Relationship with other Local Plans and the Duty to Co-operate

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Object

Consultation Draft (February 2017)

Representation ID: 5204

Received: 03/04/2017

Respondent: Mr Eric Singleton

Representation:

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.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.5 Policy SS1, Sustainable Development, clauses c and g

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Comment

Consultation Draft (February 2017)

Representation ID: 5382

Received: 03/04/2017

Respondent: Ackroyd & Abbott Homes Ltd.

Agent: Charlotte Stainton

Representation:

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Full text:

Four letters have been submitted as representations to the Draft North East Derbyshire Local Plan 2011-2033 which is submitted on behalf of clients Ackroyd and Abbott Ltd.

North East Derbyshire Local Plan Representation - Station Road, Killamarsh

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Station Road, Killamarsh - 07/00865/FL
Full planning permission 07/00865/FL has been granted for the residential development of the site of the Old Station at Killamarsh and we believe that it should be shown as a housing allocation in the Local Plan. We have a letter dated 22 May 2015 from Adrian Kirkham which confirms that this permission remains extant. Failure to allocate this site appears to be a missed opportunity to deliver housing within the built framework of Killamarsh.

The development of this site stalled due to the crash in the housing market and then latterly due to uncertainties about the route of HS2. I confirm however that this site is now available and deliverable.

We therefore request that the site covered by 07/00865/FL be allocated for residential development. The development of this site is in accordance with the Council Local Plan Strategy and could reduce pressure on the Green Belt surrounding Killamarsh.
North East Derbyshire Local Plan Representation - Hasland

Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the 5740 allocated dwellings would be on just two strategic sites. This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

In terms of the Green Belt review and the subsequent draft housing allocations within Green Belt, there is no evidence that this has been undertaken in consultation with the adjoining Local Authorities and this lack of cooperation potentially makes the plan unsound.

Land at Churchside, Hasland
The two parcels of land shown on the attached plan were previously submitted to the 'call for sites' process for consideration. They can be considered as one large site or two separate sites. They are both available and deliverable within 5 years.

We do not believe that sufficient consideration has been given to the opportunity that these sites offer to deliver housing adjacent to Chesterfield under the Duty to Cooperate.
These sites are positioned immediately adjacent to the built-up settlement of Hasland. The release of this land parcel would not result in harm to the countryside to the east or west and an area of open green belt would remain to the south, thus avoiding the coalescence of settlements.

Numerous areas of land are proposed to be taken out of the Green Belt in the north of the District and the removal of these sites in Hasland would be no more harmful to the purposes of Green Belt than the majority of those Green Belt sites that are proposed housing allocations. There is a lack of consistency in approach and because of this the Green Belt evidence is flawed.

For the reasons submitted as part of the Call for Sites, we therefore request that these sites at Hasland be removed from the Green Belt and allocated for residential development.

Another option would be to safeguard these sites for future development, possibly to deliver future housing for Chesterfield.

The development of these sites could therefore reduce pressure on the Green Belt to the north of the District and/or deliver future housing for Chesterfield.

North East Derbyshire Local Plan Representation - Holmewood
Proposed Housing Allocation - Holmewood (ab)
We wish to support the allocation of the housing site in Holmewood given the reference - ab. The site has planning permission under reference 14/00312/OL.

We confirm that this site which has planning permission is available for development and discussions are ongoing with potential developers and the landowner.

The site can confidently be included in the Local Plan as available and deliverable within 5 years.

It is important however that the viability issues relating to the provision of affordable housing and developer contributions are recognised for this site which is in a relatively low value area.

We therefore request that draft housing site allocation ab is carried forward to future drafts of the Local Plan.
North East Derbyshire Local Plan Representation -
Hanging Banks, Wingerworth
Housing Provision
The Council is proposing allocations for 5740 dwellings for the plan period (which together with the dwellings already constructed would give the potential to deliver 6,756 homes). The Council believes that these allocations would be sufficient to achieve the minimum housing requirement of 6600. The allocation of sites to plan for only 156 units above the minimum housing level required does not give sufficient certainty that even the minimum housing needs of the District will be delivered. In addition, planning for the minimum requirement is not a way to achieve the economic growth aspirations being promoted by the Council, particularly when considering the persistent under-delivery of housing.

It is noted at paragraph 4.23 that the evidence underpinning the housing and employment targets is under review and that targets may be amended in a future version of the Local Plan. This gives an unacceptable degree of uncertainty to this consultation exercise.

1270 of the allocated dwellings would be on two strategic sites and 2125 of the proposed 5740 dwellings would be in the green belt (59% of the total housing number made up of the strategic sites and Green Belt sites). This is a significant weakness in the Council's strategy. Given the previous under-delivery of housing on the two strategic sites (particularly Biwaters) the anticipated delivery rates for these two sites is unrealistic. In addition, the disproportionate reliance on the two strategic sites makes the strategy for the provision of housing numbers weak.

The significant reliance on so many Green Belt dwellings is also a significant weakness in the draft Local Plan. The recent Housing White Paper gives a clear direction that Green Belt should only be released where "all other reasonable options have been explored". Whilst I am not against Green Belt release where appropriate, we believe that there are numerous non-Green Belt sites across North East Derbyshire which have been discounted for reasons which should not outweigh a Green Belt designation. We therefore do not believe that all other reasonable options have been explored in this case. This makes the plan unsound.

Local Settlement Gaps
The evidence that the Local Settlement Gaps designation is based on is fundamentally flawed. This is because the perceived 'gaps' that the designations are seeking to protect do not exist in reality and there is no consistency or logic to which areas are concluded to be important settlement gaps in the evidence.

The Council has then adopted this flawed evidence by including the recommended settlement gaps in the Draft Local Plan without any narrative about the merits of each gap and whether the perceived need for a gap should outweigh the opportunity to deliver development adjacent to existing settlements. The provision of local settlement gaps would actually result in the loss of Green Belt land elsewhere.

In the case of the Local Settlement Gap shown to the south of Nottingham Drive, Wingerworth (in the area known as Hanging Banks) the explanation of why this area forms a settlement gap of such importance that it should be protected from development (at the expense of Green Belt elsewhere), is severely lacking. There is already development on the east side of the A61, which is also part of Wingerworth. It is not logical to try to keep a field between two parts of the same settlement. The development of Hanging Banks would unify the settlement, not result in harm to the identity of the settlement.

The proposed settlement gap in this location is not based on a clear understanding of the settlement and should be removed from the Local Plan.

Hanging Banks, Wingerworth - 16/00656/OL
Planning permissions 14/00763/OL and 16/00656/OL have been granted for the residential development of the Hanging Banks site and we firmly believe that it should be
shown as a housing allocation in the Local Plan.

There was minimal local objection/comment to these planning applications which suggests that the protection of this land as countryside is not of significant concern to local residents.

In determining the initial outline planning application, the Council concluded that the development of this site would be sustainable and that all technical requirements could be met. In addition, the Council participated in the OPUN design review process and carried out significant work with the District Valuer. It does not make sense for all this work to be put to one side when the site is an available and deliverable housing development opportunity.

This development would deliver a high quality residential scheme which would respond to the various constraints and opportunities presented by the site e.g. site frontage to A61, retention of hedgerows, responding to the woodland, backing on to properties on Nottingham Drive, soft edge to the countryside boundaries (outward facing) and the delivery of dwellings to meet the local market and deliver affordable housing such as bungalows for the retirement market etc. The development of this site would sit comfortably adjacent to the existing built up area as a natural extension. Agricultural land and woodland will remain to the south and west and there is already development on the eastern side of the A61.

We therefore request that this site be allocated for residential development and as such that the Local Settlement Gap designated is removed from this site. The development of this site is in accordance with the Council Local Plan Strategy and would reduce pressure on the Green Belt.

Comment

Consultation Draft (February 2017)

Representation ID: 5982

Received: 06/04/2017

Respondent: Advance Land & Planning Limited

Representation:

Council has yet to produce a Duty to Cooperate Statement, cannot properly assess whether the emerging Plan will deliver the full and objectively assessed housing need for the area and any unmet need of neighbouring authorities where it is reasonable to do so.

Full text:

See attached documents.

Comment

Consultation Draft (February 2017)

Representation ID: 6376

Received: 07/04/2017

Respondent: Tracey Marsden, Nicola Shepherdson & Mark Woodhead

Agent: Caroline McIntyre

Representation:

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

It is essential to understand at this early stage of the Plan preparation:

* the extent of discussions with SCC and the requirement for any additional housing to be delivered by NEDDC; and
* whether this could impact upon the spatial strategy as set out within the Plan at Policies SS1 and SS3.

Full text:

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

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

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

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

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


REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUSTAINABILITY APPRAISAL (2017)

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

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

GREEN BELT REVIEW (FEB 2017)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Housing Sites Assessment Report (Feb 2017)

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

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

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

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

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

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

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

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

SETTLEMENT HIERARCHY STUDY (2016)

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

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

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

SUMMARY

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

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

Comment

Consultation Draft (February 2017)

Representation ID: 6536

Received: 07/04/2017

Respondent: Gladman Developments

Representation:

It is noted that NEDDC is currently in the process of updating its evidence base on a number of matters, including objectively assessed housing needs. It is important that this exercise is undertaken through a process of pro-active engagement with relevant neighbouring authorities, including those within the north Derbyshire / North Nottinghamshire HMA and the SCR. Suitably robust evidence will need to be published alongside the Local Plan in due course to demonstrate that the duty to cooperate is being
fulfilled.

Full text:

See attachment for full submission.

Comment

Consultation Draft (February 2017)

Representation ID: 6607

Received: 07/04/2017

Respondent: Home Builders Federation

Representation:

The Council has not produced an up to date Duty to Co-operate Statement. Before the pre-submission LP consultation a Duty to Co-operate Statement should be prepared setting out the Council's compliance with the legal requirements of the Duty and the outcomes of collaborative working in order to find the LP sound.

A Statement of Common Ground explaining cross boundary working as proposed in the recently published Housing White Paper may also be required.

Full text:

See attached

Comment

Consultation Draft (February 2017)

Representation ID: 6673

Received: 07/04/2017

Respondent: Rippon Homes Ltd

Agent: RPS (Birmingham office)

Representation:

Paragraph 1.16 of the consultation document refers to the legal requirement of the Duty to Cooperate. Notwithstanding this the document does not set out how the requirement is being addressed in terms of co-operation with the neighbouring authorities. Therefore the Council will need to prepare a Statement of Compliance with the Duty to Co-operate Statement, without which the Local Plan should not be found sound.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6708

Received: 07/04/2017

Respondent: St Modwen Developments Ltd

Agent: RPS (Birmingham office)

Representation:

The document does not set out how the requirement is being addressed in terms of co-operation with the neighbouring authorities. Therefore the Council will need to prepare a Statement of Compliance with the Duty to Co-operate Statement, without which the Local Plan should not be found sound.

Full text:

See attachments