Introduction

Showing comments and forms 1 to 8 of 8

Object

Consultation Draft (February 2017)

Representation ID: 4685

Received: 14/03/2017

Respondent: Mrs Anna Lomas

Representation Summary:

I object to building on the green belt.

Full text:

I object to building on the green belt.

Object

Consultation Draft (February 2017)

Representation ID: 4733

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

meet the future needs of the District in locations where it is most needed" You have identified where these areas are and yet this plan seeks to build houses where they are not needed - in Dronfield and where there is no likelihood of employment on a large scale - Callywhite Lane.

Full text:


I am making comments about Dronfield, the Green Belt and Housing.

"NE Derbyshire is experiencing an ageing population"
There is no mention of provision for bungalows to be built in Dronfield. Whilst the Plan mentions affordable housing need of 30-40% it does not stipulate the proportion of bungalows that should be built. Indeed Dronfield is losing its stock of bungalows as planning permission has been granted by this authority to convert bungalows into houses or they get demolished for the plot which then has a very large house built upon the site. In allowing this to happen the council is not making provision for an ageing population. As well as affordable housing, this council should stipulate a percentage of bungalows in new developments.

"set within attractive countryside and landscapes highly valued locally"
This statement should therefore guide the planners to maintain the highly valued landscapes and not remove land from the Green Belt which will have a significant impact upon them.
"There will inevitably have to be some loss of countryside"
Why is it inevitable? It is the easiest option. There are plenty of alternatives which this council has not fully explored.
"There is a need for more housing" This is a vague statement. "Only a quarter of the population in NE Derbyshire cannot afford market housing". This means 75% can. Where then is the demand for this affordable housing you wish to build on Green Belt land in Dronfield?
"there is need to provide local employment opportunities close to where people live in order to reduce out commuting"
This is unlikely to be achieved in Dronfield when housing is 860 for 6 hectares of employment land.
You identify that unemployment is high in Grassmoor, Holmwood, Heath and Clay Cross, therefore these are the areas that need the regeneration in terms of jobs and affordable housing, not Dronfield. You identify the Birchall Estate as being a growth area for tourism and employment. There are plenty of brownfield sites nearby on which to build houses. Building houses in Dronfield will encourage more commuting and congestion on local B roads through Dronfield Bottom and Unstone village.
"In the north of the district, growth and expansion of the towns of Dronfield will have met the development needs"
This is past tense and states that in fact the job has been done to achieve the desired outcomes. Dronfield has recently been ranked 9th in the top ten best places to live. Any further growth of Dronfield will have major adverse effects. However Dronfield does need a regeneration of its town centre - the Civic which has empty units and charity shops and which lets the rest of the town down badly.
Local Plan Objectives
D7 "To protect the separation and identity of settlements by identifying key areas of countryside where development should be restricted"
If this is an objective, then achieving it by taking land out of the Green Belt is totally contrary to this statement.
D13 "To ensure that housing and employment growth takes place in a way that protects local amenity and does not undermine environmental quality"
Again another objective that cannot be achieved by taking Green Belt land.

Strategic Co-operation "..working with neighbouring authorities"
Where in this plan has the council demonstrated that they are in any way doing this? Isn't it a directive from central government that where authorities are constrained by the Green Belt they can look to their neighbouring authorities to satisfy housing demand? Why doesn't this council look to work with Chesterfield Borough Council to explore land for housing on their respective boundaries at Brierley Bridge to the south of Unstone where there is a wealth of potential brownfield sites on the old boatyard and the old nursery with the prospect of 1300 jobs across the road at Peak Resort? You don't need to be a planner to realise that this is where the housing should be. Unless this option has been fully explored I do not consider that there are exceptional circumstances to take land from the Green Belt for housing.

Within the county are significant brownfield sites ripe for development in areas where unemployment is high like the Avenue and Biwaters. Why does there have to be growth across the county? It makes sense to target these sites first which because of their size will satisfy demand for jobs and housing. Dronfield is already an urban sprawl. Recognise that the town at its modest size is a good place to live. Regenerate its centre and leave it at that. There doesn't need to be growth everywhere. It is totally wrong and irresponsible to increase the size of a town by 10% before having an infrastructure plan in place first.

"meet the future needs of the District in locations where it is most needed" You have identified where these areas are and yet this plan seeks to build houses where they are not needed - in Dronfield and where there is no likelihood of employment on a large scale - Callywhite Lane.
"The local plan aims to provide new jobs along with new housing" Where are the new jobs in Dronfield for the 860 new households planned? Callywhite Lane is not one of your Strategic Sites and employment you have said is in storage and distribution which does not employ many. By building houses in Dronfield, this plan is further encouraging commuting which is already 61%
Why does an already large centre mean it has the greatest needs for new housing? I disagree. Modest sized towns like Dronfield should not become larger to eventually become mini cities or because of their urban sprawl join with Sheffield or Unstone. Can it not be said that Dronfield has reached its optimum development level to become the 9th best place to live in the UK?
Four Strategic Sites have been identified etc, along with 43ha of employment land and XXm26 of retail floorspace.
Callywhite Lane is not listed as amongst the four Strategic Sites where most of the housing will be along with a large proportion of employment land so why build houses in Dronfield? This plan makes statements that Callywhite Lane is not attractive to investment - another reason not to build houses in Dronfield. It will only drive up commuting, unemployment and congestion.

These points would seem to be the justification for removing land from the Green Belt. However housing need cannot be cited as the exceptional circumstances necessary to remove land from the Green Belt.
Within North East Derbyshire there are huge brownfield sites for housing and employment. Why can't the housing quotas be satisfied on these sites rather than taking Green Belt land? Why does there need to be further housing in Dronfield when there is little opportunity to create local employment (6 hectares) except in storage and distribution which employs few people on low wages? The number of proposed houses does not equate with employment provision in Dronfield, when elsewhere 2000 houses is in relation to 43 hectares of employment land.

Housing requirement for Dronfield is 860. A similar table two years ago had Dronfield's requirement at 285 houses to 2031. A review of the Green Belt seems to be cited as the reason that the housing figure for Dronfield has increased three-fold. It seems purely to satisfy a spatial strategy and a need to build everywhere. "The recommended growth for Dronfield is 285 dwellings over the 20 year plan period to 2031. Up to 31st March 2014, 34 dwellings had been built and another 70 dwellings had planning permission. This leaves another 181 dwellings to allocate in the local plan." Justify why it is now 860. This council has not considered the Strategic Housing Market Assessment evidence carefully or taken adequate time to consider whether there are environmental and policy constraints, such as Green Belt, which will impact on their overall final housing requirement.
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N3 Employment Land "To improve the quality of employment land in the north and address infrastructure deficiencies to allow for the expansion of existing sites" This is yet another unachievable objective in terms of Callywhite Lane in Dronfield. There are empty sites, vacant land, empty units and this plan states that this area is not attracting businesses and hasn't done for a number of years. Given this status, why has this council not redesignated land for housing on Callywhite Lane or explored this as an option before taking Green Belt land? Because once again they have chosen the easiest option. "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. Land allocated should be regularly reviewed." Callywhite Lane will never attract the sort of businesses that employs large numbers of people. At best it will be storage and distribution which employs few on zero hours contracts.
Better to look at redesignating vacant sites like the old Padley & Venables land to deal with housing shortages if it can be proven that in fact Dronfield needs all this extra housing. As for improvements to infrastructure, is the council really going to put a new road through from the end of Callywhite Lane to join Chesterfield Road? No because it will be too costly an option for what Callywhite Lane can deliver. It is time to redesignate this land and find a way to gain access to the site without using established cul-de-sacs.


Distribution of Growth and Settlement Hierarchy
Why does this council consider it necessary to make the largest centres of population even bigger whilst making no effort whatsoever to plan for the proposals? With an additional 860 houses in Dronfield that would mean a 10% increase in population, of 2064 people, with 680 children with 37.8 more children in every school year group, with 1760 more cars on Dronfield's already congested streets. Dronfield has been ranked the 9th best place to live in the UK. These proposed changes would seriously affect its rankings.
Green Belt Review "Green Belt boundaries should only be altered under exceptional circumstances." The need for housing does not constitute the exceptional circumstances. This council should consider whether there are opportunities to co-operate with neighbouring planning authorities to meet needs across housing market areas. Green Belt land is not only important to prevent the spread of urban sprawl into the countryside, it is valuable to local communities for recreation and access to green areas.
Green Belt land has more public footpaths on it than the countryside as a whole. There is a good deal of new evidence on the benefits which Green Belt land is delivering and how these relate to the ecosystem services they provide. For example, Green Belt land has a greater proportion of woodland and a more concentrated range of public access opportunities than other parts of England. This council needs to be "more ambitious" to further enhance the green belt protection for future generations.
The vast swathes of land that this council proposes to take from the Green Belt is land that is actively farmed currently. Between Unstone and Dronfield is very valuable agricultural land which has recently been ploughed. On a regular basis cattle graze in the fields below Shakespeare Crescent and as soon as you leave the urban sprawl of Dronfield, you immediately feel that you are in a rural area. To build the proposed 235 houses here would destroy what is currently a very narrow strip of Green Belt, but one which protects the separation and identity of Unstone village. The ancient village of Coal Aston has been subsumed under Dronfield's urban sprawl. I would argue that with release of any land from the Green Belt between Unstone and Dronfield, it goes against the principles of Green Belt legislation. The government attaches great importance to Green Belts to check urban sprawl and to keep land permanently open. I believe this council has just taken the easy option by taking not just small parcels of land, but vast swathes and I don't think they can demonstrate that this is an absolute last resort - or the 'exceptional circumstances' required.
The local settlement gap between Unstone and Dronfield is a narrow one. The ancient village of Coal Aston has been lost to Dronfield's urban sprawl. I suggest that where settlement gaps are the narrowest, protection of them should be the strongest whether they are held in the land banks of developers or not.

"Callywhite Lane This is a long-standing allocation from the 2005 Adopted Plan, the northern end of which has been partly developed. Despite lack of progress on this site it represents an important extension to a valuable industrial area in the North Sub-Area. 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." For anybody who knows Callywhite Lane in Dronfield, its location and its association with heavy industry this statement in the local plan is just ridiculous. This council recognises a lack of progress on the site. Making a statement about electrification and HS2 resolving issues associated with Callywhite Lane is beyond belief. Neither of these schemes will have any effect on Callywhite Lane.



"meaningful levels of housing growth can only be accommodated by looking around the edge of the town within the Green Belt." Central government has said that Green Belt land should be protected almost at all costs. Local planning authorities with large areas of Green Belt may not be expected to provide the full quantum of their objectively assessed housing need within their area. Unmet need may have to be accommodated in less constrained neighbouring authorities and facilitated through the mechanism of the 'duty to co-operate' at the planning stage. Where in this plan is there any evidence that the council has looked to neighbouring authorities to address the housing need?


The plan makes the statement that Dronfield is significantly lacking in green spaces within the settlement development limit and that its parks need to be protected. All the more reason also to retain the easily accessed Green Belt land which has a public footpaths directly from Shakespeare Crescent onto it which then leads onto the millennium Dronfield Round Walk.

It is recognised in this plan that car parking is an issue in Dronfield but it offers no solution to the problem. With an additional 1760 cars from the 860 households parking will be a bigger issue.


"New development will put pressure on existing highway and public transport networks, services and facilities...."
To increase the population of Dronfield by 10% without any clear plan on local infrastructure is irresponsible. It is putting the cart before the horse. Having a train station only adds benefit if the station can be accessed by car for people living in Dronfield Woodhouse or Coal Aston and people can park at the station. This council is fully aware that there is not enough car parking at Dronfield Station.
Dronfield needs a bus service delivering people to the railway station from Dronfield's outlying parts or the provision of a much larger car park at the station.
The proposed building of 860 houses in Dronfield in terms of pressure on the local infrastructure means that Dronfield only has one 11-18 educational establishment on a constrained central site. Where will the 37.8 extra children per school year group be educated? Are new medical centres to be provided?
This plan has not provided the necessary information to demonstrate how issues of parking, road congestion, traffic management, pedestrian safety, health care provision and education will be addressed in proposing that Dronfield's population will increase by 860 households. Who will build the new link road from Callywhite Lane to Chesterfield Road? Is this a reality? An infrastructure plan should be in place first before deciding to build more houses. It seems we have to wait for the infrastructure delivery plans to see the site-specific details.


I challenge the council on the soundness of this plan. You have not: accurately assessed housing need for Dronfield, you have not examined other sites for housing within the settlement development limits, you have not redesignated land that has not attracted businesses within the last two years, you have not explored working closely with neighbouring councils to identify boundary fringes suitable for housing, you have not made any plans to allow bungalows to be built for Dronfield's ageing population, you have not taken into account the impact of increasing a town's population by 10% with regard to infrastructure and therefore there is serious doubt about whether many of your objectives are achievable.

Object

Consultation Draft (February 2017)

Representation ID: 5021

Received: 28/03/2017

Respondent: Mrs Helena Gayle Boulton

Representation Summary:

Callywhite Lane is in decline, its inaccessibility is already deterring businesses and many of the sites have laid empty for a long time. A renewed approach to this area needs considering. This could be space for affordable housing - modern starter homes and apartments for the town's young people - becoming a vibrant and dynamic part of the town. Look at the example of Sheffield - Kelham Island.

Full text:

Callywhite Lane is in decline, its inaccessibility is already deterring businesses and many of the sites have laid empty for a long time. A renewed approach to this area needs considering. This could be space for affordable housing - modern starter homes and apartments for the town's young people - becoming a vibrant and dynamic part of the town. Look at the example of Sheffield - Kelham Island.

Comment

Consultation Draft (February 2017)

Representation ID: 5461

Received: 06/04/2017

Respondent: Woodall Homes Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development. Please see attached Statement for further details

Full text:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development. Please see attached Statement for further details

Comment

Consultation Draft (February 2017)

Representation ID: 5527

Received: 07/04/2017

Respondent: Woodall Homes Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We support the general aims of the Local Plan Strategy but inits present form it does not deliver a sustainable form of development.

Please attached statement for further details

Full text:

We support the general aims of the Local Plan Strategy but inits present form it does not deliver a sustainable form of development.

Please attached statement for further details

Comment

Consultation Draft (February 2017)

Representation ID: 5593

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development.

Please see attached statement for further details

Full text:

We support the general aims of the Local Plan Strategy but in its present form it does not deliver a sustainable form of development.

Please see attached statement for further details

Support

Consultation Draft (February 2017)

Representation ID: 5933

Received: 07/04/2017

Respondent: Bolsover Land Ltd

Agent: iSec Group

Representation Summary:

Bolsover Land Ltd supports the growth strategy proposals in Chapter 4, in particular developing the M1 strategic growth corridor proposals as a principle economic growth location and bringing forward investment and site development in principal employment growth locations, including the former Coalite site. The proposed growth strategy appears to be justified and again, consistent with the principles of the NPPF.

Full text:

See attachment

Support

Consultation Draft (February 2017)

Representation ID: 6000

Received: 07/04/2017

Respondent: Derbyshire County Council

Representation Summary:

The broad spatial strategy set out in Sections 4.1 and 4.2 is fully supported. DCC has worked in partnership with, and has been fully supportive of, the District Council's aims to bring their major strategic sites forward for development, not least for their major economic, job creation and regeneration benefits that they are likely to deliver to the residents of the District.

Full text:

Thank you for consulting Derbyshire County Council (DCC) on the North East Derbyshire Local Plan Consultation Draft (LPCD). A report on the LPCD, including the comments below, will be considered at a forthcoming meeting of the County Council's Cabinet Member for Highways, Transport and Infrastructure (date yet to be confirmed following County Council elections). In the meantime, in order to meet your statutory deadline, I should be grateful if you would accept these comments until I confirm the decision made on the report at the Cabinet Member Meeting following a five-day call-in period. I will, therefore, contact you again at that time to confirm DCC's formal comments.

Member Comments

Local County Councillors with electoral divisions in North East Derbyshire District were consulted on the CDLP. No comments have been received at the time of writing, however, I will forward any comments subsequently received.

Officer Comments

1 Spatial Portrait

1.1 The sub-division of the District into four sub-areas (North, South, East and West) is well justified and fully supported as the basis to plan for the future spatial growth needs of the District. It is clear that each of the four sub-areas have their own close physical and functional relationships, their own characteristics and development needs to be addressed in the LPCD.

1.2 The analysis in the Spatial Portrait provides a thorough and comprehensive assessment of the issues and challenges facing the District. However, the Accessibility and Transport Section should make reference to the emerging proposals for HS2 and the Government's recent consultation proposals for the HS2 route refinement through Derbyshire, including proposals for HS2 services to stop at Chesterfield railway station via a new link that runs along the existing Erewash Valley line and then utilising the existing Midland Mainline in the vicinity of Clay Cross. Proposals are reaffirmed in the consultation for the proposed development of a new maintenance depot at Staveley. Although not located within North East Derbyshire District, the HS2 proposals are likely to have an impact on the District's economy.

2 Vision and Objectives

2.1 The inclusion of a range of both district-wide and sub-area strategic objectives is fully supported and should ensure that the Local Plan provides for a sustainable pattern of development and meets the future growth needs of the District over the Plan period . In the context of the comments above, Objective D1 could be expanded to indicate that the Local Plan will seek to maximise the economic benefits for the District that are likely to be generated by HS2. It is welcomed that Objective E3 appropriately seeks to ensure that any environmental impacts arising from the development of HS2 are effectively mitigated. Objective D6 is fully supported, which seeks to ensure that the general area of the Green Belt is protected and that the purposes of including land within the Green Belt takes account of the need to promote sustainable patters of development across the District (see further comments below).

3 Spatial Strategy

3.1 The broad spatial strategy set out in Sections 4.1 and 4.2 is fully supported. This indicates that the Local Plan will direct the vast majority of the District's future employment growth to key locations including the M1 Growth Corridor; the A61 corridor; Callywhite Lane, Dronfield; former Biwaters site at Clay Cross; the Avenue site at Wingerworth; Markham Vale; and the former Coalite site. For housing, the Local Plan seeks to focus growth in the four main towns and on a number of the key strategic sites above, particularly the former Biwaters site; the former Avenue site; and former Coalite site. DCC has worked in partnership with, and has been fully supportive of, the District Council's aims to bring these major strategic sites forward for development, not least for their major economic, job creation and regeneration benefits that they are likely to deliver to the residents of the District.

3.2 Historically, DCC has been supportive of such a spatial distribution of growth based on the four main towns and key regeneration sites through the revoked Derby and Derbyshire Joint Structure Plan (DDJSP) and more recently the former East Midlands Regional Plan (EMRP) as providing for the most sustainable pattern of growth in the District, particularly as a large part of the District is covered by strategically important Green Belt, particularly to the north of the area.

4 Housing Matters

Housing Provision Requirement

4.1 The housing provision requirement for the District of 6,600 new homes (300 per annum) over the Plan period set out in Policy SS2: Scale of Development, is fully supported, as it would meet the full objectively assessed housing needs of the District based on extensive evidence in the North Derbyshire and Bassetlaw Strategic Housing Market Assessment (SHMA), which recommended that the OAHN for the HMA as a whole was between 1,180 - 1,350 homes per year and for North East Derbyshire District specifically at between 270 - 310 homes per year. DCC's Officers are familiar with the SHMA, particularly its methodology and conclusions and consider it to be a comprehensive and robust piece of evidence. The proposed housing requirement of 300 dwellings pa would meet the OAHN of the District in full, consistent with the requirements of paragraph 47 of the National Planning Policy Framework.

4.2 It is noted that paragraph 4.7 of the LPCD indicates that further 'sensitivity testing' was carried out on this recommended OAHN requirement, which subsequently recommended a revised OAHN figure for the District of between 268 - 285 new homes pa. This provides for a robust approach as sensitivity testing of a local authority's OAHN need is now a common requirement of Inspectors at Local Plan examinations. It is noted that the Local Plan's proposed housing provision requirement of 300 dwellings pa is at the higher end of the OAHN figure set out in the SHMA and exceeds the higher end of the OAHN range following sensitivity testing. However, the Local Plan's requirement of 300 dwellings is considered to be fully justified as this higher figure would be more likely to positively support the economic growth and regeneration needs of the District and would be more likely to deliver higher levels of much needed affordable housing.

4.3 It is noted that paragraph 4.10 of the LPCD, indicates that since the SHMA and sensitivity testing work was undertaken, the Government has published the 2014-Based Sub-National Population Projections and 2014-based Sub-National Household Projections. Consequently, NEDDC is currently working with its strategic partners in the HMA to commission an update of the SHMA. This approach is welcomed and supported, as the NPPF and National Planning Practice Guidance (NPPG) require local planning authorities (LPAs) to use the most up-to-date evidence to inform their housing targets, particularly the latest population and household projections.

4.4 DCC's Officers have previously undertaken an assessment of the 2014-based Sub National Household Projections in comparison with the 2012-based Sub-National Household Projections and their implications for future household growth across the County. The assessment for North East Derbyshire District indicates that over the Plan period of 2011 - 2033, household growth in the 2014-based projections was broadly the same at 5,000 additional households as in the 2012-based projections, so the most up-to-date set of projections may be likely to have limited implications for the District's future housing requirement in the Local Plan.

4.5 Since 2004/2005, North East Derbyshire District has been defined as falling within a North Derbyshire and Bassetlaw HMA together with the neighbouring local authority areas of Bolsover District, Chesterfield Borough and Bassetlaw District in Nottinghamshire, based on extensive evidence first commissioned by the (then) East Midlands Regional Assembly in 2004 and more recently in the SHMA referred to above. DCC's Officers are fully supportive of the continued approach to the assessment of housing requirement across the four local authorities being based on the North Derbyshire and Bassetlaw HMA because of the close functional and travel-to-work relationships that exist between the four local authority areas. This support has recently been reaffirmed in the County Council's consultation responses on the Bolsover District Draft Local Plan (December 2016) and Chesterfield Borough Local Plan Consultation Draft (February 2017).

Settlement Hierarchy and Distribution of Development

4.6 The definition of a Settlement Hierarchy for the District in Table 4.1 as the basis for the spatial distribution of the Local Plan's proposed housing growth set out in Policy SS3 and table 4.2, appears to be well conceived and justified and based on extensive evidence in the North Derbyshire Settlement Hierarchy Study (SHS) (December 2016). The SHS analysed the roles that the different settlements in the District performed for their communities and based the hierarchy on a range of criteria which included population levels, facilities and services, employment opportunities and public transport provision. The hierarchy sets out four levels of settlements including Level 1: Principal and Secondary Towns; Level 2: Settlements with a Good level of Sustainability; Level 3: Settlements with a Limited Sustainability; and Level 4: Very Small Villages and Hamlets with Limited Sustainability.

4.7 In the context of the above, Policy SS3 is fully supported which seeks to focus the majority of the District's housing growth in the Level 1 Principal and Secondary towns of Clay Cross, Dronfield, Eckington and Killamarsh; and level 2 settlements of Calow, Grassmoor, Holmewood, Morton, North Wingfield, Pilsley, Renishaw, Shirland, Stonebroom and Tupton. The remainder of the District's growth is proposed to be focussed on the key strategic sites of the former Biwaters site at Clay Cross and The Avenue site at Wingerworth. As noted above, historically, DCC has been supportive of such a spatial distribution of growth through the revoked DDJSP and more recently the former EMRP as providing for the most sustainable pattern of growth in the District. The broad distribution of growth, therefore, with 2,508 dwellings proposed in the four main towns; 1,270 dwellings on the strategic sites; and 1,962 dwellings in the Level 2 settlements, appears to be well conceived and should provide for a sustainable distribution of the District's housing growth.

4.8 The definition of settlement boundaries for the Level 1 Principal and Secondary Towns and Level 2 Larger Settlements identified on the relevant Policies Maps and the approach to development set out in Policy SS12, is fully supported. The use of settlement boundaries is an effective mechanism to ensure that new housing development is provided in sustainable locations within and well related to the District's settlements. It will provide clarity and certainty to the public and to developers as to which land is included within the built form of the settlements and which other land should be considered as open countryside for planning policy purposes relating to Policy SS14, where a more restrictive approach to development is to be applied.

Strategic Site Allocations

4.9 The identification of four key strategic housing and employment site allocations at The Avenue, Wingerworth; Former Biwaters site; and Markham Vale is fully supported, particularly the provision in the Plan for specific policies (SS4, SS5 and SS6) to guide the future development of these sites. DCC has worked in partnership with NEDDC over many years to secure the delivery of these large-scale, previously derelict and contaminated brownfield sites for large-scale housing and / or employment purposes. It is particularly important that NEDDC's Officers continue to work closely with DCC's Officers to secure the necessary infrastructure required to support the development of these sites, particularly highways improvements, school place provision, including new schools, and Green Infrastructure. It is particularly welcomed that Policy SS4 identifies the need for a new primary school to be provided as part of the development of The Avenue site and the need to ensure that development of the site does not prejudice the construction of a link road from the A61 to A617, which is identified in the Derbyshire Local Transport Plan 3 as a longer term strategic highway project.

Land South of Markham Vale

4.10 It is noted that Policy SS7: South of Markham Vale, proposes the allocation of a new strategic employment site to the south of the existing Markham Vale employment site off Junction 29a of the M1 and also in close proximity to the south of the Coalite site, which could provide up to 40 ha of new employment land. The background to the policy indicates that the site could be envisaged as a natural extension to the existing Markham Vale employment site and importantly makes reference to the need to ensure that the proposed allocation of the site does not undermine the delivery of the adjacent Coalite site, which is welcomed and supported. The existing Markham Vale employment site is expected to be fully built out over the next 2 - 3 years as much of the site has been developed and the remaining plots are either under construction or at the latter stages of legal agreement. DCC's Officers consider, therefore, that the proposed new allocation is unlikely to impact on the delivery of the remaining part of the existing Markham Vale site.

4.11 A key concern relating to the proposed development of the site is its impact on the setting of Bolsover Castle. Although the supporting policy makes reference to the need to protect the setting of heritage assets, in particular the Grade 1 Listed Bolsover Castle, DCC's Officers consider it to be important that this allocation needs to be supported by a Heritage Impact Assessment and Visual Appraisal to satisfy the Authority that the policy requirements can be delivered and that any allocation in this location would not impact adversely on the setting of Bolsover Castle or the sense of arrival that contributes to the visitor experience. Officers are concerned that this site could not be delivered in an acceptable form that would not be likely to impact on Bolsover Castle. NEDDC is requested to give further and more detailed consideration to this issue.

Former Coalite Site

4.12 It is noted that the former Coalite site has not been identified in the LPCD as a strategic site allocation but instead has been identified a Priority Regeneration Area under Policy SS8 for approximately 660 dwellings and 70,000 of employment land. The latest route refinement proposals for HS2 that were recently subject to public consultation, includes a realignment on the HS2 line which has a direct impact on the Coalite site, so that the refined route proposals cut across the eastern part of the site compared to the original route proposals which cut across the western part of the site. In its recent consultation response to Government on the route refinement proposals, DCC expressed significant concern that the new route would cut across land that has been identified on the approved masterplan as forming the first phase of housing development on the eastern part of the site, which is seen to be crucial to kick starting the wider redevelopment of the whole site for housing and employment purposes and which could ultimately impact on the viability and delivery of the whole site.

4.13 It is noted that similar concerns have been expressed by NEDDC in the background text to Policy SS8 relating to the impact of the HS2 route on the deliverability of the masterplan proposals, which together with the need for extensive remediation of the site, mean that the District Council cannot be confident in relying on the housing land proposed on the site to contribute to the Local Plan's proposed housing target. Accordingly, NEDDC has identified the site as a Regeneration Priority Area. This is considered to be an appropriate and justified approach given that there can be no degree of certainty that the Coalite site will contribute to meeting the Local Plan's housing target, which would otherwise be likely to be required by an Inspector, if the land was identified as a Strategic Allocation Site.

4.14 However, this will require careful consideration by NEDDC together with Bolsover District Council, within whose administrative area much of the northern part of site falls to ensure consistency of approach. This is particularly important as the Bolsover District Consultation Draft Local Plan which was published in November 2016 by BDC, proposes to allocate the Coalite site as a Strategic Site Allocation.

Other Housing Allocations

4.15 It is noted that Policy LC1: Housing allocations, identifies a range of over 40 proposed housing allocations, which would contribute to meeting the housing requirement for the District over the Plan period of 6,600 dwellings. Each of these proposed allocations will raise a range of infrastructure requirements to support their development, particularly primary and secondary school place provision (potentially including new schools), highway and access improvements and Green Infrastructure. It is noted that a number of the proposed allocations already benefit from planning permission. DCC has previously provided Officer developer contributions and strategic planning policy comments on a number of these allocated sites, which remain largely relevant to their development. Under the Duty to Cooperate, NEDDC is requested to liaise with DCC on an ongoing basis to identify and secure the strategic infrastructure requirements that would be required to support the development of the proposed allocation sites in order to ensure that they provide for a sustainable form of development (see further comments below).

Affordable Housing

4.16 The proposed approach to affordable housing set out in Policy CS11 and the background text is fully supported and based on an extensive range of evidence. The background text indicates that the North Derbyshire and Bassetlaw SHMA estimated that there was a need for around 560 affordable homes pa in the District to fully meet affordable housing need. The North Derbyshire Housing Needs, Market and Affordability study (HNMA) (2011) included an economic viability assessment which recommended that 40% affordable housing could be delivered in the West Sub-Area and up to 30% across the remainder of the District. Policy LC2: Affordable Housing appropriately reflects the order of the Court of Appeal on 13 May 2016, which gave legal effect to the policy set out in the Written Ministerial Statement of 28 November 2014, that contributions should not be sought from developments of 10 units or less and which have a maximum combined gross floorspace of no more than 1,000 sq m. The recommendations of the HNMA study and order of the Court of Appeal decision are appropriately reflected in the policy approach in Policy LC2.

Gypsy and Traveller Issues

4.17 It is welcomed that paragraph 5.103 makes appropriate reference to the Derby, Derbyshire, Peak District National Park Authority (PDNPA) and East Staffordshire Gypsy and Traveller Accommodation Assessment (GTAA) (2014), which was commissioned by DCC on behalf of the nine city, district and borough councils in Derbyshire, the PDNPA, East Staffordshire District Council and the Derbyshire Gypsy Liaison Group.

4.18 The GTAA recommended that there was a requirement for 15 additional pitches in North East Derbyshire District between 2014 and 2034, of which 6 pitches would be required between 2014 - 2019, with 3 for each five year period thereafter up to 2034. This is appropriately set out in paragraph 5.103 of the LPCD, which is welcomed. The indication in paragraph 5.106 that although to date, no sites have come forward which allow the District Council to propose site allocation in the LPCD but that work on identifying potential allocations is continuing by the District Council, is welcomed and supported. By the time the Local Plan is submitted to the Secretary of State for examination in public, however, it is likely that the Local Plan Inspector will require the District Council to have identified land in the Local Plan for allocation for Traveller pitches, particularly to meet the five year requirement from 2014 to 2019.

4.19 In the context of this on-going work, the inclusion in the LPCD of Policy LC9 is fully supported, which indicates that sites will be allocated to meet the accommodation needs of Travellers based on independent assessment and which sets out a range of criteria for the assessment of any potential sites that come forward for Traveller pitches, in line with the recommendations of national policy guidance for Travellers in Planning Policy for Traveller Sites (March 2012).

5 Green Belt

5.1 Green Belt covers much of the northern and central parts of North East Derbyshire District. In the north of the District, the Green Belt is very narrow and strategically very important particularly in preventing the coalescence of the urban area of southern Sheffield with the towns of Dronfield, Eckington and Killamarsh in North East Derbyshire and in preventing the coalescence of the three settlements with each other. The Green Belt to the south of the three settlements plays and important role in preventing the coalescence of the settlements with the urban areas of Chesterfield and Staveley to the south.

5.2 In the context of the above, Strategic Objective D6 is fully supported which seeks to protect the general area of the Green Belt and the purposes of including land within it taking account of the need to meet the needs of all sectors of the District's communities.

5.3 However, whilst the North East Derbyshire Green Belt has been an effective planning policy tool which has assisted significantly in focussing development in the District on brownfield sites and undeveloped land within its settlements, as paragraph 4.61 appropriately points out, the Green belt has also had a range of unintended impacts such as impacting on housing need and the availability of land for new housing growth in some of the District's main settlements, particularly Dronfield, Eckington and Killamarsh, putting development pressure on green spaces and existing employment land for housing uses, and particularly impacting on increased house process and affordability in those villages constrained by Green Belt, particularly in the north of the District.

5.4 As a consequence of the impacts above, it is noted from paragraph 4.65 that NEDDC has undertaken a Green Belt Review, which provides an objective assessment of the role of individual parcels of Green Belt land in fulfilling the five main Green Belt purposes set out in the NPPF.

5.5 DCC's Officers were grateful to NEDDC's Officers for consulting them in March 2016 on the proposed methodology which was used for undertaking the Green Belt Review. DCC's Officers concluded that the overall methodology was robust and consistent with the agreed methodology for undertaking Green Belt Reviews that was developed by Officers of the Sheffield City Region local authorities, including DCC, in August 2014. Generally, the assessment criteria for Green Belt purposes 1 to 4 appeared to be appropriate and well-conceived as did the scoring mechanism. In the assessment of local landscape character in Stage 3 of the methodology, DCC's Officers recommended that the County Council's Landscape Character of Derbyshire assessment and work on Areas of Multiple Environmental Sensitivity (AMES) should be used for this stage of the assessment.

5.6 Government guidance set out in the NPPF is clear that the Government attaches great importance to Green Belts and that Green Belt boundaries should only be altered in exceptional circumstances. It is considered that the LPCD has set out an appropriate and well-reasoned justification in sections 4.62 to 4.65 for there to be exceptional circumstances within the District for undertaking a review of Green Belt boundaries. This is because extensive evidence has revealed that there is a significant mismatch between the Local Plan strategy and the proposed spatial distribution of housing and that land availability and demand, such that the level of growth being planned for to meet the full OAHN in the District, could not be accommodated in a sustainable way or where demand and viability were highest.

5.7 Appendix B of the LPCD identifies those areas of land which are proposed to be removed from the Green Belt to facilitate new housing development. Whilst the County Council's Officers would not wish to comment in detail on each individual area of land, it would appear in principle, that all the areas that have been identified for removal from the Green Belt are well related to and / or well contained by existing areas of built development and are those areas which would appear to be likely to have least harm on the main Green Belt purposes and overall strategic role of the North Derbyshire Green Belt.

6 Local Settlement Gaps

6.1 The identification of Local Settlement Gaps is supported in Policy SS11 Historically, DCC has been supportive of the definition of Strategic Gaps and Green Wedges in Local Plans being prepared across Derbyshire through Derbyshire Structure Plans (1980 and 1990), the DDJSP and the former EMRP. Strategic Gaps and Green Wedges can play an important and complementary role a local authority's Green Belt in providing a more localised function of preventing the coalescence of neighbouring settlements.

7 Highways

7.1 Policy ID6 discusses sustainable travel, and although DCC's Highways Officers do not disagree with the points covered in the policy, it is considered, however, that the Policy could be strengthened by the inclusion of a more hierarchical approach to the management of travel demand thereby providing a policy basis to strengthen delivery of sustainable transport networks. Possible wording that could be adopted, for example, that would seek to provide necessary interventions is set out below (in order of priority):

a) Site specific and area wide travel demand management (measures to reduce travel by private car and incentives to use walking, cycling and public transport for appropriate journeys, including intensive travel planning);

b) improvements to walking and cycling facilities and public transport services that are provided early in the build out period of new developments and that they are sufficient to encourage sustainable modes of transport;

c) optimisation of the existing highway network to prioritise walking, cycling and public transport that are provided early in the build out period of new developments, such as measures to prioritise the need of pedestrians above the car and improved or new cycle and bus lanes; and

d) Highway capacity enhancements to deal with residual car demand where the initiatives required under points (a) to (c) above are insufficient to avoid significant additional car journeys.

7.2 The LPCD, however, provides little understanding of the potential transportation implications of its land use proposals. As the Government's Transport evidence bases in plan making and decision taking advice, notes, it is important for local planning authorities to undertake an assessment of the transport implications in developing or reviewing their Local Plan so that a robust transport evidence base may be developed to support the preparation and/or review of that Plan.

https://www.gov.uk/guidance/transport-evidence-bases-in-plan-making-and-decision-taking

7.3 The LPCD proposes housing provision through a strategy of allocating development according to settlement size, Level 1 settlements being the larger towns and Level 4, being hamlets. A 5th category provides for 'Strategic Sites'. As regards the strategic sites at the former Biwaters site in Clay Cross and the former Avenue Works, Wingerworth, both the strategic site allocations are consented and as such their impacts upon the District's transportation networks have been quantified and strategies developed principally in the form of mitigation works of both 'hard' and 'soft' infrastructure on the A61 corridor. A mechanism for developer contributions for their delivery has been agreed.

7.4 The LPCD, however, proposes further significant housing allocations in Clay Cross and in some of the Level 2 settlements. Traffic from these sites could also have additional impacts upon the A61 corridor and on routes between the A61 corridor south of Chesterfield and M1 principally the A6175. However, no information is provided in the transportation evidence base about this.

7.5 Similarly, a number of level 1 settlements are identified for housing growth north of Chesterfield in Dronfield, Eckington and Killamarsh. Cumulatively these sites could add a further 2,000+ dwellings, however, no information is provided either individually or cumulatively about their likely impacts for each town's transportation networks. Similarly, there are a number of sites within the Level 2 settlements which cumulatively together with the more strategic sites could have significant impacts upon the corridors and in areas discussed above.

7.6 The LPCD proposes a number of employment allocations including Callywhite Lane Industrial Estate Extension at Dronfield and Stubley Lane/Wreakes Lane Industrial Estate. Consideration will also need to be given to the transportation implications of these together with other proposed employment allocations. The LPCD proposes improvements to Callywhite Lane Industrial Estate through improvement of the junction at Callywhite Lane/Chesterfield Road and provision of a new link road between the eastern end of Callywhite Lane and Chesterfield Road, although this is not shown on the Dronfield Policies Map.

7.7 The LPCD identifies a further site at the former Coalite works, as a Priority Regeneration Area. It is noted that this is considered by the LPCD to be of a strategic scale and has planning permission for some 980 dwellings. This site is not, however, included in the LPCD as Strategic Site Allocation, on account of concerns over its ability to deliver housing within the plan period. This site has planning permission with an agreed highways mitigation strategy in place. Whilst Officers can undemand the District Council's reasoning behind the approach to this particular site, as set out above, nevertheless, it does however mean that other sites are now under consideration for housing allocations that have no transportation analysis underpinning them let alone any basis for providing a strategy to mitigate their effects upon the transportation network.

7.8 Section 9.48 discusses the Derbyshire Infrastructure Plan and A61 corridor and need for partnership working. The Highway Authority in response to future cumulative impacts arising from the proposed development on the A61 corridor south of Chesterfield is developing a strategy to both influence travel behaviour and mitigate its impacts. Consideration should be given to developing a similar strategic approach to other key transport corridors in the district, for example the A6175 Clay Cross - M1, and A632 corridor(s).

7.9 Finally, as part of Bolsover District Draft Local Plan consultation, its Evidence Base included an Interim Transport Evidence Information Note. This in turn provided a useful summary of transport conditions in the Local Plan area. DCC's Officers consider that the North East Derbyshire LPCD would benefit from a similar 'transportation paper' setting out a commentary on North East Derbyshire's transport issues.

7.10 The County Council would be happy to advise the District Council over the strengthening of the evidence base on highways and transport impacts and mitigation.

8 Infrastructure

8.1 Policy ID8: Infrastructure Delivery and Developer Contributions is welcomed and fully supported. The policy indicates that

Proposals for development will only be permitted provided they can be made acceptable through:

* The provision of necessary physical, social and green infrastructure;
* Suitable measures to mitigate the impacts of development;

Where new development will necessitate the provision of new or improved infrastructure, and / or when suitable mitigation is required, the developer will be required to:

* Make direct provision of such infrastructure on site within the development; or
* Make a financial contribution to its funding through the use of a Planning Obligation, or the Community Infrastructure Levy, or any subsequent financial / levy based system that the local planning authority may adopt in the future.

8.2 The policy approach above is broadly consistent with the approach to developer contributions set out in the Derbyshire Developer Contributions Protocol Refresh (September 2016).

8.3 The indication in Policy ID8 that the District Council will use Section 106 Agreements, unilateral undertakings, planning conditions, and if and when adopted the District Council's CIL Charging Schedule to secure necessary infrastructure is broadly welcomed and supported.

Infrastructure Delivery Plan

8.4 National planning policy in the NPPF requires that Local Plans should be supported by evidence of what physical, social and green infrastructure is needed to support the overall quantum and distribution of growth proposed in the Plan. In this context it is noted from paragraph 9.17 of the LPCD that the District Council will before the publication version of the Local Plan prepare an Infrastructure Delivery Plan (IDP). Whilst the production of an IDP is welcomed, ideally the IDP should have been published at the same time as the LPCD so that it provided the necessary evidence to indicate what critical infrastructure will be required and where to support and deliver the scale and distribution of growth across the District being proposed in the LPCD. Notwithstanding the above, DCC's Officers would welcome the opportunity to comment on the IDP when it is published in due course. DCC is currently replacing the Derbyshire Infrastructure Plan with the Derbyshire Infrastructure Investment Plan (DIIP), particularly the identification of strategic priority infrastructure projects that are seen as crucial to the delivery of growth in each district and borough of the County. DCC''s Officers will be keen to ensure therefore that there is consistency of approach between the District Council's IDP and the DIIP.

Community Infrastructure Levy (CIL)

8.5 It is noted from paragraphs 9.73 and 9.74 that the District Council sees the production of the IDP as a first step in determining whether the introduction of a CIL would be appropriate for the District; that the District Council intends to carry out work to assess viability of the Plan as a whole and whether there would be enough economic incentive to provide new development with infrastructure requirements in place; and that this work will help inform whether a CIL will be introduced and what rates would be applied.

8.6 The approach above is justified and supported. Should the District Council decide to introduce a CIL, DCC's Officers would request that the District Council consults the County Council early in the process of drafting its CIL Charging Schedule. The County Council would wish to consider what infrastructure provided by the County Council is included on the Regulation 123 list as the County Council needs to be satisfied that the proposed CIL income would be adequate to fund the provision of this strategic infrastructure, especially with regard to school place provision and that any projects to be funded are appropriately identified in the Regulation 123 list.

Education Issues

8.7 The main concern from an education point of view relates to the District Council's indication above that it is considering the potential to fund infrastructure through the implementation of a CIL. From an education point of view DCCs officers would wish to ensure that the CIL pot was adequate to fund the necessary developments in schools necessitated by the Plan's proposed housing growth and did not result in funding that was less than that which is achieved through Section 106 contributions. Should the County Council not wish to include certain items of infrastructure on the Regulation 123 list, DCC officers would wish to ensure that the level at which the CIL is charged would not preclude the development from also making contributions through S106 to these items.

8.8 As noted above, the LPCD has proposed the allocation of over 40 strategic and other housing allocation sites to meet the District's housing requirement of 6,600 dwellings over the Plan period. NEDDC's Officers are requested to continue to liaise with DCC's Children's Services Officers to consider the primary and secondary school place requirements generated by these proposed housing developments in the LPCD.

9 Landscape Comments

9.1 The LPCD's approach to landscape and landscape character is broadly welcomed and supported. It is particularly welcomed that many of the Plan's proposed housing allocations appear to accord with the landscape and visual impact recommendations DCC's Officers made as part of the Strategic Housing Land Availability Assessment (SHLAA) process.

9.2 Policy SS8 identifies the former Coalite site as a Strategic Priority Area. The proposed collaborative working between NEDDC and BDC to address the comprehensive restoration of the former Coalite site is fully supported but DCC's Officers still have concerns about the potential scale of development as currently proposed with respect to its potential impact on landscape character and the setting/sense of arrival at Bolsover Castle (see comments above).

9.3 Policy SS11: Local Settlement Gaps and Policy SS13: Development in Small Villages and Hamlets, are both supported where they will assist in protecting landscape character in those areas defined by nucleated settlement patterns such as the Derbyshire coalfield, and also those areas with a more dispersed settlement pattern with small villages and hamlets, typical of the Peak Fringe. Overall this approach will assist in preventing urban sprawl and alongside other policies in the Plan, it should help to restrict development within the countryside.

10 Minerals Comments

10.1 It is welcomed that paragraphs 8.89 - 8.93 appropriately make reference to the fact that mineral resources are essential to support economic growth and are a finite resource; that there is an important need to ensure that minerals of national and local importance are not needlessly sterilised by non-minerals development; and that prior extraction of minerals is considered, if it is necessary for non-minerals development to take place.

10.2 It is particularly welcomed that reference is made to the emerging Derbyshire and Derby Minerals Local Plan (DDMLP), which is being progressed by DCC and Derby City Council which will review Mineral Safeguarding Areas (MSA) and Mineral Consultation Areas (MCA) to prevent the unnecessary sterilisation of the minerals resource across the County, which is likely to include minerals resources in North East Derbyshire District. In this context, paragraph 8.92 is fully supported which indicates that within MSAs and MCAs defined in the emerging DDMLP, the presence of the mineral resource will be considered by the District Council as part of the determination of planning applications and once confirmed in the DDMLP, MSAs and MCAs will be illustrated on the North East Derbyshire Local Plan's Policies Map.