Policy SS2: Scale of Development

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Comment

Consultation Draft (February 2017)

Representation ID: 5071

Received: 30/03/2017

Respondent: Mrs Helena Gayle Boulton

Representation Summary:

I have nothing against Dronfield building new homes in a manageable number - on sites that need developing and regenerating. Not on this scale and not on green belt. Dronfield has grown 5x in size over the last 100 years while the population has doubled. It has already grown to its capacity and has already contributed to the housing need. It appears that because some landowners are keen to sell their land (due to the huge profit that could be made in the Dronfield area) Dronfield has been hit with a disproportionate allocation.

Full text:

I have nothing against Dronfield building new homes in a manageable number - on sites that need developing and regenerating. Not on this scale and not on green belt. Dronfield has grown 5x in size over the last 100 years while the population has doubled. It has already grown to its capacity and has already contributed to the housing need. It appears that because some landowners are keen to sell their land (due to the huge profit that could be made in the Dronfield area) Dronfield has been hit with a disproportionate allocation.

Object

Consultation Draft (February 2017)

Representation ID: 5408

Received: 07/04/2017

Respondent: PMW Property

Agent: Cerda Planning

Representation Summary:

See attached

Full text:

Objections are lodged in respect of the quantum of new employment land being planned for, at 50 hectares.
Firstly, as the Emerging Plan makes clear at paragraph 2.16, the district has a low jobs density and there is a need to provide local employment opportunities close to where people live in order to reduce out commuting from the district.
To address this issue, the plan should do all it can to deliver economic growth, and as drafted Policy SS2 will likely be seen as a limit on the amount of employment land that can be brought forward. Instead, it should be seen as a minimum, and the target should be increased to provide maximum encouragement for all stakeholders to do all they can to deliver economic growth in the plan period.
Secondly, the district has traditionally relied on manufacturing and there is a need to diversify the local economy to create jobs in growth sectors such as advanced manufacturing, logistics and knowledge based sectors.
Maximising the provision of additional employment land will, in turn, maximise the potential for diversification and as such will deal with underlying economic issues prevalent across the district.
Thirdly, the 2013 Employment Land Update recommended that employment land provision for the district should be between 35 and 75 hectares. The NPPF is clear that development plans should meet full, objectively assessed needs including that for economic growth. With the evidence base underpinning the plan indicating that the plan should deliver 75 hectares of employment land, and an Emerging Plan intending to deliver only two thirds of this, it cannot be said that the Emerging Plan is meeting full objectively assessed needs.
Fourthly, and notwithstanding the above, the evidence base is in the process of being updated to take account of more recent data and is highly likely that the quantum of employment land to be planned for will increase once up to date evidence is prepared. For the plan to be found sound, it is important that the most up to date evidence base is relied upon for the purposes of plan policy preparation

Object

Consultation Draft (February 2017)

Representation ID: 5464

Received: 06/04/2017

Respondent: Woodall Homes Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

We propose the following new wording for Policy SS2 Scale of Development:

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement.

Full text:

We propose the following new wording for Policy SS2 Scale of Development:

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement.

Comment

Consultation Draft (February 2017)

Representation ID: 5551

Received: 07/04/2017

Respondent: Sheffield City Council

Representation Summary:

Our response to the consultation in March 2015 highlighted that Sheffield might not be able to accommodate all its own objectively assessed housing need. We will set out the options for meeting our growth later this year, including significant Green Belt release. However, some options may not be deliverable in the short-medium term. It is therefore necessary to approach neighbouring authorities about meeting some of Sheffield's housing needs, particularly in the short to medium term up to 2028. After that, we would expect strategic sites within Sheffield to boost supply up to 2034 and beyond.

Full text:

We welcome the commitment to accommodating a minimum of 6,600 dwellings over the period 2011 - 2033, which will meet the minimum requirement of 300 homes per year. This is consistent with a level of growth required to meet an appropriate level of economic growth within NEDD.
In our response to the consultation in March 2015, we highlighted the fact that Sheffield might not be able to accommodate all its own objectively assessed housing need. Options for meeting Sheffield's housing need will be set out in an informal draft Sheffield (Local) Plan which we intend to publish this summer. This is likely to include options for significant Green Belt release.
However, at this stage we have concerns about whether some of the land supply options being considered in Sheffield would be deliverable in the short-medium term. A large proportion of the supply is on brownfield sites and a number of the major strategic growth locations would require very substantial investment in transport infrastructure. This could make them undeliverable in the early part of the plan period. When annual build rates are taken into account, it means that a proportion of the development would not take place until after the end of the plan period (i.e. after 2034). We also expect some options to be ruled out, following public consultation, because of land ownership or environmental issues.
In light of this, we now feel it is necessary to approach neighbouring authorities to see if they would be able to meet some of Sheffield's housing needs, particularly in the short to medium term. The main aim would be to provide additional flexibility in supply over the period to, say 2028. After that, we would expect additional strategic sites within Sheffield to boost supply up to 2034 and beyond. We would therefore like to explore further the options for accommodating additional growth outside Sheffield and look at what scope there would be for NEDD to meet some of Sheffield's needs.

Object

Consultation Draft (February 2017)

Representation ID: 5596

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

we propose the following new wording for Policy SS2 Scale of Development

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement

Full text:

we propose the following new wording for Policy SS2 Scale of Development

5.016 Policy SS2 Scale of Development should be amended to:
'For the period 2011-2033 the Local Plan will make sufficient housing and employment land to accommodate a minimum of:
* 8,580 dwellings; and
* 50ha of new employment land

Please see attached statement

Object

Consultation Draft (February 2017)

Representation ID: 5622

Received: 07/04/2017

Respondent: Mr John Prestwich

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

Please refer to the attached SPRU Report on Objectively Assessed Housing Need.

Full text:

Please refer to the attached SPRU Report on Objectively Assessed Housing Need.

Object

Consultation Draft (February 2017)

Representation ID: 5625

Received: 07/04/2017

Respondent: W Redmile & Sons Ltd

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

Please refer to the attached SPRU report on the objectively assessed need for housing.

Full text:

Please refer to the attached SPRU report on the objectively assessed need for housing.

Comment

Consultation Draft (February 2017)

Representation ID: 5640

Received: 07/04/2017

Respondent: Define

Representation Summary:

Policy SS2 should be revised to include a clear acknowledgement for the District's role of complying with the Duty to Cooperate and the need to review the Green Belt to release appropriate sites for development in the northern part of the District to contribute meeting housing needs.

Full text:

We are in support of paragraphs 4.9 and 4.10 of the draft Local Plan where it is acknowledged that Council need to provide a minimum of 300 homes a year and accept the importance for North East Derbyshire District Council to work with their Local Planning Authority partners within the Housing Market Area (HMA) complying with the Duty to Cooperate (DTC).
Insufficient housing provision has resulted in a nationwide "housing crisis" that needs to be addressed as a matter of urgency. The "brief" for the preparation of the Local Plan is, therefore, very clear. Ensuring that there is a continual supply of both market and affordable housing is a critical policy imperative for the Government and a central tenet of the NPPF (para 7 & 9). The NPPF requires (para 14) that "local planning authorities should positively seek opportunities to meet the development need of their area"; and that "Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change", and set out a "clear strategy for allocating sufficient land" (para 17). More specifically in order to "significantly boost the supply of housing" it requires (para 47) that local planning authorities use their evidence base to ensure that their Local Plan "meets the full objectively assessed needs for market and affordable housing in the market housing area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period."
In light of this requirement, the NPPF continue to refers (para 54) to the duty to cooperate with neighbouring authorities introduced by the Localism Act 2011. That requires the Council to engage "constructively, actively and on an on-going basis to maximise the effectiveness of Local and Marine Plan preparation in the context of strategic cross boundary matters" (NPPG). In respect of the DTC, the NPPF states (para 179) that "joint working should enable local authorities to work together to meet development requirements which cannot be wholly met within their own areas". It requires (para 181) that Authorities "demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts". The demonstration of effective cooperation in reality means a positive outcome to the strategic planning discussions that are undertaken. As the St Albans Local Plan Inspector recently summarised "effective co-operation is likely to require sustained joint working with concrete actions and outcomes". Compliance with the DTC is, therefore absolutely essential if the Local Plan is to deliver sustainable development (NPPF paras 150-151) to "boost significantly the supply of housing" and meet "the full objectively assessed needs for market and affordable housing in the market housing area" as required by the NPPF (para 47).
Given the geographical and functional relationship between the District and the City Region, it is apparent that the District will need to accommodate additional development over and above that planned for in the draft Local Plan, in order to contribute to meeting overspill needs arising in Sheffield. The most appropriate location for that will be in the northern part of the District (e.g. at Killamarsh), which has a good physical and functional relationship with Sheffield.
Policy SS2 should, therefore, be revised to include a clear acknowledgement for the District's role in this regard, and the need to review the Green Belt to release appropriate sites for development in the northern part of the District to contribute meeting these housing needs.

Comment

Consultation Draft (February 2017)

Representation ID: 5648

Received: 07/04/2017

Respondent: Mr Robert Gilmore

Representation Summary:

Review the level of housing proposed in order to provide a more realistic assessment and target of housing need.

Full text:

I support the need for new housing in the District and it is obvious that a decent level of housing is required when considering the recent low levels of completions and current under-supply.
However, the level of housing should be proportionate to the expected level of growth and should be based on a sound evidence base (as required by the NPPF para 182).
The proposed level of housing is towards the upper end of the 2013 SHMA figures despite the low levels of projected population growth (0.5%) in the report (242 pa).
The report also details that there is 'no convincing evidence that housing supply would need to increase notably above the demographic projections per se to support economic growth' (p.127).
The level of housing for the District should therefore be reviewed to provide a realistic number of homes over the plan period. It is envisaged from the current evidence base that this would reduce the level of housing required.

Object

Consultation Draft (February 2017)

Representation ID: 5659

Received: 07/04/2017

Respondent: Cartledge Farms Ltd

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

Please refer to the attached SPRU report which outlines additional requirement for housing.

Full text:

Please refer to the attached SPRU report which outlines additional requirement for housing.

Comment

Consultation Draft (February 2017)

Representation ID: 5937

Received: 07/04/2017

Respondent: Bolsover Land Ltd

Agent: iSec Group

Representation Summary:

Bolsover Land Ltd therefore queries whether the proposed 50ha of new employment land within Policy SS2, Scale of Development, is justified; it may need to change subject to the most up to date evidence base being issued.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 5953

Received: 10/04/2017

Respondent: Panache Lingerie Ltd

Agent: Knight Frank

Representation Summary:

Panache Lingerie Ltd generally supports the proposed level for residential development of up to 1,950 dwellings within Level 2 Settlements, including Renishaw. However, the respondent has serious concerns about the calculation of the housing need. The Council states that 1,016 units of the 6,600 dwellings have already been built. This would directly contravene paragraph 47 of the NPPF, as these houses are delivered, as opposed to deliverable. Therefore, there would be scope to develop more than 1,950 units within Level 2 Settlements.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 5970

Received: 10/04/2017

Respondent: Green Piling Ltd

Agent: Knight Frank

Representation Summary:

Green Piling generally supports the proposed level of new employment land of 50ha. However, the respondent has serious concerns about the way in which the Council calculated their housing need which includes 1,016 houses which have already been built/delivered. This would directly contravene paragraph 47 of the NPPF, as these houses are delivered, as opposed to deliverable.

Comment

Consultation Draft (February 2017)

Representation ID: 5985

Received: 06/04/2017

Respondent: Advance Land & Planning Limited

Representation Summary:

In the light of the forgoing, we suggest that the scale of development will have to be increased above the current proposal of 6,600 dwellings for the plan period.

Full text:

See attached documents.

Comment

Consultation Draft (February 2017)

Representation ID: 6020

Received: 07/04/2017

Respondent: Mr W Smith

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

W Smith mentions that Policy SS2 is vague and sets only a minimum target and does not account for substantial uplifts in employment from investment to the two LEPs. The plan should also provide sufficient adaptability and flexibility to ensure it can meet the needs of housing growth within the two LEPs. It is suggested that the policy should include:
- Increased housing requirement to account for economic growth, or reduce growth to account for lower requirement.
- Greater flexibility by releasing more sites to increase housing supply which do not serve an out of settlement purpose

Full text:

See attachment

Support

Consultation Draft (February 2017)

Representation ID: 6059

Received: 06/04/2017

Respondent: Chesterfield Borough Council

Representation Summary:

SS2 Scale of development
SUPPORT the intention to meet housing need within the district, although it could be clearer if the figure of 6,600 dwellings across the plan period represents the OAN or is a target taking account of other factors. For clarity, it appears this policy could be combined with policy SS3 to avoid confusion over the employment target in particular.

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6139

Received: 07/04/2017

Respondent: Sheffield FC

Agent: DLP (Planning Ltd) - East Midlands office

Representation Summary:

Mr Richard Timms objects to Policy SS2. This is supported by the attached research report on Objectively Assessed Housing Need which concludes that
- much of the Council's supporting evidence is now out of date
- the proposed level of housing provision is unlikely to be able to support either the current level of jobs in the future or any employment growth
- the identified level of affordable housing need would be unmet
- a housing requirement of between 338 and 395 dpa would be required

Comment

Consultation Draft (February 2017)

Representation ID: 6225

Received: 07/04/2017

Respondent: Mrs Margaret Gray

Agent: Fisher German LLP

Representation Summary:

Mrs Margaret Gray points out that the SHMA Final Report 2013 and the SHMA Sensitivity Testing Analysis 2014 are now out of date. The updating of those reports may affect the housing requirement figure. Also, unmet needs from Sheffield will need to be accommodated by NED. It would be highly likely that the housing requirement would therefore need to increase which could be fulfilled by the Land immediately north of Tupton and Land south East of site aq at Wingerworth.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6238

Received: 06/04/2017

Respondent: EPC-UK Explosives Plc

Agent: Leith Planning Group

Representation Summary:

It's noted that Shirland and Stonebroom have been identified as potential sustainable locations for proposed provision of 230 dwellings in Shirland, and 85 dwellings in Stonebroom during the plan period.

EPC-UK wishes to support the Council in meeting their strategic objectives and development aims and targets.

However, this must be balanced with a fair and reasonable review of the scale and location of development being proposed. Concerns over potential impact of development within Rough Close Works(RCWs) consultation zones.

Assurances sought from Council that the RCWs consultation zone will be rigidly protected and none of the additional development proposed within the Plan will be located in close proximity to RCWs.

Full text:

See attachment.

Support

Consultation Draft (February 2017)

Representation ID: 6250

Received: 03/04/2017

Respondent: Shaw Developments (Sheffield) Ltd

Number of people: 2

Agent: IBA Planning Limited

Representation Summary:

S Whittham and K Grayson support the scale of development (minimum of 6,600 dwellings until 2033) set out under Policy SS2.

Full text:

See attachments

Comment

Consultation Draft (February 2017)

Representation ID: 6289

Received: 06/04/2017

Respondent: CPRE South Yorkshire & Friends of the Peak District

Representation Summary:

Questions raised over predicted employment growth in NED, saying that by the time the Plan is adopted, job growth will have expired and, if the Derbyshire Employment Forecast is correct, the economy of the area will have largely flattened out.

Suggestion that NED take a more ambitious position than this, and make policy interventions on that basis.

CPRE would strongly support the emphasis on reducing out-commuting.

Statement that the www.gov.uk Live Table 253 indicated that completions over 2011-16 period averaged only 142 per year, of which only 3% (20 homes) were affordable. The reason for this statistical discrepancy is unclear. Statement that housing completions would need to be increased.

Questions raised over the OAN, statement that the translation of OAN into the proposed housing requirement is deeply ineffective, and therefore unsound. (See full submission for more).

Full text:

See attachment.

Comment

Consultation Draft (February 2017)

Representation ID: 6305

Received: 07/04/2017

Respondent: Mount St. Mary's College

Representation Summary:

Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.

Full text:

Local Development Plan Current Consultation - February to April 2017

Mount St Mary's College's Objectives & Priorities
My name is Nicholas Cuddihy and today I write to you in my capacity as the CEO of the Mount Trust; a charitable trust established in 2006 to manage the property, resources and aspirations of Mount St Mary's College, Spinkhill and its prep School at Barlborough Hall.

The story of our schools dates back to 1620 when the Jesuits first became active in this park of the UK. In 1842 the Jesuit Provincial established Mount St Mary's College in Spinkhill. The school at Barlborough Hall first opened in 1939. The Mount Trust as we know it today was set up as a Local Trust in 2006 to manage Mount St Mary's College and Barlborough Hall School as co-educational inclusive day and boarding schools in the Jesuit tradition, providing children and their families with access to a seamless education from the ages of 3 to 18 yrs. We have long been significant members of the community in Spinkhill.

Our lands and facilities are shared openly and are enjoyed by many in the village and others all year round. Locals and visitors walk our lands freely and access the footpaths and bridleways at their leisure. Our Memorial Chapel frequently hosts concerts and special religious and other ceremonies. We have long established and successful partnerships with many sports clubs and other local groups who enjoy our sports fields, our public gym and other facilities. Every day and every week athletes, footballers, walkers and others come and go and enjoy our beautiful site. We see ourselves as residents of Spinkhill village and we take our responsibilities seriously in this regard. You can understand therefore how we were surprised to note that our school is not located within the settlement boundary in the proposed Local Development Plan. I will address this concern in more detail later but for now I wish to highlight this concern as I set out the context within which we wish to comment on elements of the draft Local development Plan.

During this year, 2017, we will celebrate the 175th Anniversary of the foundation of our schools. As we celebrate we are also concentrating our efforts on planning for our future. Our schools and lands are obviously hugely expensive to manage and maintain. Our heritage buildings and more modern facilities require ongoing investment. We have been a major employer in the area for more than a century and a half. We currently employ more than 170 people and as we look to the future we know we have to fight hard to survive and to thrive.

The Trust has ambitious plans for the College focusing on making improvements to its facilities and improve the extent and quality of facilities it provides to the public and local community. We are keenly aware that a significant and extended increase in income will be required to secure the long term stability of the school. As we master plan for the long term future of our schools we know we will need to devote significant funds to the maintenance and development of our buildings and lands. It is in this context that we welcome the opportunity to comment on the Draft Local Plan in this current consultation.

1. Green Belt Policies
Having reviewed the draft Plan's evidence base related to housing and growth we are pleased to see that part of the College's previously developed land has been included within the Housing Sites Assessment Report dated February 2017 (Appendix C), as 'Land off Station Road, Spinkhill'. That acknowledges the site as an 'infill site'

Nevertheless, having reviewed the draft Plan's policies map we also note that the entirety of the College's lands within the Spinkhill area is identified as Green Belt. From our understanding of national planning policy (within the National Planning Policy Framework (NPPF)), local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access, sport and recreation amongst other things (para.81). Brownfield land should be acknowledged within the Green Belt, reflecting the exceptions test within the (paragraph 89). The current Local Plan identifies the College as a major developed site within the Green Belt and we feel that such major developed sites are dealt with by Policy GS3.

We wish to therefore object to the draft Local Plan's Green Belt Policy (Policy SS9) and the plan more widely as it fails, in our opinion, to identify the developed parts of the College as previously developed or Brownfield land in the Green Belt. Neither does it enable positive planning promoted by para.81 of the NPPF.

2. Spinkhill Settlement Boundary
We would also like to take this opportunity as referred to earlier to raise our concerns regarding the Council's proposed settlement boundary for Spinkhill Village. The policies maps show that the College is not included within the settlement. We have reviewed the definition of a 'settlement' included in the glossary of the draft plan glossary and believe that the College should be included as part of the Spinkhill Settlement based on that definition. It has always been part of the village and has never been physically separate. For more than a century and a half we have played an important part in local life with leisure and recreation facilities available to the village. The village school was housed on our lands prior to its recent relocation across the road. The old Spinkhill railway station was also located on our land and accessed freely by all until it closed and the allotments which are enjoyed today by many villagers also lie on our land.

3. Housing
I note that the Council's most recent Annual Monitoring Report (AMR) (2015/16) identifies how between 2011 and 2015 the number of completions in the district has been below the Council's 300 dwellings per annum target each year. Between 2011 and 2016 the AMR notes a net undersupply of -484 dwellings for the period, and when the council includes projected completions for 2016/2017 this position worsens to-583 dwellings.

Policy SS2 states that the draft plan will make sufficient land available to accommodate a minimum of 6,600 dwellings during the Plan period (2011-2033). This figure equates to 300 dwellings per annum over the plan period and we understand that this is informed by the draft plan's 2013 Strategic Housing Market Area (SHMA) Assessment.

We note that the Council acknowledges that its approach to housing is to be reviewed and given that its Green Belt Review has established that land needs to be removed from the Green Belt, we propose that the College, as previously developed land in the Green Belt should be reconsidered to accommodate some housing capacity.

In conclusion and speaking more broadly we want to explore how we may be able to work together to succeed together. We would welcome an opportunity to engage with the Council proactively to see how specific education related policies could be included in the draft plan. This is particularly important to us as we look to the future. As we reach 175 years we are conscious of our need to develop and invest so that we can improve the educational and wider public facilities we own and provide to others. We have been a major employer and an important part of the life in Spinkhill for a long time. We want to preserve and develop that for today and for the future.

Additional Comments:

Policy SS£ & SS13:
Smaller settlements classified as "level 3" settlements in Table 4.1 can and should make a significant contribution to housing provision and this can help sustain community facilities. Limiting development in such villages to "limited infilling of one or two dwellings" is too restrictive.
In Spinkhill the land shown on the attached plan as Allotment area could make a significant contribution to housing need and the funds released by this development could help improve facilities at the Mount St Mary's College.

Policy SS9:
This policy only refers to dwellings for agriculture and forestry It should allow for "other occupational dwellings in the countryside"
The Green Belt is too tightly drawn around Spinkhill (see our comment on Appendix B - Green Belt Maps).

Policy LC3:
The limitations in this policy are too restrictive. Smarter homes and homes to provide employee accommodation, linked to established rural based employers should qualify as "affordable housing."

Policy LC7:
Although this policy is intended to include for "other occupational dwellings in the countryside" there is no such provision in the text. The policy only refers to dwellings for agriculture and forestry. This is a serious omission and requires correction. Mount St Mary's College is a rural based employer which will require employee's dwellings to be allowed for in this policy. In its present form this policy is inconsistent with Policy SS14 (b).

Policy SDC1:
This policy is too restrictive in that it only refers to buildings. It should refer to previously developed land. In its present form it is inconsistent with Policy SS14 (a) which refers to development being allowed on "vacant derelict or previously developed land." and SS9 (f).

Policy WC4:
The requirement that "any proposal (to be determined under this policy) will need to accord with other policies in this Plan is unrealistic and unnecessary as it's purpose is allow for an exception to other restrictive policies.

Policies Maps
We have the following comments on the Policies Maps.

The absence of a Map covering the whole of the District leaves a policy vacuum in regard to some areas as certain areas do not fall within any of the maps. This is the case in regard to Spinkhill only part of which is covered on the Renishaw Policies Map.

We attached a map of Spinkhill and request the following:-

- Area shown as Allotment area (on the attached plan) should be within the settlement limits and removed from the Green Belt. This wold allow for development of the land for housing and provide funding for improvement to the facilities at Mount St Mary's College.

- The area at Spinkhill identified as "GS3" in the existing Local Plan, comprising the building complex at Mount St Mary's College, should be within the settlement limits and removed from the Green Belt. It is clearly part of the settlement. This was previously shown as "major development in the Green Belt" which is illogical.

Comment

Consultation Draft (February 2017)

Representation ID: 6322

Received: 07/04/2017

Respondent: Strata Homes Limited

Agent: DLP (Planning) Ltd - Sheffield office

Representation Summary:

Strata Homes mentions that Policy SS2 is vague and sets only a minimum target and does not account for substantial uplifts in employment from investment to the two LEPs. The plan should also provide sufficient adaptability and flexibility to ensure it can meet the needs of housing growth within the region. It is suggested that the policy should include:
- Increased housing requirement to account for economic growth, or reduce growth to account for lower requirement.
- Greater flexibility by releasing more sites to increase housing supply

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6349

Received: 07/05/2017

Respondent: Mr Martin Speed

Agent: WYG (Harrogate office)

Representation Summary:

Policy SS2
The principle of Policy SS2 identifying a level of housing provision which is seen as a minimum is supported, but the local plan as a whole must ensure that a policy context is created which actively supports sustainable development where these figures are likely to be exceeded.

it is unclear at present how the Council intend to address the record of persistent under delivery of housing in the District and in accordance with paragraph 47 of the NPPF should include provision for a buffer of 20% above the identified annual requirement for housing during the first five years of the Plan period.

the Publication Version of the Local Plan prior to the Examination will need to take full account of any updated evidence base in respect of housing need, as well as the potential

Table 4.1 Policy SS3 Policies SS12 and SS14 Policy LC1 standardised methodology on assessing needs as discussed in the Government's Housing White Paper

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6396

Received: 07/04/2017

Respondent: Hallam Land Management

Agent: Freeths LLP

Representation Summary:

Hallam Land Management Ltd objects to Policy SS2 because it would fail to account for full objectively assessed housing need, would be unduly pessimistic in respect of economic growth and would fail to meet anticipated housing need arising from the Sheffield City Region. The respondent refers to the SHMA projection PROJ B which indicates high commuting rates and total jobs which would more than double. It is therefore suggested that the housing requirement figure is re-evaluated. Eventually, Sheffield is likely to have a shortfall which should be accommodated over the plan period by NED.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6406

Received: 07/04/2017

Respondent: Mr Paul Stock

Representation Summary:

We believe that the decision taken by the Council not to review the housing requirement has been made without sufficient regard to the requirements and guidance provided by national policy and practice guidance as cited above. The Council must also consider wider issues such as market signals, affordable and economic needs. The balancing of housing and employment strategies is critical in securing economic development and sustainable growth.

Full text:

Response and Representations to the Consultation Draft Local Plan (2011-33) for North East Derbyshire District Council

INTRODUCTION
1. The National Planning Policy context has evolved greatly since the adoption of the North East Derbyshire Local Plan. The North East Derbyshire Development Plan must now be found to be in compliance with the policies of the National Planning Policy Framework (the Framework) to be considered sound at Examination. Should policies in the North East Derbyshire Development Plan be found to be in conflict with the Framework then a presumption in favour sustainable development will apply when considering site allocations and applications for planning permission. The Council must ensure that both the emerging Development Plan documents are consistent with national policy.

CONSULTATION DRAFT LOCAL PLAN
2. This section deals with our responses to the consultation draft Local Plan for North East Derbyshire and sets out our detailed representations on specific local plan policies and proposed allocations.

Policy SS2 - Scale of Development.
3. The consultation draft Local Plan confirms the Council's view that the Plan should provide for a local housing target of 6,600 dwellings between 2011 and 2033 (300dpa).
4. We believe that the decision taken by the Council not to review the housing requirement has been made without sufficient regard to the requirements and guidance provided by national policy and practice guidance as cited above. It is not reasonable to conclude that housing needs are no higher than adopted by referencing household projections alone. The Council must also consider wider issues such as market signals, affordable and economic needs. The Gallagher Judgement highlights the importance of undertaking the exercise of undertaking a full assessment of housing needs, outlining that the balancing exercise cannot be performed without being informed by the actual full housing need.
5. The importance of ensuring housing needs data that informs the housing requirement is kept up-to-date is demonstrated by the examination of the Harrogate Allocations DPD. Following the hearings the Inspector wrote to the Council and outlined that the lack of an assessment of how up-to-date housing needs could be met within the Borough meant that it was not possible to determine whether the footnote 9 of S14 of the Framework had been met. The Plan was ultimately withdrawn.
6. The balancing of housing and employment strategies is critical in securing economic development and sustainable growth. Delivering an insufficient level of housing in an Authority in support of identified economic needs may lead to an increase in unsustainable commuting patterns or stifle growth prospects due to the lack of a sufficient local labour resource. The balancing of the supply of housing in consideration of economic needs is clearly set out as a key consideration in Plan making by S21 and S158 of the Framework.
7. We consider it is also material that the Council has thus far failed to deliver the planned requirement. This would suggest that North East Derbyshire as an authority is a persistent under deliverer and therefore should apply a 20% buffer to the five year housing requirement (as required by S49 of the Framework).
8. In context of the above findings it is clear the Council must undertake a thorough review with the aim of accommodating identified up-to-date housing needs in order to secure the full delivery of the Plan.

Policy SS9 - Green Belt.
9. In response to and for the reasons set out in our previous representations to the Draft Local Plan (Part 1) we welcome and fully support the fact that the Council has now undertaken a review of the Green Belt in the District since the last iteration of the Local Plan. In this regard we endorse the Council's thinking on this matter as set out in paragraphs 4.63 to 4.66 in the consultation draft Local Plan.

Appendix B: Areas to be Removed from Green Belt - Renishaw.
10. We fully support the proposal by the Council to remove the land hatched in green from the Green Belt as shown on the Renishaw Green Belt Plan, a copy of which is set out below:
11. The National Planning Policy Framework is clear in S85 that with regards to the Green Belt local authorities should:
a. Ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development;
b. Not include land which is unnecessary to keep permanently open;
c. Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
12. We believe the proposal by the consultation draft Local Plan to release land from the Green Belt and allocate it for housing development helps in removing a serious question on the ability of the Local Plan to provide the increased need for new housing especially in places where it is most needed in market terms such as Renishaw. In the absence of such a new policy it would have brought into doubt the soundness of the Plan when examined.
13. We contend the release of the land described as to the north east of Hague Lane, Renishaw from the Green Belt is consistent with the Framework. The proposed site is already enclosed on three sides by existing development.
14. The proposed site does not play a role in preventing coalescence. The site is bounded by clear, defensible features preventing coalescence and urban sprawl.
15. The proposed site represents a release of Green Belt land that is entirely consistent with S85 of the National Planning Policy Framework.

Policy SS3: Spatial Strategy & the Distribution of Development.
16. We fully support the proposal set out in the Table 4.2 accompanying Policy SS3 (Housing Provision 2011-2033) to allocate 270 dwellings at Renishaw which is classified as a Level 2 Settlement (Large Village).

Policy LC1: Housing Allocations.
17. We support the proposal set out under Renishaw (ai) in the Table accompanying Policy LC1 to allocate at least 270 dwellings on land described as to the north east of Hague Lane.
18. We consider the site represents a logical and appropriate location for development. The site adjoins to the south of the existing settlement boundary of Renishaw and is contained and enclosed on three sides by existing residential development.
19. Given Renishaw is a third tier large village in the settlement hierarchy we believe it can easily accommodate the proposed number dwellings due to its sustainability and viability. This is further reinforced when consideration is given to the desperate demand for market and affordable housing in this location.
20. The proposed housing allocation is well located in relation to existing services and facilities in the large settlement of Renishaw. The primary school, local doctor's surgery, food shops, public house and Post office are all located within easy walking distance from the site. The site is directly served by several bus services (No: 71, 73, 74, 131 and 231), providing access to wider services and sources of employment. The site accords with the principles of sustainable development.
21. The development would deliver up to 30% affordable dwellings, promoting policy compliant tenure mix. The site would provide for new formal/informal open space including an equipped child's play area for the enjoyment and use of both existing and prospective residents.
22. The proposed housing allocation is available, deliverable and achievable now. There are no physical constraints in bringing the site forward for development. It is able to contribute to meeting the growth needs of the District now, and able to deliver housing within the next five years. The landowners are committed to delivering a high quality residential scheme on the site. The development will not affect the setting of the village, and the boundaries will be sensitivity planted to soften the urban edge of the development. We believe the site can be sympathetically developed through sensitive master planning that anchors it into the landscape and builds on the existing good accessibility to the facilities at the centre of the settlement.

Policy SS3 - The Avenue.
23. We consider Plan still places an over reliance on the Avenue site to deliver 710 new dwellings during the Plan period. It is known the site has major issues in terms of ground contamination. This is extremely likely to prevent it from being able to deliver any meaningful number of new dwellings particularly in the first 5-years of the Plan period. The site was a major allocation in the previous Local Plan and delivered no new dwellings in that plan period. Given the legacy of extensive contamination and uncertainty over the trajectory of delivery the proposed housing allocation on the Avenue site should be deleted from the consultation draft Local Plan.

Policy SS3 - Biwater.
24. Again we consider the consultation draft Local Plan still places an over reliance on the Biwater site to deliver 560 new dwellings during the Plan period. The site is unlikely to deliver any meaningful number of new dwellings particularly in the first 5-years of the Plan period. The site was a major allocation in the previous Local Plan and delivered a limited number of new dwellings. Due to serious concerns over the trajectory of housing delivery for the Biwater site the proposed figure should be drastically reduced.

CONCLUSIONS
25. In conclusion we fully support:
a. the fact that the Council has now undertaken a review of the Green Belt in the District since the last iteration of the Local Plan.
b. the proposal by the Council to remove the land hatched in green from the Green Belt as shown on the Renishaw Green Belt Plan in the consultation draft Local Plan, a copy of which is set out in this representation.
c. the proposal set out in the Table 4.2 accompanying Policy SS3 (Housing Provision 2011-2033) in the consultation draft Local Plan to allocate 270 dwellings at Renishaw which is classified as a Level 2 Settlement (Large Village).
d. the proposal set out under Renishaw (ai) in the Table accompanying Policy LC1 in the consultation draft Local Plan to allocate at least 270 dwellings on land described as to the north east of Hague Lane and shown in the plan set out in this representation.

Object

Consultation Draft (February 2017)

Representation ID: 6422

Received: 07/04/2017

Respondent: Hallam Land Management

Agent: Freeths LLP

Representation Summary:

Hallam Land Management Ltd objects to Policy SS2 because it would fail to account for full objectively assessed housing need, would be unduly pessimistic in respect of economic growth and would fail to meet anticipated housing need arising from the Sheffield City Region. The respondent refers to the SHMA projection PROJ B which indicates high commuting rates and total jobs which would more than double. It is therefore suggested that the housing requirement figure is re-evaluated. Eventually, Sheffield is likely to have a shortfall which should be accommodated over the plan period by NED.

Full text:

See attachment

Object

Consultation Draft (February 2017)

Representation ID: 6461

Received: 07/04/2017

Respondent: Hallam Land Management

Agent: Freeths LLP

Representation Summary:

Hallam Land Management Ltd objects to Policy SS2 because it would fail to account for a full objectively assessed housing need, would be unduly pessimistic in respect of economic growth and would fail to meet anticipated housing need arising from the Sheffield City Region. The respondent refers to the SHMA projection PROJ B which indicates high commuting rates and total jobs which would more than double. It is therefore suggested that the housing requirement figure is re-evaluated. Eventually, Sheffield is likely to have a shortfall which should be accommodated over the plan period by NED.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6539

Received: 07/04/2017

Respondent: Gladman Developments

Representation Summary:

The Council's proposed housing requirement is based on evidence prepared in 2013/14, statement that an update is needed so LP is identifying sufficient land to meet development needs.

Noted that the proposed annual housing requirement of 300 dwellings per annum over the plan period does not represent the upper end of the OAN range identified within the Council's own evidence base.

Gladman welcomes update to housing target based on updated evidence and further work with strategic partners. Would welcome opportunity to be involved in any consultation exercises relating to preparation of new evidence base document.

Full text:

See attachment for full submission.

Support

Consultation Draft (February 2017)

Representation ID: 6574

Received: 07/04/2017

Respondent: Mr & Mrs F Elliot

Agent: Copesticks Ltd.

Representation Summary:

LP approach, setting a minimum objective for employment land, is supported. The delivery of employment development is very much driven by market requirements and there is a need for flexibility to ensure that that sufficient land of the right type is available in the right places and at the right time to support growth and innovation (NPPF p.7).

Different employment uses give rise to different developed densities and employment densities. To be reactive to changing market conditions successfully, there must be flexibility in the guiding policies. Draft Policy SS2 is considered to be sound.

Full text:

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