Chesterfield or Sheffield. Don't make Dronfield, who came in the top 10 for best places to live, become an awful overcrowded urban sprawl which you will create.
It has to be said there are plenty of brown field sites that are right for reusing as housing locations, some within just a few miles of Dronfield (and indeed some within Dronfield eg Callywhite Lane). Why is NE Derbyshire Disctrict Council not allocating these brown field sites for housing as 100's of other councils are around the country. The only reason I believe is developers want to maximise profits and they want to build houses they can sell at a premium price, all at the expense of those who have lived in Dronfield and paid council taxes here for years and years. This is completely wrong, unjust, incompetent, immoral and undemocratic.
Consultation Draft (February 2017)
Representation ID: 5201
Respondent: Mr Eric Singleton
The quality of the English and the arguments within the plan fall way below that which should be produced by competent and qualified professionals.
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.
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.
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.
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.
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.
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.
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"
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.
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.
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.
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.
Consultation Draft (February 2017)
Representation ID: 5299
Respondent: Kevin Fielding
The following considerations need to be addressed prior to any development:
Our property will suffer from:
Loss of light due to it's south facing aspect.
Loss of privacy due to new properties overlooking us
Increased traffic on the already congested road where most properties do not have off street parking
Consultation Draft (February 2017)
Representation ID: 6313
Respondent: Mount St. Mary's College
Statement that the absence of a Policy Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.
Local Development Plan Current Consultation - February to April 2017
Mount St Mary's College's Objectives & Priorities
My name is Nicholas Cuddihy and today I write to you in my capacity as the CEO of the Mount Trust; a charitable trust established in 2006 to manage the property, resources and aspirations of Mount St Mary's College, Spinkhill and its prep School at Barlborough Hall.
The story of our schools dates back to 1620 when the Jesuits first became active in this park of the UK. In 1842 the Jesuit Provincial established Mount St Mary's College in Spinkhill. The school at Barlborough Hall first opened in 1939. The Mount Trust as we know it today was set up as a Local Trust in 2006 to manage Mount St Mary's College and Barlborough Hall School as co-educational inclusive day and boarding schools in the Jesuit tradition, providing children and their families with access to a seamless education from the ages of 3 to 18 yrs. We have long been significant members of the community in Spinkhill.
Our lands and facilities are shared openly and are enjoyed by many in the village and others all year round. Locals and visitors walk our lands freely and access the footpaths and bridleways at their leisure. Our Memorial Chapel frequently hosts concerts and special religious and other ceremonies. We have long established and successful partnerships with many sports clubs and other local groups who enjoy our sports fields, our public gym and other facilities. Every day and every week athletes, footballers, walkers and others come and go and enjoy our beautiful site. We see ourselves as residents of Spinkhill village and we take our responsibilities seriously in this regard. You can understand therefore how we were surprised to note that our school is not located within the settlement boundary in the proposed Local Development Plan. I will address this concern in more detail later but for now I wish to highlight this concern as I set out the context within which we wish to comment on elements of the draft Local development Plan.
During this year, 2017, we will celebrate the 175th Anniversary of the foundation of our schools. As we celebrate we are also concentrating our efforts on planning for our future. Our schools and lands are obviously hugely expensive to manage and maintain. Our heritage buildings and more modern facilities require ongoing investment. We have been a major employer in the area for more than a century and a half. We currently employ more than 170 people and as we look to the future we know we have to fight hard to survive and to thrive.
The Trust has ambitious plans for the College focusing on making improvements to its facilities and improve the extent and quality of facilities it provides to the public and local community. We are keenly aware that a significant and extended increase in income will be required to secure the long term stability of the school. As we master plan for the long term future of our schools we know we will need to devote significant funds to the maintenance and development of our buildings and lands. It is in this context that we welcome the opportunity to comment on the Draft Local Plan in this current consultation.
1. Green Belt Policies
Having reviewed the draft Plan's evidence base related to housing and growth we are pleased to see that part of the College's previously developed land has been included within the Housing Sites Assessment Report dated February 2017 (Appendix C), as 'Land off Station Road, Spinkhill'. That acknowledges the site as an 'infill site'
Nevertheless, having reviewed the draft Plan's policies map we also note that the entirety of the College's lands within the Spinkhill area is identified as Green Belt. From our understanding of national planning policy (within the National Planning Policy Framework (NPPF)), local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access, sport and recreation amongst other things (para.81). Brownfield land should be acknowledged within the Green Belt, reflecting the exceptions test within the (paragraph 89). The current Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.
We wish to therefore object to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.
2. Spinkhill Settlement Boundary
We would also like to take this opportunity as referred to earlier to raise our concerns regarding the Council's proposed settlement boundary for Spinkhill Village. The policies maps show that the College is not included within the settlement. We have reviewed the definition of a 'settlement' included in the glossary of the draft plan glossary and believe that the College should be included as part of the Spinkhill Settlement based on that definition. It has always been part of the village and has never been physically separate. For more than a century and a half we have played an important part in local life with leisure and recreation facilities available to the village. The village school was housed on our lands prior to its recent relocation across the road. The old Spinkhill railway station was also located on our land and accessed freely by all until it closed and the allotments which are enjoyed today by many villagers also lie on our land.
I note that the Council's most recent Annual Monitoring Report (AMR) (2015/16) identifies how between 2011 and 2015 the number of completions in the district has been below the Council's 300 dwellings per annum target each year. Between 2011 and 2016 the AMR notes a net undersupply of -484 dwellings for the period, and when the council includes projected completions for 2016/2017 this position worsens to-583 dwellings.
Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.
We note that the Council acknowledges that its approach to housing is to be reviewed and given that its Green Belt Review has established that land needs to be removed from the Green Belt, we propose that the College, as previously developed land in the Green Belt should be reconsidered to accommodate some housing capacity.
In conclusion and speaking more broadly we want to explore how we may be able to work together to succeed together. We would welcome an opportunity to engage with the Council proactively to see how specific education related policies could be included in the draft plan. This is particularly important to us as we look to the future. As we reach 175 years we are conscious of our need to develop and invest so that we can improve the educational and wider public facilities we own and provide to others. We have been a major employer and an important part of the life in Spinkhill for a long time. We want to preserve and develop that for today and for the future.
Policy SS£ & SS13:
Smaller settlements classified as "level 3" settlements in Table 4.1 can and should make a significant contribution to housing provision and this can help sustain community facilities. Limiting development in such villages to "limited infilling of one or two dwellings" is too restrictive.
In Spinkhill the land shown on the attached plan as Allotment area could make a significant contribution to housing need and the funds released by this development could help improve facilities at the Mount St Mary's College.
This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside"
The Green Belt is too tightly drawn around Spinkhill (see our comment on Appendix B - Green Belt Maps).
The limitations in this policy are too restrictive. Smarter homes and homes to provide employee accommodation, linked to established rural based employers should qualify as "affordable housing."
Although this policy is intended to include for "other occupational dwellings in the countryside" there is no such provision in the text. The policy only refers to dwellings for agriculture and forestry. This is a serious omission and requires correction. Mount St Mary's College is a rural based employer which will require employee's dwellings to be allowed for in this policy. In its present form this policy is inconsistent with Policy SS14 (b).
This policy is too restrictive in that it only refers to buildings. It should refer to previously developed land. In its present form it is inconsistent with Policy SS14 (a) which refers to development being allowed on "vacant derelict or previously developed land." and SS9 (f).
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.
We have the following comments on the Policies Maps.
The absence of a Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.
We attached a map of Spinkhill and request the following:-
- Area shown as Allotment area (on the attached plan) should be within the settlement limits and removed from the Green Belt. This wold allow for development of the land for housing and provide funding for improvement to the facilities at Mount St Mary's College.
- The area at Spinkhill identified as "GS3" in the existing Local Plan, comprising the building complex at Mount St Mary's College, should be within the settlement limits and removed from the Green Belt. It is clearly part of the settlement. This was previously shown as "major development in the Green Belt" which is illogical.
Consultation Draft (February 2017)
Representation ID: 6450
Respondent: Mr & Mrs N Beecroft
Agent: Caroline McIntyre
The assessment of site BRAM/2301 - Millstone, Wadshelf in the Housing Sites Assessment Report (Feb 2017) is considered incorrect for the following reasons. (see submission.)
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 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.
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.
Consultation Draft (February 2017)
Representation ID: 6770
Respondent: Clay Cross Parish Council
'One Public Estate'. How will that affect the Local Plan?