Table 4.1: Settlement Hierarchy

Showing comments and forms 1 to 25 of 25

Support

Consultation Draft (February 2017)

Representation ID: 4840

Received: 17/03/2017

Respondent: Mr A Petrie

Representation Summary:

The re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability, also reflects realistically now the circumstances of these communities.

Full text:

NEDDC Local Plan (2011-2033) - February 2017 Consultation Draft

I am writing in respect of your recently published Draft Local Plan. I am a resident of Ashover Parish.

Having previously expressed considerable disquiet about the January 2015 Draft Plan, especially in respect of the then conflict between environmental issues in the rural west of the District and above average housing demands for Ashover, I have been pleased to find that the new draft plan proposes policies for the protection of the countryside, and a freedom from focussed housing growth in the rural west which accords much more satisfactorily with NPPF policies for the protection of the natural environment. I am also of the view that the current draft policies appear (in the main) to have been prepared in a manner which will give much clearer guidance to decision makers in respect of those environmental aims.

The re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability, also reflects realistically now the circumstances of these communities.

It is therefore my view that the latest reiteration of the plan represents a significant improvement in the strategy and policies for the rural west of the district though, by exception, I believe the following matters require further attention in the next phase of the work.

1) Para. 4.79 states that further land outside Settlement Development Limits is not required to meet the development requirement of the Plan period, however Para. 4.80 then proceeds to state that these limits are being reviewed and the revisions arising from that review are to be published with the Publication version of the Plan. This is unsatisfactory on two counts. Firstly, the statement that land outside the SDLs is not required, is meaningless if those SDLs are not yet determined, and, secondly, if revised boundaries are not to be available until the Published version of the Plan is available, it would appear that any changes proposed cannot be the subject of public consultation though the public ought to be given the opportunity to comment before the boundaries are consolidated in the Plan.


2) Para. 5.74 states that it may be appropriate to allow a small element of market housing on exception sites. This seems wholly unsatisfactory for a number of reasons.

a) Exception sites ought to be a tool to deal only with unforeseen circumstances that arise after the Local Plan is adopted. At the outset, SDLs should be set to allow for essential development inside those boundaries and the Plan ought not to assume that those provisions might be inadequate.

b) If the rules permit market housing on exception sites, Developers will refrain from providing social housing within the SDLs because they know that if the social demand cannot be satisfied inside the SDLs, the rules create the opportunity for yet more open market housing in the countryside.

c) Para. 5.75 places the onus on the Developer to undertake a survey to demonstrate a genuine identified local need for social housing before an exception site can become the subject of a planning application. It is widely recognised that such an arrangement is not adequately independent. The rules should require the Local Authority to contract the study at the Developer's expense to ensure the conclusion is not influenced by commercial issues. It should also be a requirement for the Applicant to demonstrate that there are no alternative sites within the SDL

d) The principle of funding social housing from levies on open market housing is in any case a desperate and counter-productive principle, for the practice pushes up the cost of market housing and drives even more people from the open market sector into the social sector.

e) Greater efforts should be made to move appropriate open market housing within SDLs to the social sector by purchasing it for that purpose, especially (but not exclusively) where that property was lost to the social sector through the "right to buy" scheme.

f) Any provision in the Local Plan which permits housing in areas contrary to the intentions of the Local Plan, ought to be avoided, for such provisions will be exploited by Developers, and the provisions discourage other efforts to meet social needs in ways which are more consistent with the planning strategy and the objectives of the NPPF.

To include a policy in the Plan in respect of Exception Sites is to plan failure. It would be far preferable to identify land at this stage within SDLs (revised if necessary) which is more than adequate for Social Housing for the life of the Plan, and protect it for the future in the manner that Safeguarded Land fulfils a similar long term purpose within the Green Belt.

3) Policies for the protection of Trees, Woodland and Hedgerows are very loose. Experience demonstrates that notwithstanding many abuses under TPO legislation during the life of the last Local Plan, the Authority fails (almost without exception) to pursue offenders. Policies in the plan need to address that historic weakness to ensure the Authority has the ability to protect this important natural resource.

Support

Consultation Draft (February 2017)

Representation ID: 5136

Received: 31/03/2017

Respondent: Mr A Hardwick

Representation Summary:

I particularly agree with Ashover now being considered a level 3 settlement.

Full text:

I write as a resident of NE Derbyshire and following your request for comments regarding the NE Derbyshire Local Plan (2011-2033) Consultation Draft dated February 2017, which I have bought and read through.

I agree that the emphasis on development around the main towns (and level 1 and 2 settlements) is of paramount importance.

Furthermore I particularly agree with Ashover now being considered a level 3 settlement.

Policy SS12 refers back to Settlement Development Limits, which appear to still be under review (para 4.80) which is unsatisfactory. Also there does not seem to be the current SDL's stated as plans within the Draft for all settlements.

Policy LC3 gives me some great concern at paragraphs f) and g) in that there are some loopholes here which could so very easily be abused by unscrupulous developers, who also might promise a certain mix of housing at outline planning stage, but then when reality strikes be compelled to change that mix towards more market houses at the final planning stage. I feel that paragraphs f) and g) should be removed.

I appreciate policy SDC3 and note that the Ashover Valley is an Area of Primary Sensitivity as classified by AMES.

Policies SDC5 and SDC6 are particularly important in preserving the beauty of our area and I commend their inclusion.

It is important that SDC13 is strictly adhered to in order to prevent unsightly building taking place, and also unsympathetic modern structures which in no way fit in to the existing built environment.
Paragraph o) of SDC13 warrants further expansion. Developers are very keen on creating new housing estates on green field sites, the refuse collection department is unwilling to travel along unadopted roads to collect the bins, and so developers need to assign off road areas adjacent to the highway for the bin lorries to park in which would also house at the moment 2 wheely bins per household. This would then ensure that country lanes are not made totally inaccessible by bin lorries tying to manoeuvre around perhaps up to 100 bins(if there were say 50 dwellings on an estate).

I applaud policy SDC14 and would encourage the use of Bylaws to strengthen paragraphs 8.73 and 8.74.

Policy ID1 is very important and I am in total agreement with it.

Support

Consultation Draft (February 2017)

Representation ID: 5179

Received: 01/04/2017

Respondent: Clare and Ian Blaskey

Representation Summary:

We support the re-categorisation of the settlements within Ashover Parish as level 3&4.

Full text:

We support the ré categorisation of the settlements within Ashover Parish as level 3&4 We support the removal of housing growth targets for the rural west district We seek removal of paragraph 5.74 of the plan which allows 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.

Support

Consultation Draft (February 2017)

Representation ID: 5189

Received: 01/04/2017

Respondent: Helen Boffy

Representation Summary:

Support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and,

Full text:

Having considered the content of the new draft plan, I am pleased that the District Council has taken note of the views expressed by the community of Ashover during the last round of consultation and has now re-categorised Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability which, as a consequence, will limit any housing growth in the Parish to just infill within the settlement development limits and what you refer to as 'windfall' development on brown-field sites in the open countryside.
In general therefore I support this new Draft Plan though, by exception, I do not agree with Para. 5.74 of the Plan which potentially allows some market housing on the back of affordable housing on what are known as 'Exception Sites', that is to say, green field sites in open countryside outside the settlement development limits. In my view, this provision in the Draft Plan may be open to abuse by developers and I believe that adequate provision should be made for affordable housing within the settlement development limits from the outset so that green field sites cannot be vulnerable to such treatment.
Therefore I wish it to be noted as part of the Local Plan consultation by the Council that I
1) Support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and,
2) Support the removal of housing growth targets for the rural west of the District and,
3) Seek 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.

Support

Consultation Draft (February 2017)

Representation ID: 5192

Received: 03/04/2017

Respondent: Mr David Boffy

Representation Summary:

Support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and,

Full text:

Having considered the content of the new draft plan, I am pleased that the District Council has taken note of the views expressed by the community of Ashover during the last round of consultation and has now re-categorised Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability which, as a consequence, will limit any housing growth in the Parish to just infill within the settlement development limits and what you refer to as 'windfall' development on brown-field sites in the open countryside.
In general therefore I support this new Draft Plan though, by exception, I do not agree with Para. 5.74 of the Plan which potentially allows some market housing on the back of affordable housing on what are known as 'Exception Sites', that is to say, green field sites in open countryside outside the settlement development limits. In my view, this provision in the Draft Plan may be open to abuse by developers and I believe that adequate provision should be made for affordable housing within the settlement development limits from the outset so that green field sites cannot be vulnerable to such treatment.
Therefore I wish it to be noted as part of the Local Plan consultation by the Council that I
1) Support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and,
2) Support the removal of housing growth targets for the rural west of the District and,
3) Seek 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.

Support

Consultation Draft (February 2017)

Representation ID: 5261

Received: 02/04/2017

Respondent: Johanne Boulding

Representation Summary:

Support for the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements;

Full text:

I am a resident in Ashover and would like to make the following comments on the North East Derbyshire Local Plan: Consultation Draft:


* I support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements;
* I support the removal of housing growth targets for the rural west of the District;
* I would like to see Paragraph 5.74 of the plan removed as this potentially allows some market housing to be built in the open countryside. I think it would be more appropriate to replace it with adequate provision for affordable housing within the settlement development limits from the outset.

Support

Consultation Draft (February 2017)

Representation ID: 5269

Received: 03/04/2017

Respondent: Mrs Sally Skinner

Representation Summary:

Support for the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and

Full text:

In relation to the draft Local Plan, please see below my comments
1) 1) I support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and,
2) I support the removal of housing growth targets for the rural west of the District and,
3) I seek 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

Support

Consultation Draft (February 2017)

Representation ID: 5313

Received: 04/04/2017

Respondent: JK Marsden

Representation Summary:

Support for re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

Full text:

Despite the tardiness in producing the Local Plan we support :-
* Re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.
* Removal of housing growth targets for the rural west of the District.
We seek removal of Paragraph 5.74 of the plan which potentially allows some market housing to be built in the open countryside and replacing it with adequate provision for affordable housing within the settlement development limits from the outset.

Support

Consultation Draft (February 2017)

Representation ID: 5343

Received: 04/04/2017

Respondent: Paul Eastwood

Representation Summary:

Support for re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability.

Full text:

I would like to provide feedback on the Draft Local Plan that covers the Ashover area.
I am pleased that the Council has now been able to arrive at a Draft Plan for the area, the absence of which has proved central to the progress of recent proposals for completely inappropriate development within the area; an effective and robust plan is required as soon as possible to protect an area of outstanding beauty in the future.
In respect of the proposed Plan, I fully support the following elements:
1. The re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability; the limiting effect of this approach in restricting housing growth within the Parish to infill within the settlement development limits along with isolated 'windfall' development on brown-field sites in the open countryside is both welcome and appropriate.
2. The proposed removal of housing growth targets for the rural west of the District, which will assist in preventing further inappropriate development on greenfield sites.
I do not however support Para. 5.74 of the Plan which potentially allows market housing development where associated with affordable housing on 'Exception Sites'. This seems to me to provide a loophole for continued commercial exploitation of green field sites in open countryside outside the settlement development limits. A more effective alternative is to make adequate provision for affordable housing within the settlement development limits from the outset so that green field sites cannot be vulnerable to such treatment. I would strongly recommend that the Council removes Para 5.74 and takes the latter approach to ensure continued protection of rural greenfield sites.

Support

Consultation Draft (February 2017)

Representation ID: 5351

Received: 04/04/2017

Respondent: Mrs Thelma Childs

Representation Summary:

Support for the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

Full text:

I support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and support the removal of housing growth targets for the rural west of the District.

I believe that the Paragraph 5.74 should be removed from the plan which potentially allows some market housing to be built in the open countryside, and for it to be replaced with adequate provision for affordable housing within the settlement development limits from the outset.

Support

Consultation Draft (February 2017)

Representation ID: 5355

Received: 04/04/2017

Respondent: Gemma Childs

Representation Summary:

Support for the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

Full text:

I support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and support the removal of housing growth targets for the rural west of the District and.
I believe that the Paragraph 5.74 should be removed from the plan which potentially allows some market housing to be built in the open countryside, and for it to be replaced with adequate provision for affordable housing within the settlement development limits from the outset.

Support

Consultation Draft (February 2017)

Representation ID: 5379

Received: 05/04/2017

Respondent: Jill Broadhead

Representation Summary:

Support for the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

Full text:

1. I support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements and

2. I support the removal of housing growth targets for the rural west of the District and

3. Seek 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

Support

Consultation Draft (February 2017)

Representation ID: 5580

Received: 05/04/2017

Respondent: Peter Maskrey

Representation Summary:

Fully supports the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

Full text:

My comments on the consultation Draft Plan are as follows;

1. I fully support the re-categorisation of the settlements within Ashover Parish as level 3 and 4 settlements.

2. I also support the removal of housing growth targets for the rural West of the district.

3. I note that Para 5.74 of the Plan apparently retains the possibility of some market housing to be built in the open countryside. Para 5.74 should be removed in it's entirety.

4.An element of affordable housing lost by the removal of Para 5.74 could be accommodated within the settlement development limits.

Support

Consultation Draft (February 2017)

Representation ID: 5696

Received: 04/04/2017

Respondent: Mrs Jane Hardwick

Representation Summary:

Support for the re-categorisation of Ashover and Kelstage as level 3 settlements and Alton, Fallgate and Littlemoor as level 4 settlements which realistically reflect these communities.

Full text:

NEDDC Local Plane (2011-2033) Consultation Draft

I am writing to SUPPORT the Draft Plan

I support the re-categorisation of Ashover and Kelstage as level 3 settlements and Alton, Fallgate and Littlemoor as level 4 settlements which realistically reflect these communities. I support that there is "no specific housing requirements" for level 3 & 4 settlements

I support the removal of housing growth targets for the rural west of the District

I support the importance of local settlement gaps 4.70 - 4.75

My concerns are:

4.80 I am concerned that the revised settlements boundaries will be published alongside the Publication Version of the Local Plan without public consultation.

Policy SDC2 - I am concerned that there isn't enough protection for Trees, Woodland and Hedgerows. It is too easy for developers and landowners to destroy all of these without punishment. and I feel this policy should be stronger.

Overall I SUPPORT the Draft Plan and would urge the Council to progress the Plan with speed.

Support

Consultation Draft (February 2017)

Representation ID: 5986

Received: 06/04/2017

Respondent: Advance Land & Planning Limited

Representation Summary:

We note and support the identification of Holmewood as a Level 2 Settlement and we agree that such settlements should accommodate a significant proportion of the District's housing requirement, especially those settlements that are strategically well-placed and not surrounded by Green Belt, such as Holmewood.

Full text:

See attached documents.

Support

Consultation Draft (February 2017)

Representation ID: 6005

Received: 07/04/2017

Respondent: Derbyshire County Council

Representation Summary:

The definition of a Settlement Hierarchy for the District in Table 4.1 as the basis for the spatial distribution of the Local Plan's proposed housing growth set out in Policy SS3 and table 4.2, appears to be well conceived and justified and based on extensive evidence in the North Derbyshire Settlement Hierarchy Study(SHS).

Full text:

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

Member Comments

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

Officer Comments

1 Spatial Portrait

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

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

2 Vision and Objectives

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

3 Spatial Strategy

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

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

4 Housing Matters

Housing Provision Requirement

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

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

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

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

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

Settlement Hierarchy and Distribution of Development

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

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

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

Strategic Site Allocations

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

Land South of Markham Vale

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

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

Former Coalite Site

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

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

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

Other Housing Allocations

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

Affordable Housing

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

Gypsy and Traveller Issues

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

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

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

5 Green Belt

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

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

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

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

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

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

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

6 Local Settlement Gaps

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

7 Highways

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

8 Infrastructure

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

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

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

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

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

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

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

Infrastructure Delivery Plan

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

Community Infrastructure Levy (CIL)

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

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

Education Issues

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

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

9 Landscape Comments

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

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

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

10 Minerals Comments

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

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

Support

Consultation Draft (February 2017)

Representation ID: 6013

Received: 06/04/2017

Respondent: Janet E Bradley

Representation Summary:

I support the change of category of settlements with the parish of Ashover, to level 3 and level 4. (Village)

Full text:

To the Planning Policy Team.

As a resident of Ashover Parish, I wish to make the following views known about the NEDDC draft local plan.

1. I support the change of category of settlements with the parish of Ashover, to level 3 and level 4. (Village)
2. I support the removal of housing growth targets for the rural west, (which includes Ashover)
3. I want the section Paragraph 5.74 removed. This paragraph allows some housing to be built in the open countryside. I object to this. Ashover is an area of outstanding natural beauty. Building housing in open countryside is inappropriate, and will change the attraction of the settlement. I do not want NEDDC to be the cause of ruining the rural nature of its own District.
I should like this paragraph to be replaced by one which states that adequate provision of housing be within settlement limits. This should apply not just to Ashover but other settlements in the rural west as well. (Barlow, Brampton, Wessington, Walton, Holymoorside and Walton, Holmesfield). I believe this to be possible.

Support

Consultation Draft (February 2017)

Representation ID: 6201

Received: 06/04/2017

Respondent: Chris Scott

Representation Summary:

Support for Ashover settlement hierarchy change from Level 2 to Level 3 & 4.

Full text:

Ref: Draft Local Plan
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: 6350

Received: 07/05/2017

Respondent: Mr Martin Speed

Agent: WYG (Harrogate office)

Representation Summary:

Table 4.1

The identification of Shirland as a Level 2 settlement is supported.

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6458

Received: 07/05/2017

Respondent: Mr Paul Johnson

Representation Summary:

Statement that the reliance on the existing scale of a settlement and the increasingly transient levels of local services in the Settlement Hierarchy Study, will always suggest that new development should be focused towards locations such as Killamarsh. Objection to the four main towns not being properly assessed in the Settlement Hierarchy Study.

Full text:

NEDDC Consultation Draft Local Plan (the Plan).

Comments and Objections.


General Comments.

My comments relate predominantly, almost exclusively, to the proposals contained within the Plan for the village of Killamarsh.

I strongly object to the proposed allocations in respect of the 330 dwellings proposed to be built at Westthorpe Fields, and the 100 proposed for the site to the rear and side of Manor Road, based upon a series of legitimate and material planning impacts which the proposals would lead to and which could not practically, or appropriately be mitigated against. I also have serious reservations about all the sites allocated to Killamarsh, based purely on their extraction from the Green Belt, and their significant, adverse effect on the currently inadequate infrastructure of the village.

I consider that the proposed allocation(s) to the south of Killamarsh run contrary to the principles for Sustainable Development embedded within the National Planning Policy Framework (NPPF), and to the proposed policies and principles within the Plan itself. I consider the draft allocations therefore present an inherently contradictory thread within the emerging Plan as a whole.

The principle policy of the plan, SS1 - Sustainable Development, sets out the underpinning principles to be applied to development proposals across the district. These include:

* The prioritisation of brownfield land for development;
* The location of development with the aim of reducing the need to travel and contributing to the improvement of sustainable transport;
* The protection and enhancement of the character, quality and settings of towns, villages and heritage assets;
* The protection, creation and / or enhancement of the character, quality and diversity of the District's green infrastructure and local landscapes, the wider countryside and ecological and biodiversity assets; and
* A commitment to play a positive role in adapting to and mitigating the effects of climate change, including .......to contribute to the health and well-being of communities and the environment through the location, design and operation of development.

It is strongly suggested that the proposed development of 330 new dwellings at Westthorpe Fields, the 100 off Manor Road and the 70 at Norwood (off Rotherham Road) in Killamarsh would not reflect these core principles of sustainability as part of the spatial policy for North East Derbyshire. These are addressed in more detail within this representation.

Spatial Strategy

The consultation draft Local Plan sets out Spatial Strategy at policy SS2 and SS3. This indicates the volume and proposed location of new growth in terms of housing development, allegedly reflecting objectively assessed need, viability and demand. However, there is little reference to the justification for this strategy within the Plan apart from a common approach of focusing development proportionately to the scale of the existing settlement hierarchy. Consequently the plan seeks to allocate 618 new dwellings around Killamarsh over the plan period.

Whilst the general principle can be seen to reflect past practice, I do not consider the approach has properly reflected the general capacity of the village to accommodate such levels of additional growth. Reliance on the existing scale of a settlement and the increasingly transient levels of local services, using this principle, will always suggest that new development should be focused towards locations such as Killamarsh. However, in doing so, important and up-to-date problems of capacity can be, and have been, underestimated. They take no apparent account of the historical and significant development in Killamarsh during the 20th century. This is a major issue when coupled with the failure to respond to this massive growth with proportionate and necessary infrastructure enhancement.

The Settlement Hierarchy Study 2016 recognises the historic focus of development across the district's four principle settlements (including Killamarsh) and in doing so accepts, without examination of the consequences of that growth, that this supports and recognises the concept as a viable and established spatial strategy approach.

This has resulted in the 4 towns being ignored, or accepted as having infinite capacity, within this important study of current capacity and function. This has, apparently, contributed to the 'underplaying' of the town's capacity to absorb development at a strategic level. Desk-top studies and drive-through visits to Killamarsh cannot be substituted for rational or detailed analysis. The submission of my wife, who was born in Killamarsh and has a long family association with the village, makes a number of apposite points about the adequacy of local services and the over-reliance on takeaways and beauty salons. I fully support those points.

Many aspects of infrastructure development are outside the purview of NEDDC, being the responsibility of Derbyshire County Council (DCC, for roads, schools, etc.), the NHS and, more likely, private business people. All of these groups would be expected to build or fund ongoing projects. It is stated within the plan that such funding would emanate from developer contributions or national funding pots, joining a host of other organisations bidding for similar funding.

The DCC Infrastructure Plan only has plans to develop the A61/A617 corridor, which has no alleviating benefit for Killamarsh.

Primarily my concerns, and those of RAGE supporters, relate to the adverse effect that the current iteration of the Plan will have on Killamarsh's townscape, landscape, public amenity and general setting, together with its ability to accommodate such growth sustainably.

However, there are also considerable current issues of capacity within Killamarsh relating to existing problems of congestion, bottlenecks on key transport corridors to Sheffield, resultant air quality problems and the levels of community services, including schools (or their absence). The evolution of the M1 motorway to four lanes, the building of a biomass plant, burning waste (treated) wood, with all the pollutant concerns about such plants, by the Sheffield City Council, and the development of the massive Gulliver's Valley leisure site will all impinge negatively on air quality and health. The addition of 618 homes, with vehicles, can only worsen the current situation. The latest proposed route of HS2 and the potential for fracking operations within the village will not improve matters.

Killamarsh, as you are aware, is located at the north east corner of North East Derbyshire, creating additional problems in relation to the building plans of neighbouring authorities. Literally thousands of homes are planned by these other authorities very close to the border with NE Derbyshire and Killamarsh.

These concerns are generally recognised within the 2017 Sustainability Appraisal of the Plan at section 3.8. which indicates that, overall, the sustainability 'performance'of the principle Westthorpe site is not strong, apart from the perception of its ability to deliver housing.

Given the constrained context of the town, its historic growth beyond the capacity of local services (currently in decline, not growth), and its landscape and physical context, it is considered that the focus on Killamarsh for high levels of growth are not well justified or sustainable and do not present the exceptional circumstances in which re-alignment of the Green Belt can be justified.

Furthermore, identification of LC1(p) has partly emerged from the 'detailed' site assessment within the 2017 Housing Sites Assessment evidence report. A number of the criteria assessed within this work in relation to the site-specific suitability of LC1(p) do not mirror our local interpretation of the character, condition or value of the site, for example in relation to Green Infrastructure, the significance of local rights of way and the ability to mitigate harm in the context of 330 houses on its locally significant biodiversity and treescape/hedgerows. These are addressed in the following parts of this objection.

Principle of the Allocation within the Green Belt

The National Planning Policy Framework (NPPF) sets out clear and unequivocal statements at paragraphs 79 and 83 which reiterate both the function and underpinning permanence of Green Belts, such that 'once established, Green Belt boundaries should only be altered in exceptional circumstances....'. Paragraph 4.62 of the Consultation Local Plan itself recognises this. This should be the clear and robust starting point for the spatial strategy of the plan, and examination of the relative functional merits of the Green Belt in North East Derbyshire does not in itself undermine this position.

It is clear from the evidence base reports into Green Belt functionality in the district that all areas continue to provide important functionality. The designation of Green Belts historically has not required all the various functions of Green Belts (previously PPG2 and now NPPF) to justify designation, only one is sufficient for designation to be justified.

Whilst I and RAGE supporters strongly maintain our objection to the principle of Green Belt release based upon the capacity at a general level for strategic growth around Killamarsh, we are also specifically concerned that the 2017 Green Belt evidence base work appears to have directly influenced the draft plan's allocations. Unfortunately, it has not been robustly tested in relation to its specific site-impact implications and local level effects before being embedded within draft proposals.

It is of some concern to us that the 2017 Nathaniel Lichfield and Partners Report (NLPR), 'North East Derbyshire Green Belt Review' is dated 'February 2017' (and is very extensive in its content, assessing 457 potential sites), yet the draft Local Plan was published as soon afterwards as 24th February. It would seem almost impossible that thorough examination of all of the report's findings could have been properly tested and compared in this period, suggesting the study's findings have been adopted in undue haste, or had already been decided whatever contrary evidence might be produced.

We trust that this consultation response will be afforded the proper time and consideration to inform the council's more timely review of the specific implications and effects created by these allocations, following the consultation period.

It is apparent that this multi-staged, systematic process of assessing Green Belt functionality has heavily influenced the council's decision to identify land at Westthorpe, Killamarsh for 330 dwellings (allocation LC1(k)) in the consultation plan, although the NLPR identifies capacity for 'only' 235 units (table 4.9, GB Review Part 2). It is acknowledged that if delivery of a sound spatial strategy clearly requires Green Belt release to occur (which we do not agree), then undertaking such a process would be a logical action. However, there are a number of study findings which appear to have led to prioritisation of this site over others because of the unadjusted interpretation of certain parts of the evidence base which I, and other RAGE supporters, believe are inaccurate reflections of the site's characteristics.

The site has been provisionally allocated within the Local Plan despite the evidence base report suggesting the site continues to perform an important Green Belt function (see introductory comments above).

The NLPR 2017 clearly identifies parcel KIL/GB/025 (LC1(p)) as having an initial overall score of Red (subsequently adjusted to Amber), i.e. that good Green Belt functionality is still exhibited by the land. However, in presenting this overall score on the functionality of this land parcel the following shortcomings are highlighted which erroneously result in a relatively lower overall 'performance' than other assessed sites, addressed as follows:

* Purpose 1a (Urban Containment).The NLPR assessment infers through the scoring schedule that the site is enclosed by the built limits of Killamarsh, effectively between 50% and 75%, and stating that 'The parcel is well contained on the northern/eastern/western boundaries by existing residential developments.' An 'Amber' score is therefore attributed.

This assessment is not robust. Only by cartographic/aerial perspective can the site be believed to be partially 'enclosed' to such a degree as stated. The reality is that visual and perceptual 'enclosure' of the site by the urban limits of Killamarsh is far less pronounced in actuality than this assessment suggests.

A number of reasons lead to this rejection of the study assessment. A walk-over survey of the site, and examination of views into it from south of Killamarsh, show that the degree of enclosure is significantly less/reduced as a consequence of the pronounced topography of the site in relation to its surrounding areas. The northernmost elements of the site generally occupy slightly more level ground, but across most of the site it falls away markedly to the south and the south-west. Across the allocation is a significant elevation difference of 35 metres, and very pronounced change in relief. The landform is effectively a prominent and exposed arcing slope, leading to a increasingly steep fall in relief immediately beyond the site boundary, which results in it being primarily viewed and experienced (from within) as clearly outside the visual influence of the existing edge of Killamarsh.

To the eastern site boundary Upperthorpe Road is partly sunken and bounded by thick established hedges to both sides of the road. In combination these serve to create a good degree of separation from the (already outlying to Killamarsh) housing on Fanny Avenue east of the main road. The 6 dwellings to the west of Upperthorpe Road (effectively abutting the site) are perceived as outlying to the main body of the town (which more accurately can be delineated at Manor Farm and by the open space north of Briars Close).

To the western site boundary the site also has a weak visual relationship with the built up elements of Killamarsh, despite its cartographic relationship. This again is due to pronounced changes in topography and strong vegetation cover along the roadside fringes of Green Lane. This route into the town descends into a pronounced and enclosed dip in the landscape, such that the visual influence of the town is highly limited. Westthorpe Fields Business Park (sited across the former colliery site) stands west of the lane but is sited across significantly lower-lying land than most of LC1(p). Land within the proposed allocation rises steeply to the east and north-east with the combined effect that the site bears little relationship to this element of the town.

The northern boundary of the allocation is located adjacent to the clear built limits of Killamarsh, but even this belies the weak visual inter-relationship between the site and the town. Most of the boundary is currently characterised by established tree-belt and paddock, with the built influence of the town not a dominant influence over significant elements of northern reaches of the site.

Another consideration in relation to the 'urban containment' character of the Green Belt is the screening influence the topography of the site has on the wider visual influence of Killamarsh as a whole to its southern boundary.

At present the pronounced convex slope profile and more level northern parts of the allocation serve to significantly screen Killamarsh from longer views from the south, and particularly from the dense network of Public Rights of Way and open access land to the immediate south of the town. The visual consequence of this is that in approaches to the town, from even relatively close distance, Killamarsh's southern edge remains well concealed by topography and tree cover, with 'hints' of roofscapes across its southern limits rather than a clear prominence of the large town beyond.

The historic growth of Killamarsh as extended from its core in a southerly direction and this growth has gradually increased in elevation, particularly along High Street. Therefore, development of the site would serve to significantly increase the actual and visual/perceptual extension of the wider settlement into open countryside beyond what has become a topographical limit to growth, which has served historically to significantly limit its visual prominence in the landscape of North East Derbyshire from the south.

The allocation would clearly and significantly breach this natural limit to the town and bring its visual influence over a large new extent.

In combination the degree to which the urban framework of Killamarsh encloses the draft allocation is significantly over-emphasised by the NLPR, and it should not be seen as 'infilling' of an indentation of settlement boundary. Therefore, the site should more accurately afforded a RED score when comparing this with other potential sites for Green Belt release around the town.

Although not to the same extent as the proposed Westthorpe Fields site, the additional locations off Manor Road and Rotherham Road will be given undue prominence when viewed across the valleys bordering High Moor and Wales Village respectively.

* Green Belt Purpose 2 - To prevent neighbouring towns from merging into one another. The overall score afforded to this function is Amber yet the core question at 2a 'The width of the strategic open gap between urban areas' is afforded a RED score. It stands (because of the scores afforded at 2b) that this difference is due to the adjustment influence of assessment at 2c 'Is the parcel substantially covered by more than 50% of built development?' It is questioned why the value afforded to this score is Amber when the degree of built development within the site is limited to a single stable block within a wider area of almost 16 hectares? This scoring consequently serves to disproportionately skew the overall scoring and ranking of the site in relation to other potential allocations within the Green Belt. Whether accidental or deliberate, this apparent inconsistency inaccurately reflects the reality.

Notwithstanding this detailed analysis of the scoring schedule, it is very evident from site examination that development across the site would substantially diminish the visual perception of the strategic gap between Spinkhill and Killamarsh, primarily because the nearest existing parts of the village to Spinkhill (Westthorpe Fields Business Park) occupies the sunken area (comparatively) along Green Lane, and is therefore not visually associated with the separation between the two settlements.

Hence it is strongly contended that the actual Green Belt functionality of the main site is demonstrably greater than the assessment presented by the NLP report. In practice it is contended that the site performs as highly as many other settlement-edge parcels around Killamarsh that have been safeguarded because of RED assessment scores in favour of the apparently lower performance of LC1(p). It is suggested that the score for this site, based upon the more focused application of NLPR method, should also be RED. Moreover, the following points also illustrate that the site is a less sustainable option than elsewhere (particularly to the central/eastern flank of the town) where sites have been dismissed on Green Belt function grounds alone.

Green Infrastructure, Landscape Character and Public Access

The NPPF Core Planning Principles require that plan-making should:

'take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it'.

These important national planning policy objectives appear to have been under-valued through the draft allocation of LC1(p). Whilst Green Belt protection has been addressed above, issues of intrinsic countryside value and the role it can play in supporting healthy, attractive and sustainable communities are considered in the following paragraphs.

The land across which LC1(p) lies and the wider environment of its adjoining adjacent areas presents an important and valued element of Green Infrastructure, i.e. land where combinations of landscape, habitats, natural processes, accessibility and opportunity for enjoyment together offer value to local people greater than the sum of its parts, and present important sustainability functions.

Whilst the area of open farmland within LC1(p) is not a designated landscape, it has significant intrinsic countryside value as a consequence of its elevation, aspect, mature hedgerow and tree cover and absence of incongruous features. It is of considerable local value in the context of its wider setting, and the opportunities it presents for sustainable public access as a consequence of its extensive Public Rights of Way (PRoW) network. The site is highly prominent in a wider landscape context from longer views from the south and west in particular. Development across the site would be highly prominent.

It is also clearly apparent that the site presents perhaps the most important landscape aspect to Killamarsh and offers the most intact and immediate opportunity for enjoyment of the countryside. This would apply even more when linked to the 'Killamarsh 2035' plan to locate a Green Corridor leading to this location. This is likely to be a part consequence of the longer-term influence of the Green Belt on the wider setting of the site.

Views out from the LC1(p) are expansive and offer attractive outlooks over markedly rolling farmland, with a mosaic of hedgerows, fields, small ponds and pocket woodlands which are characteristic of the Wooded Farmlands Landscape character type of the Derbyshire Landscape Character Assessment (DLCA). The DLCA summarises this landscape type as 'A small scale undulating landscape rising to the magnesian limestone plateau. Characteristically well-wooded, sparsely settled and dominated by mixed farming.' Marked changes in elevation allow longer vistas and attractive uncluttered skylines towards the Magnesian Limestone Plateau to the south, mostly free from incongruous structures.

The site offers an accessible sense of relative tranquillity. Such opportunities are made immediately accessible because of the significant PRoW and permissive paths network leading to and from the urban edge of Killamarsh, which then link into the 'Westthorpe Hills' network of paths and restored mixed habitats. It is evident from a site visit, rather than a desk-top study, or information from those with a financial vested interest, that this network is well used and valued by local residents.

Such views and opportunities are a marked contrast to the visual context of most other settlement edge areas for Killamarsh where the almost continuous heavily-developed, semi-industrial landscapes of Sheffield's south-eastern townships deny opportunity for any sense of countryside or tranquillity to be enjoyed. This will be worsened by the impact of the 745 dwellings intended to be built on Sheffield's suburban townships, almost up to the boundary with NE Derbyshire.

The existence of Rother Valley Country Park to the north of Killamarsh may be an important sub-regional recreational resource, but is not a convenient or accessible space for the large residential population of most of southern Killamarsh, and particularly not on foot. Nor does it provide a 'traditional' or historic rural landscape experience.

Natural England's 'Accessible Natural Green Space Standard' (ANGSt) provides a set of benchmarks for ensuring access to green space in proximity to urban populations. This suggests that an accessible Natural Green Space of at least 2ha in size should not be more than 300m (5 minutes walk) from home for all people and that at least 1 accessible 20ha site should lie within 2km of home. The allocation of LC1(p) to 330 dwellings would seriously undermine the ability of significant parts of Killamarsh's community to meet this objective by loss of such important and valued open spaces.

The draft Local Plan presents a very positive policy approach to protecting existing Green Infrastructure at Policy ID1, and it stands that identification of site allocations should adopt the same expectations and protective principles. By the allocation of LC1(p) those principles of identifying and protecting Green Infrastructure would not be followed. The council's own Green Infrastructure Study (2012) which forms part of the Local Plan evidence base specifically recognises green space deficit in the Killamarsh area and proposes that Local Plan Policy should recognise and accept that:

'The role of the local landscape needs to be considered so that the landscape surrounding the 4 main towns of Dronfield, Eckington, Killamarsh and Clay Cross is protected, which will maintain the rural "setting" of these settlements'.

Hence, these multi-functional intrinsic characteristics of the Westthorpe Fields site should not be under-valued, and should not be viewed as less significant in driving housing site identification than Green Belt functionality taken purely in isolation. Indeed, whilst the NLP correctly identifies high Green Belt functionality in respect of protection of the countryside from encroachment, the draft Local Plan does not recognised these additional characteristics over and above less remarkable countryside on the edge of Killamarsh and elsewhere.

The open space at Westthorpe, with its immediate countryside links, are of significant community value and their loss would have real adverse consequences for sustainable countryside access, landscape impact and historic settlement form, consequently breaching the principles set out in the NPPF.

Wider Site Sustainability Issues

The main access and egress routes to and from Killamarsh are currently inadequate for the amount of traffic using them. Each of the three routes (Sheffield Road/Mansfield Road, Rotherham Road and Spinkhill Road) have historic issues that militate against attempts to 'tinker' with them in order to aid traffic flow.

The historic problems are not likely to be resolved by developer contributions which effectively only relate to site-specific matters. This might mean widening an exit point from a development location, but would not mean, for example, replacing the road and river bridges on the outskirts of Killamarsh.

Rotherham Road is currently subject to significant traffic surges in the spring and summer, caused by queuing to gain access to the Rother Valley Country Park. This will be exacerbated when the new Gulliver's Valley site is operational.

Spinkhill Road is now a 'rat run' from the M1 motorway with massive heavy goods vehicles being directed along it by satellite navigation devices. The road here has no footpaths, is used by horses and cyclists, walkers and many other vehicles at peak times.

Many of the roads from the outlying areas of Killamarsh are virtually one-way when the occupants of houses are at home, due to the historic lack of garages or parking spaces. On-street parking is the norm. Public parking spaces in and around the village centre are at a premium, with the main parking areas being privately owned or controlled.

Into this unhealthy 'mix' the local plan wants to add 618 homes, about 2,500 people and 1,200 more vehicles.

Paragraph 34 of the NPPF states that:

'Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. ....'

Paragraph 38 of the NPPF states that where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within reasonable walking distance of most properties.

The Chartered Institution of Highways and Transportation published 'Planning For Walking' (April 2015), which was intended to encourage sustainable short distance trips by foot. It states at section 6.3 'Land use planning for pedestrians':

Most people will only walk if their destination is less than a mile away. Land use patterns most conducive to walking are thus mixed in use and resemble patchworks of "walkable neighbourhoods," with a typical catchment of around 800 m or 10 minutes' walk). The DETR publication Encouraging walking (DETR, 2000) says: Land use planning is the most important long-­‐term solution to both our strategic and practical transport needs. Integrated planning reduces the need for travel and makes jobs and services more easily accessible to all. We cannot emphasise enough the importance of this aim for planners. We need to change the way we plan and put greater emphasis on enabling access by walking, as well as cycling and public transport.

Paragraph 4.4.1 of Department of Transport Manual for Streets (2007) states:

'Walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes' (up to about 800 m) walking distance of residential areas which residents may access comfortably on foot...'

The spatial characteristics of the proposed allocation would also suggest that this is not a sustainable location in relation to sustainable movement / travel and the discouragement of short motorised trip generation. Development of the site would result in a significant resident population located at distances from essential community services that would not be conducive to walking or cycling, having regard to nationally established best practice. It can be seen that distances from within the site (particularly the southern periphery of it) would result in walking distances to the local St Giles Primary School of approaching 2 km (although internal site layout would partly influence this). Moreover, distances to the closest (state) secondary school would be over 5 km from the site. Access to the main high street shops and community services would be between 1.8 and 2.1 km. These distances are clearly well beyond the distances whereby many people would choose to use a car rather than walk, and actually reflect that the residential growth of Killamarsh to the south has reached distances from the town centre whereby further growth would be highly likely to generate considerable and unsustainable short motorised trips.

Of course these guidelines reflect the behaviour of able-bodied people. Further consideration should be afforded to both the need to make services accessible on foot to an ageing population (which describes Killamarsh) and those with young children. When taking into account the considerable slopes within LC1(p) and those (for example southwards along High Street) such distances become even more likely to result in motorised trips being taken rather than walking. Appeal decisions elsewhere in Derbyshire (e.g. APP/P1045/W/15/3132330) have confirmed that hilly routes have been held to decrease the likelihood of walking to access daily service, even over distances of less than 1km.

It is a fact that virtually any vacant space within the settlement limits of Killamarsh has now been built upon, hence the need for a Green Belt review to provide further available space. This means that any additional development will face similar sustainability issues, unless a major infrastructure development effort takes place on the periphery of Killamarsh. This will still leave the road network as totally unfit for need. Only major road expansion can solve this problem but, unfortunately, the 'cure' for this would mean existing dwelling demolition and transportation chaos for a decade.

It is likely therefore that the development of LC1(p) would appreciably add to unsustainable, polluting and congestion causing car journeys in and across Killamarsh, contrary to NPPF objectives and exacerbating already significant problems in the town.

All the main locations within the Plan will add to this unsustainability by their very presence (through the pollution from vehicles that will follow building construction) but the locations at Rotherham Road, Green Lane and Manor Road, being reasonably proximate to each other, will have the most significant impact.

Summary

For the reasons detailed within this statement, I and supporters of RAGE strongly object to the proposals for growth in Killamarsh, with particular emphasis on those sites to the south and east, within the Draft Local Plan 2017. They would represent unsustainable form and scale of development and compromise a range of material planning aspirations.

Justification of Green Belt release has been over emphasised because of the under-playing of the specific character, condition and prominence of the main site at Westthorpe Fields and the important roll it plays in settlement identity and countryside protection.

We therefore request that the allocation LC1(p) be removed from the plan's site allocations prior to the submission draft being finalised, and that the other sites be considered for removal due to the overwhelmingly negative impact they will have on the existing population of Killamarsh.

Support

Consultation Draft (February 2017)

Representation ID: 6466

Received: 07/04/2017

Respondent: Mrs Anne Eastwood

Representation Summary:

Support for the re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability; the limiting effect of this approach in restricting housing growth within the Parish to infill within the settlement development limits along with isolated 'windfall' development on brown-field sites in the open countryside is both welcome and appropriate.

Full text:

Please accept this as feedback on the Draft Local Plan that covers the Ashover area.
It is great that the Council has now finally been able to arrive at a Draft Plan for our area, the absence of which has allowed for the approval of completely inappropriate development within the area. A strong and effective plan is required immediately so that this special area is protected for future generations, both for landscape and food production reasons.
In respect of the proposed Plan, I fully support the following elements:
1. The re-categorisation of Ashover and Kelstedge as level 3 settlements with only limited sustainability, and Alton, Fallgate and Littlemoor as level 4 settlements with very little sustainability; the limiting effect of this approach in restricting housing growth within the Parish to infill within the settlement development limits along with isolated 'windfall' development on brown-field sites in the open countryside is both welcome and appropriate.
2. The proposed removal of housing growth targets for the rural west of the District, which will assist in preventing further inappropriate development on greenfield sites.
I do not however support Para. 5.74 of the Plan which potentially allows market housing development where associated with affordable housing on 'Exception Sites'. This seems to me to provide a loophole for continued commercial exploitation of green field sites in open countryside outside the settlement development limits. A more effective alternative is to make adequate provision for affordable housing within the settlement development limits from the outset so that green field sites cannot be vulnerable to such treatment. I would strongly recommend that the Council removes Para 5.74 and takes the latter approach to ensure continued protection of rural greenfield sites.

Comment

Consultation Draft (February 2017)

Representation ID: 6547

Received: 07/04/2017

Respondent: Harworth Group

Agent: Urbana Town Planning

Representation Summary:

Harworth Estates challenges the 'ranking' of Killamarsh as a Level 1b 'Secondary Town' within the Settlement Hierarchy because no justification is offered as to why the four primary settlements are split into 'principal' and 'secondary' sub-level brackets. Instead, Killamarsh should be considered as 'Principal Town' for the purposes of the direction of growth and housing provision.

Full text:

See attachment

Support

Consultation Draft (February 2017)

Representation ID: 6638

Received: 07/04/2017

Respondent: Wheeldon Brothers Ltd

Agent: Planning and Design Group

Representation Summary:

Wheeldon Brothers Ltd supports the identification of Shirland as a Level 2 Settlement with good levels of sustainability.

Full text:

See attachments

Support

Consultation Draft (February 2017)

Representation ID: 6661

Received: 07/04/2017

Respondent: Chatsworth Settlement Trustees

Agent: Planning and Design Group

Representation Summary:

Table 4.1 Settlement Hierarchy: support for the identification of Heath as a Level
3 Settlement

Full text:

See Attached. Cover letter/Summary and Full reps.

Support

Consultation Draft (February 2017)

Representation ID: 6713

Received: 07/04/2017

Respondent: Harron Homes Ltd.

Agent: ID Planning

Representation Summary:

Harron Homes broadly supports the proposed settlement hierarchy which identifies the settlements of Morton and North Wingfield as Level 2 settlements.

Full text:

See attachment