Distribution of Growth & the Settlement Hierarchy

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Comment

Consultation Draft (February 2017)

Representation ID: 4735

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

Why does an already large centre mean it has the greatest needs for new housing? I disagree. Dronfield should not become larger to eventually become a mini city or because of their urban sprawl join with Sheffield or Unstone.

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.

Comment

Consultation Draft (February 2017)

Representation ID: 4736

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

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.

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.
.




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.

Comment

Consultation Draft (February 2017)

Representation ID: 4740

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

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.

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.

Support

Consultation Draft (February 2017)

Representation ID: 4856

Received: 19/03/2017

Respondent: Dr Derek Cullen

Representation Summary:

I am writing to support the local plan which sensibly is limiting development to sustainable places. As a resident of Heath Village we already have problems with parking and traffic in the village which would be increased by further development

Full text:

I am writing to support the local plan which sensibly is limiting development to sustainable places. As a resident of Heath Village we already have problems with parking and traffic in the village which would be increased by further development

Support

Consultation Draft (February 2017)

Representation ID: 5115

Received: 30/03/2017

Respondent: Mr C Pratt

Representation Summary:

I support the re-categorisation of Ashover and Kelstedge as level 3 settlements and Alton ,Fallgate and Littlemoor as level 4 settlements which now realistically reflect these communities.

Full text:

I support the draft local plan.
I support the re-categorisation of Ashover and Kelstedge as level 3 settlements and Alton ,Fallgate and Littlemoor as level 4 settlements which now realistically reflect these communities.
I support the removal of housing growth for the rural west of the district.
I would seek the removal of paragraph 5.74 of the plan which potentially allows some market housing to be built in open countryside and replace it with adequate provision for affordable housing within the settlement development limits from the outset.

I hope this plan will be adopted with minimum delay.

Support

Consultation Draft (February 2017)

Representation ID: 5120

Received: 30/03/2017

Respondent: Mrs Muriel Pratt

Representation Summary:

I support the recategorisation of settlements within the Ashover parish as level 3 and 4 settlements and this realistically reflects these communities.

Full text:

I would like to express my SUPPORT for the plan.

1. I support the recategorisation of settlements within the Ashover parish as level 3 and 4 settlements and this realistically reflects these communities.

2. I support the removal of housing growth for the rural west of the district. This again makes more sense.

3. I think paragraph 5.74 should be removed as this potentially allows some market housing to be built in open countryside. It should be replaced with adequate provision to build affordable housing within the settlement development limits from the outset.

I hope this plan will be adopted with minimum delay.

Comment

Consultation Draft (February 2017)

Representation ID: 5171

Received: 31/03/2017

Respondent: Morton Parish Council

Representation Summary:

Ref 4.27 - Morton has been categorised as level 2 as a "Settlement with a good level of sustainability". This ranking is obtained from findings in the settlement and hierarchy study (December 2016). We believe this categorisation is incorrect and should be reviewed.

Statement that due to the geography of Morton, busus that only go through the outskirts should not be included in the scoring. This should be taken into account within the scoring mechanism The current scoring is 24 which should be revised to 8 excluding the 55,55x and SP1. North East Derbyshire should downgrade the Level 2 categorization for Morton to level 3.

Full text:

In response to the recent publication of the local plan for North East Derbyshire we would like to offer the following comments for discussion and review:

4. Spatial Strategy

Distribution of Growth & the Settlement Hierarchy.

Ref 4.27 - Morton has been categorised as level 2 as a "Settlement with a good level of sustainability". This ranking is obtained from findings in the settlement and hierarchy study (December 2016). We believe this categorisation is incorrect and should be reviewed.

5. Living Communities

Ref 5.44 - The area identified for development has been categorized by the Coal Authority as high risk, as the land contains potential hazards from former coal mining, making it potentially costly and unsuitable for development.

9. Infrastructure and Delivery
9.44 - Public Transport

When allocating development sites accessibility to bus services has been a key consideration.

From the Settlement and Hierarchy study the following points are made:

Morton is a linear settlement in the southern part of the District.

The results give 5 buses passing through Morton, 55, 55x, 149,150 and SP1. 

Only the 149 and150 actually pass through the village but they only run every 2 hours. 
The 55, 55x and SP1 services run hourly but only stop at the Corner Pin which is at the far end, on the outskirts of the village before travelling towards Pilsley. They do not pass through the village and due to the linear nature of the village they are not accessible to most villagers. 
The proposed location for the new builds is some distance away from the 55, 55x and SP1 bus routes and will not be serviced by these buses.

Although the study is based on timetables they do not take into account the bus routes which do not pass through the village. The unique geography of Morton village (i.e. linear) would suggest a subjective view may be more appropriate.

We believe judgements should be made about which services to include or not, especially when they do not serve the village. This should be taken into account within the scoring mechanism The current scoring is 24 which should be revised to 8 excluding the 55,55x and SP1.

9.68 - Plan Delivery and the role of developer contributions.
"the Council will require the developer to contribute towards infrastructure"

This has not been the case on previous developments within Morton when the Section 106 agreed contributions have been removed during the build process. This is particularly important for the schooling provision within Morton as an earlier study "Settlement role and Function Study Dec 2013" stated that Morton school had a net capacity of 70 and was oversubscribed by 24.3%. This was the third worst in the whole NE Derbyshire area and only three schools in all categories have less capacity. The school is unable to accept any new pupils and local villagers currently have to find alternative school places elsewhere.

General comment

Since the initial local plan started in 2011 total housing completions within Morton have reached 53 with a further potential planning application for another 48, this should be taken into account within the plan. If an additional 100 homes are built, it would grow the village by 20%+ which cannot be supported by the infrastructure.

It is with respect we would ask the issues raised above to be considered and for North East Derbyshire to downgrade the Level 2 categorization for Morton to level 3.

Comment

Consultation Draft (February 2017)

Representation ID: 5219

Received: 03/04/2017

Respondent: Mr Eric Singleton

Representation Summary:

The statement in paragraph 4.26: "the Local Plan aims to direct new growth to the district's most sustainable settlements based on the Settlement Hierarchy" and repeated in paragraph 7.4 conflates settlement size with 'sustainability'. This plan offers no evidence to demonstrate that enlarging an already large settlement by building on land currently designated as Green Belt is more 'sustainable' than other options.

Para 4.28 is misleading: the size of a community does not necessarily correlate to job volume creation. The plan does not provide evidence that Dronfield will generate the number of jobs commensurate with 860 additional dwellings.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.5 Policy SS1, Sustainable Development, clauses c and g

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Support

Consultation Draft (February 2017)

Representation ID: 5226

Received: 03/04/2017

Respondent: Mr David Munn

Representation Summary:

I welcome the Council's change in policy which now allocates housing growth to reflect sustainability levels within differing parts of infrastructure in the district. This appears to give a more logical and equitable distribution of new housing development. The previous proportional distribution resulted in new homes being proposed in locations which could not accommodate them.

Full text:

I welcome the Council's change in policy which now allocates housing growth to reflect sustainability levels within differing parts of infrastructure in the district. This appears to give a more logical and equitable distribution of new housing development. The previous proportional distribution resulted in new homes being proposed in locations which could not accommodate them.

Support

Consultation Draft (February 2017)

Representation ID: 5309

Received: 04/04/2017

Respondent: Mrs Christine Brocksopp

Representation Summary:

Comment: Uppertown Hamlet in Ashover Parish. Should it be specified in Level 4?
Comment: I support the re-categorisation of the settlements within Ashover parish as level 3 & 4 settlements

Full text:

Comment: Uppertown Hamlet in Ashover Parish. Should it be specified in Level 4?
Comment: I support the re-categorisation of the settlements within Ashover parish as level 3 & 4 settlements

Object

Consultation Draft (February 2017)

Representation ID: 5323

Received: 04/04/2017

Respondent: Mrs Alison Dean

Representation Summary:

4. Spatial Strategy Distribution of Growth & the Settlement Hierarchy. Ref 4.27 - Morton has been categorised as level 2 as a "Settlement with a good level of sustainability". This ranking is obtained from findings in the settlement and hierarchy study (December 2016). We believe this categorisation is incorrect and should be reviewed.

Full text:

4. Spatial Strategy Distribution of Growth & the Settlement Hierarchy. Ref 4.27 - Morton has been categorised as level 2 as a "Settlement with a good level of sustainability". This ranking is obtained from findings in the settlement and hierarchy study (December 2016). We believe this categorisation is incorrect and should be reviewed.

Object

Consultation Draft (February 2017)

Representation ID: 5465

Received: 06/04/2017

Respondent: Woodall Homes Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN.
There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision.
See attached statement

Full text:

6.01 The distribution of housing allocations across the District has been underpinned by the Council's Settlement Hierarchy Study, December 2016. Level 1 Settlements include the Principal Towns of Clay Cross and Dronfield and the Secondary Towns of Eckington and Killamarsh. Below this are level 2 Settlements, which are those with good levels of sustainability followed by level 3 Settlements with limited sustainability and level 4 Very small villages and hamlets with limited sustainability. The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
6.02 Level 1 Settlements contain 48% of the District's population and will provide for a significant proportion of the District's housing growth requirements, alongside retail and employment growth over the plan period.
6.03 Paragraph 4.33 of the supporting text of the draft plan confirms that outside the principal and secondary towns (and identified strategic sites); Level 2 Settlements will provide much of the remaining planned housing growth, which is expected to be in the region of 1,950 dwellings.
6.04 As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN. The Council identify overall housing allocations that will provide 5,740 dwellings over the plan period and consider that when combined with 1,016 dwellings already built this is more than sufficient to meet the housing requirement of the District. This however only provides a margin of 2.4% provision over and above the Council's minimum requirement of 6,600 dwellings, which is considered not to give sufficient flexibility should any of the identified site allocations fail to deliver the expected number of homes within the plan period. The housing provision set out in paragraph 5.015 of 390-420 dwellings per annum would ensure that there was sufficient headroom to take account of the economic growth strategy, reductions in and/or delays in delivery and the significant need for affordable housing provision. It is considered that this approach is compliant with the policies of the Framework which requires plans to be:
'positively prepared ....and based on a strategy that seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development' (paragraph 182 of the Framework).
6.05 There are opportunities for some of the Level 1 and Level 2 Settlements to support higher levels of housing provision. For example Site Reference CX2104 Land north of Clay Lane, Clay Cross is capable of accommodating approximately 42 dwellings and given the location in Clay Cross, a level 1 Settlement this would provide a sustainable form of development that would in some small measure contribute to the deficit identified in the Council's housing land supply, if it is to meet the full OAN of the District.
6.06 In addition to the opportunities at Clay Cross there are also further opportunities to identify further housing allocations in Level 2 settlements such as Grassmoor and Tupton.
6.07 Although the allocation of the land to the north of Clay Lane, Clay Cross is supported in principle additional dwellings could be achieved on this site, particularly as the Council have not identified sufficient housing to meet the OAN. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land.

- Additional site:
6.05 There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision. For example Site Reference GRA/1601 Land East of B6038 (North Wingfield Road) North of Cotswold Drive, which was identified in the Green Belt Review Part 2 as being capable of accommodating some of the District's housing requirement as it only partially satisfies the purposes of Green Belt. This site is then further assessed by the Council in the 'North East Derbyshire Housing Sites Assessment Report, February 2017 as being a deliverable and developable site, in line with policy. The Sustainability Appraisal also scores Grassmoor as a sustainable settlement with good access to services, facilities and public transport. GRA/1601 scores equally well to the site that has been allocated, Site Reference GRA/1901.
6.06 The inclusion of sites such as GRA/1601 would increase the overall provision of dwellings over the plan period. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land.

Support

Consultation Draft (February 2017)

Representation ID: 5552

Received: 07/04/2017

Respondent: Sheffield City Council

Representation Summary:

The strategy to direct growth to the most sustainable settlements is welcomed, and is in line with the aims of the NPPF. Three of the four level one settlements are in the north and therefore have a stronger relationship with Sheffield than Clay Cross in the south. With the majority of housing growth proposed across the four towns and four strategic sites, this is likely to result in a reasonable amount of new homes being developed in settlements where there are commuting links to Sheffield and where there is an overlap in the housing market with Sheffield.

Full text:

The strategy to direct growth to the most sustainable settlements is welcomed, and is in line with the aims of the NPPF. Three of the four level one settlements are in the north and therefore have a stronger relationship with Sheffield than Clay Cross in the south. With the majority of housing growth proposed across the four towns and four strategic sites, this is likely to result in a reasonable amount of new homes being developed in settlements where there are commuting links to Sheffield and where there is an overlap in the housing market with Sheffield.

Object

Consultation Draft (February 2017)

Representation ID: 5597

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN.
There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision.
See Attached Statement

Full text:

6.01 The distribution of housing allocations across the District has been underpinned by the Council's Settlement Hierarchy Study, December 2016. Level 1 Settlements include the Principal Towns of Clay Cross and Dronfield and the Secondary Towns of Eckington and Killamarsh. Below this are level 2 Settlements, which are those with good levels of sustainability followed by level 3 Settlements with limited sustainability and level 4 Very small villages and hamlets with limited sustainability. The Settlement Hierarchy is broadly in line with the fundamental principles of sustainability set out in the Framework.
6.02 Level 1 Settlements contain 48% of the District's population and will provide for a significant proportion of the District's housing growth requirements, alongside retail and employment growth over the plan period.
6.03 Paragraph 4.33 of the supporting text of the draft plan confirms that outside the principal and secondary towns (and identified strategic sites); Level 2 Settlements will provide much of the remaining planned housing growth, which is expected to be in the region of 1,950 dwellings.
6.04 As already set out in Section 5, it is considered that the housing requirement for the plan period of 300 dwellings per annum or 6,600 for the plan period is insufficient to meet the full OAN. The Council identify overall housing allocations that will provide 5,740 dwellings over the plan period and consider that when combined with 1,016 dwellings already built this is more than sufficient to meet the housing requirement of the District. This however only provides a margin of 2.4% provision over and above the Council's minimum requirement of 6,600 dwellings, which is considered not to give sufficient flexibility should any of the identified site allocations fail to deliver the expected number of homes within the plan period. The housing provision set out in paragraph 5.015 of 390-420 dwellings per annum would ensure that there was sufficient headroom to take account of the economic growth strategy, reductions in and/or delays in delivery and the significant need for affordable housing provision. It is considered that this approach is compliant with the policies of the Framework which requires plans to be:
'positively prepared ....and based on a strategy that seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development' (paragraph 182 of the Framework).
6.05 There are opportunities for some of the Level 2 Settlements to support higher levels of housing provision. For example an extension to LC1ao) Land to the rear of 10-52 Ashover Road, Old Tupton would provide a further 60 dwellings and would provide a sustainable form of development in this location. The Sustainability Appraisal scores Tupton as a sustainable settlement with good access to services, facilities and public transport, which supports its inclusion as a Level 2 Settlement.
6.06 The inclusion of the site at Tupton would increase the provision of housing over the plan period. It is considered that the Council are at risk of submitting a plan that will be found unsound, unless they can identify further sources of housing land and extend where appropriate identified housing allocations, such as LC1ao).

Support

Consultation Draft (February 2017)

Representation ID: 5883

Received: 04/04/2017

Respondent: Mr & Mrs David & Margaret Wombwell

Representation Summary:

Support for the change of Ashover to Level 3 Settlements with limited sustainability. Support for removing housing growth targets for Ashover.

Full text:

It is good that the Council's Draft Local Plan re-categories the settlements within Ashover Parish, assessing them as having "limited" or "very little" sustainability.
It is good too that the Council has removed housing growth targets for the western area of the District. We are though, concerned that Paragraph 5.74 might allow market housing to be built on green fields. We strongly hope that this paragraph will be amended, so that affordable housing can be planned for initially and that it will be planned for it to be built within the existing settlement area.

Support

Consultation Draft (February 2017)

Representation ID: 5885

Received: 05/04/2017

Respondent: Mrs Isobel Clark

Representation Summary:

Support for Ashover being categorised at Level 3 & 4 in the settlement hierarchy. Support for removal of housing growth targets for the rural west of the district.

Full text:

With reference to the Local Plan update for NED and Ashover in particular, I am pleased to support the recategorisation of the settlements within Ashover Parish as Level 3 and 4 settlements and also support the removal of housing growth targets for the rural west of the district and seek the removal of paragraph 5.74 of the plan which potentially allows some market housing to be built in the open countryside and replace it with adequate provision for affordable housing within the settlement development limits from the outset.
Please save Ashover as a lovely village.

Comment

Consultation Draft (February 2017)

Representation ID: 5980

Received: 10/04/2017

Respondent: Green Piling Ltd

Agent: Knight Frank

Representation Summary:

Sustainability: Green Piling argues that their site occupies a highly sustainable location within the defined settlement boundary of Renishaw. The release of their land, particularly if in addition to the adjacent vacant land to the east (Panache Lingerie site) would also enable an adequate standard of amenity to be achieved for future occupants.

Comment

Consultation Draft (February 2017)

Representation ID: 6097

Received: 10/04/2017

Respondent: Panache Lingerie Ltd

Agent: Knight Frank

Representation Summary:

Sustainability: Panache Lingerie considers their own site as a wholly sustainable location for residential development within the defined settlement boundary of Renishaw with excellent transportation links and accessibility to local services.

Full text:

See attachment

Comment

Consultation Draft (February 2017)

Representation ID: 6189

Received: 06/04/2017

Respondent: John Church Planning Consultancy Limited

Representation Summary:

No objection is raised in principle to the identification of Brackenfield under level 4 in the Settlement Hierarchy (Table 4.1), policy SS13 is considered to be unnecessarily restrictive

Statement that the words "and rounding-off" should be inserted between the words "infill" and "development".

It is requested that the policy be modified, slightly, in accordance with these representations.

Full text:

BRACKENFIELD.

The Ogston Estate has previously submitted representations with regard to future development at Brackenfield, predominantly to meet perceived local needs.

Whilst no objection is raised in principle to the identification of Brackenfield under level 4 in the Settlement Hierarchy (Table 4.1), policy SS13 is considered to be unnecessarily restrictive.

It is considered that the words "and rounding-off" should be inserted between the words "infill" and "development".

This would facilitate, in particular, the provision of modestly-proportioned new housing, commensurate with the scale of development at Brackenfield that would also assist in meeting identified need for affordable housing for local persons. It is requested that the policy be modified, slightly, in accordance with these representations.

Support

Consultation Draft (February 2017)

Representation ID: 6226

Received: 06/04/2017

Respondent: Patricia Scott

Representation Summary:

Support for Ashover being categorised as Level 3 & 4 in the Settlement Hierarchy.

Full text:

I am writing in support of changes in the recent draft Local Plan that categorises settlements within the Ashover Parish as level 3 & 4 and subsequently removes housing targets set in the previous draft. It is refreshing that the team at NEDDC have listened to the representation from the Ashover community and agreed that substantial housing growth is not sustainable in this part of the rural west region.

I am aware that developers will be lobbying hard and employing expensive legal
representation to try to reverse this decision, but I would ask that you hold firm and resist capitulation to those whose only motivation is greed. I would hope that the Ashover community has shown that it is both prepared to embrace development where appropriate through its Neighbourhood plan initiative, while trying to resist urban style development that would destroy its special landscape area, which should be conserved for future generations to also enjoy.

I would ask that Paragraph 5.74 is amended as I feel that this is likely to encourage
developers to make speculative applications on green field sites, when it would be better if adequate provision for low cost housing sited within the existing settlement development limits, was included in the plan from the start. This approach would offer a better protection to the special landscape area and close a potential loophole in the local plan.

Support

Consultation Draft (February 2017)

Representation ID: 6328

Received: 07/04/2017

Respondent: Mrs Ellen Hardwick

Representation Summary:

Support for categorising Ashover as a Settlement 3 & 4 in the Settlement Hierarchy.

Full text:

I would like to take this opportunity to offer my support for the new Draft Local Plan, and to thank the team for listening to the serious concerns of Ashover Parish residents about the unsustainable housing growth targets in the initial Draft Local Plan, which would have been extremely damaging to the sensitive landscapes of the Peak Fringe.
Ashover has now been categorised as a "Settlement with Limited Sustainability", which much more accurately reflects its status as a small, rural village accessed by minor roads, with some, but limited facilities.
The new landscape policy also sounds more robust than the previous one and thus better equipped to protect the best landscapes in the district from inappropriate development.

Object

Consultation Draft (February 2017)

Representation ID: 6521

Received: 07/04/2017

Respondent: Mr Simon Carr

Agent: Planning and Design Practice Ltd

Representation Summary:

Questions over how different the settlement hierarchy is to the previous iteration contained in the 2015 draft LP. Statement that proposed pattern of growth is spatially very uneven with no growth allowed for in the west sub-area. Argument given for Ashover to be included as a Level 2 settlement. Questions over why Ashover is not suitable for any at all with the exception of windfall sites.

Statement that to preclude all but infill development in so many settlements appears at odds with the NPPF which recognises the social and economic benefits of a limited amount of new housing.

Full text:

I wish to comment on the Consultation Draft Local Plan. My client, owns land off Moor Road, Ashover where we have recently submitted an outline planning application for up to 30 dwellings. We have previously made Local Plan representations about this site.

I wish to comment in particular on the settlement hierarchy referred to in policy SS3. I am struck by how different the settlement hierarchy is to the previous iteration contained in the 2015 draft Local Plan. I would comment as follows:
* The plan only proposes development in a very limited number of settlements. This brings into question the overall viability and deliverability of the plan. A key part of deliverability is that there must be sufficient demand for the levels of housing proposed in those locations. I think the council's evidence base on this is thin to say the least
* The proposed pattern of growth is spatially very uneven with no growth allowed for in the west sub-area (if one excludes Shirland which isn't really in the west at all)
* There is no recognition of the role of certain settlements. Ashover, for example, is well served by amenities and facilities and performs the role of a rural service centre for a number of smaller villages within the Ashover parish. Hence, even though it ranks below all of the Level 1 and 2 settlements for its overall sustainability index score, there is a strong argument for including it as a Level 2 settlement.
* Ashover was previously earmarked for 115 dwellings - now it is apparently not suitable for any at all with the exception of windfall sites.
* To preclude all but infill development in so many settlements appears at odds with the NPPF which recognises the social and economic benefits of a limited amount of new housing.

I trust you will take these comments into account and keep me informed of next steps in the Local Plan process.

Comment

Consultation Draft (February 2017)

Representation ID: 6571

Received: 07/04/2017

Respondent: Messrs FS, FJ & WV Rodgers

Agent: Urbana Town Planning

Representation Summary:

Messrs Rodgers point out that the distribution of housing growth purports to be in part directed in accordance with the Settlement Hierarchy Study and argue that the subject site would be capable of accommodation significant growth. Therefore, the site should be enabled to deliver a proportion of housing provision via a proposed allocation.

Full text:

See attachment

Support

Consultation Draft (February 2017)

Representation ID: 6609

Received: 07/04/2017

Respondent: Mr J White

Agent: JVH Town Planning Consultants

Representation Summary:

We support Killamarsh as a development location and the proposed release of sites from the green belt to support development in this sustainable location and noted as a Level 1 Settlement.

Full text:

See attachment