National Planning Policy
Consultation Draft (February 2017)
Representation ID: 4700
Respondent: Dr Clare Freeman
The local plan is not consistent with and does not uphold the principles of the National Planning Policy Framework. There s no justification for taking land out of the Greenbelt.
I don't agree that the local plan is in the context of national planning policy as set out in the National Planning Policy Framework. There has been no sequential approach to development. Re-use of vacant properties and existing brownfield sites have not been considered in the first instance- see paragraph 5 in the NPPF. Greenbelt land must only be developed in exceptional circumstances and the case for this has not been made. There has been no assessment of the capacity of the existing infrastructure- including public transport, utilities, schools, doctor's surgeries and police- to absorb the development. The existing community does not have the social and environmental capacity to accommodate this number of new houses. The NPPF prioritises the creation of safe and secure transport routes, particularly for pedestrians and cyclists, but also for all road users in paragraph 35, but yet the local plan does not acknowledge the fact that Dronfield's narrow roads struggle to cope with the existing levels of traffic and emissions- see paragraph 30. Finally, there has been no consideration as to the importance of protecting and enhancing valued landscapes so as to optimise access for education and recreation as specified in paragraph 109.
Consultation Draft (February 2017)
Representation ID: 5203
Respondent: Mr Eric Singleton
Statement that proposals in Dronfield are not sustainable. 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.
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.