Green Belt Review

Showing comments and forms 1 to 30 of 34

Object

Consultation Draft (February 2017)

Representation ID: 4606

Received: 07/03/2017

Respondent: Mr Edward Throp

Representation Summary:

Proposed regions of green belt provide an important barrier too excessive growth of the urban environment. In particular the hollowes golf course and the paths around it provide important green areas where existing residents excersize, walk dogs etc. Current infrastructure (road network) is not adequate to support such significant developments.

Full text:

Proposed regions of green belt provide an important barrier too excessive growth of the urban environment. In particular the hollowes golf course and the paths around it provide important green areas where existing residents excersize, walk dogs etc. Current infrastructure (road network) is not adequate to support such significant developments.

Object

Consultation Draft (February 2017)

Representation ID: 4698

Received: 14/03/2017

Respondent: Mrs Anna Lomas

Representation Summary:

The green belt should remain as green belt.

Full text:

The green belt should remain as green belt.

Comment

Consultation Draft (February 2017)

Representation ID: 4737

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

These points would seem to be the justification for removing land from the Green Belt. However housing need cannot be cited as the exceptional circumstances necessary to remove land from the Green Belt. Suggestions made that housing should go on brownfield sites. Little opportunity identified for potential creation of local employment.

Full text:


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

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

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

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

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

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

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

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


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

"Callywhite Lane This is a long-standing allocation from the 2005 Adopted Plan, the northern end of which has been partly developed. Despite lack of progress on this site it represents an important extension to a valuable industrial area in the North Sub-Area. Issues over access in particular need to be resolved but there is a likelihood that with the anticipated electrification of the East Midlands Main Line and (in the longer term) HS2, such issues will be resolved." For anybody who knows Callywhite Lane in Dronfield, its location and its association with heavy industry this statement in the local plan is just ridiculous. This council recognises a lack of progress on the site. Making a statement about electrification and HS2 resolving issues associated with Callywhite Lane is beyond belief. Neither of these schemes will have any effect on Callywhite Lane.



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


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

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


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


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

Object

Consultation Draft (February 2017)

Representation ID: 4741

Received: 14/03/2017

Respondent: Mrs Jane Singleton

Representation Summary:

Objection to the release of parcels of green belt land around Dronfield.

Full text:


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

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

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

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

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

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

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

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


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

"Callywhite Lane This is a long-standing allocation from the 2005 Adopted Plan, the northern end of which has been partly developed. Despite lack of progress on this site it represents an important extension to a valuable industrial area in the North Sub-Area. Issues over access in particular need to be resolved but there is a likelihood that with the anticipated electrification of the East Midlands Main Line and (in the longer term) HS2, such issues will be resolved." For anybody who knows Callywhite Lane in Dronfield, its location and its association with heavy industry this statement in the local plan is just ridiculous. This council recognises a lack of progress on the site. Making a statement about electrification and HS2 resolving issues associated with Callywhite Lane is beyond belief. Neither of these schemes will have any effect on Callywhite Lane.



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


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

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


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


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

Object

Consultation Draft (February 2017)

Representation ID: 4858

Received: 19/03/2017

Respondent: Mrs Elizabeth Ann Boardman

Representation Summary:

Objection to the proposed release of land from the green belt. Concerns over the impact the release might have on people's health and wildlife.

Full text:

I implore you not to remove ANY land from the green belt. Keeping it is absolutely essential for our quality of life.
It has been proved that exercise in the fresh air is more beneficial to health than going to a gym. It promotes well-being, improves mental health by reducing stress & anxiety. People with chest problems need breathing space in unpolluted air. Many local dog-walkers exercise in green-belt areas, away from traffic fumes. Without open spaces locally they will take their dogs some distance by car to suitable places, causing more pollution. Many parks insist on dogs being on a lead. Both people & dogs NEED the green belt.
Wild life also needs the green belt, without it many species will not live.
Please save it before it is too late - when it's gone it's gone forever.

( - )

Please do not remove ANY land from the greenbelt. It is vital for the quality of life & well-being of all residents.
This includes wildlife, there are some endangered species here.
LATEST NEWS: Recently hares have been seen regularly on greenbelt behind lower Shakespeare Crescent & Burns Drive.
This is very unusual in such an area. Will they ever be seen by our children if the greenbelt is lost? I don't think so!

Object

Consultation Draft (February 2017)

Representation ID: 4957

Received: 24/03/2017

Respondent: Mr Mark Wilkinson

Representation Summary:

Greenbelt land is supposed to stay green and not be built on. Greenbelt land is important to be kept as it is in order to separate the towns and villages. It also is important for wildlife. Studies have also shown that green areas are good for the health and wellbeing of people. By taking that away you will create more pressure on the NHS.

Full text:

Greenbelt land is supposed to stay green and not be built on. Greenbelt land is important to be kept as it is in order to separate the towns and villages. It also is important for wildlife. Studies have also shown that green areas are good for the health and wellbeing of people. By taking that away you will create more pressure on the NHS.

Object

Consultation Draft (February 2017)

Representation ID: 5042

Received: 29/03/2017

Respondent: David McCall

Representation Summary:

Objection to the proposed release of greenbelt land in the north of the District. Concern raised over potential urban sprawl that this proposed release could lead to.

Full text:

I wish to make the strongest possible objection to the proposals outlined in the local plan to develop a number of housing sites on green belt land.
The effect of continually eroding this valuable space will eventually lead to one massive urban conurbation stretching from north of Sheffield to south of Chesterfield.
Local identity is very important and if we don't stop the destruction of our green belt now, we will soon be residing in Greater Sheffield which will be a great detriment to all NE Derbyshire residents.

Object

Consultation Draft (February 2017)

Representation ID: 5078

Received: 30/03/2017

Respondent: Mrs Helena Gayle Boulton

Representation Summary:

Exceptional circumstances have not been evidenced in this plan. There are brownfield sites available for redevelopment in Dronfield and across the region. The areas identified in Dronfield DO provide a valid Green Belt function - for recreation, wildlife and inhibiting urban sprawl.

Full text:

Exceptional circumstances have not been evidenced in this plan. There are brownfield sites available for redevelopment in Dronfield and across the region. The areas identified in Dronfield DO provide a valid Green Belt function - for recreation, wildlife and inhibiting urban sprawl.

Object

Consultation Draft (February 2017)

Representation ID: 5222

Received: 03/04/2017

Respondent: Mr Eric Singleton

Representation Summary:

4.64 is nonsense. A review does not "provide exceptional circumstances". Exceptional circumstances either exist or they do not. This statement is overt evidence of the council's flawed logic in proposing land be removed from the Green Belt. This plan does not make the case that there are exceptional circumstances. Comment that the planned 860 dwellings in Dronfield is unsustainable. Statement that land at Shakespeare crescent does perform a green belt function.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.5 Policy SS1, Sustainable Development, clauses c and g

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Consultation Draft (February 2017)

Representation ID: 5252

Received: 03/04/2017

Respondent: Mr Andrew Goodwin

Representation Summary:

My objection centres around the removal of the Green Belt land surrounding Dronfield.

Full text:

My objection centres around the removal of the Green Belt land surrounding Dronfield.

Object

Consultation Draft (February 2017)

Representation ID: 5258

Received: 04/04/2017

Respondent: Mr & Mrs Anthony Stephen Jackson

Representation Summary:

1. The review of the Green Belt was unnecessary.
2. The Council failed to adopt other alternatives
3.The Council failed to identify any Special Circumstances to alter the status of any Green Belt land.
4. The Council, contrary to Government requirements, fails to take account of Dronfield's residents' wishes preferring to support the lobbying of development companies.

Full text:

The review of the Green Belt should not have been undertaken. The growth could have been attained had the Council adopted other solutions. These are:
1. The identification of ALL Brown Field sites and insisting that they should be fully utilised.
2. The number of vacant properties almost equals the required growth yet the Council has chosen not to utilise them.
The Council's justification to invoke Special Circumstances is purely arbitrary. No valid reason has been identified.
The Council has ignored the effect on Dronfield's infrastructure that the removal of Green Belt land and the subsequent development will have on it. It pays scant regard to Traffic congestion, schooling, doctors facilities, and destruction of wildlife habitat.
There appears to be some hidden reason why the Council has chosen such a high proportion of Green Belt land to have its status removed. If so the Council should under the requirements of the Freedom of Information Act, make these reasons known

Object

Consultation Draft (February 2017)

Representation ID: 5292

Received: 31/03/2017

Respondent: Mr and Mrs Andrew and Angela Spencer

Representation Summary:

The full representation makes detailed comparisons between sites, and points out errors, inaccuracies and inconsistencies in the Green Belt Review, relating to the drawing of the Green Belt boundary and the scoring of parcels as having a weak or strong boundary.

The representation sets out that the following two areas of land would be suitable for future residential development - one area of parcel WAL/GB/013, and all of WAL/GB/014, stating it would have little or no impact on Urban sprawl, has strong defensible boundaries, with well-contained residential properties and not reducing the width of the gap between built up areas.

Full text:

We are responding to the invitation to comment and are making representation to the North East Derbyshire Green Belt Review. We have studied the review and would like to bring to your attention a number of identified errors, inaccuracies and inconsistencies in the review of the Green Belt in the area. This has led to us being able to identify two areas of land that would be suitable for future development of residential homes, to meet the government and local targets, that would have otherwise have been missed. Providing housing on the proposed site would have no significant impact to local open countryside, other than a couple of neighbours, loosing a small portion of their outlook, and no effect on Urban sprawl, as it would be infill between existing residential properties to the East, North and West and a Golf course to the South, all of which form defensible boundaries, and not reduce the Strategic Urban Gap.

The most obvious inconsistency, when reviewing the document and comparing the area maps and the marking of the boundaries of the Green Belt, is where the boundaries between Green belt and built up areas have been drawn.
On all but one of the maps, in Appendix 1 Green Belt Parcel Assessment -Map Insets, the boundary is drawn across the rear of the properties, and not along the road at the front of the properties.
However, on the Walton and Wingerworth NW map it shows the A632 at the front of the properties as the boundary. This cannot be considered a boundary, when development has already occurred to the South side of the road. This does not follow the rationale of the rest of the review and is an obvious error on the studied map. It is makes sense why the road at the front of properties has not been used as a boundary of the development on all the other area maps.
Evidenced by, comparing as an example, the maps of Unstone Crow Lane & Unstone Green, Old Brampton, the previous two maps in Appendix one, with the Walton and Wingerworth NW map. To further highlight, the error can be seen within the Walton and Wingerworth NW Map, by comparing the boundary line around Wingerworth that follows the convention of the other maps, but not to the South side of the Matlock Road at Walton.

In other parts of the review, inconsistencies and inaccuracies, have led to erroneous results on the Scoring of the designated parcels.
This can be evidenced in Appendix 7 WAL/GB/013, by the fact that in this particular parcel, 6 separate areas of land of different usage (see attached Site plan A1 Areas marked A-D), namely; residential garden, equestrian paddocks and agricultural fields have been grouped together into the one Parcel.
By grouping these areas together within the parcel it does not lead to accurate and realistic scorings. Additionally, the area marked as B on the plan is a mature garden including ponds that is actually part of the residential property marked F.
The areas marked D contains a stable block on the Western boundary and is used for equestrian purposes, and it is has the "weak" boundary to the East referred to in WAL/GB/013.Taking this parcel as an example, further evidence of producing inaccurate scorings, can be seen by the difference in boundary strength, by attaching an area with weak boundary to an area with a stronger boundary. Also, attaching certain areas to a parcel can further skew the scoring by affecting the width of the Urban Gap.
Inconsistencies can be found within the classification of the strength of a boundary; on some parcels a hedge is deemed weak on others it is a strong boundary. Likewise a domestic curtilage can be considered a strong boundary.
A Quote from another nearby parcel, Old Brampton OBRAM/GB/009, that has been identified for release, "The parcel effectively comprises part of the built up area of Old Brampton, with well-contained domestic garden curtilages and Main Road providing defensible boundaries to all sides, with a clear distinction to the agricultural fields beyond. It makes a limited contribution to the Green Belt purposes."
Another example on Holymoorside HOLY/GB/024 also identified for potential release it is accepted that the boundaries where, "A stone wall forms part of the northern boundary and a watercourse forms part of the southern boundary" are deemed strong and defensible.

To quote from the document setting out the methodology "In this context Strong boundaries are considered to be: main roads; railway lines; residential, employment or other development with strong established boundaries; reservoirs and lakes; rivers, streams and canals; and substantial woodland and hedges."

Given the information highlighted above from the review, and having taken time to study the area, we would like to bring to your attention, two areas of land that is suitable for the release from the green belt and for future development.
This regards one area of the Parcel WAL/GB/013, and all of WAL/GB/014, please see attachment Site Plan A1 areas A & E, for reference to the text in this paragraph.
The area marked A effectively comprises part of the built up area, (See Marked red line joining the well contained domestic garden curtilages, on Photograph 1 attached) with around 50% bordering the urban area to the North and West of the well contained domestic curtilages, and strong mature hedges to the East with stable block behind, and strong mature hedges to the South with large agricultural building behind, giving a clear distinction to the agricultural fields marked C, and the golf course, water course and mature woodland beyond to the South. This is suitable for infill as it would have little or no impact on Urban sprawl, has strong defensible boundaries and is greater than 1 km from Wingerworth. This area has access through area E.
The area E marked on the Site Plan A1, is within the built up area, it has strong defensible boundaries all the way round, with well-contained residential properties and their domestic garden curtilages to the North East and South, road to the North and Strong mature hedge to the South East. Development of this land would not reduce the width of the Strategic Urban Gap between Urban areas.
The release of these two areas A & E would easily meet the housing requirement for Walton, as identified in the review, this would achieve a positive result out of this lengthy and costly review.


Object

Consultation Draft (February 2017)

Representation ID: 5393

Received: 01/04/2017

Respondent: Mr Eric Singleton

Representation Summary:

The council has selected Green Belt land for development without a rigorous assessment of all options and other sources of land ((5.6) including:
windfall sites (5.6, 7.4)
sites below 10 dwellings (5.8)
issues of deliverability have been addressed to justify Green Belt release (5.7)
This is contrary to the Housing White Paper 2017.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

4.5 Policy SS1, Sustainable Development, clauses c and g

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Object

Consultation Draft (February 2017)

Representation ID: 5402

Received: 05/04/2017

Respondent: Ms Rhian Harding

Representation Summary:

I totally reject the evidence led review of the Green Belt boundaries. To suggest that building 180 houses on farm land in Coal Aston meets any needs of local residents is absurd. The detriment to health & wellbeing and environmental impact will be enormous to residents who have lived in this village for a lifetime. Coal Aston is small, friendly and rural and steeped in tradition. The village has grown organically and the Green Belt land must be protected to retain the character and protect the land which is integral to the local landscape.

Full text:

I totally reject the evidence led review of the Green Belt boundaries. To suggest that building 180 houses on farm land in Coal Aston meets any needs of local residents is absurd. The detriment to health & wellbeing and environmental impact will be enormous to residents who have lived in this village for a lifetime. Coal Aston is small, friendly and rural and steeped in tradition. The village has grown organically and the Green Belt land must be protected to retain the character and protect the land which is integral to the local landscape.

Object

Consultation Draft (February 2017)

Representation ID: 5474

Received: 06/04/2017

Respondent: Woodall Homes Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see attached statement

Full text:

Green Belt Review
6.08 Although the representation site at Clay Cross is outwith the Green Belt, we consider that it is pertinent to discuss the matter of Green Belt in general terms as it goes to the heart of the Council's housing land position, and Woodall Homes have land interests in the Green Belt, which are subject to separate representations.
6.09 The Council acknowledges that in order to deliver the spatial strategy set out in the plan, particularly given the location of three out of four of its Level 1 Settlements located in the north of the District and tightly constrained by Green Belt there is a need to release Green Belt land.
6.010 A Strategic Green Belt Functionality Study was published in November 2015 and subsequently a Green Belt Review has been undertaken by Nathaniel Lichfield and Partners (in two parts), February 2017.
6.011 The Nathaniel Lichfield Part 1 report identifies three alternative Green Belt growth scenarios, which are as follows:
a. Scenario A: Restricted Growth - up to 1,000 dwellings; below the level of housing growth required to meet the District's objectively assessed housing need but would address affordable housing needs;
b. Scenario B: Medium Level Growth between 1,000 and 2,000 dwellings; a level of housing growth which is sufficient to meet the District's objectively assessed housing needs; and
c. Scenario C: High Level Growth up to 4,000 dwellings; Growth above and beyond Objectively Assessed Needs, in line with the Council's Growth Strategy, capitalising on the economic benefits.
6.012 As the Council's spatial strategy requires a significant proportion of its housing requirement to be delivered in the north of the District, which includes three out of four of the District's main towns, and those housing needs cannot be met from existing land outside of the Green Belt, the main focus for the Green Belt review is in towns and settlements in the north of the District. The Green Belt review however does confirm that the settlements of Wingerworth, Grassmoor and Temple Normanton, which are only partially constrained by Green Belt, have not been excluded from the assessment. Given the need for housing within NEDDC this approach is supported, however we disagree with the assessment in the Green Belt Review of the housing yield on non green belt sites in these settlements. The total yield set out in the Council's Housing Sites Assessment Report from all sites, including Green Belt sites in these three settlements is significantly less than that identified in the Green Belt review as being achievable from non Green Belt sites. Therefore in the case of Grassmoor it is not correct that there is a yield capacity of 335 (non Green Belt sites) given that in total there are only two sites identified by the Council as being potential allocations following the Policy Assessment, which would achieve a total yield of only 283 and includes a Green Belt site (GRA/1601).
6.013 Paragraph 83 of the Framework advises that:
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period'.
6.014 Paragraph 84 further advises that:
'...local planning authorities should take account of the need to promote sustainable patterns of development......channelling development towards urban area inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary'.
6.015 Paragraph 85 states, inter alia that local planning authorities should:
* Not include land which it is unnecessary to keep permanently open;
* Where necessary identify in their plans areas of 'safeguarded land'...to meet longer term development needs stretching well beyond the plan period
* Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
6.016 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt such as Grassmoor.
6.017 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.018 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Woodall Homes, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.

- Additional Rep for Green Belt Review:

6.07 The Council acknowledges that in order to deliver the spatial strategy set out in the plan, particularly given the location of three out of four of its Level 1 Settlements located in the north of the District and tightly constrained by Green Belt there is a need to release Green Belt land.
6.08 A Strategic Green Belt Functionality Study was published in November 2015 and subsequently a Green Belt Review has been undertaken by Nathaniel Lichfield and Partners (in two parts), February 2017.
6.09 The Nathaniel Lichfield Part 1 report identifies three alternative Green Belt growth scenarios, which are as follows:
a. Scenario A: Restricted Growth - up to 1,000 dwellings; below the level of housing growth required to meet the District's objectively assessed housing need but would address affordable housing needs;
b. Scenario B: Medium Level Growth between 1,000 and 2,000 dwellings; a level of housing growth which is sufficient to meet the District's objectively assessed housing needs; and
c. Scenario C: High Level Growth up to 4,000 dwellings; Growth above and beyond Objectively Assessed Needs, in line with the Council's Growth Strategy, capitalising on the economic benefits.
6.010 As the Council's spatial strategy requires a significant proportion of its housing requirement to be delivered in the north of the District, which includes three out of four of the District's main towns, and those housing needs cannot be met from existing land outside of the Green Belt, the main focus for the Green Belt review is in towns and settlements in the north of the District. The Green Belt review however does confirm that the settlements of Wingerworth, Grassmoor and Temple Normanton, which are only partially constrained by Green Belt, have not been excluded from the assessment. Given the need for housing within NEDDC this approach is supported, however we disagree with the assessment in the Green Belt Review of the housing yield on non green belt sites in these settlements. The total yield set out in the Council's Housing Sites Assessment Report from all sites, including Green Belt sites in these three settlements is significantly less than that identified in the Green Belt review as being achievable from non Green Belt sites. Therefore in the case of Grassmoor it is not correct that there is a yield capacity of 335 (non Green Belt sites) given that in total there are only two sites identified by the Council as being potential allocations following the Policy Assessment, which would achieve a total yield of only 283 and includes a Green Belt site (GRA/1601).
6.011 Paragraph 83 of the Framework advises that:
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period'.
6.012 Paragraph 84 further advises that:
'...local planning authorities should take account of the need to promote sustainable patterns of development......channelling development towards urban area inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary'.
6.013 Paragraph 85 states, inter alia that local planning authorities should:
* Not include land which it is unnecessary to keep permanently open;
* Where necessary identify in their plans areas of 'safeguarded land'...to meet longer term development needs stretching well beyond the plan period
* Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
6.014 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt such as Grassmoor.
6.015 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.016 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Woodall Homes, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.
6.017 The evidence base demonstrates that site GRA/1601 only partially meets the purposes of green belt by safeguarding the countryside from encroachment. In the Planning Advisory Note on Green Belts, it sets out how the five purposes might be used when assessing the contribution of land to the Green Belt. In respect to Purpose 3, it states:
'Purpose 3: To assist in safeguarding the countryside
Presumably all Green Belt land does this, making it difficult to distinguish the contribution of one area from another. An assessment should consider the difference between urban fringe and open countryside, favouring the latter and also taking into account the types of boundaries that can be achieved'.
6.018 The site at Grassmoor provides a contained extension to the existing settlement, with the road into the Grassmoor Golf Club providing a robust defensible boundary to the north thereby safeguarding the open countryside from encroachment (See section 7 Site Assessment for further details).
6.019 The omission of current Green Belt sites as allocations where they have been assessed positively in accordance with the Council's site assessment methodology is considered to render the draft plan unsound in its current form and is therefore concluded not to be:
* Positively prepared
* Justified
* Effective
* Consistent with national policy

Object

Consultation Draft (February 2017)

Representation ID: 5517

Received: 06/04/2017

Respondent: Steven and Rosemary Mitchell

Representation Summary:

Objection to review of green belt because of negative impact on the community and countryside. Green belt was introduced to stop urban spread and sprawl which is what will happen if green belt status is changed to allow development and building.

Full text:

The Planning Policy Team
North East Derbyshire District Council
2013 Mill Lane
Wingerworth
Derbyshire
S42 6NG

Dear Sir/Madam

Green Belt Land to the south of Eckington - Proposal to change to Safeguarded land
Green Belt Land - Bolehill Lane, Eckington - Proposal to Build 37 Houses

We are writing to raise our firm objections to the proposed change of status to a large area of Green Belt land to the South of Eckington to Safeguarded Land (and for any proposals to build on this land), and to the proposal to build houses on the plot of Green Belt land off Bolehill Lane, Eckington.

We feel most strongly that if this is approved the following serious issues will arise:

1.Green belt land change of use - suggests that won't be used for residential land in the immediate future. This cannot be depended upon, if the status of green belt changes, this land will be an easy target for future development, and the infrastructure will be totally inadequate. If the status of green belt can change to suit the authority, they will also change the use to suit just as easily. We have been promised by NEDDC that Green Belt land will be protected. How can we trust a council that reneges on such important promises so easily?
2.There have already been several attempts by the landowner(s) of the Green Belt land to the south of Eckington to sell plots of land for residential use on the green belt land, even though no planning permission is in place. This will just play into their unscrupulous hands. In the past, planning applications have been turned down by the council to protect the Green Belt.
3.Speed of traffic along Chesterfield Road. There is a brow of a hill, and a curve in the road at the exit of Bole Hill Lane. Despite existing speed restrictions, traffic usually speeds up leaving the village at this point to speed down the hill. We witness this on a daily basis. It is currently often difficult to turn on to Chesterfield Road in either direction, and this will be even more difficult with many more vehicles exiting opposite. Sometimes our sightline is affected and we have to have someone to cross the road to ensure a safe exit. This will also be an issue for any access to Chesterfield Road from the Green Belt land to the south of the village.
4.Additional pollution concerns for local community from increased traffic in an area where already 3 children in every class suffer from asthma.
5.Wildlife conservation - being bats, snakes, frogs, badgers, newts and other wildlife of possible protected species in and around the land intended to be built upon will be compromised. Loss of wildlife habitat for local fauna and flora as there are abundant hedgerows within the green belt area which would be lost if development took place.
6.Access to open countryside - Bolehill Lane runs onto a bridle path which continues onto Marsh Lane. There is no alternative footpath / countryside access at any of the Green Belt area to the south of Eckington. Any existing access will be completely destroyed. This will have a serious impact on all those who use this area on a daily basis.
7.Impact on infrastructure - schools, doctors, community buildings are exhausted now, more housing will only make the situation worse. The existing local road infrastructure in the village is congested with delays at peak times, especially queuing at the traffic lights at the top and bottom of Eckington, additional housing will bring more vehicles, only making the situation worse.
8.Eckington is a village which easily becomes congested as there is only one road from one end of the village to the other. Any increase in traffic, particularly on the scale that massive development such as this would put extra pressure on this. This could be catastrophic in an emergency situation.
9.Ground conditions - the above mentioned field is subject to flooding, the area has identified soil and sub-strata deficiencies (plus possible mining in the area).
10.Existing property profile - the area immediate to the above field is part lined with an existing bungalow estate, (which conforms to current maximum height restrictions). This estate has a non-invasive view when approaching Eckington along Chesterfield Road from Whittington. Building 37 houses on Bole Hill Lane and the potential 500 more in the existing Green Belt area will have an adverse effect on the sight line when approaching the village. It will be a complete eyesore.
11.No other provisions in the village. Town centre is in massive decline, this needs to be addressed before additional pressures are created. Eckington will just be a dormitory settlement, not a community.
12.There will be a massive detriment to the value of property adjoining and within sight of the Green Belt land, in some cases by tens of thousands of pounds. In addition, the daily joy we currently get from the view from our windows will be destroyed.
13.The 'very special circumstances' test remains. Green Belt land is expressly excluded from the presumption in favour of sustainable development, and an unmet need for conventional housing does not in itself constitute 'very special circumstances'
14.The NPPF states: 'the fundamental aim of Green Belts is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence'. The five purposes are stopping urban sprawl; preventing 'coalescence' (or joining together) of settlements; safeguarding the countryside from encroachment; protecting the setting of historic towns; and encouraging urban regeneration. So rerleasing any green belt land for development is fundamentally against the guidelines set down by the NPPF.

Please confirm receipt of this letter and provide a formal written response in due course.

Yours faithfully




43 Chesterfield Road
Eckington
S21 4BB

Comment

Consultation Draft (February 2017)

Representation ID: 5562

Received: 07/04/2017

Respondent: Sheffield City Council

Representation Summary:

The Green Belt methodology outlined is different to, but not inconsistent with, Sheffield's approach to Green Belt review. Identification of Safeguarded Land is consistent with the aims of the NPPF to ensure enduring Green Belt boundaries. We note there is recognition within the Green Belt review that some land parcels adjacent to Sheffield's urban area, which scored red, have locational benefits that could potentially weigh in favour of release, although more detailed consideration would be needed. This may be an issue to be picked up through a future review of the North Derbyshire and South Yorkshire Green Belt.

Full text:

This section highlights that in order to ensure a sustainable, deliverable distribution of land for new homes, there will be an impact on the Green Belt, as almost all land parcels perform a Green Belt function to some extent. The process outlined whereby parcels were identified that would cause least harm to the strategic function of the Green Belt, and then taken through the Council's site assessment process is different to, but not inconsistent with Sheffield's approach to Green Belt review. Identification of Safeguarded Land to meet development needs beyond the plan period is consistent with the aim of the NPPF to ensure that Green Belt boundaries endure beyond the plan period, and also builds in additional flexibility should a an early review of the plan be needed. For example, this might be needed if land was taken up more quickly in NEDD as a result of 'overspill' from Sheffield in the short to medium term. We note that within the Green Belt review (5.22) there is recognition that some land parcels adjacent to Sheffield's urban area, which scored red, have locational benefits that could potentially weigh in favour of release, although more detailed consideration would be needed. This may be an issue to be picked up through a future comprehensive review of the North Derbyshire and South Yorkshire Green Belt (possibly as part of a future SCR strategic plan/ framework).

Object

Consultation Draft (February 2017)

Representation ID: 5603

Received: 07/04/2017

Respondent: Gleeson Regeneration Ltd

Agent: Peacock and Smith Ltd

Representation Summary:

Please see attached statement

Full text:

6.07 Although the representation site at Tupton is outwith the Green Belt, we consider that it is pertinent to discuss the matter of Green Belt in general terms as it goes to the heart of the Council's housing land position.
6.08 The Council acknowledges that in order to deliver the spatial strategy set out in the plan, particularly given the location of three out of four of its Level 1 Settlements located in the north of the District and tightly constrained by Green Belt there is a need to release Green Belt land.
6.09 A Strategic Green Belt Functionality Study was published in November 2015 and subsequently a Green Belt Review has been undertaken by Nathaniel Lichfield and Partners (in two parts), February 2017.
6.010 The Nathaniel Lichfield Part 1 report identifies three alternative Green Belt growth scenarios, which are as follows:
a. Scenario A: Restricted Growth - up to 1,000 dwellings; below the level of housing growth required to meet the District's objectively assessed housing need but would address affordable housing needs;
b. Scenario B: Medium Level Growth between 1,000 and 2,000 dwellings; a level of housing growth which is sufficient to meet the District's objectively assessed housing needs; and
c. Scenario C: High Level Growth up to 4,000 dwellings; Growth above and beyond Objectively Assessed Needs, in line with the Council's Growth Strategy, capitalising on the economic benefits.
6.011 As the Council's spatial strategy requires a significant proportion of its housing requirement to be delivered in the north of the District, which includes three out of four of the District's main towns, and those housing needs cannot be met from existing land outside of the Green Belt, the main focus for the Green Belt review is in towns and settlements in the north of the District. The Green Belt review however does confirm that the settlements of Wingerworth, Grassmoor and Temple Normanton, which are only partially constrained by Green Belt, have not been excluded from the assessment.
6.012 Paragraph 83 of the Framework advises that:
'Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period'.
6.013 Paragraph 84 further advises that:
'...local planning authorities should take account of the need to promote sustainable patterns of development......channelling development towards urban area inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary'.
6.014 Paragraph 85 states, inter alia that local planning authorities should:
* Not include land which it is unnecessary to keep permanently open;
* Where necessary identify in their plans areas of 'safeguarded land'...to meet longer term development needs stretching well beyond the plan period
* Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
6.015 It is considered that given the need for housing in the District over the plan period, particularly the significant amount of affordable housing, it is considered that the exceptional circumstances exist to make further green belt releases, where it has been demonstrated appropriate to do so, around settlements only partially constrained by the Green Belt.
6.016 Release of Green Belt land on sites that abut Level 1 and 2 settlements are considered to promote sustainable patterns of development and such settlements will be able to accommodate the housing needs of smaller less sustainable settlements in neighbouring areas.
6.017 Even if the Inspector is of the view that the housing requirement identified in Policy SS2 Scale of Development provides for the full OAN, a view not supported by Gleeson Regeneration Ltd, the Council has failed to give any consideration to the longer term development needs of the District. Given the constrained supply of housing land in NEDDC, this is likely to result in the need for a further review of Green Belt boundaries at the end of the plan period, contrary to the policies in the Framework.

Object

Consultation Draft (February 2017)

Representation ID: 5702

Received: 05/04/2017

Respondent: Mr Peter MacKay

Representation Summary:

Statement that section 4.65 claims that in order to achieve a "sustainable pattern of development... we must accept that this will have an impact on the Green Belt", but the Council's approach to removing land from the Green Belt in Dronfield is does not fit a "sustainable pattern of development". Statement that the land proposed for removal from the Green Belt at Hallowes Lane, Dronfield (Section 5.20) and Hilltop Dronfield (Section 5.21) come with a list of factors that have not been investigated

Full text:

I wish to register my objection to the proposed local plan currently in the consultation period, produced by North East Derbyshire County Council.

My objection centres around the removal of the Green Belt land surrounding Dronfield.

My reasons for this objection are as follows:-
* Green Belt Review/Evidence base for the removal of land from the Green Belt:
o Section 4.65 claims that in order to achieve a "sustainable pattern of development... we must accept that this will have an impact on the Green Belt", but the Council's approach to removing land from the Green Belt in Dronfield is does not fit a "sustainable pattern of development". The land proposed for removal from the Green Belt at Hallowes Lane, Dronfield (Section 5.20) and Hilltop Dronfield (Section 5.21) come with a list of factors that have not been investigated. As such removing these areas of land from the Green Belt cannot reasonably be described as part of a "sustainable pattern of development" as it is not yet clear that the land is suitable for development.
* Local Settlement Gap
o Section 4.73 notes that "the Local Plan seeks to protect settlement identity and avoid further settlement coalescence and erosion of character by identifying Local Settlement Gaps". Releasing the land off Shakespeare Crescent & Sheffield Road, Dronfield (Section 5.19) would move the physical boundaries of Dronfield significantly closer to Unstone, leaving only a small green space to separate the two. As Chesterfield Council has given planning permission for Residential development right up to the southern borders of Unstone the net effect will be to remove the distinct nature of Dronfield.
o Further there is a duty on the Council to co-ordinate planning with neighbouring councils, but there is no evidence that the Council has undertaken co-ordination with Chesterfield Council or Sheffield, which are key influences on the NEDDC region. This is particularly regrettable as the councils in both areas demonstrate good efforts and practice in the re-use of Brown Field sites, something that is obvious in it's omission from the NEDDDC Draft Local Plan.
* Infrastructure:
o The Draft Local Plan proposes (section 9.71) sites for several hundred new homes in and around Dronfield, notes some (but by no means all) of the infrastructure challenges that this would bring to the town and then defers any solution to these challenges to further assessments. As such it is not possible to say that the infrastructure challenges can be met, which calls into question the feasibility of the developments and undermines the assertion that land is being removed from the Green Belt as part of "sustainable pattern of development".
o The plan for the additional housing is based around the ability to commute from Dronfield to places such as Sheffield and Chesterfield, primarily via the railway station. This is currently in a position where the line through Dronfield is part of a plan to electrify the East Midlands mainline (as noted in the Draft Local Plan, Section 9.62). However Arriva/Northern Rail/Network rail are currently analysing the possibility of moving the station out of the town as there are listed bridges in the town centre that prevent the electrification taking place. This currently has no workable solution and as such cannot be used as the basis for the justification of supporting additional housing from the Green Belt.

Object

Consultation Draft (February 2017)

Representation ID: 6034

Received: 06/04/2017

Respondent: Roy Phillips

Representation Summary:

Objection to release of greenbelt land surrounding Dronfield. Reasons for objection: limited green space in Dronfield, pressure on narrow roads.

Full text:

The Government are committed to preserving the green belt and should be released only in "Exceptional Circumstances"
"Dronfield is significantly lacking in green space..."
The local plan is at odds with both and should be re-drafted so as to exclude any encroachment of the green belt however small!
I wounder how the present plan impinges on members of N.E Derbyshire District Council or the Planners? Have the "Planners"actually visited on foot some of these proposed sites, the roads around Hallowes Golf Course for instance? There are places here where it is almost impossible to get two cars to pass side by side.

NO to GREEN BELT incursions

Support

Consultation Draft (February 2017)

Representation ID: 6035

Received: 07/04/2017

Respondent: Derbyshire County Council

Representation Summary:

Support for the release of green belt land in the north of the District. 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.

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 SCR local authorities, including DCC.

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.

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: 6065

Received: 06/04/2017

Respondent: Chesterfield Borough Council

Representation Summary:

Para 4.64
SUPPORT the methodology used in undertaking a Green Belt review. We can confirm that CBC was consulted on the methodology.

Para 4.66
We note that that some areas of release are close to the CBC boundary (and immediately adjacent in the case of releases south of Eckington) but have no objections in principle to the proposed releases.

Full text:

See attachment.

Object

Consultation Draft (February 2017)

Representation ID: 6128

Received: 06/04/2017

Respondent: Gareth Barber

Representation Summary:

Objections to the proposed removal of greenbelt land around Dronfield. Reasons for objections: does not believe that the proposals are in line with central government approach and does not fit with a case for exceptional circumstances, believe the loss of greenbelt will reduce quality of life not increase it, states that empty homes should be targeted first as well as brownfield sites, removal of the greenbelt area will impact on the character of the town.

Full text:

RE: Removal of greenbelt land in and around Dronfield
I wish to make you aware of a number of strong objections that we have with regard to the
proposed development of an additional property on in Dronfield, that, we are of the view
that the proposed development will have a serious impact on living and health standards.
Our specific objections are as follows:
I vehemently object to the proposals in the Local Plan to redesignate the areas of Green Belt
marked DR1, DR2, DR3, DR4 and DR5 on the map below.
DRONFIELD'S GREEN BELT
Your proposals to redesignate areas of Green Belt are not in tandem with central
government's approach. Housing Minister Gavin Barwell stated in February 2017 that the
government intended to focus, as a government, on developing brownfield land, specifically
in those parts of the country where additional homes are required. He talked about new
measures to help councils identify locations for development, and in all but exceptional
circumstances, that will exclude the Green Belt.
Your proposals to redesignate areas of Green Belt do not adhere to the guidelines issued
from the Department of Communities & Local Government, which state that "... local
councils should be looking to brownfield first and foremost, and be in line with government
policy of protecting Green Belt."
Your proposals to redesignate areas of Green Belt are contrary to Point 89 of The National
Planning Policy Framework, which states "A local planning authority should regard the
construction of new buildings as inappropriate in Green Belt."
Your proposals to redesignate areas of Green Belt fail to take account of the wishes of the
majority of residents. Policy S S9: North East Derbyshire Green Belt in The Plan states that
"...the majority of local residents want to maintain the Green Belt boundary ..."
Your proposals to redesignate areas of Green Belt, build 860 houses on Green Belt land, and
the adverse consequences of this, is in conflict with your Vision, which reflects your
responsibility as a local authority to act in a way which enhances the quality of life and wellbeing
of your residents: "By 2033 everyone in North East Derbyshire will enjoy a high quality of
life, with residents, businesses and visitors all benefiting from what the district has to offer." The
loss of Green Belt, and the resulting loss of recreation opportunities, coupled with the shift in
character of the nature of the town from rural to urban), will reduce the quality of life for
residents (especially when the recent studies on the benefits of nature to mental well-being
are taken into consideration), particularly for those whose homes border the proposed sites.

Your proposals to redesignate areas of Green Belt will reduce even further those areas of
recreation presently available to residents (we don't just look out onto our Green Belt - we
actively use it!). You recognise in 7.6 Sustainable Places that Dronfield already is "significantly
lacking in green space, outdoor sports and children's play space".
The effects of your proposals to redesignate areas of Green Belt around Dronfield will be
disproportionate in relation to similar measures around other settlements. The Strategic Green
Belt Functionality Study shows that that all proposed Dronfield development areas are in the
top 50% of Green Belt sections that would suffer most when measured against Green Belt
objectives; yet this is where you propose to build a large number of houses.
Your proposals to redesignate areas of Green Belt do not take into account the 731 properties which you have recorded as being Empty Homes across the whole of the NEDDC area, including 133 in Dronfield, Dronfield Woodhouse and Coal Aston, figures which I obtained from you as a result of a Freedom of Information request. Your response states that for the years of 2015 and 2016, you have assisted no owners in recycling those properties back into use as homes, the result being where those homes are now in full use; nor are you currently assisting owners to do same; nor have you taken formal enforcement measures against owners to bring about same. Your document, "Growth Strategy - Unlocking our Growth Potential" states, "if [empty homes were] brought back into use would contribute towards meeting housing needs and improve neighbourhoods".
Your proposals to redesignate areas of Green Belt is not "limited infilling" and therefore
"exceptional circumstances"; the proposed number of houses is significant in each location, each location is considerable in size, and in no way can be regarded as limited. The sheer size of each development would result in a huge impact on Dronfield, surrounding farmland, and the remaining Green Belt, and alter the character of the town and the area in which it sits, completely.
Therefore, I believe that you have not made the case for "exceptional circumstances" as a reason for your proposals to build on Dronfield's Green Belt. Unmet housing need is not "exceptional circumstances" for the redesignation of Green Belt. Nor do I believe that you have taken sufficient steps to consider alternatives to the redesignation of Green Belt; namely, bringing brownfield land back into use, consideration of other brownfield sites across the district as a whole and in neighbouring council areas, and the recycling of Empty Homes across the district. Redesignation of Green Belt should be the last resort, to be undertaken only when ALL other options have been fully exhausted.
Questions:
1. What pro-active initiatives have you undertaken to identify brownfield sites?
2. Where is your evidence that you have considered all brownfield sites, including those which would support fewer than ten dwellings?
3. In the event that you have considered brownfield sites, but taken the decision not to situate any of the proposed 860 houses thereon, where is the analysis of each site?
4. What are the issues around the viability of delivering large numbers of sites in a relatively small area in the south, which you refer to in your leaflet, "Frequently Asked Questions for Dronfield"? What are the reasons that you do not consider these sites for development?
5. What incentives have you offered to property development companies to develop brownfield sites?
6. What incentives have you offered to businesses currently occupying brownfield sites in residential areas for those businesses to relocate to nearby business parks and industrial estates, which may prove more suitable for their needs and thus render the vacated brownfield sites available for house-building?
7. What pro-active initiatives have you undertaken to identify employment land which has been vacant or unviable for several years?
8. To what extent has the fact that Dronfield is an affluent area played a part in the decision to redesignate parts of its surrounding Green Belt land (is it due to pressure from property development companies? Their profit margins will be higher for providing the types of houses which predominate in Dronfield)?
9. How do you seek to adopt the new measures referred to by Housing Minister Gavin Barwell to help councils identify locations for development, in all but exceptional circumstances excluding the Green Belt?
10. Why the emphasis on redesignating Green Belt in the north, when there may be sufficient brownfield sites in the south?
11. What action do you propose to take in order to bring the 733 long-term empty properties across the district back into full-time use as homes?

INFRASTRUCTURE
The Plan does not follow government policy, which states that "The Local Plan should make
clear, for at least the first five years, what infrastructure is required, who is going to fund and
provide it, and how it relates to the anticipated rate and phasing of development." This information is not contained within The Plan. In failing to follow policy, you do not comply with the spirit of the principles supporting Local Plans, which are to provide a clear, coherent, long-term plan to avoid a piecemeal approach. I wish to raise the following concerns regarding infrastructure and potential consequences of the redesignation of the Green Belt:

1. You state in 9.12 Greenways & Multi-User Routes that public rights of way provide considerable opportunities for people to enjoy the countryside, and that it is important to ensure that development does not have an adverse impact upon the integrity of these routes. In 9.13, you state that you will support the use of all public rights of way ... and safeguard them against development likely to prejudice their integrity. The proposals to build housing at H and I do not support this. Nor do they support your statement in D11 Natural Assets, where you seek to "recognise the value of natural assets by protecting, enhancing and expanding North East Derbyshire's network of green and blue infrastructure including its distinctive landscape character, open spaces and nature conservation sites in part by supporting opportunities to improve countryside access." Area H is bordered by a public bridleway which bisects Hallowes Golf Course, and by Hill Top Road which, at this point, has the appearance of a single-carriageway tarmacked farm track with no pavement. Both connect with footpaths, which lead to open countryside. The public bridleway and the whole of Hill Top Road act as links from one part of the popular Dronfield Round Walk to another, and also to the Chesterfield Round Walk. Their key appeal is the quick and easy access they provide to the countryside. Development at H will compromise the integrity of this public bridleway, as the bridleway would border a housing development; its character will change entirely. Development at I, which would increase vehicular traffic from this site onto Hill Top Road (via which route? - the Plan fails to include details of proposed access to this site), will compromise the integrity of the Dronfield Round Walk and the Chesterfield Round Walk. You state in this section that residents identified tranquility, landscape quality and access to the countryside as key assets of living in the District. The setting of the bridlepaths, and the setting and nature of the whole of Hill Top Road, contributes significantly to this; residents feel connected with the landscape around them. Thus, the proposals fail to take into account
the wishes of residents.

2. You state in Policy ID3: Open Space, Sports and Recreation Facilities that the Council will seek to protect and enhance existing open spaces, sports and recreation facilities. You state in Sustainable Places Para 7.6 that Dronfield is "significantly lacking in green space, outdoor sports and children's play space." Your overall Vision in The Plan talks about "protecting and creating open spaces to provide accessible green infrastructure and biodiversity networks which promote healthy lifestyles..." Your proposals for the green belt land at H and J do not support Policy ID3: H is made up of part of Hallowes Golf Course, and J, sports facilities and the Moss Valley Conservation area. Your proposals for J do not support your policy at D11 Natural Assets owing to the presence of the Moss Valley Conservation Area. Nor do your proposals for H, I and J support your overall Vision.
Your proposals for the land at G, H and I contradict your statement in Sustainable Places Para 7.6, and also your overall Vision. Houses in the quantity you are proposing will change the nature of Hill Top Road and Salisbury Road from quiet safe roads where children play football and ride their bikes. In the event that access to G is created via Burns Drive (you do not give details of access to site G in your Plan), this would drastically change the nature of Burns Drive from a cul-de-sac with a small grassed area, thus highly attractive to local children, to that of a thoroughfare, removing this location as a pleasant play area. Additionally, your proposals fail to support central government's policy on reducing obesity. Department of Health Guidelines, "An Update on the Government's Approach to Tackling Obesity", state that "Local authorities will be instrumental in implementing plans that
encourage people to do more exercise." NEDDC does this well when promoting its sports and leisure centres, which people have to pay to access. Use of the bridle paths around the land at H and Hill Top Road is free, thereby providing inclusive exercise opportunities for people at all income levels.
The benefits of close proximity to nature have been upheld in the Institute for European Environmental Policy's March 2017 study, the most wide-ranging probe yet into the dynamics of health, nature and wellbeing.

3. Car Parking
Your justification of the presence of the railway station in Dronfield to build 860 houses in Dronfield is flawed. The station is served by one car park which is insufficient for passengers' needs. There is no
possibility of additional parking: the lease of the car park is to revert to the rail operator, which may consider introducing parking charges and may reduce the number of spaces. The majority of car park users are people undertaking short journeys; any disproportionate charge for parking could discourage them from using the train (source: Friends of Dronfield Station). Network Rail will not release the yard at the rear of the car park for additional parking. The development at Manor Farm will mean the loss of around 25 car parking spaces.
For electrification of the East Midland line to occur, the station may need to be moved out of the town - the two listed bridges at Dronfield prevent electrification. It is a two-mile round trip from four out of the five proposed housing sites to the railway station. There is a steep incline on the return journey for sites at H, I and J. All proposed sites are on the rural fringe of Dronfield and as far from the railway station as it is possible to get.
Therefore, is possible that rail passengers living on the new estates may not wish to make this journey on foot, and may use less-sustainable means of travel, compounding the existing parking and congestion problems.

4. Road Congestion
Your proposals to build 860 homes at sites G, H, I, J and K is contrary to Policy ID6: Sustainable Travel - "The Council will seek to maximise walking, cycling, and the use of public transport through the location and design of new development, with the aim of reducing congestion, and improving air quality and health." There is insufficient car parking at Dronfield Railway Station for additional rail users. When the car park is full, rail passengers tend to park their vehicles on neighbouring roads. This results in severe congestion, particularly on School Lane and Lea Road. Congestion is aggravated by cars picking up/dropping off pupils at Dronfield Infant School and Dronfield Junior School on School Lane. There are approx. 600 pupils at these schools.
Dronfield is served by shopping areas at the Civic Centre, Pentland Road, and Greendale Shops. The Civic Centre area offers a health centre, pharmacy, sports centre, library, shops, meeting places, and places of worship; it is a real "hub" for the town. Severe congestion and standing traffic occurs at the junction with Hallowes Lane/Chesterfield Road, and along Dronfield Bottom, including the entrance point to Callywhite Lane Industrial Estate, and on High Street. All are main routes from one part of Dronfield to another. Hallowes Lane is a main access route for residents living at Hallowes and Hill Top, where you propose to build 420 homes. Hallowes Lane is narrow to the point where it can be impossible for two vehicles to pass side-by-side.

5. Air Pollution
The Plan is likely to reinforce a commuter community, and therefore contribute to air pollution. You acknowledge in The Plan that "most people commute to other areas for work (Chesterfield or Sheffield) and that most commute by road." It is likely that the many of the house purchasers at all sites will follow suit. Should planning permission be granted to Ineos Upstream for exploratory drilling at Bramleymoor, the preferred route indicated by Ineos Upstream for vehicles to access the site is via Dyche Lane and Eckington Road. They have stated that there are likely to be 100 vehicles a day in the setting-up phase alone, and due to the nature of the operation, many of these vehicles will be heavy freight. In addition, Dyche Lane and Eckington Road are likely to be main access routes for visitors to St James Retail Park at Norton - a development that is likely to prove very attractive to Dronfield residents. Air pollution is likely to be compounded by the proposals for 180 houses at J, on the basis that individual households have at least one car.
The Environment Act 1995 requires all local authorities to review and assess air quality.
Question:
1. Given the increase in vehicular traffic which 860 new homes in Dronfield will bring, and the situation with the proposed plans for exploratory drilling at Bramleymoor, what steps does NEDDC intend to take to ensure that it complies with the Act?

6. Co-operation with Neighbouring Planning Authorities
The population of Chesterfield Borough is due to rise by 9100 by 2031. Sites in the Borough have been made available for an additional 7600 homes by 2013. Using the average of 2.5 people per household (NEDDC planners' figures), there is spare capacity here. Peak Resort is likely to provide employment for 1300 people. Given this fact, and the proximity of the resort to the areas of the disused Unstone Boat Yard, Lister's Car Sales, and the disused nursery, these sites are likely to prove attractive as a place to live; they directly border the NEDDC council area.
Question:
1. What steps have you taken to cross-reference your proposals and co-operate with neighbouring authorities, such as Chesterfield Borough Council and the Sheffield City Region, to meet the need for unmet housing need across neighbouring council areas?

7. Urban Sprawl
Your proposals to redesignate the Green Belt at G do not comply with government policy, which states that the fundamental aim of Green Belt is to keep land permanently open and prevent urban sprawl (NPFF, Section 9).
The Green Belt between Dronfield and Unstone is already very narrow. Land at G is actively farmed and provides access to the open countryside and the Dronfield Round Walk. Houses on this site will contribute to the urban sprawl of Dronfield, and this effect will be exacerbated by the new-build semi-detached homes on Chesterfield Road, and the proposed building of seven homes on the site of the Fleur de Lys public house. There will, therefore, be no discernable gap from Dronfield to Unstone.

8. Employment
Your proposals to build 860 homes in Dronfield are contrary to the National Planning Policy Framework, which aims to provide jobs where people live. The Plan fails to include a plan for employment provision in Dronfield for 860 new homes. You state in The Plan that there will be insufficient growth in local jobs to support 860 households.
You state in your leaflet, "Frequently Asked Questions for Dronfield" that you have "considered but dismissed [land at Callywhite Lane] due to their importance and suitability for employment and creating jobs." Callywhite Lane Industrial Estate contains long-standing empty units, vacant plots and derelict land. These have not attracted interest from businesses for some time and in their current state are unlikely to do so, particularly businesses which employ large numbers of people.
I note that Chesterfield Borough Council takes a different approach; their Local Plan identifies Ash Glen Nursery, and Lister's Car Sales as sites for residential development. The planning status of the latter two is "allocation employment".
Questions:
1. What steps have you taken to bring sites at Callywhite Lane into use as sites for some of the 860 proposed homes?
2. What options have you explored with Sheffield City Region regarding employment opportunities, given that many Dronfield residents work in Sheffield?
3. What steps have you taken to identify suitable sites to the north of Dronfield, which owing to proximity are likely to prove more suitable for those working in Sheffield, and provide benefits in terms of air pollution due to the shorter distance travelled to work?

9. Access to Medical Services
There are four GPs surgeries in Dronfield; most, if not all, are already at capacity.
Question:
1. How do you intend to ensure that additional residents in Dronfield have access to a GP in the town?

10. Distribution of proposed dwellings
In the Plan, you focus on Dronfield for such a substantial increase in homes because it is the largest settlement in the north of the District. It could also be said that, owing to its size, it has the least room for expansion. You state in the leaflet, "Frequently Asked Questions for Dronfield" that detailed analysis found a high level of potential supply in the south of the District where there are issues
around the viability of delivering large numbers of sites in a relatively small area. Whereas in the North and West of the District, areas with particularly high demand, there is significant undersupply of housing land ..." You provide this as justification for the review of the Green Belt, yet unmet housing needs do not constitute exceptional circumstances for the redesignation of the Green Belt, as stated in the NPPF.
Information provided by the Coal Authority indicates that the sites at H, I and J are areas of high risk and contain potential hazards arising from former coal mining.
Question:
1. Why do you seek to make larger towns even larger without ensuring that those towns have the requisite infrastructure already in place?
2. Why have you not spread the extra housing required over more villages and towns?
3. Why did you not make provision for low-cost housing, suitable for older people, at Manor Farm? This central site, with excellent level access to shops, health centre, pharmacy, library, sports facilities and public transport, is being considered for family homes! I note the comment made by Cllr Baxter that the development is "To provide a significant financial surplus to support the Council and Rykneld's ongoing investment programme in new and refurbished publicly owned homes." This indicates that profit is the overall driver here, as opposed to a coherent approach to the
provision of homes across the whole of the town.
4. Have you commissioned the carrying-out of a survey regarding the suitability of this land for house building? If not, then why have these areas been included within The Plan, given that their suitability has not yet been determined?

11. Schooling Provision
Dronfield Henry Fanshawe School is the only secondary school in Dronfield and is oversubscribed. Space to extend the school on its Green Lane site is lacking. The majority of the primary schools in Dronfield are at capacity. Ironically, several schools in the district have closed and have been developed for housing (for example, Apperknowle Primary School). This suggests a piecemeal approach to school and housing provision. The overwhelming majority of children of secondary-school age living in Dronfield attend Dronfield Henry Fanshawe School; it is popular, successful, and highly-regarded by residents. This contributes significantly towards the strong sense of community in the town; it helps to bring the town together. Were some secondary-school students living in Dronfield forced to attend secondary school provision elsewhere, this sense of "one-ness" that many feel, living
in Dronfield, is likely to be eroded.
Question:
1. How do you intend to ensure that primary and secondary school provision is sufficient for Dronfield children, without resorting to new-school provision on Green Belt land?
12. Roads and Road Safety
Homes at H and I are likely to have adverse effects on Hallowes Lane and in the centre of Dronfield - areas which presently experience congestion and standing traffic. Homes at H and I are likely to significantly alter the character of Hill Top Road and Salisbury Road.

Hill Top Road
You have not demonstrated in The Plan that the highway network in Dronfield has sufficient capacity for this scale of development, nor that improvement works can be carried out. 190 homes at I are likely to change the character of Hill Top Road from that of a very quiet, residential road and farm track, to that of a main access road to the new houses and possible through-route.
In the event that the access route to I is via a new road through the car park of the Hyde Park, this would contribute to on-street parking within close proximity to a junction, and may reduce the attractiveness of this pub to potential customers - the pub is the sole amenity in this area.
The Hyde Park would then not be used by local folk, which has been the backbone of this pub's income for many a year, as it doesn't have any drive by customers, and therefore result in job loses when the pub closes. Hill Top Road is narrow. In part, it is a single-carriageway tarmacked farm track with no pavement. The parked vehicles of residents reduce part of the road to a single lane. The road is popular with joggers, children riding pedal cycles, and horse-riders - the road is a direct route to a farm. It is a link from one part of the Dronfield Round Walk to another, and also to the Chesterfield Round Walk. It provides direct access to footpaths through Monk Wood and towards Cowley Lane. Other than the Hyde Park public house, there are no amenities in this area of Dronfield. There is no direct access to I (DR3). The site is hemmed in by houses, a pub, and a pub car park.
The Plan does not state how access will be gained to this site. In the event that access is via Hill Top Road and Long Acre Road, this would mean that vehicles for a total of 420 houses would be using the road; assuming that the majority of households now have two vehicles, this would mean an additional 840 vehicles using these roads.
There are contradictions throughout the consultation process with overview and inaccuracies throughout that need urgent attention before any decision to remove green belt is made.
Take for example DR3 which is your reference for the parcel of land of Hill Top Road Taking into account your scoring mechanism (attached above)you state that DR3 scores a '1' in the 'to preserve the setting' category. It fails to mention that the field is surrounded and sits adjacent to properties dating back to 1880's, yet in other zone studies in your report, this fact of period properties attracts a much higher score! The same can be said for 'to assist in safeguarding' category. Therefore, I conclude that if these areas are wholly incorrect, and the report is fundamentally floored, and must be rereview, and a new report commissioned.

Hallowes Lane
Hallowes Lane, which is narrow, steep, and busy, is a main route for vehicles and pedestrians at Hallowes and Hill Top to access the rest of Dronfield and to leave the town in both a southerly and northerly direction. The road is reduced in part to one lane, owing to the presence of parked vehicles. The pavement is narrow - there is no pavement at all at the bottom of the road opposite The White Swan. Pedestrians walking on the pavement are in close proximity to moving vehicles; on bin collection day, pedestrians have no choice but to walk into the road in order to continue their journey, owing to wheelie bins blocking the pavement.
The vast majority of the pedestrians are students making their way to and from Dronfield Henry Fanshawe School, and parents with primary-school-aged children. Pedestrians are in large numbers at the beginning and end of the school day, a time when traffic is at its greatest because of commuters and school-run traffic. The junctions with Hollins Spring Avenue, Cemetery Road, Quoit Green and Chesterfield Road are busy. The junction with Lea Road is busy, has poor visibility, and there is no safe refuge for pedestrians. Any proposed access to H via Highfields Road, bisecting Salisbury Road, is likely to exacerbate existing traffic problems on Hallowes Lane.

High Street
High Street is a main route through the town; the road is already narrow and busy. There is no crossing point enabling easy pedestrian access from one part of the town centre to another - it is a "life in your hands" situation when trying to cross from the Sainsbury's side to the library side. The car park at the Civic Centre is often full.

Entrance to Callywhite Lane Industrial Estate
The extension to Callywhite Lane Industrial Estate is likely to result in an increase in heavy traffic. The present entrance to the Estate is in close proximity to Dronfield Henry Fanshawe School, from which almost 1800 students emerge every weekday afternoon. It is situated at the junction of three main routes through Dronfield. The area is busy. The road layout is complicated and does not facilitate easy passage for vehicles. There is no crossing point on Callywhite Lane, nor neighbouring Mill Lane. Both are hazardous for pedestrians who have no safe route across.
Questions:
1. How do you intend to ensure that additional heavy traffic does not compound the existing traffic problems and the congestion at the present entrance to the Estate? What steps do you intend to take to ensure that pedestrians, and students en route to/from Dronfield Henry Fanshawe School, are kept safe?

THE FORMER PADLEY AND VENABLES SITE, CALLYWHITE LANE
I note that you refused an application in 2013 for the erection of 51 new residential dwellings on the former Padley and Venables Site, Callywhite Lane, and that refusal was stated (a) on the basis that the proposed development would result in a change of use of land protected for employment; (b) the proposed residential development land is adjacent to industrial units, and that this would introduce potential conflict for residents and businesses; (c) the application was considered unacceptable as it would lead to additional traffic movements from the proposed housing along Frithwood Drive, Shireoaks Road and Stonelow Road (d) a coal mining risk assessment and contaminated land assessment had not been submitted and there was insufficient evidence that the application site was safe, stable and suitable to accommodate the proposed development.
Callywhite Lane Industrial Estate has been poorly-maintained for a long time, and is unattractive to prospective businesses. Empty units are evidence of this. Unless the area is redeveloped, the situation is unlikely to change. Taking into account the high level of interest and objection that Dronfield residents have in The Plan, demonstrated in the very active "Dronfield Greenbelt" campaign, it is likely that future objections to applications for planning permission to build houses on the five sites
would far surpass those received in 2013 regarding the Padley and Venables site. I note that you have not carried out a coal-mining risk assessment for the three sites which are considered high risk development areas by the Coal Authority - sites H, I, and J. Yet you propose to build houses at these locations, and you refused permission for the 2013 application from Bloor Homes on the basis
that a coal-mining risk assessment had not been carried out.
Questions:
1. Given the fact that the majority of Dronfield residents do not find their work in the town but commute to Chesterfield/Sheffield, and given the scarcity of suitable land for homes, is it now time to reconsider the use of this land and release it for the building of homes?
2. Close proximity to industrial units does not adversely affect the popularity of Cliffe Park, nor affect its visitors. Given the scarcity of suitable land for homes, would this area benefit from creative landscaping and appropriate measures to provide demarcation between residential and industrial areas?
3. Why is it that you required the Padley and Venables site to be so assessed, yet have not carried out assessments on sites H, I and J BEFORE considering them for housing? This can only be said to be double standards in action; I struggle to maintain faith in the planning system.

Therefore, I conclude that this consultation is wholly incorrect, and the reports within are fundamentally floored, and must be stopped with immediate effect, reviewed, and a new report commissioned.

Object

Consultation Draft (February 2017)

Representation ID: 6273

Received: 06/04/2017

Respondent: mrs Catherine Dixon

Representation Summary:

Objections to the proposed changes to greenbelt surrounding Dronfield. Reasons given for objections: urban sprawl, loss of countryside, no acceptable show of exceptional circumstances to remove greenbelt land.

Full text:

p.55-56
4.65
I strongly object to the building of new houses on greenbelt land around Dronfield. This land was deliberately set aside to ensure that Dronfield remains a town in its own right and not swallowed up into the suburbs of either Sheffield or Chesterfield, We are surrounded by some of the most beautiful countryside in Britain here and it is incredibly important to protect our environment and not allow it to be slowly eaten away. I do not believe that any evidence of "exceptional circumstances" which would allow building on greenbelt land has been demonstrated.

p.128-129
SP1
I also object to the extension of the industrial estate on Callywhite Lane. This will mean an increase in large commercial traffic through our towns (and we can't cope with the wear and tear to the roads now) and also an increase in pollution.

As a draft, I feel this local plan is totally misguided.

Object

Consultation Draft (February 2017)

Representation ID: 6281

Received: 06/04/2017

Respondent: Mr Simon Dixon

Representation Summary:

I strongly object to the building of new houses on greenbelt land around Dronfield. This land was deliberately set aside to ensure that Dronfield remains a town in its own right and is not swallowed up into the suburbs of either Sheffield or Chesterfield, eventually resulting in the merging of the two larger conurbations. Residents of Dronfield do not want to live in Shefterfield!

Full text:

4.65
P55-56
I strongly object to the building of new houses on greenbelt land around Dronfield. This land was deliberately set aside to ensure that Dronfield remains a town in its own right and is not swallowed up into the suburbs of either Sheffield or Chesterfield, eventually resulting in the merging of the two larger conurbations. Residents of Dronfield do not want to live in Shefterfield!


SP1
P128-129
We are surrounded by some of the most beautiful countryside in Britain and it is incredibly important to protect our environment and not allow it to be slowly eaten away. I do not believe that any evidence of "exceptional circumstances" which would allow building of housing on greenbelt land has been demonstrated. In the words of your own plan "The District has a low jobs density". Can an already stretched local economy and infrastructure with reduced investment due to government cuts realistically support a larger population?

1.21
P6
One of the aims stated in the plan is for a "safer healthier more active community" surely depriving a community of undeveloped green spaces is totally at odds with this goal.

3.5
P20
The plan also suggests that allowing the proposed plan will give Dronfield "Defensible boundaries against further development", this is an extremely weak argument, as the plan is proposing to scrap current boundaries and build on supposedly protected greenbelt land, this will set a president and make it more likely that future developments can simply redraw boundaries at will.

I also object to the extension of the industrial estate on Callywhite Lane. This will mean an increase in large commercial traffic through our towns (and we can't cope with the wear and tear to the roads now) and also an increase in pollution. The high tech industry that the plan says it wishes to attract will require far better access to transport links than Dronfield can offer.

As a draft, I feel this local plan is totally misguided.

Object

Consultation Draft (February 2017)

Representation ID: 6334

Received: 07/04/2017

Respondent: Elaine Bullers

Representation Summary:

Objection to developments on Green Belt land in Dronfield, Eckington and Killamarsh. Concerns are for exceptional circumstances, merging of towns, loss of green space for recreation, impact on wildlife, strain on services, increase in traffic, unsafe road conditions for cycling, pedestrian safety, plans for the future of public transport, medical services, use of brownfield sites first.

Full text:

NEDDC Draft Local Plan consultation:

To North East Derbyshire councillors and planers, I would like to register my one to to the Plans to allow building on the Green Belt around Dronfield specifically and the proposed erosion of Greenbelt in other areas such as Eckington and Kilamarsh.

I support the regeneration of former industrial sites in the district, such as Clay cross, Coalite and Markham Vale.

Government planning policy says Greenbelt can only be used in exceptional circumstances which I do not believe this plan justifies. The Greenbelt to the North and South of Dronfield has a strong roll to play in stopping Dronfield merging with Sheffield and with the Chesterfield Borough district which once the new Peak Resort is built and the land opposite the Sandpiper redeveloped will join with Unstone village, the far end of which is only separated from Dronfield by a couple of fields west of the railway.

The proposal will also reduce sporting facilities and green space which your own plan says we are lacking in.
Loss of habitat and valuable farm land in the Moss and Drone Valleys. These area are home to wildlife such as the bats, badger, fox, owls, pheasants and woodpeckers and other common birds and the cows which I enjoy watching watching grazing, If you allow this proposed development in the Moss valley conservation area I will suffer from a loss of visual amentity which goes against the plans stated aims of everyone in the district having a high quality of life. (3.3)

Over 800 new residences will stretch already declining services and increase traffic both during construction and after! Again a reduction in my quality of life. I used to enjoy cycling round the area but past increase in traffic and speeds made it feel unsafe and after several people I know were knocked off I reluctantly gave up. I am glad to see the current resurgence in cycling past here but the unsafe passing by speeding drivers on here concerns me.

The plan contains few if any definite plans to mitigate this traffic which already makes crossing main roads in Coal Aston and Dronfield bottom by the post office a problem. As a pensioner the schools do not directly effect me but the school run traffic does, along with parking at times to get to the shops at greendale and Dronfield bottom.

If you expand Cally White Lane with out fixing the traffic it Could become impossible to cross to the post office and bank.

The local plan does not have a travel plan to integrate bus services to reduce car travel within the district and allow better access to the shops and rail network across town.

There are no provisions for increasing medical facilities within walking distance of Coal Aston.

The plan fails to take account of the aging population round here, other than building family house to bring in young families, in a location well away from the schools

Their are many brownfield sites in the vicinity which need using first with quality environmentally sound development, some of this land is in neighbouring districts such as Staveley, Sheffield and Chesterfield, with other smaller sites in NEDDC also not covered in the plan.

In conclusion I am against the proposed loss of Greenbelt land for an unjustified expansion of Dronfield

Object

Consultation Draft (February 2017)

Representation ID: 6366

Received: 07/04/2017

Respondent: Mr John Reedman

Representation Summary:

I refer to that part of the area shaded as and identified as a Parcel partially meets Green Belt purposes as I object to the rezoning of existing and green belt recreation facilities, in respect of the historic recreation facilities behind Coal Aston Village Hall which were originally provided by private and charitable means.

Full text:

Appendix 1 Green Belt Parcel Assessment - Map Inset (Document 11105426v11) and Page 3 - Nathanial Lichfield & Partners Map dated 27.05.2016 (ref. GIS\41714\02-42) -
I refer to that part of the area shaded as and identified as a Parcel partially meets Green Belt purposes as I object to the rezoning of existing and green belt recreation facilities in direct contravention to the advice provided in The National Planning Policy Framework document of 27 March 2012 and it's updates - section 89 exception 2, (provision of appropriate facilities for outdoor sport, outdoor recreation), in respect of the historic recreation facilities behind Coal Aston Village Hall which were originally provided by private and charitable means.

The Dronfield Area Proposals -
I agree with the well researched objections published by Dronfield Town Council despite it having come to the council in March even though some parts of the plan that directly affect Dronfield have been under consideration as potential plans since May 2016

Object

Consultation Draft (February 2017)

Representation ID: 6379

Received: 07/04/2017

Respondent: Tracey Marsden, Nicola Shepherdson & Mark Woodhead

Agent: Caroline McIntyre

Representation Summary:

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

Full text:

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

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

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

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

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


REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUSTAINABILITY APPRAISAL (2017)

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

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

GREEN BELT REVIEW (FEB 2017)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Housing Sites Assessment Report (Feb 2017)

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

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

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

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

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

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

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

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

SETTLEMENT HIERARCHY STUDY (2016)

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

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

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

SUMMARY

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

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

Comment

Consultation Draft (February 2017)

Representation ID: 6392

Received: 07/04/2017

Respondent: Tracey Marsden, Nicola Shepherdson & Mark Woodhead

Agent: Caroline McIntyre

Representation Summary:

It is considered that the site ECK/2201, which lies within parcel RID/GB/002 remains available, suitable and achievable and should be released from the Green Belt to meet the district's housing needs over the plan period.

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

Full text:

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

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

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

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

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


REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUSTAINABILITY APPRAISAL (2017)

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

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

GREEN BELT REVIEW (FEB 2017)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Housing Sites Assessment Report (Feb 2017)

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

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

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

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

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

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

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

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

SETTLEMENT HIERARCHY STUDY (2016)

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

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

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

SUMMARY

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

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

Object

Consultation Draft (February 2017)

Representation ID: 6449

Received: 07/04/2017

Respondent: Mr & Mrs N Beecroft

Agent: Caroline McIntyre

Representation Summary:

Clients' site is included within the parcel of land assessed under WAD/GB/006. Conclusion on Parcel WAD/GB/006 is that this scores 'Red' in an assessment against the Purposes 1 and 3 of the Green Belt by checking unrestricted sprawl and assists in safeguarding the countryside from encroachment.

Statement that smaller elements within each parcel which may score different in terms of the purposes of the Green Belt is not considered. Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Statement that there is a lack of consistency in the approach to selecting parcels for assessment.

Requested that the GB Review of Site BRAM/2301, be reconsidered on the same grounds as the approach taken to Parcel HOLY/GB/024.


Full text:

This representation relates to land to the west of the Millstone, Wadshelf (Ref BRAM/2301) and should be read alongside submissions made previously in respect of this site at the Call for Sites stage in January 2016.

The Site

The Site is located on the western side of the village of Wadshelf and sits adjacent to the Settlement Development Limits for Wadshelf, as identified on the Local Plan Proposals Map (2005). The Millstone, and White House beyond this, to the east of the Site fall within the Settlement Development Limits for the village.

The Site is bounded to the east by the Millstone and the White House, which is separated from the Site by the drive to the Millstone. To the south is Main Road and beyond this a number of farm and residential dwellings. To the west is the Village Hall and village play area, and beyond this further housing to the junction with Baslow Road. Despite the role of the Village Hall within village life, this does peculiarly fall outside of the Defined Settlement Boundary. To the north is agricultural land which slopes up in gradient away from the Site.

The Site is low grade agricultural grazing land and is currently unused. An existing power line crosses the Site.

Given the Site's position and relationship with both the village of Wadshelf and key village facilities we consider that its inclusion within the Green Belt and exclusion from the Settlement Development Limits of Wadshelf - along with the properties to the west of the site - is an anomaly.

We consider that the Site is available, suitable and achievable for housing and as part of the review of the settlement boundaries there is a strong case to exclude the Site from the Green Belt. We set out our justification for this below.

REPRESENTATIONS TO THE DRAFT NEDDC LOCAL PLAN

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

Housing Need: Review of Boundaries to Level 3 Settlements: Within Policy SS3 'Spatial Strategy and Distribution of Development' and Tables 4.1 and 4.2 Wadshelf is defined within Table 4.1 as a Level 3 Settlement.

The Draft Local Plan states at Paragraph 4.80 that the review of smaller settlement boundaries which is still to be undertaken. Therefore there has been no review of the boundaries of most Level 3 settlements as part of the current draft Plan.
The Plan has been prepared on the basis of the 2013 Strategic Housing Market Area Assessment ("SHMA") and the sensitivity testing in 2014 and not on an updated assessment. This document is now four years out of date, and an updated Assessment should be completed as soon as possible to determine the more localised need for new housing. This will be an important consideration in the review of the boundaries to the Level 3 Settlements.

Furthermore, the previous draft 2011 - 2031 Local Plan Part 1 Initial Draft (February 2015), which was informed by the Evidence Base, outlined that there was a need for 5 new dwellings in Wadshelf over the plan period. It is noted within the document that this figure was limited due to the lack of Sites available within the Settlement Development Limit and the Green Belt designation around the village. It is assumed that this need will be reassessed in the light of the revised Local Plan SHMA and updated housing targets process.

Although it is noted that Maps for two settlements, Cutthorpe and Holymoorside, are provided but there is no reference to these within the Draft Local Plan. As discussed below, it is considered that our clients' site, along with the land to the west, is not materially different to the area of land proposed for removal from the Green Belt at Holymoorside (Ref HOLY/GB/024). This area of land to the west of Wadshelf contains the Village Hall and playground and further existing housing as well as our clients site and forms part of the village.

Consideration should be given to the removal of this land from the Green Belt as part of the review of smaller settlement boundaries, which is still to be undertaken.

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

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

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

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

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

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

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

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

SUSTAINABILITY APPRAISAL (2017)

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

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

GREEN BELT REVIEW (FEB 2017)

Within this document our clients' site is included within the parcel of land assessed under WAD/GB/006. This parcel of land included both their land at land to the West of the Millstones (BRAM/2301) and a significant area of land to the north, north east and north west.

The overall conclusion on Parcel WAD/GB/006 is that this scores 'Red' in an assessment against the Purposes 1 and 3 of the Green Belt by checking unrestricted sprawl and assists in safeguarding the countryside from encroachment.

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

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

Within the NEDDC Green Belt Review large parcels of land are generally considered, for example Parcel WAD/GB/006 covers an area of 2.4 ha. However there does not appear to be any general consideration of smaller elements within each parcel which may score different in terms of the purposes of the Green Belt and therefore may be suitable for removal without impacting on the overall objectives of the Green Belt in that location. The Review process therefore seems to be at odds with the detail of Stage 2 of the 'Common Approach to the Green Belt Review' document.

Furthermore, there is a lack of consistency in the approach to selecting parcels for assessment. Had the same approach been taken to our clients site (along with land to the west) as that taken for Parcel HOLY/GB/024 within Holymoorside, which covered an area of 0.877ha, the conclusions regarding BRAM/2301 may have been different.

In summary within a more localised assessment of BRAM/2301 the site can be considered as follows:

* Purpose 1 'To check the unrestricted sprawl of large built-up areas': Wadshelf is a remote, freestanding rural settlement and is not in close proximity to other settlements. The village of Wadshelf already extends beyond the Settlement Development Limits to the west of the current boundary. The removal of the Site from the Green Belt would not result in the sprawl of Wadshelf, as a number of existing dwellings and community facilities are already located to the west of the village, and to the west of the Site, outside of the Settlement Development Limits.

* Purpose 2 'To prevent neighbouring towns merging into one another': No comment as the Green Belt Review scored this a 'Green'.

* Purpose 3 'To assist in safeguarding the countryside from encroachment': As stated above, the existing settlement of Wadshelf already extends to the west of the Site, outside of the Settlement Development Limits for the village. The northern edge of the Site has a strong boundary and the elevation of the land to the rear of the Site would reduce any visual impact of the proposals. The removal of the Site from the Green Belt, and its inclusion within the Settlement Development Limits, and any subsequent development on this Site would not pose a significant or unacceptable threat to the countryside.

The consideration under 3a should not be afforded any weight when the percentage of an area selected it entirely related to the area selected in the first place. Had the land at Wadshelf which forms part of the village, but falls outside the Settlement Boundary, been considered in the same way the site at Holymoorside was then the percentage of the site covered by development would have been significantly higher.

* Purpose 4 'To preserve the setting and special character of historic towns': Although recorded as an Amber score, it is considered that the Conservation Area boundary for Wadshelf covers a larger area than the Settlement Development Limits, and as such any considerations regarding the setting of Wadshelf would remain governed by the relevant heritage policies. Furthermore, any development on the Site would not dilute the character of the settlement as a small agricultural settlement.

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

The Green Belt Review Part 1 identifies that based on a range of Growth Scenarios, ranging from A to C, that in order to maintain the vitality and viability of smaller settlements through further small scale development Wadshelf would need to deliver between 7 and 23 dwellings over the Plan period.

However the review process concludes that for Wadshelf and a number of other settlements:

"There are no sites identified which are suitable for release which could accommodate the housing requirements of these settlements. As such, the housing need identified under Scenarios A, B and C would have to be accommodated in nearby settlements or alternative options set out in the Part 1 Report considered."

Had our clients' site been considered using the same approach adopted for HOLY/GB/024 then the conclusions with regards to Wadshelf within the Review may well have been different.

Therefore, in summary it is requested that the Green Belt Review of Site BRAM/2301, forming a Parcel along with land to the west of the site which functionally falls within the village of Wadshelf, be reconsidered on the same grounds as the approach taken to Parcel HOLY/GB/024.

It is considered that the release of this land from the Green Belt would regularise the position within with regards to the extent of the village and the Green Belt boundary. Furthermore the release of any land from the Green Belt forming part of this smaller parcel of land would largely relate to existing dwellings, the Village Hall and playground and with a limited opportunity for new development.

Housing Sites Assessment Report (Feb 2017)

Within this document our clients' site is assessed under Ref BRAM/2301 - Millstone, Wadshelf.

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

* Green Belt: for the reasons set out above, it is considered that there has been no consistency with the site selection process when considering parcels of land within the Green Belt Review. As a result the negative conclusion regarding parcel WAD/GB/006 works against the assessment of our client's site.

* Access: Whilst the site does not currently have access from the highway, access could be created using the same principles applied to developments to the east and west of the site. it is therefore considered that this is not an issue in respect of this site.

* Design: The policy conclusions with regards to the Conservation Area and design appears to take a more negative view than the comments elsewhere within the document. These note that "If any development of the site would be sought then it should be delivered with good design and low density." This could be achieved and a scheme sensitively designed to have regard to the views of the site and the conservation area. It is therefore considered that the policy conclusion is overly negative with respect of this issue.

* TPOS: The TPOs referred to within the Policy Conclusions relate to land which falls outside of the land being considered. Whilst they may be a consideration in terms of any future proposals for the site, in their own right they are not a constraint to the development of Site BRAM/2301.

* Services: Wadshelf scores the same as Cutthorpe within the Settlement Hierarchy Study (2016) and yet the decision has been taken to remove an area of land from the Green Belt within Cutthorpe which is largely covered by built development and forms part of the existing settlement (Ref CUT/GB/003 and Housing Study BRAM/2401). Whilst it is acknowledged that the removal of this site has resulted from the Green Belt Review rather than the Housing Sites Assessment, it is clear that the removal of sites from the Green Belt within other Level 3 settlements is being progressed within the draft Local Plan.

In summary, for the reasons outlined above the conclusion not to consider Site BRAM/2301 further as a Housing site is based on an incorrect assessment of the site and should be revisited.

SUMMARY

In summary it is considered that the site remains available, suitable and achievable and should be released from the Green Belt to the district's housing needs over the plan period. Furthermore the removal of our clients site would ensure that the approach taken to Wadshelf is consistent with that taken in Holymoorside and Cutthorpe.

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